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'~ ,i~/ _ ~~ Al~nphnllln /},. q't~anpa.pr, ltlttl.IlbifC' vn, Anut)Ith 1, 'ih,nnnltn~, pn l: pllda111: l aN 'Pllhl uault'p nb! noMMciN NI,laAfi t 1tiD' c!NMHIa1tI,ANiI cot!N'I'Y, 1'f1NNtIY1.,Vl1NtA 1 1 No, !!!I - Il.~ (Jl ~G' c!1V;11i 'Pn11tM .. i id'Rta'Plar."I''foN hltoM nn!Ipi: gryp cuti'1'opY Nt?'i'_L_'lL ~l~'_iilRlilfl(LAN~IiI?Lii Yoll IIAVN pp11N Al1p1p 1:N Colllt'I'~, fl' yeti Wlltll Cn clnfalul npni.ltnl: I:IIU nln.litlu tlnt ft)1'th 111 talo fplloWlll^ ptlpnv!a, yrn) IIIIInC nppant' rtP. t:Nn Itanri.np Ilahndtllnd hn1'ai~il, 'lfi ynU 111.1.1: I:ra do f)p,.'latn utlna_Illny Ireoc!tu)d npnl.ilal: yell nud 11 b'l:NAi., ot~dor Inny bu nlll.nt'od ctdrllnuf yrn) t!rnlll:iltq I:IIU ral iol' l~agtlapl:nd llt t:11n I'Plal:.l.tn1, T.Il pnrl:.taulnr, yotl mny hu nVir.~bn~l I!1•om ynq,' rnaidnnun etilcl l.nnn olhnr lplpc)rtliitl: ripht:a, A. Ilnnl'illp On 1:111ft Illnttol' ..ln Hnind111.nc1 fol'. Llln ..S.L'_ ! ~7lJF~t[t.iV 1ppp, nt.-~-~-.~ , .f~ __,_ my taf tahruary, I ,mi, .iq cotlctu~onm Nq,_l.:ol' hlta (:unlla~tlnllrl C!otltlfy quurl:hotlna, Cnrlitlln, Ponnsy.lvnni.ti, Yat1 NUA~' obey I:ha order thap is attiaphed tent:l.l 1t ie mndi Gied ax terminated,. by the eonrt aGl:ar notioe and Ilearinp, IP you disobey this 4t•der, the pnl'.loe may arreap yott, Violation oP this ordoz' may atlbJeat ypu to a charge aC „ indirect nriminal aantempp Wliioll ie pllnialtehla by a ~ilta oC tlp to ¢1, 000, p0 an{1/ar tlp 4o six months in ~sil,Under 2;i'Pgio,A, A611q, Vio}anon may also suq~eot yoq to proaaauGion and criminal panait:ies tlndor t11a henusylvania orimap node, Under Cedoral ~aW, lp ll,p,o, g2pBp, uhie prdar ie anCorueabla ' anyWltare in the Unitad Atatea, tribnl latlda, U,9, Territories and Oho Qulnnlonwealth tiC Pnsrto liiao, TG ynU travel o}}tsids aG t11s stato and' ipGentionaliy Violpl:o thin Urdar, you may ba stlb~oat to Codaral criminal proaeedin2a lulder the Violonae Agaitlet Women Aat, 10 U,6,p, gA261-x262, YqU 811oULO TAKq TIII6 fiA['gh Tp YOUIt GAWYgh AT UNOiC, YOU IIAVIC TI1H N1t91i'1' TO HAVd A GIt19YgR I;gpNgAqNT YUl1 AT Tllq IIgARTNq, Tliq eoU1tT WILL NOT, 11oW19VgN, APNOTNT A LAWYgfI MON YOU, .II+' yoU n0 NOT.I{AVq A LAWYgR UN nANNUT AL~60Np o~q, DO TO oN Tgt,gr110Ng Tllq OFFIUq figT FOFtTII UICI,oW To F'INU OU'r WNRNq' YOU OAN qhT GgaAL IIISLP, I6' YOII I:ANNoT r''1'NO A LAWYgtir YoU NAY HAVq To pltooggp WITIlol1'r oNq, oUMptCNLANU tlauNTY UAN ApAonTATION ' 2 LTUICR'rY AV4~Nllq anryL;xaLq, RdNNavuyANIA 17o1a TgLgpNoNq NUMpgFil (717) 249-x166 1"Ii3QJLNA WITIt nzaApxLITIg@~a~' OF'~yp The Court nk anmmon Pleas of oumbarland county ie required by laW to anmply With the lunariaans With oisabilitieu Aot oC lphp, 'por ibCormatiatt about aoaessible Cneilitiea and reasonable aogommodalaons available to disabled indibiduals having businaha bekore iho aotlrt, please aotttaat our oCCitla, -All arrangements must be made at least 72 hogre prior to any hearing or btleiness bafiorb the south, ''Yotl muei• atL•and the scheduled oonEarenae nr hearinU, ...... - ,..,. ,r .,l __ Hbap#tan~.e fi, ?'t-aaplur, t :tN TIIP Cot1R'n ot~ eoMMPN ni,eAp ' r~1.a~ttt:~.c>: t i AF'' ~oMljPRi,~Np coUN'l'X, l'pNN~YI,VANxA „ Vp, t INo~ ~~ - ~u~~~' pl'VZta 'rpliM ~Toaeplt lay 'Crepplpr,' t ' pet'ppdaRt t ~lio'z'b7c'i'zAN FROM ApUt3W ~~ t eap'ropY '311M1'QI3~1IiY Pt;4."l.Gl~"1'zON [~'tt0~ AttUBfa O[;]dj~j; paPettdan4~'~ p Name t aaaaph ~,, mxapalar peEendaut~p,.pate oC -3irtltl Q/9/BQ ~peEendanG~p eooial aeaurity NUmbert 44B-9U-773q Nalne o£ Protaated Per.gotl( pbaphan~.e A, Txepplex 11ND NOWT bltip _Z.~...~ day oP Fak~rugryr ],989r upoz< aonN~darabiap , of pha agl:aahed Pahition A,ox Protsea~~on Pxam Abuser the.gouxls hexaby enhaxa phe PolloWin9 Tempoxat~~y Ordext ~, ~1, Det°endanG shall naG abuse, haraxar apalk or tltxeahen any of phe above pergonp iri atl;y plane Whexq 1:hey miehG be Eound, q '2 , peEepdnrtt ip eViat:od attd exa7.udpd f.'ronl t?laintiEE ~ p ropidenao located al: , auntberland county, t?engpylvani.a, {a "1'oaidettao Whiolt ip jointly owned/leased by the parL•ie~tt, owned/.leaped by fire ontiretiept owned/a,aaped aole~.y by ' 1~lai;ntiEf/I)e.fondant to Whioh P.lainti[L• ahd the ,minor ohild/ran moved L•o avoid abuse, Wltiah ip not oWnpd or leaped by the peCetii~anl:, or any other porntanent or temporary rep~.denae Wherp nlaintit:c may li.vn, n1ai11tiEE iq grahted exoluaive poppeppion of L•ho repidenoe, AefondanL al~all have Ito right ox pY~ivid.egr3 to pater or be prepeltt on tlta prHmipop, oxoepL• for L•lte limited pul:ptiae of Lranaf:erriltg audLody of L,#te partiep~ altild/ren, ascendant shall remain in hip vehicle at all times during the L•ranscer of custody,) ' lm~, S~cnepfs Enx aualt aonCaaC Wit1t the minor child as mad! be permilahed Undex Phrngraplt !3 ok thia.Orderr beEendant is ~. ;r ;~ 5r` ~; 1 ~~,, k~: ifu' ~r ,, ~; .;F,. _. _ ,- - .. ..... . i. , ' pxahih~Ged~~Gxam 1lav~tl9 ~Ny ppNx~-p~' Wl~~t g~a~itGPP aG and #~agAG~enr ~.'tta~ud~a<}~r #~RG t'to~ liM~~ad Ga at-y aankaa~ aG ,.: „ Pla~~-GIGG i a ~pxaPa ae eMPlaytnartG ~ 1aaGattdanG- l~ ~ppaai~laally , axdared I:a aGaX away Rram G~1a Go~.a.aw~aq laaaG~.arta Gnr kha ~~ dµxaGlAn aG ph~.~ Qrdaxt Plpitz~~G~ia req~.dt3naa .laaaGad at: a~~4 R~xnar Fi~ghtvRX 4axl~.a?~ar dµmpR~xlppd paµn~yr Pfltiµl~~l'Yt-;t~ar f4 , rapidanae Ga Wh~ah Pl~~tlklGG MPYad ~R aVa~.d ahµpRr and attX aphax rPA~denaa P~.airtGiGG MaX agGabl~ah, Q~at~pk Gar Gha l~,nt~~ad pwx~Qaa a~ kxauaflexrirtq aual:adX aG plta part:ap t alt~ld+ A,aG~~danG ahazl , xaMa#n ~.p ltdp vettlala ab all' pimaa ditr~t-q Glta 4ra~aGex aG , au~aQdX, ~4, . ~~atea~pk Gax gµoh anpl;aab wik11 Glta M~nar a$ild ap tna~ tae ,. paxA-~pbed µndag Paragraph 6 aG khiq oxdax, AeGenda-tk shall Hats aonbagG PlaintsiEG hX ke~,gphoua ax b~ auk ophex Maanpr ~.t-Plµd~.ng Ghx'ough kh~.rd pexaana, ,. !$I~,'" Pendlttq tsha pukaome o~ k3te kinal heariµg in khia Makt:ax~ Pla~.slblGG ie awarded ~eippoxaxy auat;ady of t:ha Gollowinq' Minor phildt Mariah Kaylee Trepalex; t-nkil t:he ~~,s-al l-earingr ail aonkaak betWaen DePandanG pnd" bha child shall kie a~.Mit:acl po tshe GalloWingt D®GendanG shall have khe child bhe Weekr3nd.aE February a6, 1899, GxoM D'rittaY ak 3tOU P,M. uri~il eµnday ats 3tOU p,M, 8egirining March br 1899, De~endastk shall have partial autat:ody of t:he child khe Girek bh>`ee 'Wae#~eiida aP eaoh month Erotn 1Priday at 31 GO p,M,' untsil ptlstdgx 3 t QU ~,sn, . ". The ~,adal° laW enPoraesnent agetsny ~,~ the ~uriadiatioh W}texe the aliild its laoated shall ensure that the child is plnogd isi.the care aud.onntrol'oE PlairitiGP in aaaordaslae With the karma nG ' ~hia..order, p 6 ,: Uei:endatiC aha11 itnmodiat:ely' roliriquial- L•he Ca11ow~.ng Weapana,L•o t:he aher.iC~~q OEt:ioe or a degignaLed .loohl.7.aW onEoroetnenl: agenoy for Lho deliVory L•o Llie sheriE'a oEPioat bePendant: is prnltiUiCod trots naapQaping, L•rana>?erririg or acquiring ariy oL•her WeaporiFi [or L•he dUrakton oC Lhia Order, . ~ 7~ ,,7rhe fnlloWing additional reiie~ ip granhedt The.Clumberlarid dounky ~lseri~Gtn Uepnrkmenk rJhnll akkempk.Cn make eorViae nk P~.ainkiEPr a requeaL and Witito--k pfre~paymet-k o!i ,. ,: . _ } ,,,_ ,. .... . ,. ,. t+eapr #~ut: ~+9rv~.aa mRy by RPPPmp~~PlFad uRdp~' °u~ P><a~?l#aRbiq RFt~.a , P~ P~.Y#,z pr9aadu~a, ,~ T~}~.p order ahRl~. bq t><PPtFPt:ad iu ,pha afP~:Pp at' the Pra1:~FPnapRry and ~orWR~dad ~A phe @hari~~ ~Pr aarYlanr Thp.PrgpZgQnaqRry.phRll naa aeud a aapy of ~ltia ~xdar 1:P ~at'andRnt: by mR~ir ' ~h~a Qrder w#}a~l ramRin ~.n eft:aat until modified ar baxtn~nat:ed , by 1:hFl pat}r~ and Qan #~a a~tendad bayahd NR ariginRl exprah~an dR~e ~,~ the aaur~ >'inda ~haG nefandant has uam,nip~ed pna~har Rap `~~ at Rk+u~a ox ~~!a engR~ad in R ~ataern ar ~rnaGiop NhaG„indigepea ~~ aantinued risk oP #larm Go ~iRin~i~e, :I ~ 1. .. oefendat~t is en;Ja~,ned from dtunaq~,nq or daatrPyinq any prap~rty pWnlad ~pinkix bx t:he psrt:iea or aWnad solely by ~lainti~~, , ~~ nePendRna;, ~a„ tP xePra~.n from liargaaing Plaint:ipQ~ a, relativaM ar the'minar dhild, Cdr A aerGit:ied ao~y of ,,Chia order shall ha ~rovidad to the Polioe department Whore Plainti;Cf rea~d4a and any opher.apenay apeofied heretskter~_Pennpylvpnia Ntata.Poliae (~ 9, Tlizr~, O1tpU1R -3UPpR,9bDfiJ9 C.~ ]1Ni' PRIOR f?CA OItWi~Tt' nNp (LLI ANY PIZ1012 ' ORpglt RALATTNq TO OJ1iLD CUpTOpY X10, THIq ORDER APPA~>Dl~ ~MM13D~A1'$LY TA DsFUNnANm' ANn d11AAta , REMAIN xN EFB~tlT UNTIA MODIFxEA OR xgRD9INAx>GA 8Y T}i~p COt1RT IIMxER NomxtlE AND xRAR=No, ~~ . t~omzaE To aE~Exng~ ,. , Defendant is heretay notified that violation of thie_Order nay repult in nrreat fox indirect criminal aontampt, which iN' punishable by a Rine-of up to Ql~oOp,pp and/ar up to eix months in fail, a3 Pa, o, p, pbll4, pdrisent oP 1Plainpif'i' to DeA~nderit~e xetuxn.,bo bhe residence shall net invalidate this order, Whioh oan only be ohariged or modified through t~}e filing of e~prop~iNtr court`papers for that purpose, ~3 kn,tl,q, p811;1,, befendarit i~N ,~ further notified Chat Violation of this Drde~ may Mub~ect'hl~a-/her to strata'charges and penalties under the p~nnaylvMni• Crimea tlode and to federal oharges erid.perialtiea under the Violence Ageinet Woven Aot, 1A U,p,tl, pq„AA4I~AAB;i. Any prateation order grMntad ,. ~ ,.„ ~: } , , ~, ~.. , ,.a-a ,. , _. .. ,, ~..,.; #~y a pPUxa Ala}' #~a pana~dared ~ri ana~ PFIAaetaupi{~ pxPpead~.~g~~ ~.a;alud~.n9' p#{~id pua~ady prpopedi;;yap uud®x ~l~la A~ (APmea~ip ~ala~i.p~a# p~ ~ha ~arinaXivari~a ppriapl~da~ad s~at:u~aa, NG~'~d~ mil ~+AW $N&PRa$M~N~' AEmxaxn~,~ ,; ~'h~P pxda~ aha~.l ba arikprge~ b~ ~ha npl~pa whA have ~uxiad~a~;#pr~ avax'~'lsil~~l~~~a raa~dari:pa oR a~1~ lopa~ipriP w#~axe a viQia~ipn ae ah~,a axdax oppux~i pA ;vhaxe ne~endan4 maX #?a loas~ei#, x;~ pe~andar~>: v~'ala~ey Raxagxa~ha ~ ~hxaueh.. G oe ~#~p oxda~, AaEand++n~ maX ha axrea~~d pn bhp phax~e of iRdreap px~.m~.rial Qptl#~r-mp~, Ari axxaaC fox vipla~~.pri ill` x#~~a Qxdax mad' #aa made W~4hpup waxxfl;lG, bailed aplelX pr; pxobghla pa;;ae~ Whaxher px rips bha Viola#snri ~a ppmiill~~ed ~ri Gha pxaaeu,ga oP laW eriflpxp®me;tt~, ~uppegtianp 4a an axxawa, 4#~e isW ~ri~prpamerik pEPipar phall palWe all WeaporiH aped ax p#1xaa~enpa bq'#~a uaad during ~ha viplaa~.ari pi' G#lip oxdax AR dux`iriB Pxipx iripidpriba pL' abuse, Waa~at-q mupu epx~hwixh #~ri,delivered ~p bhe sheri~~~a p~~iae ill' #;e pnuri~y which-iaaued Shia ordex~ w~;iari'p~kipa shall mairiuairi ~aaaeaa~.an p~ the WeaPpriH uri~il ~ux1a11er Oxder pE Ghia aoux~~ unless Che Weapon/a'-axe avidenae o~ a gximer iri which aaae~ ~#;eX shall xema~.n With the laW en~oraemenu sgnttay Whpae okfliaax.'made ,. bha grrepu, ~Y mitw con~'~', ~ ~TUdge Joan cttrey ,~ ?~LCorna~ fox Plaintiff :. ;; ,,, ~~ ,. ,. ,~ ~~. - _ , ,: ;~ ~~ ' o4~~platlia A`,. '1'ra~ylar. ~ ~N mNA gPU~tT o~ ppMMoN F'raQl19 ~y~~nt;~.~r? t t or put~ataRl,~Nn cprrNmY, „~WNNSY~VI•NzA v~ ~ ,. ~ ~Tcape~~1 Ta, 7'>:aapler, ~ l3a~apdarll: i PROTQC'PIO~r PROM ApU91p ;, ;, DANA CJCIs'1'OpY " Ppm~'mTON POR PRO'T'AC'1'T'ON PROM' p a~lfl ~~ .. ,. ' ~, ,.P1a~,11~iP.fia ~1ama iP at:epllanie n, 'A~'egpler, ~,~'~ mhia 1'eti~:iota lri Ei]ed. ott Uelto7,i of p4ep~ariie 1{, 'Trepplc~r ,, 3; T11e tldtn© o~ i:l~e pe>'pon Wha yeakf~ prol:eat:~,on from abµae'"i~ ai.ephanie A, m~'Qaaler, 9., nl.ain~iff ~ 9 addr~rya io' ?339 Ititner Flighway; carligle, ~, Pennaylyanit}, 170.13, , 5, Defepdsnt regideri aL• tlia falioWi~g addreaa.t ConodogUin©l: MoUilo Idom~ Aatatee (aMlp) laoti 1©3, NeWvil.le~ PenripX7.vr~nia, ;, ,. r, ~, Deferidalll;~p &oaial aeaUrity NUmUor is 9A6-©o-773A, ~, ,. DafendanC~p dat:o of Uirt:h ie o/9/G9~ Defendan4•~p pla.ae of ...employment is ItaadWay~I7xprepq, 1p0 ' RosdWay prive, Oarliale, I~et~naylvania, 170].3, G~ Tiefandant'_ia P1ainL•iff~s lruaband,_ ,. ,,, ;; ,, ,... ,. . ,. ~. f ,.. , ++„ „ I '~, nla#.nt~#.ff ~pelFS I:entnoa,ary a4aa4:nd Af t: ~p a, to i I`. Y 1 l: ~ W na ~l{ildt Max~.a)1 (caylo~ x334 Ii.1.1:{lax lligllWay la/a7/~~~~~ 1'xegglex caxl~.~a.e, [~A, 170#3 Q, )'lal.ilt;~ff And pa>'endan4 nxe (:ho paxegt~ Qf 4hQ following Nmf~l~~~gx all~.ld t ..~..1{G ,~g~ nCid 96a , ~a~ls~la~{aylae 9 Y~'g ~ pld x334 Rit: ar 1I1 y ~~ cAxltela,~ ~1*, 7013 ,. T11g EollQWin~ ~nfoxmagion is prpYidea,~n pupporG of " ~, PlaillL•iPf tp {^ac~pe~C fox an order nP. nl;tld aUafod.yt ;,, '` (a) 'rha al~.ld wap nn): born nub of Wedlopls, , (b) ,The, nllild. ie prANonl:ly in L•1le aupbc~c#y .oP PlainGiPP, , t3~epltaq#.e A, 'i'xof3aler, Whn 're~idAt3 aL• 2339 I~i{:nor.~ J11g1~Wa~, ~; ,~ Qarl~;ae ~ cumbarland cou~l:Y; Psnnpya:Vania, ~~ (o) ,51nao her b#.rl:la Glta oll.ild haq resided WiL•h L-lae Pol'loW,~ng perponq and aC the L'olloWing addreagapt , ' Perraon(el ohi,ld Address, un~,at3y ,. ~liixd- ~ e n~mw "lived w~ ~h oonE±denb~,, ~~ Maxiah Itaylee„ Plaint:ifP and cM17, 7~oL•iQ3 ~Preaeler Defendant ~+?/27,/94 , Newville,PA, t:o 2/17/99. Plainl:iff and 2334~~1ZiL•ner Highway 2/17/99 ' brandparenLq_ .Carliele,.Pn Lo PreaenL (d) P1ainL•iff, Gha moL•her of L•ho a)iild, ie currently repiding nt 2339 Ritriox I#ighWaY,~ Carlisle, cuinbe~-land Count:; renn'sylVania, , (e) . the is married, _ ~;, _ (fI Plaintiff aurxsllL•lY regidos WiL•h Lhe following persanp) ,. ,. „ „ ': ;..~; ,. ~. 1 ,. r,. ,, .,. ,. _... ,.,~. ~. ~. ., ~~I!' - ~ R~nhua?c} atad shaaon Na~~:lit:ala :.'l~iq~Q a~j.~ugh~p ariap~~Na~a:ti{:ala ua'ot:hor , ' (61 PePelldalal, the fa4laex', of flee a11~il,d is alla;ratal:ly re~id~.aae a~ ~Mw >aoGa.ns,Nawvt~.~o, aumbax~.and aounGY~ i'Qntaayivan~.a, fh)' Ne `ip plarried, _ ,. ,, (i) Plgint:i~f has Gaol; previoUely Par 4la~.pat:ed in qpy ~laiagor~ori oonae>?nipq,.oualody oi' ,l:lae aUoye men4l.ataed ola3ld ~.~ stay atlaea^ CogrL• , .; (~) Plai}at~.ff has no ~41oWlodge of. a11Y uUa~o4~Y roae~ opnaertaiit9 this ohl.ld ponding before a oo rl. i ~ d~aag~ Juri'adiagioq U.' h this ar any QGh~r , ,. , .; ,, (k) Pl~inti>?f dose not krioW any peraoq tao{: a r ,; aptioaa Who lase playpiaal oUetody of the a i.l, or aka ty to t;laia:. ~ ~ '':~' . au.ptody, or yiai'l:atioaa riglatq 'With roapeoL~~ to flee ,alaild Co haV'e '. ~' ',, (1)"' mlae oast; lnGereat:a ana ~tp alai.ld will Ue Perltlanept tye'~.fare of the minor ',; met: if ouatody is temporarily orata~ed to „#~laint~,fP ' '~penciitag a kaearin9 ~.ta. thiq Illatter Par r~aeoaa~,iilapltidi~51 ~~~, ; i ,~,, , ,t, t1) nlaiat.iff ie a reaPonNible ';f;'`ts` pgrept Who has ~ ~l~, proV.ided for the etlloL•ionaa. and- phy~ioal needy of Ghee d ~~ t',`,, :;, child ainoo hor 1~irth, and who can heet~~tak~ Dare o~~„ ~' `,,t,3~}~` ~,, , hlae manor child, ,Ft , r , (a) Defendant has ehoWn~by hie aUuae of nlaitati~f ~~ `,sib"'~~ that- he is rioL• ,~,~ ,+,,, an appropriate >'o1e Iltoclel fo , 1 ohild, - r t ae minor ,', t ,~~trt~~` i '`~#`~~ __ ,t, rl ,'r3hy~1 1'~ i ~~ 9+ The feats 'of Lhe moat resent iriaideriL• of ~~ ` folloWa t abUae ,are t;a , ~{1`~~ . Nttuc ~ ., ' ari or abouL• l~ebruary 17, 1999,. as Plaintiff Waa folding '. ' alothea,_ UefendanL• etatered the bedroom, .picked. Up lrhe folded .. ~ ,3~tp}~, olothee~ and threw l:hem arouhd Lhe room, befend~nt• stood i.h frortL• .of Plaintiff ' ~}; , lreaaed hie )Body 'agaittaL• her aiad f ~~'~~ i yelled ah ti ~, , {~ si` , ,'„'~, , ,us :. E , ' a ttl'j y . t „ t r{~ ~. .. ._, .. ,~;. lla;',,. Ppi'endant: fpt.no(!U'1.7. aa,.nint:l.1;C t-a t:hQ 1'l~~a>• uP1~nt1 ~ pllkthed 1 111.P Wll(?~•a body oa11p.1,n4 Ilan, l:U 111.1: hQ~' P1boW and ul~taltl.dPr LP~ultl.ng 1n pain, tlefandant~ g;~alaupd l'l.ala;t:i>?(: by tl;o t;~~a arm aaupl.ng a uruipa," WIt1.le Plaint:{.r.r wary ot1 t:hp tl.oca>', 'peean~i~nt; _ pNiled hapk l~ia- t•':I.pt: 1•n e t; ltregl:an1.11t3 manner. aaupi.ng t;er to cage fcalt hPr pa[gt:y, lo, I~afetldant hap 'QOmmll:i:pd t:lte :fola.owl~ng' Prior aptp of abuse ' agal.npG Plainti.r.f t a, ~ oti or abput: t:he and oC January ].999, Wl;en P1.ai'j;t:iti'f and lter ao-WorkPrn Ware bpwlius a>'tpr wor.1K, ~pe>:endant pnt:ered tl;e bowling al1aX and ahgked one oY l:ha P1an(:i~P'p porWo~^ycorp, ,pefandan~ left l:he bowling .alley, ,sltort].y L'1lereq~L•er, Plaiiltifl: and a friend left: t;o pick Up Plaintiffip dauglll:ar, Defetlda'nt tailgal:ed 11er fo#~ awhile, I:hQt1 pulled l;ip ~>'uok aaropp tl;e road in l:ront of her ear, Defendant violenl,lY punaktad attd ltiol~.ed the aa.r., attempted to alnaah tl;e window, and yelled at Plaint:ifP. i ~, a+~Ua• n9 hP>. I.o feat. i=or lter. pafetry a~;d L•~aumat:ising. t:l;e Plal,ntf'f~f3 daughter who was ih the beak peat crying, '. ' Plaintiff rattt>:ned" t•.o ltor repidenae and ..dropped oi~>; Iler , ...friend, DeTottdant jumped oUL- from beL•Ween the t>;uak end the oar gauping Plaintiff to fear and drive.away itt'an attelnpl. to avoid fur.tl;or abuse, De1.'endanL' pot in Ilib trua)G, ohaped P1ainL•iff, pull©d in T;ront of her, and pt;opped, I)efondanl: approached Plaintiff and y"lled'at her . to return ltotpe, Plainl::Lff,_ fearing fot her pafaty, drove away, ,. ~. b, In or &bouL- Doaember 1990, Defendant became enraged, picked up a,tolev9.pion, ripped Lhe plug from the-Wall, „ and GhreW iL• at Pl'aintiff' almopL- hi t:ting her, t)efendaht pipked up a soaking chair and forcefullyl•hreW it.tlle, denting the Wall, , a, Eiinae 1907, Defetidanthap abused Zlaintiff in Wayp I •~ ' itiiilUding the following t tlu~oWing glappep aL• P1ainL•iff, • ~ ~ grabbing and forcefully throWitig her L•o the grouted, pul.l.ing hip fipL• beak and threatening, L•o punch her ,, aaud~.ng her.. L-o foai• for her pafe'Ly, De>eildatit hap , ,. ,, .r. . , ._ ~, .j, , _ , . , . ,~ ,. ,. .. ~. ,~, ~~•ammed lle~' ~1Pad aaai.nat Ella Ploor, baPGPn hPl~ wl 1:liP ibnd w~•1:1- pa.ap4l.a t~asll aanp, a11Q1~Pd der wh~..~P P11P was nrPgnant:, and Brabbad holy brPaat atld gQn~•t;aa. araaa whoa" , ~.: 11P baaanlP all~r~, ,. x1, 'P11a Pollawillg po].iae deparl:nlon~ Qr ~aW PnPorpemPllt aQenpy , ~.n. Plle .area ip Wd>i.oll P~ain~iPP a.~.vP~ a11o11~d ba ~r(~vidad w~•I~h a oopY QP Llla Px°o~ep}:~.on O}c~ert i~ann~yl•Van~.a' ShaGo..Poliaa >?eparl;man4, ,,, :ta, mlae>'P iP . an .~•mm~da4o -and pa~opant: danger oP PNrl:llor abuse ,Prom 1;11e DaPehdant, ,, 19, B~.a~.nl.iPP ip aPl~ipq l,lle co~4rt L'C]"PrdHl' AeEoridant l:o 'pUay .. away erotp' GhP. repidogoe at: x334 R1•t:rler liigllWay, carliylPr' ' ' ~'ent~P}+xvan~.a, wlliall ire ow,led by P1ai11tiPf ~ P 'AarenGP, .. ,. ~~" ,, 19~ PPPQndanl:. oW~P a duty o~ pllpport l'o P1.ailltl.PP and the, minor oll~.ld, ~~,~. ,a; ~ r ~i ,. WFILII?pt'Ottq, PLATN'PIPP RrQulaama Tl(n'1' 'I'liA CO[7}Z',~ pNx!-R n Tb1M~'ORARY ~ ~, Of;DWRr AND, AP'TAI2 liL1ARINq, A GxNAU ORD>AIi '1'IfA'P WOttI,p DO 'PHiq ' b'otaUOW~Nat ~ ,. '. ,. ,.;; A, TZc~Prairi Ae>;elidant Proln aUur~ing, throatening, harap~ing, ~dx ~ ~, ,+, ptal>xipg t'1ainGi~P in arty plane where nlaint~,PP maybe Pourid, „~ ~r r, n, Order Dot?endanl: ~.to aLay,.aWay Prom l'lairitiPP ~ p; repidetlae and: '` ~~' , ,,1r5# prohibit , Dependant Proin .attailtpting to enL•er ally tr9mporPry or , , r` permanent:„regidonae oP nlainL•iPP, ~ ~ ~.~,; k,4 ' .~ ,' ~.` ~,~ 14 , C', Award PlaigtiPp tehlporar aUpLod oP G ie minor ahi7.d and ~~ }"'4 Y Y 1 ,, t<<,~,';; plaoe the Pol].oWitlg royL•riotiona .~o;^ aonL•aaL• boL•wee1~ Depeq'darih ,~[ld '' pct o11i.;lat'bePendant nha7.1 have Glio ohild Lhe'Werjkend oP r~U~Uar ryg '„ '~,~~Ir~it a.99g, Prom rrida t. s t oo ~ ~ , ; , ,,;~q'~j%', ~rr~.E~, uegiriuing Marsh 6,1999, Aependal>.L~nhalldliavetpartia].~auN4ody, p~,'';~.,,, ,1~ tni, Llte a1lil.d tlle' PiraL•, L•h>•oo Woo-~enda oP eaah month Pxom ~'r~,day ~~ ~ 'l,~~ t~~~ ~~'' atoa p,m, ilntil. aunday 3100 p,tn, ' ~,,~ ,~~j ~_ ,,r 4 , A, l~rohihit.• peEandanL• from having Any oonL•aat• Witt Plaihti~~, ,~;.~,'i,,Ff either in pPrgon, Uy L•elopitono, or' in WriL•ing, peraoria~„ty~bk ~ ,,~',~;"~~ through third pexaone, inoluciing, UuL• not; lifpiL•ed ta, any'.at~rit~-grd sk g . ,~,~, r , ~ ~+_,~ „ ' +i. r~~ .. ~ _ ~ r~ _ .. n , ~ fay 1 ~'tj ~ -`~4t: f i7 ... 1_ "~' 1C. o.t+'i~ ", ., ~ :; ~. ~• ~. , a4-i~:1.a~.Itt:~f:l?~p plapa op amploynlenC, e~coepG as I:l'{a, CpUrt: play f.in~ napessary WiGli res~aol: l:o par4iaa aUSl:ody WiGlt I:ha, m~.nor phild, , l~, Prahipi.l: AafandaTl4 frpln having any oo{tL•aoC w1.4h ['lainGi>f ~a ~alal:ivaa and minor ali~.ld, AxpepC ns Cha opUrt tray ~~nd naoegpary, W~.l:h rospaat: to partial apsCody WiCll t:he m~.itor ah~.ld, ~', order Ae>?andan4 t'~o pay Ceinporary suppot^l: for P~.ainG~.>•x and Glte miner nlt~.ld, inaludiilg medical support: and payment' of l:lte rant or nlar~~age on Clte residanpe; ' q, „order Defendant: Gp pay Clte oosGs of t:ltis aoLio{i, inoluding ' filing Ease, serV~ao fees, and suroltargp of X25,00, ~;, ll, order Defendant Co pay ~2fio,0o Co reimhttrsd one of I,agal 9arviaoa.~ Ina,'s fut1ding souraep for Cho dosC df lit;igat:i411 ,ln 4his oase, ~ - I, OrdQr Cha Eo7.loWing addit:l.ona.l relief, noC ].isGed aUoVai a, DefendanC is en~oiped from damaging or desl:rgying any properCy 4Wned joinCly Uy C1te pa.rCies or oWped solely Uy , ' P1ainCiff, " b, DefendaniC is Lo ref rain 'from harassing f~1a~,nkifE~a. ra.'lala.vea and Che minor child, g, dranC auah oL'lt{~r r©lieR as the oourL deems appropriaCe, order Che poli'~e or ocher. laW enfordemenC agenoy Co serve ~, DefendanC With a-Dopy of Gh.s'PeCit:ion, any order issued, and Ch© ' order for Hearing, !?laintiff Will inform Che designal:ed '~ gtiChorit-y oi' any addressee', oChor Chan DofendanC~s rasidenoe, wlierA DefendanL• Dan Ua served, ~- ODUNT II Op&TODY t1NDE~t P>BNNgYI,VANIA tlU&TODY~{~ 1G, The allogaCions,of Count I aUoVe are inoorpo.raL-ed llerdih "' ae if fully sec forL•h, ,. iG, 'I'ha UesL• inL•brasL• and perlnaneriL• welfare of L•lte ,tpinor _. 1 r a11i:1.d will ua: pp>'vpd by aanP.~.xniintt aual:ody i,n PJ.~~.µ~:i!?P. µ~ µah ~ni:t:#t is pa~anx~+p#t i-a aJ' L•ho pe-:~~.la~t, _ . ,, WN1~RWrPRW, pµrau~nl~ ~o ~a na,a,ar21 s3a1 BL. &~„ end Ql:her ~ttpp~.~.pab~.p rµlap and 1.{iw, na.µinG:lf.t~ prays ~lt~µ 1laµargh~•a. coµrr !;q ;, aw€4x~i at~p~ody oP t:he m~nc~i~ altitd, ~o lte~ Na.ain4i~~ praye L•ar pltolt oG:ller. ~ali.e~ qq may ba ~µµt;,;and ~ ,~ px'opar ~ , Raspoal:~u~ly ~ubm~:4Ged, .. ,. -~ ,, AuL•ornay ~or~ P1ainCif~' '; taApAT~ a~RVxcpa, -tNC, 0 T.rV1•pe RoW". ~. .. garlip].a, PX~ 17013 (7171 a43^9A00 ' Da~edt cad (, ~ ~~,~-~ ,.' ,. , .1 .i I.1~ i_ i '~1 i ,l, i. .~ .. ,. ~, I~ . ,, .. r. ~. ~' .. . • _"'~^'-Aw~w~Wmli1PFRT'n^`IIRSN~*<'fiM~M~A}~M~I~~R~~ tih'phgnle A,'I'runhlur, ~ tIN'I'I11? ('c~~llt'I'c)Irc'ntvltilclN I'I.I?~5 hltllnlil'I' t!)~'c'1.1Mill?lil.r\Nt)!'oltN'I'Y,1'I?NNSYI-YANK . vn, I " iN!), r-,-- IltHrt c'IV11;'I'ItRM ,Ittnvlt~t I,,.'I'I'uH51v1', t ~~ ~~ I)vl~itrlttlll Ihh!)1'I;C"PION I'ItOhl r11)1151~± ~~ u1Nl) cUti'I'ol)Y L; INAI, LLil)liit Olr ('OI l 1)ulhndnnl'y Nnttntr~IrlHUnh I+~'I't'unnlut+ ~~ (')vfundnnt'n l)iilu ttl'I31rIh; Hl9/(r9 laulvlulrlnl'y Snvlttl 5uuttt'ha' NUiitbcl'i +I+IC+•HII.77,1~ Ntttttu ul' I'rn{uulvcl I'urscut? Htuphunlu A, 'ft'vnnlur ANU NOW, thin •''~Ililny of Mut'uh , I')~r), Ihu un-trt Iutviltµ;InrleQlvtiutt uvul+ fhu put'tlun .. and Ihu nultJuut-nntttur, II In QR1~14RP'.I), r1t),IUp(,h:p, and I)h:Cltpap 4in fallrtwnt I'lltittllPf In ruprunuiltud by dnnl- cytl'o1' nl' 1.1'.(.AI, til+'.ItYIC9~.5, INC,{ 1)ufundunt la -+upl'ununtvd' by Murlc W, Allnhnunv vl'tinldin, (inldn, tihul'f and Mpeliuid, -Thu pnrtlux nl4ruv that tlro follr-wlttK n-ny.itu unturuc.l tIH nu Ardor of Court, pul'vndnnt, nlfhottgh ugroohtN fllut nn Ardor nuty hu ontvrud, dnun nrtt ndndt tn.ihv nlluHntlnn nwdv lu ihu'I'utillnn, " ,d Nlnlndl'I'n rutjuusl fltr nlrhtnll'ruluullrm order In rlunlud olt. ~PIt1lnNft's ralnunt fnr n hlpnl NrutuvNon c)rdvr In µrnntwL ' ®I, UOfolldtlitl Hhllil Ilot IIIt11~V, xtllliq IIIII'IIHH, thlwnlun I'lulnliff ol` Ihq' olltut' prufuutud pvrnvu in uny phlvo tvhoru thu~~ might hu fnund, L~ ; , Uulitndnnl IH uut»plclul~' uvluturl and uxnluclud Il'om Iltu I•uwkluttuu of *INoNCONlrll)I7N'I'IAI. r11)bltl'stiS I~Ito~~ WI IICI (I)I?IrI:NI)r\N'I' IS I;XCI.,III)I?p) or rgty olltgl' I'unlduttau lvlturu I'htlhlll'I'nnq- livv~ C?xulu4lvu putiyuaylun rtl'tltu rusldultuu is el'nltWd lit I'luinlll'I', I)ulbndnnt yhnll hove nu rlghl ru' prlvll4`gu lu untor nr hu Itruxol~l on fhu prutttiaus, ra (iit ~Innurldiilc aq~l Ilmul, I)olundnm trot>' uriiur~Qu` rcyldunualu rulrluvu hlr+/hvr clothing and ;. '~ ,. x • ~:;, ,. ,. .. " ~t, ' „ , other i?urxnlllll el'I'ue1N prnvl4lud that I)efPnd{mtin in Ihu unmpnny nl'n lilw unlin'~emul,p nfilgpr' ~ ,;' whoa Nueh relrlPVnl IN nln4lu, ~f3, 1~>4eel)t uN prnvllled in 1'nrnllrl-lih 5 nl'ihiN t)rller, pefendnnt iN prnhlhitell f1'nm ;,' hnvhlK ANY ~:(?N'1'AC:'I'rvith Phlinilff ni amy Inwtlnn, inululllntl, hu{ not Iindted to Ilny unlNnet nt I'hlhllift'n Idneu of en1l11nymPnt of tinnntiull Renhmm~nt,'~Ilt- Wnhlat Ilntfunr- I~p4111, Gnl'IINIe, tinl'Inll llle hnnl'n I'111iI1tlff In R'nl'Itlllµ~ Refenlhlllt IH nilueifleully 111'IIUI'elLtn Nt11y,111Yi1y fl'11111 llle fnIlnlVlllu IIIPIIIIpllli fnl' file dlll'lllhln of tills RI'(lul') Itinilltiff'N 1'PHI11eneQ Ineutud Nt ~3:i~ RI1nPr t11µl1wny; t=tirllNiu, ~nlllilul'Innd ~•Innll~',1'vlglsylvnnhh na41 nl-y other 1'onidenee hhlirltlff only eefnhllNh~ •' ;, ~A, luxovpt nN prnvhled hl I'nrut;rnph 5 of thin'f)1'dor, pufendnnt Nlliill not uiatnet Phlhltiff , I-y telephnlte nl' by tiny ntlll+l' nlannn, htuludhltt third pnrtlun, ,. ~5, Cnxh-dy of the nlinm' child, Mnritlh It:nyluu'1'1'unNlur, nludl hu i1N fnllnwNl Nov utttlehud 'I'olipiarn-y cuNtnlly ~rdul' , - (_7 (i, hofalldlnlt shllll hltlltadllllaly 1411'11 PYoI' 4n tho Nltw9fix ol'llua, or to a lnanl law unfat'oumunt '' ullunuy liti' dellvoly to Iha Shurifl'x Qfllua, Iho IitAnwlne wunpnnn uxad nr tht'un1~11ud In ha tlxad Uy putunclnnt ht nll uul ctl'nhtlNO IlBnlllx(Nlidltlll'f and/nr tho mhos' uhlld/i'oiti - Q 7 pufandanl IN prohlhltod h'c~ll pnNxoxxing, It'nnNl'orring ctr I~uglilrin~ nny'nlhor w~a~~rntN tnr Illy dpriltlml Uftlllx ot'dcl'~ rally tYVhitnllx dullYOrud lrt tho Nltal'U1'Uildol' Nltt'liBt'llltll G of thlx Ordor ar nndpr Pnl'nhi'nph C ol'thu'I'anlpnl'IUy ot'dat' xhnll n+tl bu rotul'nucl until Iln~lltw' ordor of Cnurt, , ® H, .Thu fnllnwlnq ndltitlnnnl ruiluf Ix µrnntod nN lulthnrirud by ~GItIH nf,IhlN Aolt n; 'Phis ordol' nhnli ronulht bl uffcut nntll atndlflutl dl' turnllnplud by thu court" and unn ho uxtundod hoynnd Itn.al'lµluul oxllh'ntinu data If tllu Court flndx U-nt I)uPuhdlult ' IIIIN cnnulllttorl Iulothul' Ilot Ilf III111Na nr hnn ungnµoll Itl n Inlttorn nl' prnotloo that IndialtuN " ulmthulod rixlt of hnrul In I'Inhltlff, b, I)ufalulunt IN utlJnhlod from Ihnnuyhlg nr duntwlyhlq nny luvglorly ownod Julnily lty tha It11rtI0A 111' IlWnad Nlllal~' by i'Inlptlff, o,. I)ufondnnt IN til 1'ufl'niu from hm'nNeluµ plaintiff's rulntlvue nr tho mp-m' u111116 ~ d, . '1'ho court unNIN mul fuuN nru N'nlvud~ ~ " ,. „, . ..,. .. ., ~. _ is ~~ ~~ .. ~'~i iaPfunllnnl ix diruelPll,t~1 pny 1un~Ilnruly etq-Iiill'1 fnl' Stephnlti~ r1, 'I'rundior unli Mulqull .u ; KIIyIVV'1'pVHNIPI' IIH f11II1111'HI''~~f1111~Ih1 IIVI' 11111111Th `I'IIiH AI'(IVC.1'pp dpIlI1111'1 di111II 1'Vlllilill IN PffPP1 RN1iI 11 fiI1A) HRhI1p1'1 ui'41V1' iH PIIIPPV{I'Tly IIIIH CIIgP1, IIIIIVVY'DI'1 1IIiH (11'IIPI' HTIIII) TIITIdV IIN11-R1111IPAT~y If NIIIIllliff IIIIPH 11111 ~IIV Il DIIIIIhIIITIII flll' d11I1I1111'11Vi1T1 111P C(Ilil'11Vi111i11 fIfIPV11 Ii11yN pf 1IIP IT111P Ilf 1IIIH 1L1'IIVI',"'I'IIP IIIppR111 Ilf 111TH 1P111l{1111'lll'y 1114IV!' (IIIPH 11111 pPVDNHiII'IIy POfIDPI IaVfV111h1111'H P(11'1'VVI HII 1 11-I'1 IIIITI 111IIIIh tYhI II HI Q i h ' 1 ) i I ' I 1 I ~ V V III ~ V 11V1 PI lIl ll IIPVIII I IpIPV , 1VI111 (IIP t~11111pII1lPH J111hP d11I1T1p1'1 IIDIII'lll!{, (111y N4I~NH111lPIIIH Ill 1I1V fI1N1I NIIInllllt llf Hllppnrt r, AIIRII (1P PI'~IIIIVITI 1'P11'lINV1IYV 111 1IIIH III11Dt 111 1IIV Ilhhl'11I1)'IRIV I1111't5', la'1 Q, 'I~hu VnHIH of Ihle I1Vl,IP11111'u 1VIIIVUII llH Itt 1?IIIIIl1If1 1111tI I111pnHV(I 41111)ulblllilllll, ~~ ~. la I I i, I)V1DI1(IIIIII Hh11II 1111y'G* IR ItIRInllil lIH Up1111tPIlHNlIt111 11t1',1'lhhllll'1'H n114•nI'•ptwkDl IItHHDdI ` 1Yhloh 41I'P IIH Iltllq\VHI ,, OIZ ~l Itllllnllff IH ernnlud IUnvu,)rrpruHulll it pcilllon, \vllh npl,i'apriilp Ilttlluu In pta'undmlh tQ GlnHUrt Iho I11Ullu o1'lhu,Illdeu t,Y UUuI'l ltt vvhluh the 1»111In11 Hhttllld hu pruHUillud~ I'uctllU?ilhl~ i'cVttVUly of c,Ul^PI^I?puhPl IOHHDH, 'fhu pUIhlnll.PhRII 111u11hIP till Unhlhll ItU111~7•hlg IIII Dllllillutl olll•t1f^IttlUhOl , IQHHUH, unploH nl'uIl hIIIH I11UI uHllitl(11uH pf,lvpllh', IIIUI 1111 Ortlul' Huhudl11I11811 hullfipg, Nn fcc Hhall bo 1'ctjilli'od by 111D I'rclhcilnhn'y's nffluU Iitr lhU lilhtg ul'Ihls pDlhh,q, " ,. ,. la 12, IIRApY TNI]IcA'I'OIt ,, I,CI It1111111If1'01; pl'nlcUlutl I,CI'dUll(H) IH 11 HIri,IIHU~ 12t1'lllul' HI,gIISU, 11 pUl'Hnll 1VIta cpllllblUlluH pr hOH oahn(tllutl \Vilh I)Ufclldplll, h ltpl'clll of 11 uo111111ot1 Dhllcl, !1 chlltl ol'lhE1l Itlt1'Hpp', pl' II ohlld t)f Uolcndplll, ,. 2,C1'I'hIH OI•tiul`IH hiiing Untol'ud ItilUl'tl huuPing al'w111o11 DUIUlltlpnl ruuolvud tlullllll nolloo mtd ,, hRti 1111 ol,pnrillll~(y ht,l,o Itunl'tL ,, „ ,. " 1,1~1'nrng~~aph I,aI;IhIH order has Itucn uheokud to ruHhnfn L)ol'Undnnl Ihttnt harnHHln~, Hlnikhl(3, ' t,l' lhl'c111UItI11~j,1'+Illilllli'ttl' prolcolud pcl'HOIt(H), 4,C1 I)cfutldllitl I'Upl'UAdt1lH II urotllhlu Iltt'unl to lltc phyHlctll HnI'cly of 1'Inhtllfl'ol' ulhur pl'olcolcd pu1'HOII(H) 012. a f~ ~I'hU (Ul'I1tH ol'IhIH Ort1Ur Itrllhll111 I)Clblltlpttl I)'ultl uHhlg, gllUlllltlhly ltt IIHU, ot'tI1rUHlullhtg lu IIHU ). 'j ~ thyHlegl li,I'cU QgIdI1Hl I'IIIIIIIII)'ol' (tl'(1lOClcd I101'HOIt lhlll 1VOtlld I'CIIHOI1lIhI~' ho p;(I,UDIDQ lU OIIIIHu ~ ,tunly Injury, `. Y ' ., .. ~ '~ ., i .. ~. ~', '19lIS c)lipl~~lt SUI'I~;Ilc~i4plu,~~ ENV I'Itit)It I'1!'A tal~l)I~;It ANI)I~ r~NY PIi14)It ' AI~I)1(It Ii1~.1+A'1'INfi'I'A ~'lllld) ~•'US'1'OpY, ,. 1±1, ~A Imnvlninun of thin (,)r11vr xhull uzph'u i-- nnu ~'vur~ NA9'If•1';'!'A I)V:1~9~;NI)r1N'I' VIAI•A'19ON UI~„1'lllS ORI)hli MAY RIC5U1; I' IN YOUR r11i1ttS'1' (iN'1'lll~ ~'FIAR4~1~ ()I~ INI)IItICG'1' GIiIMINAIa GAN'I'GMP'I' \VIIIG.11 IS PUNISFIAll1,l4 UV A I'INIa OI+ UP'I'A fil,tNlll ANRIO1(A~~IAII. SIuN9'~NcIC (1[! UI' 9'f) SIX MAN'191~, Z1 I'!1,c,S, ~(rl Ids VIAL+A'PIt)N MAY AI~SA SUIi,11~;C't' YA--'PA pltc)SI~,GU'I'If)N ANI c1~IMINAIa I'lCNA1.'1'IIuS UNI)lul('1'IIP; PGNNSYI~VANIA G'I(IMI.S c~)p1, '1'tpS oltl)Idlt IS rNl~c)ItGICnNI.t• IN Al,l+!!11~'1'V (SO) S'I'A'PI~;S,'1'lll~'. I)Is'1'ltlt'1' c)1~' cCl.UM1ilA,'CIt11iAh1~ANpS, t1,S,'19~;IiR1'Pgltil;S, ANI)'1'lih Gc)MMc)N1VG,AhPI1 c)R ItU1Cit'1'A ItIG'O UNI)I~;R'i'FII~; VIaI.U;NC.9u A(iA1NS9' WaMf~;N AGTIAN, IN U,S,G, ~~ ~Z~fi~, I1~ Yul1 q'1~'AVlul, pU'1'SII)IC ~I~"1'IIIu S'1'A'I'~I.~ANI) INTf.N'1'IC)NAt,1aY '~ VuN,ATr 7'Ii1S ~I~pP}It, Vnll MAY lil4 SUlidl~c'1"PG GIUpIuRAI, cItIMINn1, 1'Itpc1&Irl)INc;S UNI)I~It'I'FIA'I' Af:'I', 1R I1,r,G, ~~'x2fil~~2t;2, Ili 1'Akt~~illAPlfi 12 O1~ 'I'RIS Q1;1)iC1; HAS ll1uU,N c111CeKl~;l), YbU MAV!111a SUll,irc'I"I'O I~IPIuI;Ala. 1'RASrcU'I'IoN ANn rrNA1,'t'IIS UNI)Iui1'Cilu, ~~IiRAI)Y~~ i'Rc)VISIc)NS c)f'i'FIIC cIUN c~N'I'Itol, AG'I'IpN, (N t1,S,c, gf)22((.~), P'Qli P()RSrSS1oN,'I'ItANSNoIt'P olt arch;tl''r c)r rlltrAltMS c)It AMhiuNIThN, N~'i'ICh;'1'o LAW,I~;NI~'c)ItcrNII~,N'I' UI• rlrlAl.S 'I'ho pniiuu wbn bravo Jurixdiutlnn'm~a' Ph-h-Nft'x ruxirlorwu c)It nny IoenNnn Whom n ' vinlntin-- of tltix Ortlut• (iuupt•x OIt whore pofundlutt nuq' 110 I(ICn1U(I, xbull onfnt'oo dtix Qrtiur, Ate nrt•ont for vi111ndnn of Pltrugrnphx t thrnuKh 7 of Iblx ortlor mny ho without ' rvnrrl-nb: bpnoQ xr-loly on pt•r-hnhlu ouuxp, whvtl-vr nr not tho vlnlnNou in onmmitlod In tho juwxonuv of fho p(IUoo, 2,i lh-,C,S, p61 Id,. ;~ y11i1xOllUUnt t1F1111 IIt9'oxt, lhu pallou offloot' xhnii xuiru qll wuuponx uxod nr tlu•ulttoi(o(I In bu uxud durhrg tho vl(Antlnn of iho Ihrotootlu110rdor nrduring lirlor inuldoute of nbusu, '1'ho ~Innvrl fiw upprrgtriltlo nnmu'a-' tItIU) xilllll IIIIIi11t11tU I111xN09x11111 Ilf tllo \VUllhllllx Illlti) ,.nu'thot+brdor nf.thix Cntn'h Whoa pofun(hmt ix pluood nndut• mo'oxl for vlolntiun of tho .. Ordor, Uofunduut xh1111 Ito htlcon t(- tho npprollrioto unfltnrity or' uuHh1~'Itiox bufotw whntn Uofondnnt In to bo nt'ruluned, A "Cnprplnhrt fllr Indh•oot rt4nUnnl C(n-tonrpt" nlatU thou' IIU U(IIIII11l1tCll IIIIQ Nl~lto(Lhy iho pnliuo ofgeut• qlc I'InbrNff, I'hthrNfnx prexonoo Intl plunutln'o uro nut twq-tb•od to fllo tltu uompluin6 ,. ~ i` ~, - ~ j'~. .. .1. _. .. 4 ' If nuffiuiWUl (?irn--q-1x fir vlnletine of Ihln rarAer ern nllese-I, Refen-hntt nhnA hu ' '' 'nrrelµeerl, hentl xpt nntl hetl- perUun yiree -tatleu ttf thu +lilu of the Iteerl--R, , ItY'I'IIP; c~tttlt'i', ' ~; , ;, ,~ % '( ' dr exluy ~alar„It~„ ,lud~~ '' 1 ,. If untot~ud purnuent t~~ the anexunt nl' I'Iebrill•I' eiul laofolidanu ,. ~ ,. ~--• . ~ Ste ~lutnlo n~ 'I'runxlor • .''Jc~HUhh I„ TI'uxxlel' Ple~etiff , I)ol'und4ml ,i,Inen cte•oy ~ ~ el'k W, Allaluxrxo ~ ,. , Attoreoy fc~P I'Inlntiff r tlrrenoy liar pufued,~ill ~: ,. ,,.,; ~;. ,, ~~ _ ~ ~ ,r~i ~„ ~E,a. , ; , • #~k .. ~ i !i~ ~~, ~~ ~ ~~ ,~ +tdlr I ,. ~. a ~~ e ~, r ~~. ~, ~ ~ t,'r~~t' ,~ ~, ,,~ ,. ~t,t _.~td ,. ~ ,. .. I IAA 1 ~~~,'~ . ~~ ,. •, , II ~ .. ~ ~. htaphanlu A.'I'r~NHlar, I IN '1911? c'ttUlt'I' (tl' ~"nMMtaN pI.I:AIi ~R I'Inlntll'f ( ' t r;a)MHI?RI~~lNp ~'ttl.tN'I'Y, PI?NNSYI.VANIA _ v, ,. t , i Nt~,')r)=I(tf•ct c'IV11-'I'I?IiM - JoHpplt l,~ 'I'1'UNNIPI', I ,. _ halbndnltt ~ .I'Rt)'I'I?t-"I'It)N I'ISC)M ~IIU`11i _ ,, ; r1Np c'1159't)IaY ~, , , , . !i?.l~Ali~Y cu~,'I'ci11~Rh1.R ~' ~~ ' ANP NnW, thlH ~dny ctl', 14c)c), Igxgt ontlHldat'ullint ul'lltu pnl'llaH' CottNaltt , Ayrauptunh thu InllntvhtB or<far Irr aulal'ud \vhh 1'ayllfd (n otlHln4ly ol'tha p411'lluH' ahlltl, Mitrinh~ fGnylaa'I raHHlort ', '; ' Pltthrilfl', hurolnnllot' i~al'arracl Icy nH tho.ntolhor, Nnd Pofottdtnil, horoinnftor rpft?rrad t~ nN tha fttlltar, Hhnll hava Nhnrad IuBal ouHlctdy al'tlty vitlid, IIr it • „ z, Thu ntc~lhut' Hhitll hnva prlmnry pltyNlun) uuHtody of tha oltild, ' " .' ,, ~. 3, ., '1'Ita fnthot' Hhltil Itnvu purllul vuNlo~ly nl'titP oltUcl lho 11t'Nt throw woakottdH oJ'ono-t ut,~ulh A'rnn i~rltltty at atoll p,tn, tntt115tntday uI atoo p.m; ' , ~' , ,"~~ ;.;+ ~~ q, 'I'ha ItnrllaH Hhnll Hhnt'o Iho Ihu li~llc~whtg holldnyH nt tlntaH lterood ulion bythe ;, ,~ pnrtlaHt 13nHter, Manutrin) nny, tho I~aurth of July, nttd Luhor,pny, _ : 1;~= ~~ ;'.. 5; 'I'ho Atthor Hltltll hnyo tha child'ChrlHuttaH L'vo Nnd ChrlHuttnH pay anah your tl'ont a . ; ',}r,;, CbrlHpnuH d?vu rit Gfgo p,nt~ until ChrlHutinH Iffy nt Ggto p,nt, ~'~ ;;, ,~ , ~, ,,-~n 1 G, 'I'ha litthor, Hhrill hove tha right jo Hao Ilia ohlid cm hor blrthdny nt tt tl~na to bt+~ ~ r ~ ~!! ; ~'~~~ tterood upon liy Iho pnrtioH, _ ' ,, ~ ~ ~, ~~'1~ ~,:!~kl~ id'~ ~ -~ ` r` ~ t~ DTI '/(t7rt~iA~. 7. 'I'Ito futltap Hhall huva Ihu risltl to pnl'tlNl ouHtady nl'tha ohlld far atta Waok of agph "' ,c,1'' f~~'~ r i{ r r,~, i 1 i(7 1r`~7~~ Huntntor, 'l'ho fitlltor will f31vo lho tttoi,tat', ul IoaHl Iwo waokH nollou ste to Wltal! hla iforlo{- a;F . ~, j, i,,},} t ~~' ~ Hunattor ouetody will tnko plgoa, '1'Ito nuaAtar will havo Ilw rleltt to hava tlte~ ahlld oil wogltatts~~ ;,; j .,~~~ u ~ dut9no that lima ultlaHH tlta littltat' InkaH tha altlll on n vucnAon trip htaludlttg wankQgdHc `I"1-q ` ` '; ,'I+~s` ' ' ~, itttthar ulHO I1lIN Ilia rlglu Icrhike ha altlld ou a ainttntar vaarttlan Inohulllt8 q,ginrtlttiyltt of;jWp,,i+,1,~t '~ ~ l+ lt~ WaakondH~ , .,, 1' t`J N. 'I'ha tttcxhar and Ihthor, by nuuuni ayraentont, ntny vary 11'utn thlH Halmdtt~a at ~t-~,,,t~ „,~~~r ' Umo, but Iho ordar ahnll ronudn In al'fLat until 11u•Ilwr ordat' ol'aourL ~" r ,' ,, `,rr y,,,~ c), Thu nuriltor and li~tltot' Hhnll glvo atop alltor 2q hour ttotlao ar raaeottnbla'gbt~tF,~ ~' ~ ~t,,J,,m , , ."uE.. l,,;~~ r x,,~„ ,i` ; ,Fi'}qtr , -~ ~ 1 S ,:.y- +. r ~)fi ,• ,,. ,, ,;; nn atnpr~anuv (fa Huhuilulutl pui'Ind nl'pnrUnl utie+tn-iy nuucla In hu ulutuulut) m~ titncllltutl uncl tl ntflku=ttp purled t+hall I» nl'furud within it runennnl)lu Iitnu ft'aiiiu~ 10. `i'hu mnthpr and li)tliut' 8httll hnvu tha rl~ln to rultannflhl}? tuluphlniu tuininul.lt!Ith ~• Ilia uhild whllu. HhuiH ht Iltu ntliur pflrunt'a ~nru, ,, L Thu ntntliar and lidhuh n~rua that utiuh Hhnll nnlil)~ Ihe'~~thur iminedlfltuly nl' nt~diufll utttvt'~onulue witluh m~laN, -vhll~ thu ultlld IH in )het pnrunfH u1uw, 12, Nc,illror Ilfll'ultl 811x11 llcl 11ItylIllaB 1Vhioh Inay aHlrfllllta tlla ahlld 11'nlfl tha nlhur . ptu'anh nr Iglt+ra thu apinlc)n nl'dtU ahllcl pN to the nthur pnront nr which nary lunnpul' Iho fi'au tntcl ' ,• ttnltirtd cluvalopmuat nl'tt-u uhlld'8 lava nr ragpaot It.,r thu nUnm parunt. I~. 1-ithur ptn;ly,,nary ruituutat a ~-'nnulllatlnn Gntlurvnao,'hut thin ordor shall rwnnin in afl'uut ponclint3 IGrth~r ord~-' nl'C'nur1~ '' Ity thu~,c~in~t, / , ~!~} , ;; d usluy tiiw ~,ir,~ dudt3a If unt~rucl pui~aunnt to Ih4t uaneunt ul' I'Itdntll'f intcl f)ufi+nclnllU f ' ~ 9 ~ /~ i~ / / .~„ St~phn to A, h'OANIOr 4 i" JoNOplt 1.., 'I't'~tae+lar - • , I'li-indfl' ! putunclanl D ~, ~ 'I, nnn Caruty M rk W, Allahnusu ' Altpt'nuy inl' Plnlnlllt' ,. rlUnrnuy li,r 1)ulutul)i ri '~, - •; „:' >, ,~ • ., ~~ ,: ,3 a N}lWliTl~'l~' ~ p !?('%'d'UI2I~ - (2.G;glJLF,~1 C'~1Su.I~Ot ~9~9~O~ppfi I' , COMMMMON WIHn I,'1'~1 Ole Pl~NnNl9~'1rYnWI~11 ~ ~~ r ° ' ., „ COUN'3,Y p1~ cuMpfill2LnNt3~ ' -! ~ ~ 1 „ ~ ~ W A ,'' , TR 4 8L,1J Z al>u[ II~f x_'~paal,cl~n~ r, ,, .: nAVTD hICICINNI~Y ;. .. -----_..__, al1D>?trf Ol' uonul%y a!}e].'3EE- OE ' pUMlaglil~ANp co~1114y., PDipleylYan.1.~1, Who UD~.Itg dua.y aWgrta aopoa:ditlg i ,`'Go ~~wl a~tya, I:IIe wj.l:h~n 1~a~mucTloN rROM nl3ust;r ' upop ?'Rwsar~Ga aoalLnll ra w~a AD>,vpd ' dWfDllddlll: ~' 1,1 -- „ "_'_' ,. --~----~-~..T (:hp , ~ 127 lIOUR,9, oh L•IlD 2_ Gl;h d7y ~1' Gel],;41ArV ' 1999 a1L _ G'O1QOl)OgU7NI1T MOI3TIdu'FIOM4 17a1 "" I ' " I~0'1' 1 A 3 ~'' ~1NWVII~hhu, 1'A 17291 - ~~ - CounLy, Pe1111ay.1VAniq, !] ll~tld•l llg Co aoa • P ~ '^^-I rUMallRI~Ai~ ' ~~ '~ ~ ~ ~ _ll I,, `IRgaalaL7R , ~l ~1'l1e ~3tld AL-L•eaL•ed oop~ pE l:hD PItOTlaC`1'TON C'ROM AAUA17 ~ , ~o£1DI:he~: WiCl1 ANl CUa'1'013Y, NO'1'TC17"Olr III7 RIIjQ ANll' OItU17R, I~~ "TG1MP0!'4ARY PRO'1'1CT'TON CROM AI3U91] oltpruR ~`-^-' .and pit. I.lle artlne 1.i111o, direct•i.n itr:, ~t.LDtlt:ioll t,o l; e., co' t.e ~ I ~. ,. 9 ~ r ' 11 !1' i1L'q LllereoE., t911Dr~.E ~'' COpl: f31 ,. ~. ~. a0 A ~ r ~oalyyc ~ellg l0 00 >l WDrs + _ . AP1~1~aVil; 7, 99 r aura large ©'p~, '~ ~ ~, , R ~~~~~ ' ,. _ ... X33 ; 9T '. ~ ~ ' 0301/1999 1 f5' ! . „, aWorrt atld pUlsaor#lie~1 L-o bD[ore ipo , "Ialia /..,:k^ dqy pf ,Z11.er~c.(~'.._____~ .. ',, ,: 19~7h. A,D~I ~~~~p( ~, ~. ' .:r '~ ~. , ,. _ .,~ p ., li _ i. i .. i n I . , . j i ' _ ~~ e. i~~ .I_.r~4't ~? ,.~ ._,. ._.-a rn.p 4 ~. ; r ` H'I'M+IInNli3n,'r1s119a1.1~1t ,. I IN'1'lll: ~'OUlt'I'pl~ c:'(~MMt)N I+I.Idr1~S ol7 1'1'AIN'IYI+h t c'UMIiIItI-ANI)c;pl)N'I'Yi1'13NNSYI+VilM1 V, ,. , a J~HIiPIIC.,'1'IiIIHfl1,111; t -, I,, ~ hlil'11N1?AN9' c VU•1(Iryf c'IYII-At''I'IUNI:AW I , ~ I IN t.'L15'I'(]py ' i." _j ,, , ANh NoW, ihiR Is I ~, L' --.~li__ clnY o f dl 1 ,r , an111, upn11 vnltHi~Iul'ntinlt of Ihu'pltuvhocl Gnntplnln4l it iH Itul'uby.ifh'vulvcl that thv pllrlive pncl thulr r4npvvllrw unaiHUl npppnr Ifvlui•u ~~.Lx, c rn Fsl L, Illy vnnvilhUtr, .111_ Atll 1+InnP, Cpglllol'10111) Colltll) t:'n~ry 111 s Cp, 1111'IIyJ~ nll (110 _ HIII I•j~Y n i~u 1 •~, .2Q01, Ilt.~q,111~ '' ' fln' n I'i'vFlverUlH'ollatnclY ~Ilnil:runua, -, AI Huvh urntlVrunuv, IIn vllilrl \VIII Ifu glllcly td 1'vflnlYV Ihv lflflpvH ilt IIIHlriltpl (11' if thin vunnnt by nvvnnfifliflhvd, In clp,lhlu 1111(1 IIAI'I'n\Y IhU IHRIIuN tn.lfu IlOllt'cl by thv vuurl, nntl to vnlvr into n Iongfurliry ' el'duG All ghilcirun liav fivv nt~ nldvr nt11Y nls(, by pruHUnl nt Ihv onulurunuo, Iglilurv in igfpanr nl qlu vnnl'vrunv~lniiY ' pnfvldv ermlitclfl 1'nr uhUy Itif a IongfnrnrY nr jfvrnuutvnt m'clur, ,. . ,. Itok'I'lll'scouli'I', ~. . ' ;, 1)yl iHi -l~rtlz~c•E.a',Srileay,..Cs ~ • ' " CIIHIodY CnltuIN111 '1'ho Cnlu•t of Cnlttittnlt -'Iwlx of CUlttburingd Cn1l+tty iR 1'ugiiit'vd by Itl\v o o(i1t1pIY 1vit11 tho Attluripnnn • ,\Vith PiflnlflHtuH Aol of I ~)o, For (I11cfrltUlllcill Ilholll IluueHRiblp Illullillufl Itntl 1'n11HnI1gUlu IIUOnIAltl~cllltl~llfl ';111'lllllllflo t(i (IlRnblvd ilfchvl111inIR hnviltlt htlaill(fHll bulnl'u tlty uvgrl, hlonflu onntnol nuritfliuu, All tnTf1118olttoltlfl, I1tlIRl Ifu I110c10.111 Ivgal 72 hnlll'H Ifl'Inl' (n Illly IIt7111'lltit nr If11RI1toHH I)UIl1r0 the Uolll'l, Yatlltltji+t Itltvnll Ihv' Ru1tu(lulvd pnnlbl'onvo ~f1' hogring, ,. yoU 91iouLU'1'AKU'191I5 1'AP13k'fc~ l'oUlt A'I'PoItNIiY A'1' oNCl3, IIt Ybu po No`i~ ;. FIAVI3 AN A'3~1'OI2NIiY olt cANNo'I' AI+I+plth oN4, c'lo'I'o ok'I'Ilr.IiPlloNl3 q'III3 ahl+Icl; S13T ,. 1?oR'I'tt 1)I31.oW'1'o I+INp ou'I' Wlil?121? Ybl1 cANUI.i'I' I,IigAL'Ii13i.Y, " "` ,, ,. .. ~. Cugflfurlpllll t'olnfly I)nr ARHOUInUvn ~' 2I•IUvrlyAvunuu ,. . ,, ,,, t.'lll'11RIU(I'nllltflyll'Ullhl 171111' f ~ '~ 'I'olepltnno (717) 2'I(1~116G ~'. ' ' ~: ' "+~a i. 1 Yi r' . (il`? i~ , •..~ .. „ .. .; s~.. tw /I+( . .,, i i , I J 1d%_ ~.. , ti'---i Eti3 ,. .. , ,.. ..~. .._ " f;~YUt~Y4Mln'I tnaMA~w tutVUitV~lmury~b.. `Iftlhl V IV9~ pp Iu.1pA f ~. PehtJ n~q~~ro~~1'tvaA`,t j _ ... .. 1 ~ ,. ,. i ~, S`i'IiP11ANii: !~, 9'R13' 1-intili ;' ~ ,I,I,ii, Gp{JR"I' III paMMpN~hl.i3AS Qit -~ uM1~13-ti.ANla C~~1N'i'Y, NIINNt9Y1,YANir1 v, t NO. ~a- I nRC UIYII. ~1G'fipN - 4.i1W ,. +, . JoS13itF11~,'i'iti'-591,1'Itl t , I t Iaufvttdnn{ t IN GUS'I'OI?Y I ;~ ,. ~. ' .Q-~hlat or cod t ANU NOWt lhiH ___._ Auy af__ Nq, fo~n(;11i ~'~-o~' , I ~ nttuoho4l it4)ll{ian {a Ma4111y 14 IH herohy 41it'uolpd Ihnt tlla p J't~~`• IAau of 1110 Itafar° ----- ~~• "~ naalapponr ,. :. ,ni, far a AS~~ ~ i wlll lia uutA~ la i•o9alva lira ientiva j ro llonrintt CuHla4ly et '~V~Gc~-Y 'v, ltn Pffart 4(1191111{U{at'IfII11Ho111tu ,nSev*e4fMlNIIIrNf~4lJUytltlat4p4111(11'fa\Y ' 11141 1HH41a~ (a bo I1P(11'41 Ity Illo Cat1I'1, tt441 la uitlal' 141a H 14tllltgrRl'y or41oP, Alh oitildron aao flVg ar ' nl4ior tn4ty 4Ae4a be pmHO41 ul lho oottf4jronuo, Itnihu'o la 4pltont' 4t Ato pa4foro4PP titt4y p1'avlclo 13raun4l~ ihr oiiUy of a lomporluy ar pornnutonl ar4lar, ' .. rOli'PIiI3 COURT, .,, , .. ' L~yt ' ,,; ;, Ct191ody Co1tc111n1ar -- '4'Ito Caurl of Cattt4lalt NIoIIH of CUtnhvrlaud Cautily l9 ('eg4A4'od by I4w to aop1 by Wllh tlto A4lorlpuaswl{lt PlHuhiHllos Aal of 110, I~oriltftirt1t11Uott tlboul ltooo9taiblo fnallitlo9ntu~t•oggottrlblo iloootttitlodl1l1o11H,41Vtlllpblo to cUspltlo4i 111411VIdu4tls It4Vit1~! InIHIttoH9 bofol•o A1u aallf'It pl4?4H4t oopptol our ofAoa, All t1174I1got114tItIH i11U~(11o 41A41o al lopH(72 ho111'9 pl'Iar lR 44y I1o41'llt~ or1tUHIuo9H Itcffftrp Ilia oatll'l~ ' Yat1 (1111Ht nt1o411 Ale 9glloclu1c41 oallforo114o at',11out'lltg~ YOU SI.10Ui,h'I'AKl3'1'IIIS NAPI?It'f0 YOUR AT1'OItN~Y A'I' ONCL, III YOU UO ~~ NOT IIAV!? nNATTO12Nl?Y Oft CANNOT ApltOttta oN~, Uo''1'O ok'!'~1.13hF1oNL'I'N13 Oi11tICt; S13'1' ItOft'I'Fl 1~1?I.OW'I'O IIINp OUT WIILIi13 YOU C~(V OG'I' IJt;QA1.1i131.!', • ~, ., ~~ , cuntborl4nt41 cou4ly ~nr Aaaaoiullo4 2 1.Ibet'ly AVo4tto CarN9lot Ho4t1HyIV4ltiu 17011 „, 1'olophotto (717) 2111J•1I ciG 'k _,l ~.. , •. S'I'1?NI Ir1Nl1? A,'1'ftf?SSLI?I2, ~ ; IN '1'111? cnult'I' pr c'OMMUN NhI?AS OII Hlninlll'f%Nulltinnur ; C'uMNI'~I21~ANIa C?OUN'I'1', i'I?NNSI'hVANIA i `,, ~ tip, Q9.10H(i C`IVIh AG~'I'ION -LAW i ,IUSI?NI I I„ 'I'RI?SS1.1?I2, ; ' I)ul'u;ulutil/Itpapandnnl; IN CIJS'I'OI?1' 1'I?•h1'I'ION'~'O ~~~Lll'Y CIIS'1'C21a1' 0131)1?~ I a 1'{aliNunur h Slohhnniv A. 'I'raaalur, Mi adult indivlduul aul'1'onlly 1'9NI{IIIlf3 nl Lal I s~, cunuduquinal Mahllo I?aUttua, Nowvlllp, ctanhnrlun{I c'uunty~ Nnnnaylvanin~ • 2, .. Itnaltalt{lnnl IH ,lataplth 1-, 'I'ruaalur, nn adult individual uurrantly roal{Nn~ u1 l.al 127, Caltadaquiltal Mablla 1?aNqua, Nuwt'illn, cuMbal'Iand caUnly, Pbnltaylvanltt. 1, 'I'ha jiurllaa nrp Iho Itnrunla cif Morlnh 'I'roaalur, horn Uapu;nhat' 27, I')')'h who i~ lho „ '' Httltluol of lltia ouslady anlirnt~ '1. A 'I'ompornry ('Malady Ordor lvaa onlot'ad an oP ahau(MIU'olt R, 1999, put'aun{ll to n i~inal ordor of Coin'1 in a I'I'A and Cusl~ady noll~n Initlnlad by tha Notltlanor, Said ordora afro alulnltod hol'olo and nna'kad aH I?~hlbU "A," ~~5, pni'atgt'ap113 afllto'I'otttpot'nl'yCUalody0i'doryl'anlal2aapaMloltluualotlyafthoohiltl Iha Ilret Ihruo woakanda al' oa{oh ntanlh, (1'nm f'ridity al 3;oti p,nt, until Sunday al a;oo p,tn, Po1ltlrnwt' 1!i i'otlll0alln?~ Ihia 11U nhItllBntl l0 avury olltor waakand dttu Ui lto{• ahuutttatpnooa olttingltlB .: slnoa lhu anll'y al'lhn'I'olpparnry Caalody OrdM' ~' ~ ' WFII?I21?1~01213, I'alilianorpraya l'ourlianal'ahlu Cotu'l to l'anppalnt Iho C{IslotlyCaltolllalor I:~ 'la napaidur Ilto ahavo gltnngoa In lho al'iginnl Ol~da;•, - , MAI2'1'SON UI?A121)OI21~1~ WILLIAh1S .~i O't'1'O ty-- 'I'homna ,I, W I nta, I?squh•a . ~' ' 'Ibn 13na1 high Slranl ;~~ CnrHala, I'A 1701 J ,, (717) 2q3-1381 , Allarnaya l'ar l'lalnlil'f/I'olldannr !)alai .~ /Q Id ~ . 1 ~ ~ °~ i ;a i ' .. , ~ M ,. ~. Stephanie A, Tra~alar, Fiaintifl' va, Jns4pil G, Tt'eaelar, Patbndant tiN TH~.GpURT of ~QMA1pN.n~iIAS ,. t tAF c{]MRSi~i~ANp t'AI~NTY, P~NNSYI,VANiA t t tNO, 99 - ipsb RIVt[,'i'RIi.M j tPRnTf;9TION rt~QM Apua~ „ tANp Cl1S'pOIaY ~lA,~tin>atiOn couaT ,. pafopdmlt'a Namat daeenb I.. Traeali+r patbndanfa pate gfAigin t1/9Ib9 I)atbndant's aaaial Sanurity Numi-art AM1b-811.77.1q Name of Prataatad~P~areont 19tophRnlo A, Trarler ANp NOW; ihia ;,Z, day at Marsh ,1999, the tlaurt bpvlag Jul'blllotioq gVer the partioe Rnd the pub,~eot-mRtter, It b OlitDluRrID, A,1p,lUp(~ID1D, aad D~CIUI6,A ae teligwat,, ~,~ Plaintltit to reproeoatod by Jopn Cprey et' I,EtiAI, 81tiItVlC~l9, tNC,; Aefpadagt (o reproeeptett by Mark W. Allehquae of l4aldle, duida, shga r,nd NIaalNnd. The paliiep et{ree that the [o1loWlpg way ba eaterell Re an Ordar of CaurA 1Dofondrnt, Nllhqugh ggreelpg that Nn Order wAy bo apterod, done not Ndtnlt to the Nllagatlap mllde is the PgN(laa, Q Plaintiffs raquaet for n rinal rrotantlon Order ie danind OR I>31Plalptifll'!e ro~popt for a Flnal I'roteotlon Order ie greeted, ,, ,. ,. (~ l~ ll8fapdNnt pha11 pat abneB, etalli, Ilarase, (hrtlNten PlRiatlff er pny ether 4lrgtanted' parson In any plNtlo whore they might ha found, ^ 2, bofandant le oomplatoly avloted and n><oluded tYom tha raeldanao at ' ' ~[NONCONPIpBNTIAC. AnOtt~~S rROM WHICt! pF,PL1NpANT 19 FiXCLUpE1~~ or any , olhat: taddonae where Plaintiff may Ilvo, G~xoluslvo pnaeoselott of the tealdenno is granted tb " PInInNC$ pafbndant nhail hava no right ar privllago tq enttlr or ho praeont on the prtlmitae, b On [itteort dato and timtli, pafondnnt may entor tho roeidaltoa to rE+trlova hle/lter niothing and ' I:xu~.ilrr,,~~„ ,_ ,~ , ~~ ,. } ,Athpr,~prannai aft'aatA, prgvidad that pe~'pndant is in the anmpany pf a law anfarcamant a>9fipar when Auph raMavai is made,. ~3, puxaapt aA pravidad iq PnrAsrflplt ~ of thiA Ardar, Ilpfpgdapt iA prnhibltad tFgm bRVing AN'K pANTAG7C wllh t'ifliptiff nt aqy iapatinp, Ippludiag, but pat AmitPd tp flpy ppptapt at i'iaialifPA piaaa of amplaymagt at AnnRgzq IfpAlflnrapt, ~A9'Walgnt Aattgw Road, t~IriiAlo, durigg thR pours 1'iaintin iA wgrHias. pafapdpat iA Apavlilapity grdarpd tq AtPy away from tba fgilRWlgB iaaatlQpB fqr the dnratinq of tbtA Urdari PiaiatiffA ('eAldRgpp IaaRtPd at 23~~ Ritgat' RiehWa,V, L'ariiAie, pglgbAClan41 Callgty, PagnAyivapia~ nqd npy ,other realdpgc~ plalnNff poly aatabilAh. ~A. ItXPPnt NA provided in I'arat;rapll s of thht order, Dat'pgdant Abell pqt PRntRat Piaigtlff by talopbggo qr by say other maaAae, ihoiuding (hlyd parlieA, ,.. ~~ fib. c;uatady of the ralqur oblld,lNeriah Kpylea Treeelar, Abell fbq aA fgllaWal Aeo atlaahod Talgparary Cgatady Order ~ ~. A 6, 4afgndagt shall immediately tom near to the ~Ilorlt~'A Olliap;' or to a laoal law ogforppmant aganoy for daiivory to the Shat'IfPa Otltna, the fbllgwins wagpaga used ar tllroafagad to bo tlaed by pofendant in an eat of ab!!ae n~ainat PiaindD' and/or the miner ohild/rom ,. Q 7, Aafondaat is prohibhad t1'nm paaeasaing, transferring or aaquirigg nny other wopppna fbr liia durntigq of this Ardar, Any WanpnnA delivered in the ahadff Under paglBrpph 6 of tl-ia Order ' or Itgdar Paragraph b of the Temporary Order shah not be returned until tlutltar Order of t:at!!t, ~ d. mho fallowing addillanal rollof IA granted ae autharlxad by ~61Qg of thlA Aotl - ~: a. Thla Ortior'Ahall romaln tq offset until madiflod or terlpigatod by the Cqurt ' Nqd cap bo a:tended beyapd Ike original e><piratlon date if the Cqurt MdA ihat'Dafandant ,. har oommlttod annthor set of abuse nr haA engaged In.a pattern or preatioo tbpt (ndlaatoa continued risk of harm to 1'iaintiR. ,, b, Defendant la onJolned 11'om damaging or deAtroying anyprgporly owned ,, jointly by the parties or owned Aolohy by Plaintiff, o. Upfandant la to rofrnin from baraaAing Plaintiffs rolatlveA or fl-o miner ahlld, d, Tbo court seats and foes are waived, (»4, APfantIRNR lA dltroPlP(i IR pRy tamparRry ANppRI't` fRr StephRNlR ~~ TraAler Rat1 l1~Rrlpp ~~ IGgylse T1'oa4lPr R41'RIIRWAI ~gAA,AA par taaNth, Thlw Ardor far ANppRrt AbRIf ramRlp,ln RfXPpI Np1II R tlnRl ANppart RrdRr IA entPrPd by jaN CQNrI, 1<I<RWeVRr( thl~ AIdPi' RaNII IctpM4 RNtRp1N1IPRIly It pIPlNtltl'dRes nRf` IIIa R PRrapleiAt fRM' suppRti Witb lbo QpNM'l! Wltblp IlnROq tlpy~ aCIhP,!1RtP Rtth-q Qrdor, ~RhP wtanuRt pttbir tRwparRry ardor (IPBA pR1 aoPParwHly ,~ reQaPk K10~PpdNgR~A PRtt'IrRPi ANN11art.RlIII~NHRN- WIIIeII shell ae (IRtPrnrlpPd lq poPardgltPR ,. wlla fha pNt(lelhtea wt t'qo wuppart Iiopriigg, Any polNelatanta In the t1aR1 Rrnt-Nnt a[ support „ „ AhpII bR Prodlted, rotraRRitvP fa this dRto, to IhR RppraprlRtR ppr<y, A lA, Tho oasts of this action are waivod as to Plahriiff and impaaed an Aatbndant~ ,. ,. A 11, Uafpndant shall pay h" tp plgintiff as aompansatian far plalntll~'fs out-of-packet lnsaos whiobura as foUpwst Olt ,, ,, A piainUil'is srarttod leave to pt'osent rt podtian, with appropriate Itatiop to laRfandant, to ~insatt tho Home of the Judge or aaurt ta.wldah tho petition should be presantadJ rRqueatl!16 roaavery of out-afpaokat lassos; T1tR petition shall InaludR an Rxhibit itemising all alaimad out-aftxwket lasses, aapiRS of all aUls and aatimatos of mpair, and an Order sohaduling a hParing, Na f(!o shall be rpqulred by ttte pratltanptary's aftloo for the~tlling of this pathian, ~ , , C) 12, EjItADY MDICATOIt ,. ~, l,p plaintiff or rataoted person(s) la a spouse, thrtnor spouse, a jwraop who aahablfates or has oahabitad. with >aotbndant, n parent of n camman ul(Ild, a Fhiid of that parson, or a child of Dofondant, , - 2,q This order is Going Pntcrod agar n honrlag of whloh Defondant roaelved actual Halloo and Itad an opparlunity to Go heard, 3,q paragraph I of Utis order has boon ohaokad to rostrnin Defondunt tYom harasaing, stalking, or ihrantening plainNffar protootod person(s), " ~~ a,Q bofondant reprosanta a arediblo tltrcut to,tho phyaloal dntbty of plalndff pr pthar prptoated {xiraon(s) Olt q The temta of t1-is Order' praltlbit pofundattt ttottt uslttt~, aiiompting to use, or throatening to use hysicnl force against I'iaindff or protected parson that would roasonaGiy bb aKpcatod to oausq ~oduy ittlury, ;~, ,~ . ,. 4~ l~, T~IIa ARIIRlt aAP~RI~WA~${w ANY PItIAR PFA gltDGlll ANDI~ ANY I'RIAR ARDk1>~ [tw1.ATINq TA t=Hil,p QgSTAIIY, iq, All pravitlana of tbp. Ardar shell ax~irp is aae yeer~ - NO'y1Q1k'f! q Ii~t~b~NDANT VIAI:ATIAN Ok' TIIIa ORDER MAY itCuSUi,T IN YOUII AItRr$'P QN'I7IW CIIAROID talk' INAIR~CT CRIMINAL, GANTPMPT WHIcH la nUNlaiiADl,m HY A FtNu1 Ak' UP TA 51,000 ANDIOR A BALI. STNT61NC19 Ok' UI' TO al7t MUNTIIa, PA,C,a, ~b11A, VIAiaATIAN MAY pI,SlO aUq,1CuCT YqU TQ I'ROaF,CU'I'IAN ANII CRIMINAl4 pI+~NAI.x1~S UND>gIt T1IW I'RNNaYI+VANIA CRIMIIa CpU61, ~'IIIa , ARDIIR la ENFORUAADI.W IN AI,1, FIFTY (b0) aTATES, TIiR D119TRICx OF COIaUMDiA, TIAIyAI, LANA$, U,S, TiCRRITl,1RI~39~ ANA THhl COMMONWRAI.TII OF PUlCRTO RICO UNDDR THT VIOI+I4NCR ApAIN$T WOM»N ACTION, Id U,9;C, a,Z~biS, IF XUL1 TJtAVICG OUTaIIAIw OF TH)tl $TATIil AND INTIINTIONAI+I,Y VIOGAT111 TIIIa ORpTR, YAU MAY AIG I9Upd~CT TO I~DtORAi., QRIMINAta PRACIapDING1S UNDDR THAT ACT, Ali U,9,C, ~6 ZZ61.2Zb2, CF I-ARA(iRAPH iZ OF Tlilbl gRDRR HAS DIERN CIITCKED, YOU MAY DD aUD,T6CT TO Fd1DRRAG PROAMCCpTIOIV AND pENAi.7'IRS UNDIDR TIIII "DRADY'~ PROVI910Na OF TIIR GiUN CONTR04 ACTION, 18 U,B,C, dAZ~((i), FOR )'ga~TN51ION, TRANl9PORT OR RICCLIII'T OF FIRQARM9 OR AMMUNITION, NOTICR TO I.AW 61NFARC6M>,uNT OFFiCIAI,a The police Wha have Jurisd~latlan aver Flalntill'e reaidenoe OR say laogltaa where a vtalattan of this Order aaoun+ OR wbere Defeudagt -nay be (acgted, ahdl oufarae Ihui Order, Aa street for vlalatlon of Paragraphs 1 Jhmugh 7 of ibis Order uuy be Without warrant, based solely na probable aauee, whetbor ar not the Violadan b oomtnitted lathe ~prosonae oKihe polloe, 23 Pa,C,a, ~b113, Subsequent to aq street, the poliao oflloor shall Aolae ull Weapaue used et threateniad to be used during the vlolgt(pn of the I'roteoNon Order ur during prior Inoldepts of pbuee The (Insert the appropriate name ar title) shall mglnUla paseeeslap of the Weapons Until ,. ibrther Order of this Caurt, When Defendant le pissed under arrest for Violwtlop of the ' Order, Defendant shall be taken to the appropriate autharlly ur autharitlee before Whom Dnfeudant ie to Ue arralgnod, A "Camplpint fur Indlreot C1lminal CnntempN~ shall ihoa be anmpleted and signed by tho pallao alhoor OR Plaintiff, rlalntltl'e proeance and signature are not required to filo tho oamplalnt~ .. ~, ~. ,.; I~`; 4~ _.. .. ...... ,.. ~.; ,!r ..' ~' i 1~ ARf1lPlenR sP(INNdA fnr YIAIPIIPp A/ lhle pl'dPC flrp RUoRed, [14fAndgn~,AhAll aP RrrRlRa~d~ buad aal And halq pnrliw Avon nollaa ai thn dRla of lha hARrINR~ ~'_ II ~Y TNR ~AUItT, (. ~. ., . ,, J. aalay Olflr, ~~ dudga [f elntocad purauflntla Ula aopsant of PlaindfPnnd Uatbndantt ~„ ~-. -top unie p-, TroNelar - , •-•'' aaeph [,~ 'i're~alar , . „ . Plaintiff Datbndant ~ ~ .. I , y,~ , "aoapCnr~Y k W~ Allahoueo ,, A~ttomay for #'laintiif , ttornay for Uafan N ~~ ~~ ~ ,• • ,. I, , ,. ,. ~• . ~, •, ~,' ~. . ~ ~. t' ~~ li ,, _ ~. „ li i n atephnnlq A. Trpaalen t RV.Tffi~ ~AUItT AJ~ aAMMAN pl.l~r1.~ t) plaintiff t ,. t t?uMHRIt[,ANp AAUNTV, P~NN~YI,V'~NIA. v, t t Np, ~g,ltllif- GIV[I','I'hl~lVt ~fAaeph h, Tt~eaaler, 1 Detpndant t PItA7'~CTIAN i7i.AM AAUS~' ANA CUSTADY, TP~MPORARY IHT DY ORS " ; 5.~. o ..r AND NAW, thla _...:, day af, I R~9, u n aenaidaretlun of the parties' Cpnaent Asroament, tho fallowing Alder is onterad with reBaM tQ uuatody of the parties' ohild, Mariah >t;ayleu Treaslert ,; ' 1, .Plaintiff, herolnatter rafbrrad to as the matbar, and Aefbndant, heroinattar mfatred to ae the lbtlter; ehali have shared legal ettatody uftha child, ~~ 2~ The mother shall havo primary phyeival euatady of tiro ohild, ,. 1 ~, Tlta fbthor shall havo partial ouatpdy of the child tho flCat three weekends of each ` ' month fiom pdday at 3iQt1 p,m, until Sunday at atQq p,m, M1, Tha parties ehalbehare Uie ilia fallowing holidays at limos ngread dpan ay the '' pettiest 8astar, MantariaLDnY, thii rough pfJuly;.and Labor Day, , S, Tito ththar shall havo iho child 0lixiatmns [iva and Chrlatmaa Day oaoh your ftnm ' gluietmas Gve at f to0'p,m, tuttq Cl-rletmas pay at btop p,m, ~ ' b, ' The fhthar shall hnVo tha fight to see the olilld an her birthday at a lima to ha ~~ ' ugcaed upon by the partiPa, .. :, id 7, " .Tim thtltor ahaif havo ilia right to partial ouetody of the ohhd for ono weak of eaoh 1 aummen Tito flttltar will gWe tho mathor at toast two weeks notion as to when hie period af,. aummar qustady will take plaoo, Tlto mother will havo tho right to havq the ohild on Weakanda ..during that tltrmo unloae tlio fatitor takoa tha olilld an a vanaden Trip inoluditg Weakettda, The mother ales has alto right to tako tho nhlld on u aummar vnaaden inolUding a maximum of two'- ,. ' weekonda, ,. ,. B, ,_ 'Cho mathor ctnd ththar, by mutual ngreotnnnt, may vary tYom this eohQdule at any ttno;'but tho order Shull romaht in affbot untll'ftathor ordor of oourt~ ~' "" ., ~,;;. , 9, '['Ito tnotllar and fluhor ahnh givo ciloh athor 2A hour gatloe or roaeonable notlao In ~ ,' - Ir ,. . ~~ ,, __ ~ u ,. 1 . ~. .....', ..eft ~. ~ ~. .. i. .. ~ , ' II ar- pmPraena.}~ it'n ~oltadule~ pednd aFpartlai auatpdy naed~ to pe Pat-aP-~~d ar madifiPri and a tnakP-up pegpd ahaU l!e a(~red within a reaaanabie time tinmP~ , ,I IA, The matller anti r~-dler altali have the risllt to rPASa~lnble {e4ephane PantaPt Witil tltc ahil~ while ahP is in the ether parant'a care, 11 ~ Tftp mother and tbther akraa that Paah ahaii natit}' tltc other immediately aP ,. ;, I medical amPraPnaiPa which atiaa wldle the PI-iid is in that pprent'a Pare, ,. ;: , i 2, Neithor parent allall da anythins which may oatrPnsP tho Phild #tam the ether Pamnt, ariNuro tho Qpinian aPth~ ahUd as to the attier parPnl ar which may hamper the 1~'ee and I. atural devalapment aP41te ehiid'a lava ar"rcapegt Par the nthPr parent ~ ,. I lay Rttlter parryy may roquest a Canalliatian Canfbrenae, but this Older ahnli rornaiti In ' et~at pondlnp ti-rdtar Order at'Caun~ Ry the Catut, ~, Daley Oler, r.. ,ludse~, If entered puratwnt I,a the aaaeent 4Pplalagffattd Aefandutiu ,, „.. !~ ' ~'Sta h ' is A, Trasslar ~' pld~ntifF . , ~. I '.,: ., . ~- !?. Darr Carey k' W, Allahauso Attarnuy for l'labrilff tomny far gotbnd t ~~ r' Ir ~~ ,; ., , ~< ~}s: ~' ,t ~: a=.c d ~~~ ~~~r~ FAIL ~~+ ~. rau~ r,~pY f~aoM i~~cp ~ ,~,~,~,,,~ ,, , m TAetlnwnY whorttol, I here unto ettt my hwnd ,,, ~ .;~~,~',~~ an<t tho I of sald Al t1arN11e, ~`~z,~tl ~. ~ hl duY 11~~ ' ~'~~` ~ ,a .. ~ ~~ ,. not-otery , ~.~ ~ ~,~~ ;r ,ta sa a ~1 t!~}'fit,", . _ ..._ , .., • _ _ ,. ,, ' ~• yt7izu~tcn'rtcl~ , I'hp iblP~n111d Nulidnlt la Mntlily le hasud Ilpnn llllhrntgtinit wltiah IaIH boon e111hUi'PCl by ,. .. 111y PnllnePl 111(IIP pl'Phlll'III~ul1 of Iha Illwellll, 'I'lIP Illll~na8a of (I1P daP11111P11t IH Ihtll of on4111~P1 and nnl my ntvn~ I have rand IhP dnunmunt and In Ihu P>;IPnt thnl it la hnAPCI apnn infnrntnlinn wlliPh I l1avP divan to my Pnnnevl, Il (e tlva and Pnrt'PPl to IhP has+t n f t I t kttctwlPd a I fitt' n Y @ , I 1 1111111 Il and haliPG 1 n l11P ot;ton4111i1t II1P PnnlPnl ttl'lltu dPPnntPnl le (IINI of anntlyPl, I llllvP I•PHPCI~NItnn ununaPl in nlnkina tldH vvrl(LWatlnn,, ~ ; ~1'111a NhtIP111P111 !111{1 YPI'iI1P11linlt lira n1tldP HIIItJuPI In tha pPn11111Pe of 18 Tta, c.s, SaPUPn q~Oq I'Pltltilti3 h'iIn~lVnl'n 1111AillPallolt la Ilnlil~tl'1119P, WldP11 Iti'nYidae !1111! If 1 I1111kP kltntYi11~11y ,pllaP ovurnlPnlN, I nnty hP HultiaP(to Prlntinnl punaldus; '' ,. , ~ ~, , "Pp111 n1a A,'I'I'o9slPi' ~, ,.' n, li .. r~ ' ~~ I 1 ~, i, ~t ~ ~ ~. ., ~r 1I~ 11:, L ~. ~. .~. - , ~ ~. ' ~. "~L. ~ ~ . .. { ., 'I i. ~~ ~i I i / ,~ JJam~{{ ~. .. ,. 1 .. ~. .. 1'. ., E x-11 I I,'I'rlain PI I'akanr(~ttil, tut nulhnrl~aci II!lVII( I41f MITI'IHnII,hWII'(Ic1rlf WII11pI11N ~ otlP, harahy ~ ' „ . ,,, aarllly thttl n oapy of tho I1~raBohrlt I'allli(ut 1(~ M(~tlil~ ~uNln(IY~wtIH Hut'vod thln (Iota I?Y dapnHitin~ ~nmo ft~ tho I'aa(Qf(ioo tit GprliHla, V~, Ilt'at aluHa itutil, poHln~o prapttitl, uddt'asHpc) IIH f~~llawat I, ,. ~1 . Mark W,Allsh(uteu, I~aquira,_~ ~~ ~ ~ ' SAIpIS, SIIUI~I~, FLoW131i ~ LINLISAY 2G WoH1 lilBh StraVt CIn9lsla,l'A 17013 MAR'I'SON R13AItholtrl' WILI.IAMS 5c o'I"1'o ,~ . 1. ..:: Iiy-- C-~' o tt 1~1 13oko~lt'atid 1 ~ 'Ibtt I?qat lil~h SU'aot CIUI~HIo, NA 17013 (717) 2A3.13g1 ,. , nuted~ ~Y6lCCUL(.I 9 ~ Z~ ~ ~ „ 1 ~. ,," ,~, „ ;1 , ;, , 1 ~, ,, ,~, 1. .. i f. ~ 1~ .. ~ r ~~7 ., 1 •. ~~ ~ it ' - 1 1 'R „ y ~~ i .. 1 1, ~ ._ _.._ .. -Irr ~ r • ~ . .: 51'1?I'I irlNll? n,'I'Itl?htil.l?It, Nlnlnttll' ~. v ,I(al;latit 1.,'I'Itli~StiL,Islt, ' pef~nclant 1~I'li 1 it ;~hll')~ IIJ'I'lii? c'c~Ult'I' c)i' cnMMI)N I'I-I?AR c)I+; I ~'UMI31iIthAN1~ I-~oUN'I'Yc pl?NN~YI,YANIA t t. !'IVII, ~c'I'Ic)N LAW i t Nt), e9- I(1NG ['IVII- i 1N c'U,5'I'ohy. ' ANI? NSW, Ihla~(!'~ ~~sluy of hubrunry, 2(101, tq?an oaheldut'stltan al' Iho nltlwhosl citatPdy 4.(ntollluliun Itoltnrl, II la nrd(t1'UCi'sU1sI sih•vulud Ihnl tIIIN caurl'H prior grdol' li)r pgHlndy unlvrusl nn Mstroh H, Igl)g nl Iitu ubnvn tvrut tlnd nunthur iy vstualuGl nttsl roplttvad witlhlhu fallnwhtp ordcrt. "I'hu Mnlltur, ~Stupltttniu ~, 'I'r~nylotti and IIW I''illhul', doltuplt.l„ '1'ruraslur,sltnll uplny sI1111vd luynl ouxlndy of Murlnh Kayl~o'I'ruyslur, hot'It IacoulnhuP 27, 199'1, .. " .• 2.. 'Cho Matltor ahnll oltlOy prlmnl•y pltyslool ouytndy al'Iltu Itthtat' u1111d, ' - ~ Thu hufllor yliall uglc)y pnrtlitl phy9lual uutitaslyi)1' Iho ntlnor ohpd un Uia tiryt {Itrcq \vuukolldH of onoh ntcntth, thu flow bolny Q•am I'tlduy nt 9t00 n,m; until Stutslay nt (1t00 p;tn, Igor oxoltango cll'. ottetady, Malltor ehttll dnllvui' Ilto p1111d to'' 941 lar'a ,, Mnt•kul (tl Iho huglnnlnU ol'tho wuukolul IhI"1'ttthw' to Ittku uuslody t)f tltu•ultilsl alt • hlislgy stt 9;00, n~nt, nttd I'(ilhor tilihll dnllvot' Iho chll(I to Mother's ~ppi'ont'a hotho on •, ' sund;sy hol\voon ~}i0o and dt I S h,nt~ ' ,,. ~r ~+ttlltot' Hhnll oltlny ouslntly pf Iho Ittiltat' olth(I an halidny9 to hlolttdo. P.,nstur, ~~ ~ ' ' , ,~ ~ Mcnwrlnl nny, duly ~I'~', l~nhnr~l)ny and Chriainuta ~;vo Il~oin GIGO It,nt, an ~~hri~Unlts ;, _ I?vn Ihrou(3h li;o0 pan, an ChrlHtnttts ptty, S. ~~ I~plhut' shall httvo tlw right Io hnvo oustculy \vhlt lltu. nthtor ohihl t)i); tlto ohhd's ~ • birlhdity ut n onto to bo agrood upon by tha plirllox, c,r, ~ ,',' ,,; ,, . 1;, , t ,: !,~ I~nlltor sltnl) Ugloy uno wquk'i)I' vlslhltlotl wills tho ntlnar altild dutio~ iho my M 1 •' 1Vilh I'gtltUP BI\'lity nt lUnet I1va \VUUhB nUIIIUi i ' ~/' ~ ~ 1' ~t` 7. 13u111 rin'tlov shllll Ut~lpy I'utt9ollnblo IUlophono Caitlllt7l Whh silo Itllt ,Q t~'~'l oll t11~j ,~+ nltll(1~H III 111U OIhUI' plll'UntIN UIIHtO(ly~_ "v ri) r• . r" ~dtii;., i~ n- Ins ep H. 13ollt pat'utttti_slttdl nollly Iho .otltol' tuu'onl with. rospoot lt) otnorgontiy ntodl(yat ~~ ~ i~°i shuatfons that nrlso whop Iho ohlld Is'In that pnrunl's-corn, •~~ ;,' ~i~ r~~ ~I ~~~ . (~, , ~~1?5`t - '; ~r tI~T ~h - '. 1. ~(. • t fl .,. _.. ,. ~ ~ •. _. ?, Nulihul~ p1u•un1 >ihull dll unydlln~ Ih{u nle~' uslr{tnyo dlu child Il•uni hu c~~lhur pnrpm !fr htlnru Ihu nhlnhm nl'lI1P PhI14I IIH Ih Ihu glhpl' purunl nr whluh Ippy hanthur Ihu'li•vu uncl nnlurtll duvulnpntvnl nfihu uhlltl'a Ic~~fi~ and ruappul Illy Iha lilhur hnrunl, ', Ict; 1'h~ plu'tlus Wray madlly I,hly Prclpr na Ihuy Il~{•ua, ~h;iunl nn n~ruunwnl.l'utwuun Ihu pNrdue, dtia hl•dur alnlll unnlrnL ' I I ~ 'I'bis cahclor ly u11141'~d i1n{'annlll IP {Ilt tlyl'apnlull{ I'unphud by lltu pnrll~a ul {1 G~uHlncly ~'4111ui1ih11{tll ~'nnlbl'agaa~ °Ih lilu u1'p~ll uhhvl' 11{II'Iy.dpyil'uY In Illndlly Ihls Of4Iu1', (h{Il 1~{+!'b' Wray pullllnn Iltu unurl Irf It11YU tI1V al{hu 11~{IIII aahudnlurl tvhh Iha c{{ytncly CunUlllnln{', 13Y'I'lll+ eni nri, aat 'fluttttns d, Wllll+Utla, liaquh'a ' „ ,;, ~Inlulnn d,'Knfiuaky, I,;hqulra ., c~.+-~~ -+ ~~.~! p~" ~~ •~ ; ,. ..r ;, _. ,. _, ,, ~~ ~M ~_ `;. s .. I(.4' ~. i.. t•' ~_ ~' .~ ~ ~ ~~• ft iI ~~ ., - r ~E • rt{Y.+` .. - ':( 4 N , - ~.. ~. ,_ ~~ ~. s9'(;NlinNlf; A,1'Iil:aShlat, ~~ •~ I IN'1'I II ~'~Wli'I' (~~1' ~4?MMnN•NI~fAS,G)~I~ 1'hllnlilt' I ~~UMIi1:1tLANh (;pl~N'i'Y, NI?NNfiYI-VANIA „ I,. , \ I ~'IVII, ~c:"I'IcaN ~ HAW ,, ,_ ,I(~NI?Il111,,.'I'RI?;ilila?It, Nt~,'J!)- IIIN(i C'IVII, hulultclnnl r, IN ~'llt;'I'c)pY „' ,, . Nf~nP dU41l3t~1 d. Wuxluy c)IVI1,11', ,. C(1NCII~IAT1(1N ('ONI~1;1(1~'N('P' gun MARY RD'POIt'1' IN AC~I?Iti~ANC'i WP19i 'I'FII cllMlilflzl.ANh ('c)uN'I'Y c'IVIL, Rt)1,1? c)I~ NIi(~C!lipultl I'~ 15,3wNQ~), lhV 4111+IVt'HI~I1V41 ~llHltttly Cnllollllllnl' NIIhI1111H ll1V Il1II+11VI118 PVlml'll , I, . ,. Thu porllnunl Inihrlnn)Inn horttlinili~ l{+ the uhllcl whn Iri lhu atil?luoj ctl' lhin liti~nlilut ly ItN ,~ 1ltllnwet Mucilth Knyluo'I't'u;l;llal', hnPl1 I)uuonlhul'?7, I')9q, 2. ,. A Cnnulllnllnn conlurultou'woa hvltl'rnt I~uhrutny, N, apnl, wllh tho fhllnwina httilvklunla In ~ ~~ ullondunuul ; „ ,~ _ , '1'11u M{+Ihul', tilulvIttulluA,'I'rueylul', wllh hul'uotihaul,'I'bunta4,t,, WIIIhutls,Isatµtil'ui andtlto ~ ~~ ~• I~i1111VP,';Inxuplt I-, 9'pui•slul', WI}I1111s y~ilA+su~„Ic+11111111,1, Kuhuuky, I~.dg4111'u li a, Thu pul'llos agruu to tltu ullp•y of tllt circlul' In 111u liil'n1 ne titlt~ohud, hA I'I. ii .~ _ . „ •'r,f' S`I'I:NI I~NIIi ~, li~lt~tl'sl; I IN'I'I II? G1c.'1 !at;'6' ~Ir c:n a ~ • , ' ('i'RI<S,SL,171t), ,1, MM~N l l.l.r~~ cair ~, hininilff ,. ~ ~ i!M131?lilt-'tlVf~ ~cauN9'Y, NI:?NN~Y-.,YrlNi~ ~ , •;~ v, ~ clYll-~~'I'-c)N._Iai1W 1 ,,, ,IaSI?pll''I'hi;~fihllt, ; hol'un(huil Nla, t.)y. ) ~ , Il N(i'GIVfI•'II?I~M ~, ,, ~, ' , ANh NcaH,, lhly Flu, thty t~l, Mtt ; aonh Y Igmn onnelclulltlinn of 1?t?I'un(itml'y ~. - G?ntul'~unuy NuNlinn 11,t' Sltuulnl Itullul; Ihla.lttttllut' iy rulul't'vd In'titu ~Il~inciy urnwiNttilnn Itt'dpoae Ituraul-Itl11n G,C,h,I', 191S,J2.I,,tnul Iltu Cntlrl Ashnlnlalt'alnr is rogttualucl In 11-uililtilu Utls rufblrttl, It;Y'i'FIL coUlt'I', ~_ •. ~ i 4~ tI111i11u,A, I"ItiPlfui~ u' • ia~ wuynn SU~oul , MiclcitutnivlL hA 17057 " rJ Nhdnlll'1; prn Su ~ ,. l.eslict n,'I'rnnuo, I:iyq, ~~~ South Iit111oVuP SU~uul C ~ , , Cnt'Hylu; I'A 17(113 ~ J I~llnl`Itoy IitP laulglttltlitl ~~ ,, Cnut'l Aciminlylt'tltor't• OI'lloo ."~~1rf~r~C(a(~Cca~hF1 , n'u • ,, ,,. , ri _. _.. . .. .. rr .... ~ .i.. r" y \ r ,,. 1 r ~. 1 1 9~ , ~P TI1 ~ ~~~ 1O'~1 IC~I~1'AI'iy ~ , .. , 7DpG hlfll' ~~ Nhl 2~ I ~ ~~ ' , ,. QIIM~+~at~,~~ ui i aUN'11~ , f 1; ~VNarl_upN~ „ `.. _ _ I ,.. ~ , ,. .. I ~~ ,. , I . ,. 1 i.I Ir Ir ~~1 „ .. ~ ~ r ~~ 1~ r. ~ I1.~ .i - .. . " , - III ~. i._ ~ I. r. '...I i. ~.. Ir. )4 .. II ,, 'I I, i.; ~~1. ~, ~ Ir i , •. rl'. j }} 4- 7~3 :) { r ~~ ~ , it ~ 1 -c . 11 ~. I _ r - •1 Ili ~~ ~~ ' ~, 1 ' .~ , 1_ I, , Ii .~. 11 r. ~. I 1' ~',. /. ~. .< y , .~ ~'1 Y ~. 1• I, Sri.,{: r ~ ' 1,, r ' i~ ~ 1 :. ,. ,. ~~, „ ~) ,.,.i AI'R 2 b ~iilh> . ,.. ;; tt~, ~ , h'I'I?HI IANIf? ~~ I1AItPl?It ('I'lil?`)~I.I.It), ~ IN'I'lilt G'caltR'I't~l' G'ctMM(aN I'la-~;; cal . _ . NIiIIn111'I' ~ c.'(~MIiI1RL~Nh ~'c?IIN'I'Y, I'1?NNIiYI-YANIA v, _ ~ '. ~ ~ i Nct, ~~o•IONC, c.aYll,.'I'I'I;M .,. ,ic~511'li'I'RhS;;LI;It ? , hul'~ndahl i IN cllh'I'~~hY , ~nn)It o~~~ c~ault'r ' ANIa Nc~W, thlN .-. dtty nl' , «hn~,, nn 1?nwr~taitey Ganriny la aphudulucl Ilre -. _dity of_.~~__.___ al ______ ~~'ulauk ~ .nt. ut tlto c'innhurlancl ctnmty c'c~urthrntau . ' ~In Gturt-'~nni N~,, ~~ In ~'arilalu, I'unnyylvnnitt, ' , ,.. ,. , ,. ' d, , , ptKtrihutiagi ~ , LoAIIo t1,'I't~ntuo, (?yqulPu 5tuphnnlo lini'Itur, I)ulbndunl _ ~ ' ,. ,. ~~ ' „, ~., „ , ; _.. ,, , ' , ,I ~. i ~. ,i Y .. ~ ~ ~ , ;a'1'IiNIInNII n,lrn-tNlat c 9'Iif:hSld'-I2), I IN'I'IA: c?plal~'I' cal+' cep , , , ' ,, 1'lohtlil'I' MMpN 11.1 AS qlr ,,, , c uMI11:IiLnNla ccal.IN'I'y, I'hNNyyhvnNln ,~ , , l:I li 1'lil? , I Nr), Ilo,igflti clVll,'I'IRM. ,. _. dC)5 ' ~ SSl,lai 1 ' laulbt)citntl t IN ctU,S'fopY ,. , ,~ ANp N(a1Y, .~._~ --.____, ,.tgtr,, Ip,nn endHidcrullrnt n1'ihu Illlhphusl Gnniplnht6 Il is hul'dhy dlruclud thnl tiro pntlluk nndlhuh ruapptillvu unmlr;ul nppu111' h~fin'u __. Iha enI1plllttlPl', III ______ ___._,__ ~ - -___ ;till lhu d0y nl' -------------- _._._, znlir, ut n'uluuti, __._,nt„ li,r n I'r~•I Iwlrhtd t'?iiytnrly c~nnlur~nuu, ni anUh uunlurNnuw nn ul'linl'lvlll liu mntly Ih rganlvu fhu iaalica in cllaptltul t,r it'Ihla unnnal hu nullnmpllehu(I, in,clpllnN nnsl narrt,w Ulu IasuuH in hu hual•sl by tltu cclin6 nnsl icy utllor inin n tumpnrnry~ nrclul', All uhlldron nev 11vu ol~ nldur nul)' nlau hu pl•vsutn nl qtu vc,nlurunuu,; l+nlhnw In nppunr nl ihu '. vnnlurvnoo Inny hmvlclu 81'PI11111a li~l' ullll'a' of n tuntjinrnl'y nr purtnnnunt s,rclul•, +c~lt '1'I il? caUlfq,l ' liyl , ~usindyCs;nuilluln_'_' ~______._,, 'I'I)o cslnl~ npcngnn(m Plugs of c'Innborlnltcl cauuty Is retpdtusl by Inw to unllthly wlih Ihu nnturlwuy wilh ~I)ianblllllua Aut sll' I+1t)ti ' gvrlihlblu to dlanblusi Ig411YIlIII11ItitlnlYillg Iltgahluaralhu~ tau Iho utrill~ I,11'luaaui+ Ut1111111,U1 a1q+In~lY1!:u LrA111t1uh111ul1a nrrmt~pntupta mu~l hu nlnil6 rll luaa1;72 huura lulor In.tluy hupl'1118 t~l' hgehlpaa huliil'p 1110 (ip11i'1, Yau moat ntlund Ihu aollurhllocl vnnlbPuuvusu' hunriny, YtaU sIInU(,p'I'AKI:'I'Ills pni'I:R't'o YOUR i,n\Vl'I?k r1'I'oN(:I?, II+YoU iio~ • N~`I, I1AVI A i.nWYI?R c)K cANNc)•I' AI+Fc512h nNl., flea ~I'p olt'I'II.I?pFIcaN1? . 'I'I i-. 01'I'ICf of+; I' I+OIt'I'li 13IiI,o1V'I'c5 I+INU c)U'I' 1VI I1i1213 YOLPC:nN GI?'I' 1.1?Onl; ~. Flisl.P, ' _ •,. ., cugtburlnnd county liiir Aaaauhulun ,, 12 Solllli liudlin•d SII'COl • Cnl'llxlu, IrA .17011 '~ I'hollul (717)249-31G6 •, • (N00) 990~910d ~, ,, , ,a - ,,,. ~, , a, '~~t. ,.. , V ,. ~, ~' .. ,~ .. - ,. ,. „ ,. ti'fla'I lANll? A, I l~lthlai ('I'lil`i~tiL,iai), ; IN'1'111: ct)Itli'I' OIL c'ta c) t I'Ininlil'I'' MM N 1 1.1,5 ct-P y, ~ G'l~Mlil'•lil•~NI) ~'tal1N'I'y, l'IiNN51'I:VANI~ ,. , „ 1 NO. er?.1111i(, c'IYI1.'I'I;ItM hulundfuil ~ ~ I(V ctu5'I'pl?y, , ,', .IsMU.RC,I~N(~'1' 1'1,,'1,1'1'10 ' U'OI2 Sl~l~r~tnl ~ ,, p, ,~ NOH' CgMI„y, I.valiu ~,'I'nlttun, fHClult'a, lltr I'ullllnn~r, Mr, dnttoph'I'ruyHlgr, }tltcPht HIIPPnrI ttf gtlylsrr(u+'san(',v (,'vNNn+IJnr,S%n,('Itl! kr+Nrf/'tworH ttH fulluwvt , . I v y(llll' I'U1I11111tu1' IH ,t(1H0 1 , I It'I'ruHHlul', tthn tpHltluH 411 I27 LMIi, Nutvvlllu, pp, 1,72A1, 2. I2uHpt,liclunt/I'htlltlll'1'jH tiluphtilllu 1111rpur wlta rq++itluH ilt lilt) WIIHnIt 94raN1, Altnl'llitult~ "IOC, Micitllyli,wit, l'n 17057, „ , , ,. , 11 • liaplmit}lultl, 1111'ct}Iglt uullllAUl, ,IalUllril ,l, Kn rook .1, I y, Ilbcl Ihu nhrtVu cltuku-od COHlnt1Y '~ `, .. . }~~ ,, . (tollon~rvdlu•dlnl; Mnrluh k, `I'ruHHlur ht Iha(~umhurltlnd cuunly Courl n('Gnlmm~tt 1'IanH, ~' 't;,; `I~ Ult Pt' nbtuU I+uhl'nnl'y R+ 2(1011iu++~toticblll/I'Inlttlll'f luul' I'u ~ ~ • , ' ' dlidllul allultdud tt CUHlatly '. ' , •I ~ t', +. , ~,t,•~ CoItoI11t11jait tviUt I hthul'1 X, UIIPt~y, IHgllll'u pH Ihu CuHlndy CutlvlHtga}, ~ ~ ~ ,~r,tat, 5 . Aa }I 1'uHllll ot'lltu C'Uelotiy C(lltulllttllnlt,tlll Ulxlur nftatll}'f W11H u111u1'et) UIt ur t)))oll) ' +'' ~ u t~, I?uhl'unt'y I d; 20111 by Ilw I (ollnrllhlu ,luclyu OIu1', (O1•dul' tlltnuhull !IH I?Xlllhi( "A") ~ ~~~' ~ 51~~'{,}~~11 ('' ~ 'I'Itu l'uhl'ut0'y l q, 200 l cliHarcly Urdur yl ontoO, (tualuilufuOUt'luiplll'f prlttttu'y, pilyH~q~l,~ ', `~'a,~h'~~'lrjyty{~~ - 1 g'i~~ilgl.~ . ~OHlody ul',lhu ntinnr ultlld, MIII'lnh Kuyluu I ruHHlur, r' ~ ''!1'.}~i~~ . {~Sa t ~ ,~ . IlI 111 5u tlultlltt,l, 12 ~ , ~ ' ' ~ ~'~ ' t ooS, I2t.Hlxtltclolll/I IIIInIIII Illttl l'ullllultul' Higltutl q (I(1UlllftOjjlt `311~''t''«~~ • Hlnllgg lltnl, "Mnrlith K, 'I'ruHHlur tVill 1'UHIt10 tYil11 Illlltul' 1111(1 tlllull(I NL1v1'lll0, I?lutriunlttry ~ ~ ' ai+'~t4r'' °(y! . ' , `p + + i 6' v~'~ ~~' ' ,~ tiiid~~4 r. ~ .. - ' 11 4lyliy F??+S ~ I, r "1 L ,r r, tivhnal Ihr 1111'uP IttalUhHl" 1'he clnptllttVlll t11Htt, HItIIVII IhOI Ihp "It!11'IIPH will PttltlhlNP Itt hV itn It thrpu ntnnth h'Inl hnNIH until both pat'tluy litut'uully n~l'uu Ihnl uhlld IN NuuPUV(IInB In r. r' Ilut Nuhnn) unll unultsuling," (I?nvlnnunl nltuuhPtl nN f?~hlhlt "H°) ~_ tl, tan nr nhtnn hdiu'ult ~5, ~up(t, ItuzipantlanUhhllntil'I'anll hPtillanvr Hl~nu<I it dttttnnt~nh ~~ rr Hlutlnll Ihl~t~ "Mnrlnh K. 'I'ruHHlul' will tunidnu~ In rvHldP N'Ith IiuhPr, 1, haevtl cot thN Ir , ittluruHl nt'tha vltildl" (I?ttuunignl auttuhucl aH I;~hlhlt "c„) r. ' 4), Ituppctudunt/I'luhttll'f htlN IndluRWcl IItIII Hhu IH pl0nlting Ia u?;ul'IIIHU II1V cll'I(llltltl ai'clal'tt(' I I~ulirutu')' ICI, 2(ml, whuru nut~hur hltN prliitery, ph~lNlunl uuNtiicly of Marlult K.'I'rPHHlur, ' , . (. 1 ;1 . r I I -. l o,1'ullUaitul' IuuIH thu atttihur niunutlly, rand In lhu pnHl, phyNl~nlly Itliusur+ Zhu mhµtr ohllcl, II ~, ,' I r'r~ I! Mtn'hllt KI'I ruHHlur, whllu In bur uuNUnl~'r ~ ~,, 11 ~ }I,_ t 1, I'ulhic~nur IauIH thu LhIId, Marluh K,'I'ruNHlor, iH In an unHtn6lu unvh'onnwnt, wildly, .I '', ` ,'.., , ',s r 11 ~~ 1511 r' ruHlcllltg w1t11 IZuHlxtnclunl/I'htinllfG duo tct tltu I)tull Ituypnntlunt hNN Ittovud Itthtai' o1111ci to I ' , ),l'^r+,1¢j}~F~-1 ~, ,~~' , Ilvu tlll'lurunt ItctntuH~nnd uhnnyud Huhuul diNu'luttil)vu IlntuN In tlvu yum•N, I I <~I ,ft l,~~cr„'; ~1~ ,~ 1 1 r t! Innr ohllcl, Mnrhll ~ ~t ~ z, Thu M t KI 'I'ruaelur ItIIH Inclluntud Ut tltu I'utltlttctur Nltu wlNhoH to IIYu I i 1~ ti: II .. ~. I ifs' Is{v#t \vhlt I'otltlctnul'1 1 I ., t `r (1``14~~1`1+y4, ~I I• _ 'fi`t ,ti' 131 I'ulhlonui~, and ItuNprntdunl hnvu nnollwl' child, Antonio NnpnNlnn, dtUu of birth Ayg~ipt;?~y},t~t~}' r S J 4+'~~ ?u, 200 1, whloh PPIIIIonor Hlgnod un nuknuwlud~ontunl of pnturlitly litt' thlH minar a~1~~~t " Ir ti , 11 ~,~ ~~I muI llndurHlgnud uaun,aul hnN Illucl un Alnunclucl Colttplnlnl to ncltl to thlN dackPh ,' ;'1'•';~ - ' +~Jl ~r ~1, I'cUtlonur hullUl'UN lull) 1hUl'Ulttl'U g1'cl'H Ihlll IhU Illlnor, Antonlo,Nnpollpm iN'itlHd rnAld~l~~iM1~ r ' In lilt UnNlllblu unvlPUnltlunlr "~ly~s,3~~~ s ~ ~ I ( ,I ,i r Ir 11 Clt`~,r~~y~ 1, ' ,r f(~1~,4! .t i. ~ r n ' Iq lr ~' 11 ~~yj~~~ t 1O t ' _ 11111'tll 1~~~ r r I 151r ' r 1 I 1 If ,~~~ 1 .. .. 1 ~tl ., art it 1 ' .. .1 I ? I 1Yttl~ttt.V'111i1~'s Yltin' I'allllltnur lua tuutlllll ' 1'~I uuHlx Ihal illy I Innurnhlu r'nurh ~i'anl it ,• ' 141111(01'{II'I' gl'II41' BI'IIII(Illl! Itl'lllllll'y 1)h)'xlulll 4NHIntI~' 411' IIIP 41111c11'VIl 111 111u (11111PI' ItWllltlly IhP xulutclullny ul'u huarine nn Ihu ntgllurx ulludud hurullh ! „ C 1 AM61N1)P:1) Cllti'I'OpY CQMI)L,AIN'I' I5, Yinlr Itullllttnul' ix J(txulth'I'rusalov, \vhn ruyillux tit 127 c'MI'., Nuwvlllu, I'u, 1721, ' Ih, l)ulcll<IIIIII IH tilul)hi111IU I IRI'llul' Wllo puxiclux III 14t) WIIxOn till'uPl, /11flIPlI11U111 10(i, Mldtllutttwn, I'll 17pS7, , 17, I)PlPlltllllll huu~x 1't'1111N1'y ullxlntl)' OI~111u litlln\1'llly uI111tIIP111 ' NIIIIIU t)1'PYVIIIItuxlllulluu A(;4 Mnrlnh K,'I'ru>•ylur 127 CMI ~ I I yuurx pld ' Nuwvillu, I'R 17241 ' r1111011Io NRp01111111 I qt) VJIlenil ti1fUO1, Apl, I OG ~{ yptlPx OIII ' ' ~' MlddlulnN'tL I'n 17057 ,... '1'hU ullilcl \1'qN 110( h(tl'Il (till uI 1\'UlIItlUll~ ~ 'u~ ~' I K, I~I1P uhlitl Ix 111'UtiUlllly Ill 1110 UIIHltttly 01'tilU1t1111111t) I Illl'pul' 1\'llt)1'uxidox g1,14~ WIIHOp ~~~ ' SU•ua6 ApprUnunl IOri, Mlddlulo\vn, I'll 17057, ( : ;j ,,~r UUI'111g Ihu 1111x1 Il1'U yulll'x, lllu u1111tI1'UI1 1111\'U I'uxltlUtl \VIQI IIIU litllo\1'lll~ Iwl'xnllx lliltl'lll 1110' ; 'it' Ih11UWI11g 11tItIPUxeCx1 ` 11x1 All I'urxnnx I,IxI All Atlclruxxux ' I)nlux ,~ ' Mn1'lilh K, 'I'1'uxxlur ' I Y:t cMl; July 2ono ltt Mliruh 2001 ,' ' SWphunio linrpol'. Nwvvlllc, I'n 17241 ~ .,'`; ~' ~ ,, .::;+; ~„ . , ,, ,,j, ' ' , ~, fiE! 1,~y 1 ,~tF~l 1 '~ ., .~ , . . h:i .d..w~ySry' ,. ,. ,, ,. Anlsmin Nlquillllut ~ ' ' ItI1nNr l ll~hwny zoAl In 2(1(mz , , Marinh K,'fr9HHlp1' ~nrllHlu,.itll 1701a tils?phtu11911Ari1up '" ,,,: „ Mttnnitt NH~1nIllnn 111H K91nn Iinltd ~ 2n0~- zp111 M01'lllh I(~,'ll'9NHI91' ~IIIltitullNlt111'ktr I'll 19?57. ~' ' y1U111111111P I1111,ItUt. . ~, .. AI111~Itiii N11~ipllllpl ' i2(i'P!11YI111pUHU 200;t,?pOr{ Muhinh Kr I r9NH19r ., I~rlur ~'ruei'Nn, 2 , ,, S19~thnnlu Flnrpur ,. I I9I'Hh9y, I'n ,. AOlnnin Nnpstltlan, ' I ~l~ WIIHnn ;U'~9Ir Apt, 1011 ~cinq la pr9y9,n1 " S19phlulist FUu'Iwl' MIcIc1191c1tvIL pu 19057 ~ , Mariuh K~'I'r9HH191' f~'~ WIIHnn RlruuL Apt. Ip6 2npl (o ~upl, zno~ 519phanl~ tinr~tul' , Mldsllulmvn, pn 17(157 .. , Mtll'1011 IG.'I'ruNHlul' 127 (.'MI; ,, ti9pt~ 2p(1S t~ prliHUlll 'dgN91t11'I'1'uNHIUI' ,. NV\Y1'lllUrlt41'19?gI . • ~ I'~, 'I'i19l11t111191' nl'IIIU 9hilti IH 51UItIti111iU.I1111'1191' 1VI1S1 1'UNI119N RI ' I~lt WIIHttll till'uUl, Aplll'1111911I ~, ' Ic1G, Midslbtowl l~ Nu 190,57 , ;,'.; Shu IN Illlb'1'i9d~ ,~, ;, 'I h9 f111hU1',11' Ihu uhildr9n IH.,IttNUph'I'ruttHlur, whst ruHld~e III 127 CMI?, No\V1!IIIU~ hlt, 17241 ~ ' ,, I lu iN Illlll'I'iU,li , L , ,, 2(tr ~I IIU I'9111IIUlltthil) 01'~IUIUIICIIIIII IlI lhU Uhi1C11'UIl IH IhlII (1I'I'l1lhUl'r - , 'I'llu <IC~Ullcillltl 910'I'ultliy 1'UHIdUH wllll IItU N11io\Vllly p91'anltHl ' Nnmo " ItulullnnNplp _ ' ' MUIIHHp'I'I'UHHIUI' WIIu ' ' Mlu'inlt ~ CHlluy hnuglll~lw `I'1'9NH,'~I' , 'I'ylur Bc Mnlthuw tit9p-HnltH ,, (-'nl'dur ,. „ ,. ' ,. _.. . . , , ;, , , ,, ,, ,., , , 21 ~ The r~hllllutahlp lil' phlinlll'I' la Ih~ phlldiwn I~ Ihllt ltf Mlrihur. ~ ',;1 , ~, ' 'I ha:Itlglltllll 11111'I'Vllll~' I'u>i141PH wllh Ilw Inlllt\Yllltt pufHPllHt „ „ Nnmv ,. I~WhtllnttHllllt ., C'p-'pY llllllll(t1Vi1 I3(tY1'I'IVh(I ,,; ~ntanln NIIpOIllml ~h lcl ,. ; ., 22~ ItVlIlh11V1' IIIIH II(1( hlll'GIUII)IIIC(I l18 l1 It11I'ly (11' ~\VIIIIVHH, (tl' IIl Ilpl7l11V1' Pl1I7tlVlly, IIl ClI1V1' I11184111Oh ;,, , ., CgpUUI'I11118 lI1V VIIHI(t(ly nl~ lhU Vltlllll'gll IIl 1I11H pl' IIIlltlhUl' Ug411'l, " ' ,,'' ItUIIII(tI1C1' IIIIH 11p 111Ii11'I11711In11 UI'll OIIHIIi(ly I71'ctVUUd1118 UgI1VUl'pI11B 111V oI11I(II'ull ItUIllllllg ~l) 8 UPUI'I ' ' , i PI'IhIH C(tllllpPil\VUIQlI1 q1' 1111' ctlllVl' HII11U, I)ullllltpVl' dPUH11nl kl1(7\V gI'll rul•H(tll Ilnl (1 plll'ly I(I (I1V pl'puuudingH 1VI1n hnH pllyHlV(11 utlH(itdy pP, i, ,. - - ~ - , IIIV Ollll(II'alt UI' gI111111H'l0 h{I\'0_QUHlO(IY PI' \'IHItHIIUII 1'IttI1lH \Vllh 1'CHI)UUl (0 lIro ~I111(I,- _ -- , , 23, IZCIIH0118 Ibl' ~1'11111II1~ 1'CIIVI'1 ' hUli11011~1' IH ItVH(ilI11U (lt I)I'(1Yl(lU lllu Upl'U llll(I Illll'llil'C \VI11CI1 IIIU uI11Il11'UIl IWU(IH Illy I1CgIlI1)' (IQVVI(tItI11U111, ~ , CUgfl ol'(IVI'C(I dUlUl'lllllll(ll(tll pI VUHIStcIY IH 1'Cg41Il'U(I Ill IIYUIQ UoIllI1111I114y OolllllC( hCl\YCCII IhU : " ~. .. . Itlll'IICH 1'Cylll'(III1B It111'Ullll(I fUHI1(711HIhIIIIy Ii71' CIIHIIt(Iy~ ~+ 2iI, I?pOli Itlll'Chl \VI1l1HC Itpl'ChIIII I'Itr(I1lN III IhU Uhlllll'CIl I111VC Intl 410CI) lCl'I11II111IU1I II11Q'lI1C I1CI'N014 ~; ~f N'Iut I)IIH I1I1~'HICIII VIIHIody nI' lI1V VI1IIlIl'CII ItIIYU I1CLI1 I11QI1ocI (IH Itlll'IICH In IhIH QUII(111~,AIL,glI1Ct' `a' ~`. ItCI'Htt11H, 11111110Q hUllt\V, N'I1(t lll'0 (llln\1'Il lu Illl\'0 UI' UI(II111 11 I'IgI1l a CIIHIo(I)' op YINllllllnll nI Ihu i.~ ~. ~,~ ,.. ~ ~? .. ~ ~ ' I~ !~f ,. ,. t~l-Ilclr~lt will hu ylvutt nttlitw rl'Ihu Ituudpnuy nl'litly IIP114t11'llltfl (hP 1'I~hf tR Inlurvuttut r. ,. , ,, ,, " _ NIIIttP _ /1clclt'utie Nllsls nl't,htlltt ~Nnuv 7 t' I Illlupul' 1'VChlus(~ lhu ynUi't 81'4111! hI'1111Rry olletacly nl'lhu gltllch'oll ,,,. ~ , MQpli~'Y Cl1S'I'Qpy ' .. r „ 25, Your 1'ulillnnur la dnsohh'I'I'PHYIUI', 11'11P rusiclon at I27 CMfi, N~wvlllu, Nn. F7?41, ,. 2fi, Ro'spuntlunUl'Inlgliff,lri 5tuphnnlu I Inhhur tvho ruylclus ul I'19 Wllenn tiU•pttt, Apnrunont ~ 'It)(i,~MldcllultnVn,1'u 17057, . 27r On I~uhruary ti, 2001, Ihu I Iottnt•ghlu'Ii~lWtu~cl ,Ilttlgu Olur ultlvrutl tltu CuH(c,dy Ordor ; ; ttttnohotl nx I~hih11 „A„ ~ ' ., , ` `" 28, 5inuu Ihu utttry pPstiicl Ortlur, Ihuru hots bault 11 ylgltlilotgtt oIt111t~o In oh•o1111ttilnltuoH•ilt (lttl(t r ' ' £t ,~ 1 4r Itr 1'hu tttltuu• oltll~i, Mnrinlt I~,'Il•uaelurluts Ituul~ rosldlny tviflt Itor ~llhut• Hhtou, r ; .. Ii ,,~>r r. ,' Sultlouthur 2005, ~, • „ ,,; ., ~ „; ,,y ,~,~ h, 'I'ht: uthttu+oltllcl+ Murluh ICr 'll'uevle~' Itay Q\171'Q4~{Oll NhU 1VIIIItH 10 I'OAItIU 1VI(h 1101 Ilttltari ' ' ';';, !',,, ,';` ~, /, , ,•; h; 'I'Itu 1'ulldouul' hu4 nal horn ullutvucl lu suo hIH srrih Aninnlu NtginNlpn t+ittbolbhllt, " ,r "`+~'t~ o, I'ulhlupul' 1`I liusl tlblu lt, provltlu n slahlu Itnllsuholcl Ibl' Iltu uhlldrult, ~ ! .: ,7" j , rf' r . ~,,q,~ ~. -. r Ar. ft~t fir ', ' ': ~ rt t rt(~~'j,~ IL r, r }t of _~i3 Y( _. ,~ ,. ~ ,1• .. N'I'INFIANIf'. /!, i l!~ItNI?R (I'itla5l.ls'Itl, , IN I'I ll? ('c-l~Iit'I' ~)i~ c.'r)MMc~N Nld?rlti alp. ' "1"Ininlifl' 1(91MIII'?ItLANI~ c'(~UN'I'Y, III:NNhYI-MANIA , Y~ ,. i Nt), +~+~•IbBr1 CIV11,'I'1?Itlvl ,. i~l.l;lt 1 , hul`vndalll 1 IN c'I.IS'I'c~pY . ., ,. , L'I.R'1'l1~ir:A'1'1~ r)I~ til~ I2VICI~ ' ,.. ~, ' ,. , ~. 'I~ Loally A~'I'nllWt+~ I?NClllll'u, t11lc1fltuy lisp ,loqupll '1'I'oHNIPP, cln ho1•uhy aortlly IhnIJ 1I11N cloy >i~i'Y~41'll Cnl1y pl'41114 f;lliFl',y~lrc,l' f~V(l/fr~ll,/liP,\~~4plpf ff4'f14;'/'4111ni1 ihu Ii)IlnlYlilg by duhol{Ill11g HIIIIIo IIl (hU uI111Bd y11114H I11RIIr h115411•3u Ill'o11111d, i11 C+11'IIHIU, I1u1111Hy11'tllllll, IISItII'UN;IU(I 41H~1411111WN1 ,. „ r ~;. „ SIV111111111u IIIII'pul' ,. „ iq'11YIIgnn Sh'uut ,: - MI-1QIt+In/l'th PA P711fi7 „ ~ , , , li l~ ~ ~ ,. ~~ J -)nlodl ilpril a~, aoor, ~~~_~_ L2~.~._o f ~~~~~ o n, 'I'l) prll, I hquhro Atull~puy li,f' I)olbadlnlt ' ~~ ii i, , l t, , ,, S'I'1?pI IANU~ A.'I'L~1?5hl•la?, hlulntll'f v ,lphl'sl'I~1 L.'fRI?S~t.l"ali, P'Nfundant ,.,, e ,r ~x h ~ h~ .i ~~ hhl~ a l1 ~„I,, ! IN'1'Ills uc~uh•'i'.'t~l~ GUMMPN 1'1.13A~ fal~ ~ GuM-31"sRLANpf=ouN'fY,l'hNNsY1.VANIA CIVI1. i!G'1'IQN ~ LAW NC,?4-IoH~ clYll. IN CU;l'PoUY >,r ANf~ Nt~W, this _~~~,day of 1'abntary, ;cool, ~.i un nonsldnrutlan of thu ~ntaahocl Ct,etpdy ~ canvillntitm Rupart, it is nrdarad and dlrcotad lhtq thl caurt'a Wiar ~lydar it~r oustody antorod pn Maroh K, f~c~ ~ at tha abavu form and numGor (s vaoatod purl rupluoacl with rho fallowing ordort I, '1'ho Mc~Ihar, Slaphnnio A, 9'roaslor, and tha I'athur, dasaph L, 'I'rossl~r, shall atjlay aharad Ipeal oustody of Mnrinh Kaylao'Crabslar, barn poaontbar 27,19'a~{, "„ 2. Tha Mntitar shall ottlnY primary phyaloal oustody of rho mhtar child, 1. 'fho rathor shall onlaY partial physloal oustody of th'a minar aldld an rho first 1h{oo ~' woukonda of anoh month, tlta limo balnll Font Friday nt fatoo n,m, until Sunday qt ~~" " . 4ioo p.m, War oxclimlgo of atistody, Matltor shall ilallvcr tha ahlld to Snylnf'q Market ttt rho bu~innlne~oftho waok~nd for path4r to tskP~attt;taly~t~f tho ghlid Au c C'riduy at 9ip0 a~i11'~ and Cathay shal6dallvor iha ohild to Mathar's parent's hotno an " , ~~ '~~' Sunday botwoou gtho and AtIS p,m, •~~ ~:. 4, Catltor,;shall altlayy oustody of rho tttlnor ahlld an holidays to inbluda Castor, r ~, , , '~ Mamarlnl 17ay, duly ~{~~', Lnbor Pay and Chrisunas ~yo Itom 6,0o p,nt, on Chrlalmaa ~ " ' ' ~~; hVo,thtouglt 6t00 p,it1, an chrletmas lacy, ~~' , ~ .,, ,~i 5.. ~ Farhat' shall havo Iho tight to have oustody with rho ntlitor o1111d on lha phlld'H °' ~~, :'_~~ '~ ,~'' blithday nt n tlnlo to bo agraod upon by rho partlas, . ; ,,, ;,+it% ' ~ G, Cathor slutll ot~oy oua weok of visitatlan with tiro tnlnoruhild during lira aumritgr ;, '.1 ~'{`~~ ~ ~ whh I~uthur giving at least two weoks natlaa~ , `' ~' ~, %',Y~s ~'~ 7, f,.. Roth nuilos sltal! ottJay roasanablo tolophono gottluat whh tltn'mluar ohlld whon'th~~ '~'s~l~t~,~ t ~ ~ K ' 'a ~t+~ t's oustod ro ll arb h hild ~ y, ~ lt ~ s to t or pa n o ~~ ~l { ~,~ N, both pnronts shall nalhy rho othor pnront wiilr respool to otitordonoy mt'dlQal ~ " ' „ ?'i~~'l'~i t I f situutions tluu ariso whoa rho oltlld Is ht that parattl's onto, " ' Il ~ P ' ' + ' . ' y ,. t ,f;~7 ~~ ; t ~9~ ' ~ ~, -, , ,r;, ,~ < ~ ~1 t l ' s, ~~ s ;',, ~~ i. ~~~r ._ , tip', .. ~+ ~~ NPlthar nnrettt rYltnll -InTUIY{hin~ lh--t mny PVII'nltyP the altllsl (~nnt the athar Pnrent nr , '~ htit-rP the c-hininn nFlhe ahl(c- na In thu nlhur rrnrpnl nr whlc?h Wray hamper the feu and natural clbvelaintent nl'the Pitild'n Ittvo }qui respect fnrthe nihor pi~rant, ,, 14. Tha pnrtlea mny ma-111Y this ar~ar -ta tlipy nyreo, Absent nn npruamant (rotwaan the parties, thla ordar shnll'anntrPl, '. Thin ardor la ~ntarod pars-~nnt to nn narpatnant ranoharl by the'pn-'tles nt+n cuatncly QoneAintinn Cnnf~raitep! do Iho nvont aliher early deslras to mndify this prdpr, !hq{ + " pn~Y mny petltinn rho onurt to hnva the nnso t~~nln dohuduled whh the cusiatly ~nnnillntar, ,.,. f~Y'I'IIG ~auR•r,,, ,. ~~ ~~ osloy 0 r, Jr~r ~~~ + ! ooh Tltomrlsd~ W,Illiunta,I'sag4fira ~ahnnn J. Kopcuky, Gs~ulra ' ",. - I ~ i. + _ ,~ r. .. r; ' ~.I i 1 I ~, + i. Ii i~ 1~~+ ~ 1, 1. +. i ~ +! ~s „ rb, ~ iT1 + , ~" P ! :, ,. - ,, t ~. .. _ - , i 4 >+ ++, , ~t~~ TRIJ~ C~rY FRgM RI~Ct7hp ' -: „I~t ,.: In rostinu,ny t~rharFbl, 1 beta ugtb eat rtt~ hind "+t~--~ and t o coal bf §,tld urFaf C rllela, (~d~ ,', ~~,~ ~ ~ j' . ~~. ..... !! r,,. '1 PMUIQna bt~ ~ ~ , ; y,~` ~,,. ,fa1~~~• i i(F. ! t, s~.i~{ :_ . ,= . 1 i + (~ ,.. i .. ,, •.. i 1 ,. ~. ,. , ,.. ; 1 .. ... ., „... , .. ,S'1'!!NI IANIf3 A, T'Ii~Sal.l;n, t IN TII~+GOUItT' al; UoMMoIV PIaI:AS AI; ,+ Itlninliff t GUMLiGIiI-ANp GoUN'i'Y, ItGNNi~Y~.YANIA + , t Y ,. r CIV11~ AUT'hN ~ I,AW t<QSI?Itll L~'fITC:SSI.[iR, I t NA, ~9~ IANG clVlt,, L, pofpndnnt t IN CUSTopY ~ ~ ",. Nrlnr dudeut ~, Waaloy olor, dr, ,, CONCII.IATIO~CON(1'r12P;NCfO sUi~]lyIA12Y 1_____ Zr;t_ ~nRr .~ IN AUCQRpAN~t WI'fll '1'111: CUMfi4IZ[.r1Np coUN`1'V ~IV11. RUI,G~ oR ItRocGpl.IRl: ~15,1.g(h), Iha undvr9ll~nud Cuat~tsly t=unolllatar vllbmits thA f~Uawlnn rorctrl{ j + n 1, 1'hu portitant lnfannminn pNrtnhthts to the ohild who is thu aubJpat of this Iiprtadpn la ua fal~nwal , ,~ Merhth f~ay{av Troyalar, ham Duaomhor z7,1~9q, '+ + 2~~ A Can4(liat~4n Confaronaa \ytla held an hoh111aty R, 2ppl, Willt tho f~liowina htdlviduala in attondnnaut 'Cho Mnlhur, Stophtutlo A,'('rosalurt with (luraoimaul,'fltomas,1, Wlllitnna, G+s~lllru{ atld thQ rathar, .Jpaeph l„ `fruaalor;,withhie caunaol, Johnna J. Kopooky,aiaqufrol + ] 'Llto,pnrtips asrgo to Iltu uttlry of lui nrdur in Iha farm as nttaahud; ,, ,. ' +, , , ,, 4 ~' ~~L .i '' uA CI3 liubort X, alirUy, ~a rur - .. , ' 1 „ Cuaptdy Cottolllato~ ' 1i'_I n4 H 1 II , • r5 ~1 II I17 !'k! ~IkF ~~ 11 t 14111~~It;lJt .1 ~ ~. HH 177 tl is +}~''## t /rr/-. . ;' 1 R ~~z' 1~. ¢gf ~ p. + {l .- '. _ 11 k ~''ii`i`{k~~ ~• , .. t 11) 1 Y4)r~ti *;~ t ~' r I r+ ~t~~ ,,. •, r ~t k~'(Ikk tl[kt~y{1(51. .' .... _. ...u ....... , .... ,, , ~-~~ l ,~ I „ I\,1C~L~ I~''~~ 1~7~~1~1 ,; C I-c.~~a~l ~ ~~~(~ ~ , ', _ , ~l..ri(@ ,~ ~. ~.c~ Inc. `~, . Cl.~c~ r'~c~,~, C~~ . { , , ~~~, ~~ , c~~ ,~ a:~ m~~~,~1 '~~ ~Y~~~~~ ~~ ~ ,~~cL~ ~~ ~ _~ ~-~.. (Y~~~~(~.~~L r 'fed. "'~` ~- -1-u .., ~ , Ir~~~~ 1 'l'_ C1~11 [..~ ~~ r ~~ ,/ .) ~`1 I ~.._l II.,~IA I'~ .1. ~.. ~_ .II t , .l 1 ~~ .>>, ,~ ,1. ~~ ~1 . „ ~~ ,,: ,~5¢7 ,; L . ,. ~,, ; ~, ~,1 ~. ~ ~~ 1 ;,Ivr, l -, '~'' ,'. I ( ~ ' r ~ ~ 7~ ~ jS~i~~1~~4 - I~ I 1 p SS tt }~rjtS . 1, ~I~~,. },~ ~.~~ ;~ slrl°, rr;~€ ~ ~ _ . n~~ .. . ;. ~: ~ 1-1~ .~ ~ ~~ ' ~~~ 4,~ J r ,~ ' 1 ~s ~ ~ ., ,, .CSl(1` ,' 1I11 ~, I ~'U ~ ~, ~ I f it 1 'f 4V^l I ~ ~ ~.:~\ , ~(+~~`'~1 C I 1 // 11 ~~~~ r in ~ i~'~''~ {1~'~t i 1~ . 1. f~ ~ t,~ „{ rrvM ' . - ' '~ 14sT't~` ~~ ~ ~ in ~ y+ t.t .. ~ -. ~'t ~' \^ J ~' ~~ ~I „..~_ I~ +r~,k~,~;~ ,, , .... -, r.----„ . ..., µ~ • ) r ~~.~ n .-. ... .. ~ ~. - ti'I'I:I'IIANIIs Al IIARPI?R CI'Blly,y'LI?R) t IN'I'I II t'Ol'llt'I' OI' ('Cttvtt,~111N NLI?A'iC~j~ I'I.AIN'I;A'I' . t c'Ut`-111f?ItllrlNl) (Y)UN'I'1', 1tI:NNti1'LVr1Nl~ V, I I uu.111Hfi CIY11, r1c"I'I(>N I,r\1V -' - t ,, ,• dciSl?I111.TItl?5lihlll2 pl'.I'I?NI)~1N1' 1 . IN ~'llti'I'OI)Y' - i ,. ,' ~iltl)i~a~c~rc:n~ ~' , ANA NO11', ,-,-...-- -'l'tlu>!dnt,_htUy~,gu, znlir,_.__.__.____-., upt,n usatxldurnllnn nl'Ihu lula4huil C'anlitlninh - II Ix h~l'vhJ' dh'ualP(I Ihdl parNPx nlld Iltpll' I'ux~laulivv oc,tlaxpl altpala' hol'tn'p IlghNl~l X. (1111'ay, l;atp ,,Ihu poltulllnlPl'i , _ltl~__~111~'_ll119ic1l111L41'lluttl ~Rl!u1>' ~'!~!Il'IhiII!+!', r41a191~ qit ..~.-_..___l'!'lfhil'i ~~llll4'..l~it_~illlllJ_.--^ :-___.. III _{II~IL_(1M . , •limit I'ru~l lunrlnu c'uai,4ly Csnlbrunuul Aa xllult vcmloraltua, nn ul'litrl tvlll hu Illlitlu In I'pxI11YV IIIU I4xU0x III tIlNl,lllyt nr II' Ihlx p111111t+1 I1V:IWUplt11)IlxhU(I, a, tivlliiu and narrow Ihu (xxaux h, hu hulu'd by Ihu ucnu'I, nncl I+i unlor Inla.n lumps+rnry nl'sl~r; All 4hllsh'un alto lh~u str alder mnv'ttlxu hu prpxonl al lh~ os,nlUl'9noa I'nllutc lu ntipunr al lhu ~(,nl'uranuu ntu~' ' prttvl(lu eripnuhl litl'vnhy nl'n luntlua'nry nl• pul'ntnnunl rn'tlun .',. • - 'Chu vanrl hulluh~~ dlruuta Ihu linrllur In farnixh env nlul nll v>;Isllnu Ih'itluullan Il'nUt A~Uuau al'der's, ~iliuulnl liullef orders, on(Lc?uhinlh' ar(lurs In Illu carlnlllnlsm'IN hnln~x prluu (a suhuthllurl hunrinu,. li~,l . Ivl _ hfyGvr(-X, GI{r1.',}5_~'yJ,..---- 1~~11 _ _ ,, ~ " C'U`zltuly (.'allullhllol' I .1 , Thu ('purl al'C'oatnu,n I'luax arc'ulflhurlnnd Cnunlff~ Ix rudulred liy lnw~~a uamply whh ihu Anwriunnx ~; tt'hlt Ulsilhllhox Aol t,l' fcJl)(1, I'ar btli,rlaallult nhaul nucuxxiUlo litollillus Itnd runxnhnhlu accantlttodallpllx ut'nlluhlu Is, dltiahlud Inslividaaix,hnvluu htlxinuxs before tho uatiil ~,lulixu nnnntvl t+ur ul'lluu, All arriatguntunrx ,mull bu nuldunl luaxt 7? hourx prim' lu any huarlay or baxinuxs bularo Ihu uaur6 1'on~ innxl allend tliu xclt~dtQ,pd us,itlurultuv ar ItuarlaU, Y(7U 4110111.1)'1'AKL'I'Iilti IL11'li.lt'fO Y(HJI2 A'I"IOI(NI?Y A I (tN('li, II' \'triJ I)O NOT I IAVIi AN A'I"COItNI?Y (:112 aANNc)'I' Al~poltl) uNl?, cu)'I'o OI2'I'I?11.1'1 IONI';'I lil? OhI'IC.1. SI?'1' ~~ '1 I~Ok'I'FI I1C;LOW'I'O I'INh OUT 1VI IIiltl? YOU C'AN OI?'I' LI?OAI. 111:1:1'1 ~'unthurlltnd;C'i,uaq' Hnr Axxnulnllon ' 32 SaIIIl1 1ledli,l'tl tih'ucl C'arllslu,ponliaylvluda 17aIJ 'I'clephnltc (717) 2~I'J~.t I G(, , , I .. ' ~ X:j~:c 'Ii,j'Vi,~y : ~: ,. ~ I'CINII~NII', ~~ I I~ItI~l:;li 1 ~~ CI'i~1:;~51.,1?dt) ~N ~ 'I'IUc~l~)1)I~'I'ol,~x)MM(~)NIV.,I~fiUI' .MAY (-~ZUUG , hininlll'I' I,I~MIlI,ItI~~Nlacc)1.)N11,1'I;NNSyI.Y ~~~ ~ ' ,. ,, „ L , c,IYl1, ~c~l'InN - I,nW ~' r i `1 `1 ) , .1 Q,lliltl~) '1'1l1711'11a 4i 111 i ;~. ~ ~ - ,,. ~ .. ~ .. Iaplynclnnl N!), hi~,laNh ~.'IYI1.,'I'IshM ,. c~~., ct~cx_~1 ' ~NI~ NSW, Ihlh ~Ilp clay of Mny, z0oci, uhan v0ltniFlWrlllinn of laol'vndan4',ti ' "1'dttul'I3Phu~' 1'ulllinlt.l(11' Sltuul+ ll I~Ullu(; (hiti Itlilllc±p (S 1'P~u1~1~V{1 Ict Illy UIIHlctdy ogllPlll ll ll nlt pl'ttuur•,y Itlll'4111Q)I IU C,C,IZ,I~, IJ15,12r1, tUtcl Illu GctUl'I ~cllttip141Pl11c11' 14 1'g41UuNlucl 4n ,11t~IIIIaIF Ihin rul'~rl'nl,„ ,, ~. 1:11"I'I Ili c.'(lUlt'1', ~, ,. Slolilttutlp A. 1-)ul'por, ..1'11 WIIea1t St)'~~4 ' ,. , , Altpclntu114I06 ,. , Mltldlu(owtti NA 17057 ~~ " Nltlip.411't; hI'o So ,' ,. ;. ~~. ~ r.,oHllo A~ `rolnoo, l7yc~, , .. 15.5 S(toth I~IQIt(tyUl' S11'UUl Cnl'Ne1o, I'~ 17013 , ~Ulcirltuy litp UUI'ol)clgltl ~~ N~'l Adlninlsu'nlcn''H grnU~ IPo ,. f , i.~ ~.. ., .,1`11 .~A Y~' ~- ~ .. i_ , ~. ,. .. I' ' ~n N'1'I~PIIANIIC A, IlAltl'I+:Ii ('I'RI4Nyl,l~li),, r IN'1'lll4 ccillR'1' AI• CAMMfaN 1-I~WA9 A1- ': 1-Inintiff t °AIIMlllulilaANll' f={~UN`PY, I'IuNN~1YI+VANIA t- v t Nt),!~!- ~ IAAb c1Y11, Ac' , ' I IAN ~ I,AW ,. t df)y141'II'1'1114Nyl,lull, t IN cUt+'1'(IpY hufvndnttl ,. CUUIt'P Oitl)1''It , ANp NOW, Ihiy .z.~a~t, tiny of dnnu, 21111(, npni- vanxidarnlinn r-f tity uttt-vllvrl 'CUxtri~ly CanvilinUon Itvpnrt, tho fnlluwhtd Ards' ix onlvradt,. 1`, A buih'h-n in° xaltuduiod I„ ~nurh'nr-m NUt 1 of IUa Atnt-uorlnntl. Gr-ttlily ' Cuurtbmtxu rm ..A-o ,~~ rlny of Dt!lo-~c _{ 211!1! of '3d . n-, At tbix honrint;, tl-a 1-pthvr aAnll 1-o fha mnvbts party nnrl ~~ Hiudl provouA (nitlnny wltn taxan-nnyr C~I~nxal far tlto pnrtiax xltull Ella witl- Iho' Cuut+t and r-ppnxh-~ a-unxul n Monu-rnntlnn- xattintt farlh iho Idxtnry of auatntiy. ill tllix Utlxa,,tlla ixxnox atp't'antly Itoforu tUo Cutlrt, a lixt of wih-oxaua wl-n'rvill ha vnpod to toafil~ an Iw1-1-If of onuG puny and n xlumm~ry pf nnfiulliufod tvatbnony ", Ilf OIIOiI WIt11oxN, 'i'Idx Motnornudlun xholl I-a plud of loan! fivo (s).anyb prim fit Ibo h-uutlnaud dauriuvt dnty, 2, I~opUh,q furgiur Ordor aP~lltix Cnurf, Ihix Cmt1't'x In4nr ouxb-dy Order of l~ul-rgnly 1A, 2(1111 ix vnontod and roplnoad vvlllt thu f'nllnwM~ `I'I,MPgttA12Y Ordvta A, '1'Uo i~nthor, dnxuph'I'ruxxlor+ and the Mothur, 8tot-lundu A, itnrpar, xlndl unJuy xUarod logo! onxludy of Mnriul- Kgyioo '1'ruxxlor, (lnl'l) I)uoumbor 27, Jl,) and Anlunto Mq-nllhtn, (-orn Auguxf 211, 211111, II, ,'1'ha I~'ntl,or xhull onJuyy prinatly phyxlonl onxhidyuf Mnrinh ,uid tha Mnthor ala-11 unJny prinnuy pltyxlogl unxtndy of Anhmlu, ,, C, Motl,o-' xhnll unJoy tunq-nrnry uuehnly wifU Mnrluh nn ulfornnlh-g ~~ Woultmuix frun- I~rich-y nCStllll pdm nnlll Sunday nt 411111 pdn, '1'hix uuxtbdy timo lvlll xhu'1(1-u Wuoltund nffor IhtlUui~ ruturnx hvn- vnoutinn, '1'ho pnrtlox may -nnrlll~ tllo plult~up and dullvory Nmox If tl,uy nproo, iCxul,nngo of a-Nhuly xl-nll by bnnrllod lvitb tl,u pt-rtlox x4n1•Ing trnnxporbltlnu.nnd IUo ~~ pnrtlox muy ngrou to moot ugwtl dixtnnou, ~. ' ~, _.. .. . , .. .,.. ... ~.... ~. , . , G.llhk.' :a R+ An Illu rl'uP14P1141 (11111 M111'lldl alll~'a rvltll 1)Ad, 1)111) allllll IIIIYP tt!Illpul'tl~'y uuatntly rvltll Mlimdn nn Nnhn'dny frnnl UIIII- n+nl, until S!(III p+ul+ i~.zuhnllgu of uualntly fnr h'nuapnrNlllun aNnll hu Ihu annlu na sui fnrth nhnvu+ It la ,. nndurahlntl tlult Mnrlnh n'IA hu rYllh Illul Ind MNmlin dlu9np tNnau Iinlu ' fl'lIn1PH+ ,. ~+ 111 thu uvula tlroru nru nuy Inn~nr lii'oldulna 11n1t tluvule 1 wllh ulllwr'nf Illu uhlltlrun prior to tliu hunriny a1+t fttrll- nhtrvu, luynl ununau~ fnr A-u pnrtiua mnyy . anllnut thu uualndy (:nllullininr diruully In auhutilllu n tuluphnnu annfurunuu unll nntl tliu ('nnuilblinr piny ruunnunuud nn Ardor to thv Cmu'1 to unnliq' tUu uzlatinq Hllnnllnu ml uuahuly+ ~~ q, I~or~uzullnuyo sir uualndy,,tllu'purllua aludl uhvnya uxulnulµu ullatntly iil iNu Flyhlg d ruatnurunt ml II•nulu 1.1. ' '' 11Y'I911C COUI('1', ,, Cut ul not 1'IIIXIcur, bequp'u ~~ s (u A,'1'onlun, ICNquh'o a ~` , ' ~~ . , ;, ~. ,. ., ,; „ ~~ }. ,, ,,;, „ . ,..., y'1'IuP11AN11u A, HtlRPI';Il ('1'I~I~~til+l~llh I IN'191U: Gpllli'1' t)1'' GOMMAN NIdCAy Al'' ' 1'hlinllff I ~'UMIIICRI+ANp CpUN'1'V, DIaNNtiV1,Y~Nl~! ~' v I NQ+')')'~ 1118G CIYII, A~'•'I'1ON ~ I,AW .~ I , dO~ll~l'11'1'lil':51i1,141~, I IN CUS9'AIIV 1)pfunllnnt I ' 1'rinr dul~gpl Thu Ilnnllrnhlp.l, Wuxluy Alor,,Ir, ,. CONCII.IA'170N CONI~ICItP:NCIu S111M(~1AIiV ItICI'OItT IN ACGpttl)ANGI~ WITIi ~'I'11I+. CUMI)ICRI,ANp CpUN'1'Y cIV1l,, ItU1.l; gl~ PItQCICPURI~~ 191£++3~t1(h), thu undpralµned Caxtmly Cmwignlm' xllhlllilx 111P fnI1lNYillg , rulnu'll ,. , 1, 'flip purtlnonl infnrpuginn porhlhling to Illu uldhb'un who Ih'o tlw aul-Jupt `i1P thln IlUgnliml ix na fnQowxl' ' Mnriuh Kyylop'I'ruxxlor,born I)uoomhur 27,19'1A ~ ,Anlllnln Nnpnlhnn, horn Au~uxt 211, 2(1111 ' . ~ ~ ~ .. ~~ 1+ 2, A Conulllalinn u/mforpnou wnx hull on Juno Iq, 211nci wllh lhu fnllnwhlg indlvillunlx hl ' I111u111111I1CO1 ;' ~ ~ . ,, '1'ho Molliar linrpor hxqulro Sluplnnllu A with bur oouuxuh Rachnul 1'h-xkor ~ ` ~ , , , 'i'ho I~~I1111C1', +IIIxUllll'I'1'gxl(ICI'i N'IIII hix OIIIIIIxUI, LCxllp'1.11111011, I$N(llllro ' "' ' ' , .3~ ~I'h6 pnrllox uro ltofnl'p 1110 C1111UIIIIII111' 1111 11 V111'IUIy of ixxllox~ Sinoo 211111, 1ho Mntllpr ~, ~~ i; ~ hod prhualy Ilbyxlenl ouxtody uf. Marluh, In 8uitomhor' of 2111131 Molhor Ilolivpred '~ , -' prlnuuy pbyxlunl wlxtody of Mnriuh to Ihu Ihliho-' }Nut Milo o1lJoyod xnmo pprlnllx Ilf , ' ' i <<; ' lanpnrnly oux(ndy on iho woolcoudx, I~albor lx now xugguxtlnl{ tlult Murhlh daax nnl .ti, ' ,; ~ wont lu t;a to vlHif hor Molhor and Ihul Iho Molhor ntuy huvo boon nl-nxivp lp tho aldld ~, ,.~ ' ' '',' ;"`. it tllo pnNl, AI Ihu conulllallnn ounPoronuo, tha P'nlhor did not Nuggoxt gnylbhlg ,, ~ + '~'• dramntiu to (ho Caulalllglar rulnllvo U- ullupnllonx of uliilxo or prior nlixbandling bf Ilro ~, ~ '''', ohild by iho M1lthur, '1'ho Cunollhllnr ix inglroxxod with tllC foot tbnt tho Mnihor was prinwry ouxlodhul of tl-p oblld.,for ovol' four yohrx and hntbor hnx boon prlnlaly ' ' t;' ouxlodhul of tho eblld fnl' upproxhnnloly nhlo numthx, ani Ibo ConuillnUN' Ix oat cooing „ '~ `r• ~ unj~ xpociflu roaxon wIW xnpurvlsod vlsltatinlt IIUUdx (11 (IC (11'11U1'Ud~ Ilowovor, raUloN'e ~ ' ~ ° ~+ ' p11NI1I111) IN (hilt IIC N'lII IIIII tlgrCC NII 11 110111'I11µ 11111x( IIU Nl`hl'd111Ud Inl (hilt Ixxno~ " ~~ ~`~ ,~~2 ' +1 _ , I ~: .. 7 .., - ~ - ~ ~, ifi nq; l(! i, ~ .. _. .. . 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PIdI(IrP11 to vielt wllh fIIPh' pI1rP111H IR n rOgen1111hIP aPlthlµ gpI-~PPt In IPKIII PnNI1gPi_fnr „ tI1P (1111:PIItq hllYhlµ the nllhhy 111 PQIIhIP1 (IIV G'(IpP11I111111' YIII 11 I111QIIP'P1111fo1'PIIPP Iil IIIP ' ,, oYPlll lI1PrP (11'P Rlly IHNIIPB lhnt 1111cP (1111VV hPIWPPI) 11111V 1111(1 IIIP 1iI11P Ilf lhD IIPIII'lily, , h, '1'hP C~InPlllutm' rvumnmPn(Iq nn Ar(lur Irl IhP tbrnl nq n1lnPllu(1, ,. . , ,. ,. ~_ ~ntol dllllu,~~ 211(!6 ,. ' Iluhurl ~ ~111rny,1+, uir'-,,, rngtn(ly CunPltint(' . ,. I~, • ~~ iii, ~. ~. ~ - f ~~I .. .. ,. ' II, ~. , ., 11 '- 1 i 1 1 I i ~1 '1 '~.r'- :, _• .. - ,i ~ .. ~, ,, sTFIaHANI~ 11ARP~R (TRPsa!-FR>, ; IN ThIP couRT of of?MMoN PI-~A9 .. Plain tlff „ ~ ~ ouMpFR1-ANP oouNTY~ ,, PPNNflYL.VANIA v, , No, oorlptit3 olVlh TERM .. ~oaPPH TRpast.CR, olVll. AoTIoN • t•AW , pefpndant , I puaTopY AFFIpAVIT Op MAIL BHRVI~ -. I. Rachel Haynos Pineker, Pequire~ herphy ~ertliy4hat on 6aptamuer 2t3, 2008; I Aalved a true and oorroat Dopy of the ou~(ody Memorandum In-the aiaove~aaptlonod auetody aotlon upon pefendant's attol'ney vla fll'st-olpas mall Wand f~aalmlle as~falloWal haelle Tamao,. GegUlra ,. Rominpar & Whore 1G6 south Hanover street oarllsle, PA 17013 (717) 2~1-ot37t3, y •~ ,. ._. aahol Hayllaa ('Ineke B gUir~ 11A Walnut atreot, 2n,i Floor •• Harrleburq, hA 17101 (717) 72A-0614,:. Attorney I,p,#o3o30 ~~ ~ - Attorney for Pl~Intlff/Roepondent pate; 8eptemk~er 2©._2003 , ,, ,,. ,........_ , ,, .,-.r.~,,r.._...., , , , .. ,, ,, ,. ,, ' _ ; ,. ,. ,, ,: ,;. ,, ,, !_ ; „ ,i ~ ~ ;. ~ . ~,; ~. :. ~ ,. , ,~ ,, ~ , ,. ,.. s: ,~ , . ~, ~fi~ ~: `; t~~l ~s gal ~ 1 x it ,i , ~ t~ ~ ,'; !r 5 1 ~ „ ~ i y , ~ ~ ~~ l ; .f. ~ ~ ' ~. wit ~a Ir))~ n i t ~~ ~ ~l rt41 •1 r yr !} ;~ ,.. - { ~ dl ~ ~i FP E ate e , ~ ! i f 1 ~~~ .. ~i l ~§j g~yi "t ~ ... " ~. ' ~ ,. ., ' ' ,. i ( r}}tlttYhC.Y rid f~`iZ4~{~(. - ~ n .. ~ I ~ i~ tf+/ ~ 1~3 I~ ~~ V ~. r ! ~ p ~ jS Y~ i~ - .. .. ~~ ~ 1 ) ~ -.q ~. 1 ~. _ f~:[ ]f;~ ., 1~ i. .. b !,i ~ ! I ~~ 4i 't~j. ~~ ~t Na. 1~q9- a~~ ~'yl~KyS vs, ~r~ssle,~ ~~or ~D ~y_,~7-a?~U(~i ~y; ~ vtio7~" S CG-h ~ «l . STEPHANIE A. HARPER (TRESSLER), : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 99-1086 CIVIL TERM JOSEPH TRESSLER Defendant : IN CUSTODY EMERGENCY PETITION FOR SPECIAL RELIEF NOW COMES, Leslie A. Tomeo, Esquire, for Petitioner, Mr. Joseph Tressler, and in support of this Emergency Petition for Special Relief avers as follows: 1. Your Petitioner is Joseph Tressler, who resides at 127 CME, Newville, Pa. 17241. 2. Respondent/Plaintiff is Stephanie Harper who resides at 149 Wilson Street, Apartment 106, Middletown, Pa 17057. 3. Respondent, through counsel, Johnna J. Kopecky, filed the above docketed Custody action regarding Mariah K. Tressler in the Cumberland County Court of Common Pleas. 4. On or about February 8, 2001 Respondent/Plaintiffand Petitioner attended a Custody Conciliation with Hubert X. Gilroy, Esquire as the Custody Conciliator. 5. As a result of the Custody Conciliation an Order of court was entered on or about February 14, 2001 by the Honorable Judge Oler. (Order attached as Exhibit "A") 6. The February 14, 2001 Custody Order granted, RespondentJPlaintiff primary, physical custody of the minor child, Mariah Kaylee Tressler. 7. On or about September 12, 2005, Respondent/Plaintiff and Petitioner signed a document, stating that, "Mariah K. Tressler will reside with father and attend Newville, Elementary School for three months." The document also, stated that the "parties will continue to be on a three month trial basis until both parties mutually agree that child is succeeding in the school and counseling." (Document attached as Exhibit `B") 8. On or about March 25, 2006, Respondent/Plaintiff and Petitioner signed a document, stating that, "Mariah K. Tressler will continue to reside with father... based on the interest of the child." (Document attached as Exhibit "C") 9. Respondent(Plaintiff has indicated that she is planning to exercise the original order of February 14, 2001, where mother has primary, physical custody of Mariah K. Tressler. 10. Petitioner feels the mother mentally, and in the past, physically abuses the minor child, Mariah K. Tressler, while in her custody. 11. Petitioner feels the child, Mariah K. Tressler, is in an unstable environment, while residing with RespondentlPlaintiff, due to the fact; Respondent has moved minor child to five different homes and changed school districts five times in five years. 12. The Minor child, Mariah K. Tressler has indicated to the Petitioner she wishes to live with Petitioner. 13. Petitioner, and Respondent have another child, Antonio Napolitan, date of birth August 20, 2001, which Petitioner signed an acknowledgement of paternity for this minor child and undersigned counsel has filed an Amended Complaint to add to this docket. 14. Petitioner believes and therefore avers that the minor, Antonio Napolitan is also residing in an unstable environment. WHEREFORE, Your Petitioner respectfully requests that this Honorable Court, grant a temporary order granting primary physical custody of the children to the father pending the scheduling of a hearing on the matters alleged herein. COUNT II AMENDED CUSTODY COMPLAINT 15. Your Petitioner is Joseph Tressler, who resides at 127 CME, Newville, Pa. 17241. 1 b. Defendant is Stephanie Harper who resides at 149 Wilson Street, Apartment 106, Middletown, Pa 17057. 17. Defendant seeks Primary custody of the following children: Name Present Residence Age Mariah K. Tressler 127 CME 11 years old Newville, Pa 17241 Antonio Napolitan 149 Wilson Street, Apt. 106 4 yeazs old Middletown, Pa 17057 The child was not born out of wedlock. 18. The child is presently in the custody of Stephanie Harper who resides at 149 Wilson Street, Apartment 106, Middletown, Pa 17057. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Mariah K. Tressler 183 CME July 2000 to March 2001 Stephanie Harper Newville, Pa 17241 Antonio Napolitan Ritner Highway 2001 to 20002 Mariah K. Tressler Carlisle. Pa 17013 Stephanie Harper Antonio Napolitan 108 Kelso Road 2002- 2003 Mariah K. Tressler Shippensburg, Pa 17257 Stephanie Harper Antonio Napolitan 126 Townhouse 2003-2004 Mariah K. Tressler Briar Crest No. 2 Stephanie Harper Hershey, Pa Antonio Napolitan 149 Wilson Street, Apt. 106 2004 to present Stephanie Harper Middletown, Pa 17057 Mariah K. Tressler 149 Wilson Street, Apt. 106 2001 to Sept. 2005 Stephanie Harper Middletown, Pa 17057 Mariah K. Tressler 127 CME Sept. 2005 to present Joseph Tressler Newville, Pa 17241 19. The mother of the child is Stephanie Harper who resides at 149 Wilson Street, Apartment 106, Middletown, Pa 17057. She is married. The father of the children is Joseph Tressler, who resides at 127 CME, Newville, Pa. 17241. He is married. 20. The relationship of defendant to the children is that of Father. The defendant currently resides with the following persons: Name Relationship Melissa Tressler Wife Mariah & Cailey Daughters Tressler Tyler & Matthew Step-sons Carder 21. The relationship of plaintiff to the children is that of Mother. The Plaintiff currently resides with the following persons; Name Relationship Corey unknown Boyfriend Antonio Napolitan Child 22. Petitioner has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Petitioner has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. Petitioner does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the child. 23. Reasons for granting relief: Petitioner is best able to provide the care and nurture which the children needs for healthy development. Court ordered determination of custody is required to avoid continuing conflict between the parties regarding parental responsibility for custody. 24. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. Al] other persons, named below, who are known to have or claim a right to custody or visitation of the children will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim None WHEREFORE, petitioner requests the court grant primary custody of the children. COUNT III MODIFY CUSTODY 25. Your Petitioner is Joseph Tressler, who resides at 127 CME, Newville, Pa. 17241. 26. Respondent/Plaintiff is Stephanie Harper who resides at 149 Wilson Street, Apartment 106, Middletown, Pa 17057. 27. On February 8, 2001, the Honorable Edward Judge Oler entered the Custody Order attached as Exhibit "A". 28. Since the entry of said Order, there has been a significant change in circumstances in that: a. The minor child, Mariah K. Tressler has been residing with her father since, September 2005. b. The minor child, Mariah K. Tressler has expressed she wants to reside with her father. b. The Petitioner has not been allowed to see his son, Antonio Napolitan since birth. c. Petitioner is best able to provide a stable household for the children. 29. The best interest of the child will be served by the Court in modifying said Order. Date: 7 ~ U 6 Respectfully submitted, ROMINGER & WHARE, ~; ~~ ,I'e~A. Tomeo, Esquire 155South Hadover Street Carlisle, PA 17013 (717)241-6070 Supreme Court ID # 200198 Attorney for Defendant STEPHANIE A. HARPER (TRESSLER), Plaintiff v. JOSEPH TRESSLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-1086 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE I, Leslie A. Tomeo, Esquire, attorney for Joseph Tressler, do hereby certify that I this day served a copy of this Emergency Petition for Special Relief upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Stephanie Harper 149 Wilson Street Apt. 106 Middletown, PA 17057 j' ; " Dated: Apri127, 2006 ~~~ ~-o es 'e A. T eo, Esquire Attorney f Defendant VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Joseph Tressler, Plaintiff e ~~ ~. CX hi~i ~ ~ rk;B~.~200f~ STEPHANIE A. TRESSLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION -LAW JOSEPH L. TRESSLER, NO. 99- 1086 CIVIL Defendant IN CUSTODY COURT ORDER ~ ~ ~ daV Cf Fenni3ni, ~QQ1 nnpn rnnSidP.r2?!OP. Of the °~ach°•~ C!'~tCL~y ANC. NOR, this ~__ -, r ••- Conciliation Report, it is ordered and directed that this Court's prior Order for custody entered on Mazch 8, 1999 at the above term and ntunber is vacated and replaced with the following Order: 1. The Mother, Stephanie A. Tressler, and the Father, Joseph L. Tressler, shall enjoy shared legal custody of Mariah Kaylee Tressler, bom December 27, 1994. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy partial physical custody of the minor child on the first three weekends of each month, the time being from Friday at 9:00 a.m. until Sunday at 4:00 p.m. For exchange of custody, Mother shall deliver the child to Saylor's Mazket ai the beginning of the weekend for Father to take custody of the child on Friday at 9:00 a.m. and Father shall delivec the child to Mother's pazent's home on Sunday between 4:00 and 4:15 p.m. 4. Father shall enjoy custody of the minor child on holidays to include Easter, Memorial Day, July 4'", Labor Day and Christmas Eve from 6:00 p.m. on Christmas Eve through 6:00 p.m. on Christmas Day. 5. Father shall have the right to have custody with the minor child on the child's birthday at a time to be agreed upon by the parties. 6. Father shall enjoy one week of visitation with the minor child during the summer with Father giving at least two weeks notice. 7. Both parties shall enjoy reasonable telephone contact with the minor child when the child is in the other pazent's custody. 8. Both pazents shall notify file other parent with respect to emergency medical situations that arise when the child is in that parent's caze. _,~ ~~ t {~ l ~ t ' 9. Neither parent shall do anything that 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 and respect for the other parent. 0. The parties may modify this Order as they agree. Absent an agreement between the parties, this Order shall control. 11. This Order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. In the event either party desires to modify this Order, that party may petition the court [o have the case again scheduled with the Custody Conciliator. BY THE COURT, ~-~ , J. J. Wesley O r, Jr. cc: Thomas J. Williams, Esquire Johnna J. Kopecky, Esquire 7R~Js ~~~Y FR'rJfvl RECO~,fland In Testimcm~ v:h_reef, I here unto set m/ and t e seal os said urt at Carlisle, Pa. Thi ~~... a o . ~~°.~.~....., ..~. ..r. pr thonotary STEPHANIE A. TRESSLER, Plaintiff v JOSEPH L. TRESSLER, Defendant Prior Judge: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.99- 1086 CNIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE W[TH THE CUMBERLAND COUNTY CNIL RULE OF PROCEDURE 1915.3-8(b), the undersigned C:!stody Cer:ci!ia;~r su~^.las $.e fol!ewatg repo:': 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Mariah Kaylee Tressler, bom December 27, 1994. 2. A Conciliation Conference was held on Febn~ary 8, 2001, with the following individuals in attendance: The Mother, Stephanie A. Tressler, with her counsel, Thomas J. Williams, Esquire; and the Father, Joseph L. Tressler, with his counsel, Johnna J. Kopecky, Esquire. 3. The parties agree to the entry of an order in the form as attached. o~ ~ DA E Hubert X. Gilroy, Es re Custody Conciliator ~~~ ~ n~~C ~~~~~ ~~~~~-~~~~~x~ ~c~~-~~> i `~ (~ ~2~~e~ A. 1-~.~~~ ~ ~ n> %~-~~~- ~3 i4~ ~ r~41~ ~> ~~ 11~ C~~ ~~.+--ham C~.r.~z ~~.~~r: ~~ ~~ ~ r~ ~-~t ~~~ .,~ , 1, a '(~Ylnr (I ~ ~ , ~ Y'~. ~h~a'L ~1~~t,~Yr1~n~L i~-'1~ ~-~' ~'~.ti ~~~ a i ~ ` _al ~~ ~:1~ ~ (~x~,C~~. rr~~' --~-~"1'~. ~(1U(-I -}~'_~i1~?~ rat (~-~~~~~; . I ~ ~~ ~_. ~~;-tt-~~tl hCZ°_~;~~ ~,r~-hl ~-:,111 ~:t~-I ~u~;~ ~`1 ~~__~i~. i<<' i ~~ . '~hi~~ ~~ ~~~ L. ~~~~ J~-~~ L I r~~~lE~r ~' t Y~u~ L ~~~~ ...~~~ ~ 1 ~nll~, ~t'r~'~~ ~~~_ C~Z A N~~P°r ~`c~3~~~ C~~ ~~ ~~~~ ~+~~- ~"~ ~~ Z~ ~`` n1~ ~,~1 r ~S~ ~~` ~-~- r--. ~ ~... r` 1 ty a?~ ~. ~_~ !~ ~' ~"C~' ~ STEPHANIE A. HARPER (TRESSLER), Plaintiff v. JOSEPH TRESSLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.99-1086 CIVIL TERM ORDER OF COURT AND NOW, this 4~' day of May, 2006, upon consideration of Defendant's Emergency Petition for Special Relief, this matter is referred to the custody conciliation process pursuant to C.C.R.P. 1915.12-1, and the Court Administrator is requested to facilitate this referral. hanie A. Harper 149 Wilson Street Apartment 106 Middletown, PA 17057 Plaintiff, pro Se Leslie A. Tomeo, Esq. South Hanover Street Carlisle, PA 17013 Attorney for Defendant BY THE COURT, "fib 0 J Court Administrator's Office -._.1j~,r~l G'~-~ sis/~~ :rc ~Y~bn~~~~t~ £ I ~Z Wd ~- A~tN 9002 ~~~I~ STEPHANIE A. HARPER (TRESSLER) IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V• 99-1086 CIVIL ACTION LAW JOSEPH TRESSLER IN CUSTODY DF.,FF.,NDANT ORDER OF COURT AND NOW, Tuesday, May 09, 2006 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel. appear before Hubert X. Gilroy, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, June 16, 2006 at 8:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR. THE COURT, By: /s/ Hubert X. Gilroy, Esq_~,/~_ Custody Conciliator F_. ~ The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1.990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. Ail arrangements must be made at least 721iours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~IIP~~"i4 iA~i1~P~d hl.11!!~ ~:~'~~ ~~ `~ ~~~!13 ~~ ~£ ~~ 0 ! d~~ 900Z A~.t71v(;;~.~~~ ?Hl ~~J ~{~~~~ ,iUN 2 ~~ 206 ~--- STEPHANIE A. HARPER (TRESSLER), IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v N0.99 -1086 CIVIL ACTION -LAW JOSEPH TRESSLER, IN CUSTODY Defendant COURT ORDER AND NOW, this --~~a-Lh- day of June, 2006, upon consideration of the attached Custody Conciliation Report, the following Order is entered: 1. A hearing is scheduled in Courtroom No. 1 of the Cumberland County Courthouse on the ~ day of O~C=Ce-(,u+.c~ 2006 at /; 30 ~. m. At this hearing, the Father shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth the history of custody in this case, the issues currently before the Court, a list of witnesses who will be called to testify on behalf of each party and a summary of anticipated testimony of each witness. This Memorandum shall be fled at least five (5) days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's prior custody Order of February 14, 2001 is vacated and replaced with the following TEMPORARY Order: A. The Father, Joseph Tressler, and the Mother, Stephanie A. Harper, shall enjoy shared legal custody of Mariah ICaylee Tressler, born December 27, 1991 and Antonio Napolitan, born August 20, 2001. B. The Father shall enjoy primary physical custody of Mariah and the Mother shall enjoy primary physical custody of Antonio. C. Mother shall enjoy temporary custody with Mariah on alternating weekends from Friday at 5:00 p.m. until Sunday at 6:00 p.m. This custody time will start the weekend after Father returns from vacation. The parties may modify the pick-up and delivery times if they agree. Exchange of custody shall be handled with the parties sharing transportation and the parties may agree to meet equal distance. a. L_ .__ ~-, N LL Q7 Cis ~~~ CL~.J ~: ~ i r» CJ D. On the weekend that Mariah stays with Dad, Dad shall Gave temporary custody with Antonio on Saturday from 4:00 a.m, unti15:00 p.m. Exchange of custody for transportation shall be the same as set forth above. It is understood that Mariah will be with Dad and Antonio during those time frames. 3. In the event there are any major problems that develop with either of the children prior to the hearing set forth above, legal counsel for the parties may contact the custody Conciliator directly to schedule a telephone conference call and the Conciliator may recommend an Order to the Court to modify the existing situation on custody. 4. For exchange of custody, the parties shall always exchange custody at the Flying J restaurant on Route 11. Cc: l Pinsker, Esquire slie A. Tomeo, Esquire ~@i?lam'/~~ J w AGO 0~ BY THE COURT, STEPHANIE A. HARPER (TRESSLER), : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v N0.99 -1086 CIVIL ACTION -LAW JOSEPH TRESSLER, IN CUSTODY Defendant Prior Judge: The Honorable J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Mariah Kaylee Tressler, born December 27,1994 Antonio Napolitan, born August 20, 2001 2. A Conciliation conference was held on June 14, 2006 with the following individuals in attendance: The Mother, Stephanie A. Harper, with her counsel, Rachael Pinsker, Esquire The Father, Joseph Tressler, with his counsel, Leslie Tomeo, Esquire 3. The parties are before the Conciliator on a variety of issues. Since 2001, the Mother bad primary physical custody of Mariah. In September of 2005, Mother delivered primary physical custody of Mariah to the Father and she enjoyed some periods of temporary custody on the weekends. Father is now suggesting that Mariah does not want to go to visit her Mother and that the Mother may have been abusive to the child in the past. At the conciliation conference, the Father did not suggest anything dramatic to the Conciliator relative to allegations of abuse or prior mishandling of the child by the Mother. The Conciliator is impressed with the fact that the Mother was primary custodian of the child for over four years and Father has been primary custodian of the child for approximately nine months, and the Conciliator is not seeing any specif-c reason why supervised visitation needs to be ordered. However, Father's position is that he will not agree so a hearing must be scheduled on that issue. 4. Father is seeking a period of time with the minor child Antonio. Father bas not had any custody with that child since the child was born. Mother suggests that Father should have supervised visitation with Antonio because be has not seen the child. The Conciliator is impressed with the fact that the Father is able to take care of Mariah and the Mother does not disagree with Father having primary custody of Mariah, but the Mother still suggests that there should be some supervised visitation with Antonio. 5. A hearing is required on all issues because the parties can't agree. However, the Conciliator strongly feels that an interim Order should be put in place to allow the children to visit with their parents in a reasonable setting subject to legal counsel for the parents having the ability to contact the Conciliator via a phone conference ie the event there are any issues that take place between now and the date of the hearing. 6. The Conciliator recommends an Order is the form as attached. Date: June ~, 2006 Hubert . Gilroy, E uire Custody Conciliat STEPHANIE HARPER (TRESSLER), : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 99-1086 CIVIL TERM JOSEPH TRESSLER, :CIVIL ACTION -LAW Defendant :CUSTODY AFFIDAVIT OF MAIL SERVICE I, Rachel Haynes Pinsker, Esquire, hereby certify that on September 28, 2006, I served a true and correct copy of the Custody Memorandum in the above-captioned custody action upon Defendant's attorney via first-class mail and facsimile as follows: Leslie Tomeo, Esquire Rominger & Whare 155 South Hanover Street Carlisle, PA 17013 (717) 241-6878 Date: September 28, 2006 114 Walnut Street, 2"d Floor Harrisburg, PA 17101 (717) 724-0516 Attorney I.D.#83930 Attorney for Plaintiff/Respondent ~~'' `•~ C is = rr ' u -- ~~ ;~~r+stt CX3 -L~~ ~~_ c`; " , STEPHANIE A. HARPER IN THE COURT OF COMMON PLEAS OF (TRESSLER), CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v JOSEPH TRESSLER, Defendant CIVIL ACTION - LAW N0. 99-1086 CIVIL TERM IN CUSTODY IN RE: REQUEST FOR MODIFICATION OF CUSTODY ORDER OF COURT AND NOW, this 9th day of October, 2006, upon consideration of Defendant's request for modification of custody with respect to the parties' children, Mariah Kaylee Tressler (date of birth, December 27, 1994) and Antonio Napolitan (date of birth, August 20, 2001), and the parties having agreed upon a custody order with respect to Mariah Kaylee Tressler, which has been entered of even date herewith, and an initial period of hearing having been held on this date and not having been completed with respect to Antonio Napolitan, it is ordered and directed that the record shall remain open, and a further period of hearing with respect to custody of Antonio Napolitan shall be held on Thursday, January 11, 2007, commencing at 1:30 p.m. The Court will enter a temporary order with respect to custody of Antonio Napolitan pending the further hearing in the matter. Both counsel have requested that the stenographer transcribe and file the notes of testimony from r:., ,:~~ ~~.,.~ ! ~ ; , v? r .-./. ~r today's proceeding. It is noted that at the time of adjournment on today's date neither party had completed the presentation of his and her cases-in-chief, and at the time of adjournment the Plaintiff was being subjected to direct examination by her counsel. It is noted further that as of the time of adjournment Defendant's Exhibit 1 had been identified and admitted, and Plaintiff's Exhibit 1 had been identified and admitted. No other exhibits had been identified or admitted. By the Court, ~chel Haynes Pinsker, Esquire YWCA of Greater Harrisburg Legal Center 114 Walnut Street Harrisburg, PA 17101 For Plaintiff eslie Tomeo, Esquire 155 South Hanover Street Carlisle, PA 17013 For Defendant :mae w. STEPHANIE A. HARPER (TRESSLER) , Plaintiff v JOSEPH TRESSLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0. 99-1086 CIVIL TERM IN CUSTODY IN RE: AGREEMENT OF THE PARTIES ORDER OF COURT AND NOW, this 9th day of October, 2006, upon consideration of the issue of custody with respect to the parties' child, Mariah Kaylee Tressler, born December 27, 1994, and pursuant to an agreement of the parties reached in open court with the assistance of their respective counsel, Rachel Haynes Pinsker, Esquire, on behalf of the mother, and Leslie Tomeo, Esquire, on behalf of the father, it is ordered and directed as follows: 1. The parties shall share legal custody of Mariah Kaylee Tressler. 2. Father shall have primary physical custody of Mariah Kaylee Tressler. 3. Mother shall enjoy partial. custody of Mariah Kaylee Tressler with periods of visitation as the parties shall agree. 4. The Father shall provide Mother with any and all information pertaining to any therapy or counseling services that Mariah Kaylee Tressler is receiving, }'-Tr °~~ 3\.,k,.l'ai ;' 1's ~ c" .~~1 ~s~ ~ g ,"_~~~ ~~~7 t,~1~1 - , -_~ 3i-~i specifically the name or names of any counselors or therapists for Mariah, as well as dates and times for any scheduled counseling therapy sessions. By the Court, J. esley Oler, Jr., J. ~chel Haynes Pinsker, Esquire YWCA of Greater Harrisburg Legal Center 114 Walnut Street Harrisburg, PA 17101 For Plaintiff eslie Tomeo, Esquire 155 South Hanover Street Carlisle, PA 17013 For Defendant :mae f STEPHANIE A. HARPER (TRESSLER), Plaintiff v JOSEPH TRESSLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0. 99-1086 CIVIL TERM IN CUSTODY IN RE: REQUEST FOR MODIFICATION OF CUSTODY TEMPORARY ORDER OF COURT AND NOW, this 11th day of October, 2006, upon consideration of Defendant's request for modification of custody with respect to the parties' children, Mariah Kaylee Tressler (d.o.b. December 27, 1994} and Antonio Napolitan (d.o.b. August 20, 2001), and the parties having agreed upon a custody order with respect to Mariah Kaylee Tressler, which has been entered of even date herewith, and an initial period of hearing having been held on this date, and not having been completed, with respect to Antonio Napolitan, it is ordered and directed as follows, pending a further period of hearing and further Order of Court: 1. Legal custody of the child shall be shared by the parents; 2. Primary physical custody of the child shall be in the mother; 3. Temporary or partial physical custody of the child shall be in the father, at the following times: a. During the school year, ~~,~ . _ ' S~r'~ i i ast .. ~'t1~11 ~ -1 x;-11 ~~, -~... 1. On alternating weekends, from Friday at 7:00 p.m. until Sunday at 7:00 p.m.; 2. On Thanksgiving Day, from 2:00 p.m. until 7:00 p.m.; 3. During Christmas vacation, from December 25 at 2:00 p.m. until 7:00 p.m. on December 30, 2006; b. During the summer, for alternating two-week periods. 4. Exchanges of custody shal_1 take place at the Flying J. Restaurant on Route 11. By the Court, ~chel Haynes Pinsker, Esquire YWCA of Greater Harrisburg Legal Center 114 Walnut Street Harrisburg, PA 17101 For Plaintiff ~slie Tomeo, Esquire J 155 South Hanover Street Carlisle, PA 17013 For Defendant :mae STEPHANIE A. HARPER (TRESSLER), Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.99-1086 CIVIL TERM JOSEPH TRESSLER Defendant IN CUSTODY PRAECIPE TO CANCEL CUSTODY HEARING Please cancel the custody hearing scheduled for January 11, 2007 for the above-captioned matter. The parties are in the process of resolving this matter amongst themselves amicably, and the scheduled hearing is no longer necessary. Date: January 3, 2007 Respectfully submitted, ROIV)<INGER & WHARF L~`lie A. Tome Esquire 155 South Hano er Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 200198 Attorney for Defendant G Q ~~-'- ~ ~_` ~ i. ~" G ~" ..,.- STEPHANIE A. HARPER, (TRES SLER), Plaintiff v. JOSEPH TRESSLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 99-1086 CIVIL TERM ORDER OF COURT AND NOW, this 9`'' day of January, 2007, upon agreement of counsel, that a settlement is being reached in the above matter, the hearing previously scheduled for January 11, 2007, is CONTINUED GENERALLY. Counsel are requested to contact the Court if a hearing is desired in this matter or when a settlement is reached. BY THE COURT, ~chel Haynes Pinsker, Esq. YWCA of Greater Harrisburg Legal Center 114 Walnut Street Harrisburg, PA 17101 Attorney for Plaintiff ~eslie Tomeo, Esq. 155 South Hanover Street Carlisle, PA 17013 Attorney for Defendant rc 1 ~ ~ : ~ ~~~ o ~ ~3~r t~~~ -+nr~~ ~s~~t~ a.J~~~_ ,~"ar • ~ STEPHANIE A. HARPER IN THE COURT OF COMMON PLEAS OF (TRESSLER), CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . v CIVIL ACTION - LAW NO. 99-1086 CIVIL TERM JOSEPH TRESSLER, Defendant IN CUSTODY IN RE: TRANSCRIPT OF PROCEEDINGS Proceedings held before the HONORABLE J. Wesley Oler, Jr., J., Cumberland County Courthouse, Carlisle, Pennsylvania, on October 9, 2006, in Courtroom Number One. APPEARANCES: Rachel Haynes Pinsker, Esquire YWCA of Greater Farrisburg Legal Center 114 Walnut Street Harrisburg, PA 17101 For Plaintiff Leslie Tomeo, Esquire 155 South Hanover Street Carlisle, PA 17013 For Defendant ;a ~„ n t +,~ t ~~ ~~~ ~ r~~ ;rte{:,rti"~(a (~~} .- 1 i 1 ~;iC'~~~~' ; (' ' "Hl ~0 • • INDEX TO WITNESSES FOR THE PLAINTIFF Alisha Flemister Cynthia Keller Joan Martin Stephanie Harper FOR THE DEFENDANT DIRECT CROSS REDIRECT RECROSS 64 71 73,75 74 76 83 85 87 88 94 -- __ 96 Joseph Tressler h 13 29 30 Melissa Tressler 33 37 -- -- Sharon Napolitan 43 46 -- -- Stacy Napolitan 52 56 -- -- 2 t • INDEX 'I'0 EXHIBITS FOR THE PLAINTIFF MARKED ADMITTED Ex. No. 1 - photographs 112 115 FOR THE DEFENDANT Ex. No. 1 - photographs 10, 11 63 3 • 1 THE COURT: This is the time and place for a 2_ hearing in the custody matter of Stephanie A. Harper 3 (Tressler) versus Joseph Tressler at No. 99-1086 Civil Term. 4 The subjects of this proceeding are the parties' children, 5 Mariah Kaylee Tressler, who's date of birth is December 27, 6 1994, and Antonio Napolitan, who's date of birth is August 7 20, 2001. 8 We will let the record indicate that the 9 Plaintiff, Stephanie A. Harper (Tressler), is present with 10 her counsel, Rachel Pinsker, Esquire, and the Defendant, 11 Joseph Tressler, is present with his counsel, Leslie Tomeo, 12 Esquire. The matter is before the Court on the father's 13 request for custody with respect to these -- primary custody 14 with respect to these children. The Court understands that 15 the parties have reached an agreement with respect to the 16 custody of Mariah Kaylee Tressler, and I can begin the order 17 if one of the counsel will dictate trre conclusion of it. 18 AND NOW, this 9th day of October, 2006, upon 19 consideration of the issue of custody with respect to the 20 parties' child, Mariah Kaylee Tressler, born December 27, 21 1994, and pursuant to an agreement of the parties reached in 22 open court with the assistance of their respective counsel, 23 Rachel Haynes Pinsker, Esquire, on bet-calf of the mother, and 24 Leslie Tomeo, Esquire, on behalf of the father, it is 25 ordered and directed as follows: 4 • ~ 1 1. The parties shall share legal custody of 2 Mariah Kaylee Tressler. 3 2. Father shall have primary physical 4 custody of Mariah Kaylee Tressler. 5 3. Mother shall enjoy partial custody of 6 Mariah Kaylee Tressler with periods of visitation as the 7 parties shall agree. 8 4. The Father shall provide Mother with any 9 and all information pertaining to any therapy or counseling _10 services that Mariah Kaylee Tressler is receiving, 11 specifically the name or names of any counselors or 12 therapists for_ Mariah, as well as dates and times for any 13 scheduled counseling therapy sessions. 14 (End of order.) 15 THE COURT: All right. Ms. Tomeo, is that 16 order satisfactory to you and to your client? 17 MS. TOMEO: Yes, Your Honor. 18 THE COURT: And, Ms. Pinsker, is it 19 satisfactory to you and to your client? 20 MS. PINSKER: It is, Your Honor. 2.1 THE COURT: All right. That leaves the issue 22 of custody of Antonio Napolitan, and father's the moving 23 party. Ms. Tomeo. 24 MS. TOMEO: I would like to call Joseph 25 Tressler. 5 • • 1 Whereupon, 2 JOSEPH TRESSLER 3 havin g been duly sworn, testified as follows: 4 DIRECT EXAMINATION 5 BY MS. TOMEO: 6 Q Please state your name and address. 7 A Joseph Tressler, 127 CME, Newville. 8 Q And what is your relationship to Antonio? 9 A Father. 10 Q Are you employed, Mr. Tressler? 11 A Yes, I am. 12 Q Where are you employed? 13 A Excuse me? 14 Q Where are you employed? 15 A Roadway Express. 16 Q And how many persons are living in your 17 household at this time? 18 A Five -- six. I'm sorry, six. 19 Q Can you please tell us who they are? 20 A Myself, my wife Melissa, stepsons Tyler and 21 Matthew, daughters Mariah and Kaylee. 22 Q What is the current arrangement with Antonio, 23 the current c ustody arrangement with Antonio? 24 THE COURT: I'm sorry. Could you speak up 25 just a little bit, please? 6 • • 1 BY MS. TOMEO: 2 Q I'm sorry. What's the current custody 3 arrangement wi th Antonio? 4 A Every other weekend from 5:00 Friday until 5 6:00 Sunday. 6 Q And how long has that been in effect? ~ A Since August 10th. 8 Q Prior_ to August 10th -- 9 THE COURT: August 10th of what year? 10 THE WITNESS: 2006. 11 THE COCJRT : Thank you . 12 BY MS. TOMEO: 13 Q Prior to August 10th of_ 2006, did you have 14 any contact with Antonio? 15 A No, I did not. 16 Q And why is that? 17 A When Mariah would come over to visit, I was 18 told that he was not my son. So I didn't push the issue. 19 Q Can you clarify that a little bit? When 20 Mariah carne over to visit, you were ta1_king about -- 21 visitation was initially -- you only had visitation of 22 Mariah initially? 23 A Yes, and that was the first three weekends of 24 every month. 25 Q And who stated that he was not your son? 7 C7 1 A His Mother. 2 Q And you never pursued that issue anymore? 3 A No. 4 Q When did you come to find out he was your 5 son? 6 A Excuse me? ~ Q Wheri did you come to f irld out that he was 8 your son? 9 A I have always paid support for Tony since the 10 day he was born -- or I'm sorry, since the Domestic 11 Relation s Off ice. That would have been about September of 12 2001. 13 Q Okay. When did you begin to seek custody of 14 Antonio? Do you recall? 15 A About July -- or no, June of this year. 16 Q And why was that`? 17 A Well, he's my son, and I should get to see 18 him. I found out that there was abuse in the house. 19 Q That's why you're seeking primary custody of 20 Antonio? 21 A Yes, it is. 2?_ Q Do you currently suffer from any kind of 23 physical or mental problems that would prevent you from 24 being an adeq uate caretaker of Antonio'? 25 A No, I do not. 8 • • 1 Q Okay. What kind of activities do you pursue 2 with Antonio when you exercise your custody on weekends? 3 A Tony goes, just like t}ie rest of the kids, 4 outside. He rides his bike. You know, anything that is 5 outside during the summer. 6 Q Do you have enough room in your household for 7 Antonio? 8 A Yes, I do. 9 Q He wolzld be able to have his own bed? 10 A Yes. 11 Q And why do you feel it would be in Antonio's 12 best interests to reside with you as his primary caretaker? 13 A He needs love and the nurturing, and he is 14 not getting that with his mother. I can prove that. 15 Q What is hi_s relationship like with his 16 sister, Mariah? 17 A Excellent. He's all over her when he's over 18 on the weeken ds. I9 Q They're close? 20 A Yes, they are. 21 Q What is his relationship like with your other 22 children? 23 A The same. The only one he's really not used 24 to is Tyler. Tyler's the oldest step-boy, but he's with his 25 grandparents a lot on the weekends. 9 • • 1 MS. TOMEO: May I approach the witness, Your 2 Honor? 3 (Whereupon, Plaintiff's Exhibit No. 1 was 4 marked for iden tification.! 5 BY MS. TOMEO: 6 Q When was the last time Antonio was ir. your 7 custody? 8 A September 29th. 9 Q And -- 10 THE COURT: Of what year? 11 THE WITNESS: Oh, I'm sorry. 2006. 12 THE COURT: Thank you. 13 BY MS. TOMEO: 14 Q On September_ 29th of 2006, did you notice 15 anything unusua l about Antonio? 16 A Yes, I did. 11 Q And what was that? 18 A Bruises. 19 Q What kind of bruises? 2.0 A It would be bruises on his backside, on his 21 arms, and there was a small one in the middle of his back. 22 Q Did you take any pictures of these bruises? 23 A Yes, I did. 24 Q I'm now referring to Plaintiff's Exhibit 1. 25 A Excuse me? 10 • • 1 Q I said now I'm referencing Plaintiff's 2 Exhibit Number 1. 3 A Oh, I'm sorry. 4 Q Okay. 5 THE COURT: You say it's Plaintiff's Exhibit 6 1? ~ MS. TOMEO: Yes. 8 THE COURT: All right. 9 MS. TOMEO: Oh, I'm sorry. Defendant's 10 Exhibit 1. 11 (Whereupon, the item marred as Plaintiff's 12 Exhibit No. 1 was amended to be Defendant's Exhibit No. l.) 13 BY MS. TOMEO: ~-4 Q Did you take these photos of Antonio? 15 A Yes, I did. 16 Q And can you describe to the Court what these 17 pictures are? _l8 A The first one would be a bruise on the left 1-9 buttocks. There is two here -- two pictures of bruises on 2.0 the right arm around the elbow, and, let's see, two of the 21 left arm in the elbow area, and another one with a bruise in 22 the left center of the back. 23 Q How did you come to notice these bruises? 24 A At approximately 9:00 F_r_:iday evening he was 25 getting undressed to take a shower. it • • 1 Q And you noticed the bruising at that time? 2 A Yes, I did. 3 Q What, if anything, did you do at that time? 4 A At that time I asked Ylim what had happened, 5 and that was it. He got a bath and he went to bed. 6 Q Okay. Have you pursued this issue any 7 further since taking those photos? ~ A Yes, I did. I went to the Middletown Police 9 Saturday and talked to a Sergeant Ranck, who referred me to 10 Detective Sweitzer, who I contacted Monday. 11 Q And what, if anything, was the result of 12 those interactions or those conversations? 13 A Tomorrow at 2:15 Children and Youth will take 14 custody of Tony for a CRC hearing. 15 Q I guess to wrap everything up, if you could 16 just re.iter.ate why you feel that primary custody should not 1.7 remain with the Plaintiff? 18 A Pictures speak a thousand words, and Tony 19 needs love. 20 Q You don't feel that he's being cared for in a 21 satisfactory manner? 22 A No. No, he's not. You don't beat on a 23 child, and that's taking care of there. 24 Q One additional question. Have you noticed 25 12 • ~ 1 any bruising on Antonio prior to these photos of September 2 29th, 2006? 3 A Yes, I did, and I have taken -- or, I'm 4 sorry, my wife took photographs of them. August 10th there 5 was a hearing, and there was a PFA granted. 6 Q Against the Plaintiff? ~ A Yes. 8 MS. TOMEO: I have nothing further, Your 9 Honor. 10 THE COURT: A Protection from Abuse order 11 entered against the Plaintiff and in favor of whom? 12 MS. TOMEO: In favor of Mariah and Antonio. 13 THE COURT: In favor of Mariah only; is that 14 right? 15 MS. TOMEO: I believe Antonio was included in 16 that order. 1~ THE COURT: All right. 18 THE WITNESS: Yes, he was. 19 THE COURT: Ali right. 20 CROSS EXAMINATION 21 BY MS. PINSKER: 22 Q Mr. Tressler, you just testified that there 23 is a CRC hearin g tomorrow? 24 A Yes, there is. 25 Q Can you tell me what that is? 13 ~ ~ 1 A Basically the -- Detective Sweitzer, the 2_ District Attorney, Children and Youth, and these people from 3 CRC, which is the Childrens Resource Center, are going to 4 interview Tony on tape to find out where these bruises came 5 from or who did it. 6 Q At 2:15 tomorrow? ~ A Yes. 8 Q Would it surprise you to know that Children 9 and Youth has not contacted my client at all? 10 A They will tomorrow morning. 11 Q You're sure of that"? 12 A That's what Children and Youth told me. 13 Q So they're going to remove Tony from school? 14 A They are going to take custody of him for the 15 day for this hearing. 16 THE COURT: Well, it doesn't sound as if it's 17 a hearing. It's some kind of examination. 18 THE WITNESS: It's not a hearing. It's an 19 interview, is what they called it. 20 THE COURT: I see. 21 BY MS. PINSKER: 22 Q Mr. Tress7_er -- well, let me rephrase. You 23 said the most recent visit with Tony on, I believe it was 24 September 29th -- that was the start of your last weekend; 25 is tY1at correct? 14 • 1 A Yes. 2 Q You said you noticed bruising, correct? 3 A Yes. 4 Q So did it ever occur to you that that may 5 very well be from the wear and tear from an active 5 year 6 old? ~ A Actually, the bruising on the rear end, 8 maybe. The fingerprints on the arm, no. 9 Q But you don't know for a fact that they're 10 fingerprints? 11 A No. As a fact, no, I don't. 12 Q Did you contact my client to talk to her 13 about your concerns? 14 A No, I didn't. 15 Q So you just simply decided to proceed with 16 contacting the police? 17 A Yes, ma'am. 18 Q Now, it is true that there was a PFA entered 19 by Judge Oler in August of this year on behalf of Tony and 20 Mariah, correct? 21 A Yes. 22 Q But the order is what is referred to as a 23 contact order, meaning that my client is allowed to have 24 contact with the children, correct? 25 A Yes. 15 • • 1 Q And isn't it true that the order did not 2 remove Tony from my client's custody? 3 A That's correct. 4 Q So there is this PFA order in effect, but my 5 client has custody of Tony, correct? 6 A Yes. ~ Q Okay. And isn't it correct that in the past 8 -- actually this past summer of 2006, you contacted Children 9 and Youth regarding similar concerns'? 10 A Yes. 11 Q And isn't it also correct that Children and 12 Youth did not open a case against my client? 13 A That's correct. 14 Q They did not= pursue it? 15 A No. 16 Q And they never removed Tony from my client's 17 custody, correct? 18 A Correct. 19 Q Okay. So currently you testified that you 20 have, I believe, six people living in your household; is 21 that correct? 22 A Yes. 23 Q And four of them are children, correct? 24 A Yes. 25 Q And are the children under the age of 18? i6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 1 '7 18 19 20 21 22 23 24 25 • A Q A Q A not five, four. Q in? • Excuse me? Are the chi]_dren under the age of 18? Yes, they are. What are their ages? Eleven, eleven, ten, five -- or I'm sorry, Can you describe what type of house you live A A mobile home. Q Okay. And how big is it: `? A Fourteen by seventy with a ten foot by thirty foot addit=io.n. Q Is it. what would cornmonl_y be described as a single wide? A Yes, it is. Q It' s not: a double wide? A No, it is not. It's single. Q And how many bedrooms do you have? A Four. Q Okay. And so where does everyone sleep? Who gets what bedroom? A Mariah and Kaylee, who is four, share a bedroom. Tyler has his own bedroom that we just made in the addition, and Matthew has his own bedroom. Q And I'm assuming you and your wife have your 17 C7 1 own bedroom? 2 A Oh, yes. 3 Q Okay. And so where would Tony be sleeping? 4 A In the same bedroom that Matthew's in. 5 Q And, I'm sorry, how old is Matthew? 6 A Matthew's ten. ~ Q Okay. Would Tony have his own bed? 8 A Yes, he would. 9 Q If Tony came to live with you, where would he 10 go to school? 11 A Excuse me? 12 Q If Tony -- you're seeking primary custody, 13 correct? 14 A Yes. 15 Q So if Tony came to live with you on a primary 16 basis, where would he go to school? 17 A At the Newville Elementary. 18 Q Would he be in kindergarten? 19 A Yes, he would. 20 Q Would he be in a half-day kindergarten or a 21 full day? 22 A A ha.1f day. 23 Q Do you know which half_ he would be in? 24 A No, I do not. 25 Q Have you contacted the school about the 18 • • 1 kindergarten program? 2 A No, I haven't. 3 Q And are you aware that Tony is cu rrently in 4 kindergarten in school? 5 A That's what he says. I have not been 6 informed by h is mother of that. ~ Q Have you asked? 8 A No, ma'am. 9 Q Have you contacted the school? 10 A No, I haven't. I don't know the school. I 11 have not been informed. 12 Q Have you asked? 13 A No. 14 Q So you haven't made any inquiries into his 15 schooling? 16 A No, ma'am. 17 Q Okay. Now, you said it would be a half-day 18 for Tony? 19 A Yes. 2~ Q Where would he be the rest of the day? 2_l A With my wife. 22 Q Okay. Does your wife work? 23 A No, she doesn't. 24 Q So is she at home during the day? 2.5 A Yes . 19 r] • 1 Q And, I'm sorry, I believe you said you also 2 have a 5 year old or a 4 year old? 3 A A 4 year old, yes. 4 Q Is your 4 year old at home with your wife 5 during the day ? 6 A Yes, he is. ~ Q And you stated that you work, correct? 8 A Yes. 9 Q What's your work schedu]_e? 10 A One in the morning unti7_ eleven in the 11 morning Monday through Thursday. 12 Q Do you ever work on the weekends? 13 A Occasionally. 14 Q And what do you do at your job? 15 A Jockey. 16 Q What is that? 17 A Hook trucks to like over-the-road. 18 Q And so you said you work from 1 a.m. until 19 11 a.m.? 20 A Yes. 21 Q And I'm assuming, correct me if I'm wrong, 22 that you sleep during the day? 2.3 A No, ma'am. Occasionally I'll lay down for an 24 hour when I get home, but I don't go to bed until between 25 6 and 7 in the evening. 2.0 • • 1 Q Okay. And then you sleep until when? 2 A 11:45. 3 Q Okay. And then you go to work? 4 A Yes. 5 Q Now, you stated when you testified that you 6 only had vis itation with Tony since this past August? ~ A Yes. ~ Q How can that be true though? There was a 9 custody orde r entered iri June giving you visitation on the 10 weekends? 11 A Yeah. Well, I was wrong. I had this PFA in 12 my head and. so I missed by a couple of months. 13 Q Okay. So prior to August 10th of this year, 14 did you have any visitation with Tony? 15 A Yes. 16 Q What was the nature of that visitation? 17 A Every other weekend. 18 Q When to when though? 19 A Excuse me? 20 Q What amount of time? 21 A It was from 5:00 Friday until 6:00 Sunday. 22 Q Okay. So when you're not with Tony, do you 23 call him to see how he's doing? 24 A No, I don't. 25 Q Why is that funny? 21 • • 1 A It's funny because you can't call. His 2 mother doesn't like to answer the telephone. So I gave up 3 on that a long time ago. 4 Q Do you try? 5 A Not anymore. I tried with Mariah, and I gave 6 up. ~ Q Do you ever send Tony cards or have contact 8 with him in any other way? 9 A No, I don't. 10 Q So the only contact you have with him is the 11 limited weekends that you were granted by the Judge? 12 A Yes. 13 Q Okay. Now, you testified about the fact that 14 I believe you were told that `Pony was not your son? 15 A Yes. 16 Q And who told you that'? 17 A My daughter Mariah. 18 Q I'm sorry. What did she tell you exactly? 19 A That her mother told her that I was not 20 `Pony's dad. 21 Q Okay. So you heard it from your daughter 22 who's 11'? 23 A Correct. 24 Q Isn't it true that when `Pony was born you 25 denied paternit y of him? 22 • 1 A Yes. 2 Q And isn't it true that Ms. Harper sued you 3 for child support? 4 A Yes. 5 Q And when you went to the child support 6 hearing, you denied paternity? 7 A Yes. 8 Q Isn't it also true that genetic testing was 9 ordered at your request? 10 A Yes. 11 Q Isn't it true that you did not appear for the 12 testing? 13 A Yes, it is. 14 Q Isn't it true that you then later stated that 15 you were Tony's father? 16 A Yes, I did. 17 Q You acknowledged paternity? 18 A Yes. 19 Q So you did establish -- paternity was 20 established, and you did have the opportunity to submit to 21 genetic testi ng? 22 A Yes. 23 Q And you chose not to do that? 24 A Correct. 25 Q Okay. And isn't it true that since Tony was 23 • • 1 born in 2001, you've had -- you've decided to have no 2 contact wit h him? 3 A That's correct. 4 Q You weren't interested in having contact with 5 him? 6 A Oh, I wouldn't say that. Yes, I was. ~ Q But you didn't have contact with him? 8 A Correct . 9 Q Correct? And you didn't take any steps 10 ]_egally to have contact with him? 1-1 A I couldn't afford it at the time. 12 Q But you can afford it now? 13 A Yes, ma'am. 14 Q So you never attempted to file for custody of 15 your son ? 16 A No. 17 Q Okay. So you have interest now because 18 you've d ecid ed it's a way to get back at your former wife, 19 correct? 20 A No. Revenge has nothing to do with this, 21 nothing. 22 Q Not even a little bit? 23 A Right there is what it's about. 24 (The witness held up a photograph.) 25 Q Isn't it true that you did cancel one of your 24 1 weekend visits with Tony recently because you had to work? 2 A Yes, that's correct. 3 Q And so how often are you away on the 4 weekends? 5 A That was, I would have to say, maybe the 6 first time i n the last two years I had to work a weekend. ~ Q What's Tony's favorite food? 8 A Excuse me? 9 Q What is Tony's favorite food? 1.0 A Waffles. 11 Q Waffles. That's his absolute favorite? 12 A That's what he wants al]_ the time. 13 Q What's his favorite toy`? 14 A Play Station. 15 Q And what's his favorite TV show or character? 16 A He doesn't watch TV. 1~ Q Could you expand on that? Meaning he doesn't 18 like i.t? Yo u don't allow him to watch it? 19 A He doesn't watch it. 2_0 Q What does that mean? 21 A If he wants to watch TV, he watches TV in the 22 evening when he goes to bed. He picks a movie out. That's 23 what he goes to bed with. lluring the day he does not watch 24 TV. He's playing. He's got a house full of kids to play 25 with. 25 • • 1 Q What is the routine at your house on the 2 weekends? When's bedtime and stuff ]_ike that? Dinner? 3 A Dinner is between 5 -- 4:30, 5:30, in there. 4 Bedtime is - - on the weekends for the 4 year old is roughly 5 9, a lit tle after. The older kids stay up until about 10. 6 Q Where does Tony fit in t-hat since he's 5? 7 Does he go to bed at 9? 8 A Right. He would be with the younger one, 9 with the 4 year old. He would go to bed about 9. 10 Q Do you tuck him in? 11 A Yes, I do. 12 Q Do you read him a story? 13 A No, I do not. 14 Q Does your wife? 15 A No, she doesn't. 16 Q He doesn't like stories or you just -- that's 17 not your rou tine? 18 A That's not our routine. He wants to watch 19 TV. 20 Q Okay. So you allow him to do that? 21 A Yes, at bedtime I do. 22 Q You and Ms. Harper were married at one time, 23 correct? 24 A Yes. 25 Q And isn't it true that you had a history of 2.6 • • 1 abusing Ms. Harper? Of being physically violent toward her? 2 A No, that's not true. 3 Q Isn't it true that you 1-lad a PFA entered 4 against you? 5 A Yes, that is true. 6 Q That my client filed against you? 7 A Yes, that is true. 8 Q That contained a custody provision? 9 A Yes. 10 Q Regarding Mariah? 11 A Yes. 12 Q And isn't it also true that Mariah resided 13 with her mot her on a full-time basis until September of last 14 year? 15 A On paper she resided with her mother. 16 Q I don't understand you r_ answer. 17 A When Stephanie lived in Plainfield she stayed 18 with my mother except for the weekends when she lived with 19 me, and on Mondays she was with her mother. The rest of the 20 week she was with my mother. 21 Q And how long did that Happen for? 22 A I really couldn't tell you. It was the whole 23 time she lived in Plainfield. 24 Q I'rri sorry. What? 25 A It was the whole time stie lived in 27 • • 1 Plainfield. 2 Q How long did your mom live in Plainfield? 3 A No, not my mother. Stephanie. 4 Q How long was that? 5 A I couldn't tell you. ~ Q Because you just don't remember? ~ A No, I don't. 8 Q Okay. So you don't have a great memory for 9 this stuff? 10 A Some things I care to remember and others I 11 don't. I mean why would I care how long she lived 12 somewher._e? 13 Q Because it affected your daughter? 1.4 A We]_l, I don' t move . 15 Q Okay. But isn't it true that Mariah, until 16 September of last year, did not reside with you on a primary 17 basis? 18 A That's correct. 19 Q She had always resided with her mother, 20 correct? 2-L A Yes. 2.2 Q And Tony has always resided with his mother? 23 A Yes. 24 Q Since his birth? 25 A Yes. 28 • ~ 1 Q Okay. How many times have you or your wife 2 taken pictures of Tony since you've seen him? 3 A On several occasions. I couldn't give you an 4 exact number . 5 Q But never, since you started making these 6 allegations, has Children and Youth ever decided to step in 7 or remove To ny? 8 A No, they haven't. 9 Q Because there hasn't been anything to remove 10 him for, correct? 11 A I guess not. 12 Q Do you --- well, scratch that. 13 MS. PINSKER: I don't have any other 14 questions at this time, Your Honor. 15 THE COURT: Ms. Tomeo. 16 REDIRECT EXAMINATION 7.7 BY MS . TOMEO 18 Q Mr. Tressler, what is your relationship like 19 with the Plai ntiff? 20 A Excuse me? 21 Q What is your relationship -- what kind of a 22 relationship do you have with the Plaintiff? 23 A Absolutely none. We don't talk. 24 Q At all? 25 A No, we don't. 29 • • 1 Q How long has that been going on for? 2 A Since December of 2000. 3 Q Following your divorce? 4 A We1_l, when we separated, yes. 5 MS. TOMEO: I have nothing further. ~ RECROSS EXAMINATION 7 BY MS. PINSKER: 8 Q Mr. Tressler, isn't it true that you and 9 Ms. Harper did have communication regarding Mariah, 10 particularly ba ck in September of 2005'? 11 A Yes. 12 Q And at that time isn't it true that you and J_3 Ms. Harper deci ded that i_t would be in Mariah's best 14 interests for h er to live with you for a period of time? 15 A Yes. 16 Q So you have had communication with he r_? 17 A No. It doesn't work that way. 18 Q How does it work? 19 A It works when it suits Iier. It's always been 20 that way. I've known her 20 years. It's always been that 21 way. If it ben efits her, she'll talk. If it doesn't, then 22 she don't talk. 2.3 Q Okay. But it's a misstatement for you to say 24 you haven't had any communication with her since 2000? 25 A The only communication I have had is in 30 • • 1 hearings, and when she didn't want her daughter. She wanted 2 her to live with me. 3 Q Isn't it true that you also had concerns 4 about how Ma riah was doing in school, and she was lying, and 5 you and your wife and Ms. Harper sat down to talk about what 6 was in Maria h.'s best interests at that time? ~ A The concerns in school, yes. 8 Q Okay. Isn't it true that you had that 9 meeting with my client to talk about what was best for her? 10 A Yes. 11_ Q That my client attempted to have 12 communicatio n with you regarding Mariah? ]_3 A Yes. 14 Q And isn't it true at treat time that you 15 stated to my client that you would be more than happy to 16 sign off on all your parental rights to Tony? 17 A No, it is not. 18 MS. PINSKER: Nothing further, Your Honor. 19 THE COURT: Ms. Tomeo. 20 MS. TOMEO: Nothing further. 21 THE COURT: What is your date of birth? 22 I'HE WITNESS: 8/9/69. 23 THE COURT: And do you know what 24 Ms. Harper's date of birtYr is? 25 THE WITNESS: June 30th, '69. 31 • 1 THE COURT: And what was the date of your 2 marriage to her? 3 THE WITNESS: September 28th of '87. 4 THE COURT: And the date of your separation? 5 THE WITNESS: There was actually two. 6 THE COURT: Let's say the last separation. 7 THE WITNESS: That would have been December 8 of 2000. 9 THE COURT: And the date of your divorce? IO THE WITNESS: I could not tell you that. 11 THE COURT: Do you remember the year? 12 THE WITNESS: No. I believe 2002. 13 THE COURT: Okay. Any other questions by 14 counsel? 15 MS. TOMEO: No, Your Honor. 16 TF~E COURT: If not, you may step down. Thank 17 you. 18 MS. PINSKER: Your Honor, if I may make a 19 request before this witness begins testifying. As you may 20 recall, my client i s currently pregnant, and she would 21 request a five minu te recess. 22 THE COURT: Certainly. We'll take a brief 23 recess. 24 (Whe reupon, a recess was taken at 2:20 p.m.) 25 AFTER RECESS 32 • • 1 THE COURT: Ms. Tomeo. 2 MS. TOMEO: I would like to call Melissa 3 Tressler. 4 Whereupon, 5 MELISSA TRESSLER 6 having been duly sworn, testified as follows: 7 DIRECT EXAMINATION 8 BY MS. TOMEO: 9 Q Please state your name and address for the 10 record. 11 A Melissa Tressler, 127 CME, Newville. 12 Q Melissa, what is your relationship with 13 Joseph Tressle r? 14 A He's my husband. 15 Q How long have you been married to Joseph? 16 A We got married October 19th, 2002. 17 Q And do you know Antonio? 18 A Yes. 19 Q In what capacity do you know this child? 20 A With the few visits that I had with him. I 21 know he's my h usband's son. 22 Q You obviously have witnessed your husband and 23 Tony interact with each other, correct? 24 A Yes. 2.5 Q Will you tell me on a daily -- on a usual 33 • • 1 visit what that interaction consists of? 2 A Tony usually likes to play with our youngest 3 daughter. They're all but the same age, but when he's with 4 his daddy -- I mean ever since the child has met him, he has 5 called him daddy, and he plays with him when he gets time 6 to. He wants to talk about trucks and motorcycles, and he's 7 interested in the fact that my husband drives a big truck, 8 and every time when we pick him up down at the Flying J, our 9 meeting place, you know, if he sees one of those big trucks 10 go by he's screams daddy, daddy, that='s what you drive. You 11 know, they talk about that kind of stuff. 12 Q So considering the fact that there has only 13 been a few visits with Antonio, you believe that they have 14 developed a relationship? 15 A Yes. 16 Q To the point where he would be comfortable 17 living with him on a full-time basis'? 18 A Oh, yes. 19 MS. PINSKER: I'm going to object to that, 20 Your I-lonor. The witness does not have a background or 21 really a proper basis to make that kind of opinion. 22 THE COURT: Ms. Tomeo. 23 MS. TOMEO: I am just asking for purely her 24 opinion based on her observations. 25 THE COURT: If you are asking for an opinion 34 r ~_~ • 1 as to custody, certainly she's not qualified to give that 2 opinion. So I'll sustain the objection. You may ask her 3 what her observations are about the relationship and so 4 forth. 5 BY MS. TOMEO: 6 Q Have you observed anything unusual about 7 Antonio when he visits your home? 8 A Yes. 9 Q What would that be? 10 A Bruising. We started our. first visitation "11 with Antonio the weekend of July the 8th of 2006, and I 12 noticed bruising on his back. And ther_e's been several 1.3 occasions where he's had bruising, whet=her it's on his back, 7.4 his arms or his buttocks. 15 Q Have you ever approached Ms. Harper about any 16 of this bruising? 17 A No. 18 Q And why is that? 19 A I don`t talk to her. 20 Q So you have no relationship with Plaintiff at 21 all? 22 A Not anymore. 23 Q Did you ever have a relationship with her? 2.4 A Yes. 25 Q Concerning Joe's daughter Mariah, correct? 35 • • 1 A Yes. 2 Q Why do you feel it would be in Antonio's best 3 interests to see -- let me rephrase that. Why do you feel 4 that your husband would be a better primary caretaker? Do 5 you believe he would be a better primary caretaker? 6 A Yes. ~ Q Are you employed? 8 A No. ~ Q What do you do during the day on a typical 10 day? 11 A My day starts at 5:45 a.m. I usually get up 12 and have enough time to make a cup of_ coffee before I'm 13 waking Mariah up for a shower for school. Once Mariah's 14 finished, I wake my oldest sore up because they're both in 15 the same grade, and they both eat breakfast about 6:30. At 16 7:00 we head up to the bus stop. The k~us picks them up at 1'7 approximately 7:15 in the morning. 18 When I get back home -- I have another son 19 who's 10 in the fifth grade. I get him up and get him 20 dressed for school. I feed him breakfast. I have a four 21 year old daughter at home who keeps mP very busy. His bus 22 usually picks him up around 5 minutes until 9 in the 23 morning. 24 When I come back I nave errands, cleaning, or 25 whatever I do for_ the day, and at 3:00 Mariah and Ty]_er, the 36 • • 1 two oldest, are home, and we work on Homework. We work -- 2 Wednesday nights -- we go to church every Wednesday night. 3 Marian sings with the choir. My kids are part of the youth 4 group. A typical day is just homework and getting them 5 ready for bed, and then we start al]_ over the next day. 6 Q If Antonio were to come live with you on a 7 full-time basis, would you have any problems accommodating 8 hi_m into your daily routine? 9 A No. 10 Q So it would be no hardship upon yourself? 11. A None . 12 MS. TOMEO: I have nothizig further. 13 THE COURT: Ms. Pinsker. 14 CROSS EXAMINATION 15 BY MS. PINSKER: 16 Q Ms. Tressler, from your testimony it sounds l7 like you take care of running the house, making sure the 18 kids are fed and clothed and at school and all of those 19 details; is that correct? 20 A Yes. 21 Q Does Mr. Tressler ever assist you in any of 22 that? 23 A Yes. 24 Q What does he do? 25 A Well, that depends. If laundry needs 37 • • 1 started, he usually starts laundry. He helps me with 2 dinner. He works a full-time job. He helps out a lot. He 3 helps me get the kids ready for bed. He helps with their 4 homework. 5 Q Are you aware that Tony is in kindergarten 6 this year? 7 A Yes. 8 Q And isn't it correct that you live in a 9 different sc hool district than Ms. Harper? 10 A Yes. 11 Q So Tony would have to -- if he did come to 12 live with yo u full-time, he would have to start a new school 13 district, co rrect? 14 A Yes. 15 Q Okay. Now, you said you have had obviously a 16 few weekend visits with Tony? 17 A Yes. 18 Q And to your knowledge has his sister, Mariah, 19 been present during those visits? 20 A Every one of them. 2.1 Q For the entire visit? 22 A Yes. 23 Q SYie didn't go anywhere? Didn't hang out with ?_4 friends"? 25 A Mariah spent one weekend since we started 38 • • 1 getting Tony with her grandmother, and it wasn't even a full 2 weekend. Sh e left on a Saturday afternoon and came back 3 Sunday after noon. 4 Q Well, which grandmother are you referring to? 5 A It would be Stephanie's mother. 6 Q Did Tony go to visit too? ~ A No. 8 Q Why not? 9 A Because we took him to Middletown Police 10 Station. 11 Q Oh, okay. Which I'm sure was fun for him. 12 Now, ever si nce you started getting visitation with Tony, 13 you and Mr. Tress]_er testified that you have noticed 14 bruising; is that correct? 15 A Yes. 16 Q Okay. And isn't it true that both you and 17 Mr. Tressler reported these bruises to the police? 18 A Yes. 19 Q Correct? And isn't it true that Children and 20 Youth had also been involved? 21 A Yes. 22 Q And isn't it true that Children and Youth did 23 not find any of the allegations substantiated? They did not 24 open a case a gainst my client? 25 A The first time they did riot find any 39 r~ C 1 bruising. 2 Q Okay. And they didn't do anything, correct? 3 A No. 4 Q And isn't it true that the police took no 5 steps after their initial investigation of your complaint, 6 correct? 7 A Yes. 8 Q And isn't it true that Tony has always lived 9 with Ms. Har per, his mother? 10 A Yes. 11 Q Okay. On a full-time basis? 12. A Well, whoever she lived with at the time and 13 his mother. 14 Q Okay. And now you said that you and 15 Mr. Tressler have been married since October of 2002? 16 A Yes. 17 Q Is that correct? And isn't it true that 18 Mr. Tressler left Ms. Harper to become involved with you? 19 A Yeah. 20 Q Do you have any children of your own? 21 A Yes. 22 Q How many'? 23 A Three. 24 Q Okay. And is one of those children a child 25 you have in common with Mr. Tressler? 40 C, 1 A Yes. 2 Q Okay. Now, Mr. Tressler testified that Tony 3 would have to share a bedroom at your house. 4 A Correct. 5 Q And which child would he share a bedroom 6 with? ~ A With Matthew. 8 Q And how old is Matthew? 9 A Ten. 10 Q And would they each have their own bed? 11 A Yes. 12 Q Does Matthew know he's going to be expected 13 to share a be droom? 1.4 A Yes. They love each otrier. 15 Q Now, to your knowledge, would Tony be going 16 for a half-da y or a full-day of kindergarten? 17 A I would not know that until I took him down 18 to kindergart en to register him. 19 Q Okay. Have you made any inquiries to the 20 school about kindergarten for Tony? 21 A No. 2.2_ Q And if he were only to Y-lave a half-day of 23 kindergarten, what would he do the rest of the day? 24 A He would be home with me and his sister. 25 Q So you would be taking care of him? 41 • • 1 A Yes . Until his daddy got home. 2 MS. PINSKER : I don't have anything further 3 at this time, Your Honor. 4 MS. TOMEO: I have nothing further. 5 THE COURT: What school district are you in? 6 THE WITNESS: I'm in Big Spring School 7 District. 8 THE COURT: What did you say? 9 THE WITNESS: Big Springs? 10 THE COURT: Big Springs. 11 THE WITNESS: Yes. 12 THE COURT: Now what school district is the 13 child in now? 14 THE WITNESS: I'm assuming he's in Robert 15 Reid Elementary Sch ool in M iddletown. 16 THE COURT: In what school district? 17 THE WITNESS: In what school district? 18 THE COURT: I'm sorry. I'm just having 19 trouble hearing you. What school is the child in now? 20 THE WITNESS: I'm not sure. 21 THE COURT: All right. Any other questions 22 by counsel? If not , then you may step down. Thank you. 23 MS. TOMEO: Our next w.i.tness I would like to 24 call is Sharon Napo litan. 25 42 • • 1 Whereupon, 2 SHARON NAPOLITAN 3 havi ng been duly sworn, testified as follows: 4 DIRECT EXAMINATION 5 BY MS. TOMEO: 6 Q Please state your name and address for the 7 record. 8 A Sharon Napolitan. I live at 108 Kelso Road, 9 Shippensburg. 10 Q Ms. Napolitan, what is your relationship to 11 the parties in this action? 12 A Stephanie's my daughter. 13 Q Have you ever witnessed Mr. Tressler interact 7.4 with Antonio? 15 A Yes. 16 Q And what were your observations of the 17 interaction between them? 18 A It was very calm. They interacted well 19 together. I see no issues. 20 Q In what kind of setting slid you observe them? 21 A Home environment. 22 Q And it seemed to be a normal -- 23 A Absolutely. 24 Q -- father, son relationship? 25 THE COURT: Well, two people are talking at 43 • • 1 once. Why don't you finish the question, and then you can 2 provide the answer. Start the question again. 3 BY MS. TOMEO: 4 Q It seemed to be a normal father, son 5 relationship? 6 A Yes. ~ Q Have you observed your slaughter interacting 8 with Antonio? 9 A Yes. 1.0 Q And in what capacity did. you observe them 1_l interact with each other? 12 A As a mother and a child. Is that what you're 13 referring to? 14 Q Let me rephrase that. Were you a member of 15 the household at the time that you observed Antonio and your 16 daughter inter act with each other? 1 1 A Yes . 18 Q How long had you been living with them? 19 A They were living with us a couple of years. ?_0 She had Tony w hile she was there living with us. 21 THE COURT: And when was this? 22 THE WITNESS: He was born in 2001, and she 23 came to live w ith us when she was about 2 months pregnant. 24 So he was born August -- it was I think. January of 'Ol, in 25 around there. 44 • ~ 1 BY MS. TOMEO: 2 Q How long did she reside with you? 3 A Three years. Almost three years. 4 Q Over those three years, your observations of 5 the interactions, from what you can remember, between your 6 daug-titer and Antonio, was it a normal relationship that they 7 had? 8 A To a certain extent, at. times it was, but 9 Stephanie has always had anger issues tl-rat would always come 10 into play, and so if she was having, you know, one of her 11 experiences with the anger, you know, the kids would usually 12 get it in some way or' form. 13 Q Has she experienced anger issues for most of 14 her life? 7-J A Pretty much. I think when she became a 16 teenager is when it really qot worse, and over the years, 17 you know, we've tried to get her to get some counseling, but 18 that's not something that she would do. 19 Q Have you ever seen her anger manifest itself 20 on her children'? 21 A Yes. 22 Q In what ways? 23 A It was Mariah most of the time. She was 2_4 usually very angry whenever she would come home from a 25 weekend with Joey, and she would brow}~eat her constantly for 45 • • 1 anything that she wanted, you. know, cahat was going on and 2 stuff, and then there was the one time in particular that 3 they were fighting, and I went to see what was going on, and 4 she had Mariah on the floor, and she was on top of her, and 5 she had her hands around her. throat choking her and Mariah 6 was starting to turn blue, and so I grabbed Mariah from her 7 and got her off, and I said to her, if I wasn't there, you ~ would have killed her, and she said, yes, I know. 9 Q llave you ever observed leer act out towards 1-0 Antonio? 11 A Yes . She used to get angry with hirn as well, 12 and she used to make comments about never wanting a boy. 13 She was always very adamant about not leaving a boy, and, you 14 know, he was a typical boy, and he would cause a little 15 trouble. Her anger would flare up. Sere would scream and 16 yell and push, shove, grab by the arrrl, stuff like that. 17 Q To your knowledge, has she ever sought l~ counseling or any kind of therapy for her anger issues? 19 A Not to my knowledge, no. 2.0 MS. TOMEO: Okay. I have nothinq further. 21 THE COURT: Okay. Ms. Pinsker_. 22_ MS. PINSKER: Thank you. 23 CROSS EXAMINATION 24 BY MS. PINSKER: 25 Q When is the last time that you recall 46 • • 1 observing your daughter with her son, Antonio? 2 A It's been probably a year or more. 3 Q So it's a long time? 4 A Um-hum. 5 Q Now, you stated that they lived with you for 6 about a period of 3 years, correct? F'.rom 2001 until 2004, 7 approximately? 8 A Yes. 9 Q And you also just testified that you saw my 10 client get angry with the kids; is that correct? 11 A Um-Hum. 12 THE COURT: You'll have to say yes or no for 13 the stenographer. 14 THE WITNESS: Yes. 15 BY MS. PINSKER: 16 Q Did you ever contact Children and You th about 17 your concerns? 18 A No. 19 Q Did you ever contact the police about your 20 concerns? 21 A No. 22 Q And when is the last time you recall 23 observing your daughter with her daughter, Mariah? 24 A Probably about the same time period. It's 25 been about a ye ar since we have had any contact. 47 • ~ 1 Q But isn't it true that although you haven't 2 had contact with my client and her children together for a 3 year, you have had contact with your grandchildren? 4 A Yes. 5 Q And how have you managed to have contact with 6 them? ~ A Through Joey. 8 Q Okay. How often do you see them? 9 A Probably -- maybe every other weekend. 10 Q Okay. And when is the last time you recall 11 seeing Tony'? 12 A About two weeks ago. 13 Q How much time did you spend with him? 14 A Probably about an hour. 15 Q What did you do? 16 A We were visiting over at Joey's house, and we 17 just were talking and watching him play. 18 Q He's a very active child, isn't he? 19 A Just average. Yeah, like most kids. 20 Q Does he like to play outside? 21 A Sure. 22 Q Does he like to ride his bike? 23 A Yes. 24 Q Does he like to get dirty and play outside 25 and -- 48 • ~ 1 A He's a boy, yeah. 2 Q Okay. Well, when you say he's a boy, what 3 does that mean? 4 A They ride bikes, they play, they do all kinds 5 of things. ~ Q They _run all over the place? ~~ A Sure, yes. 8 Q They trip and fall and. bang themselves. 9 A Yes. 10 Q Right? 11 A Um-hum. 12 Q He's not a boy that just sits in the house 13 and watches TV? He's active, correct? 14 A When he has the opportunity, yes. 15 Q Okay. And you've observed him being active _l6 and enjoying that? 17 A Yes. 18 Q And you know that he likes to ride his bike? 1.9 A Yes. Z0 Q Obviously, you're aware that your daughter 21 was married to Joe for a period of time, correct? 22 A Yes. 23 Q And isn't it true that during their marriage 24 you were awa re of the fact that Mr. Tressler abused your 25 daughter? 49 • • 1 A These were things according to Stephanie. 2 Q So you were aware that it was happening? 3 A From what she told us, yes. 4 Q And I'm assuming you don't have any concerns 5 about Mr. Tr_es sler now even though he used to abuse your 6 daughter? A No. 8 Q So all of those concerns are gone? 9 A I know Stephanie, and I ].now how she can 10 bring anger. on anybody. 11 Q Oh, so that means that she deserved being 12 abused by Mr. Tressler? 13 A No, I'm not saying that. 14 Q Well, then -- 15 A I didn't see the evidence. I know what she I6 told me. 17 Q Did you ever observe, when your daughter was 18 married to Joe , choking marks around her neck, that you 19 recall? 20 A I don't recall. 2l Q And do you recall whether or not your ?_2 daughter h ad a PFA against Mr. Tressler? 23 A Yes. 24 Q So you're aware of that'? 25 A Yes. 50 • • 1 MS. PINSKER: Okay. I don't have any other 2 questions, Your Honor. 3 MS. TOMEO: I have nothing further. 4 THE COURT: When was the choking incident? 5 THE WITNESS: That was probably between 2001 6 and 2002. ~ THE COURT: All right. You may step down. 8 Thank you. Anything further, Ms. Tomeo? 9 MS. TOMEO: I would like to call Stacy 10 Napolitan. 11 THE COURT: Well, we're really starting to 12 run short on time, if I'm goinq to have any evidence 13 received from the other side. What is your offer of proof 14 with respect to the next witness? 15 MS. TOMEO: She was just going to testify as 16 to the interactions that she's observed between Stephanie 17 and Antonio basically. I guess additional testimony. 18 THE COURT: All right. Ms. Pinsker, how much 19 time were you going to need for your presentation? 20 MS. PINSKER: Well, Yo~_zr Honor, I have 21 obviously the testimony of my client and three other 22 witnesses that I feel are relevant, anc~ they're present 23 today. So I'm assuming I'm going to need upwards of three 24 hours, close to. 25 `I'HE COURT: Three hours, did you say? 51 1 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 2 2_ 23 24 25 witness then. • • MS. PINSKER: Possibly, "Your Honor, yes. THE COUP.T: All right. Well, call your next Whereupon, STAGY NAPOLITAN having been duly sworn, testified as follows: DIRECT EXAMINATION BY MS. TOMEO: Q record. A Middletown. Q this action? Please state your name and address for tYle Stacy Napolitan, 2700 East Harrisburg Pike, What is your relationship to the parties in A Stephanie's my sister. Q Okay. Have you observed any kind of interaction between Antonio and Mr. Tressler? A No. Q You have never seen Mr. `.Pressler and Antonio together? A He wasn't allowed to see him, as far as I know. Q Okay. But just recently you've never seen them interact with each other? A No. 52 • • 1 Q Have you observed your ,sister and Antonio 2 interact with each other? 3 A Yes. 4 Q And what kind of interactions have you 5 observed? 6 A Do you want both positive and negative or 7 does it matter? 8 Q Sure. 9 A Well, positive, I mean she -- I think she 10 thought she was trying to be a good mom. She had mental 1.1 issues that we tried to get her to get help for, which she 1?_ hasn't done, but, you know, he always had nice clothes and 13 everything, but, you know, if he ever messed them up he was 14 in a lot of trouble. She has anger issues, and when she's 15 ticked off and she's having a bad day, she takes it out on 16 Tony. 17 Q Do you recall any specific instances where 18 she's exhibited anger toward Antonio? 19 A Yes. Once when I was baby-sitting him, and 20 she came home. 21. Q What happened on that occasion? 22 A He wanted attention from her because he 23 missed her all day, and that got on he r_ nerves so she -- I 24 mean he kept at it, you know, trying to get up on her lap or 25 whatever, and she snapped out on him and started hitting 53 • • 1 him. He fell on the floor, and she started kicking him when 2_ he was on the ground. 3 Q Approximately how long ago did this happen? 4 A That was two summers ago. 5 Q Two summers ago? 6 THE COURT: Wait. This occurred -- she took 7 this out on Tony; is that right? 8 THE WITNESS: Um-hum. 9 THE COURT: And when was this? 10 THE WITNESS: This was two summers ago in 11 2004. 12 THE COURT: 2004, in the summer? 13 THE WITNESS: Um-hum. 14 THE COURT: And what did. she do again? 15 TIDE WITNESS: She was smacking him, and when 16 he went down on the floor trying to get away from her, she 1.7 started ]ticking him, kicking him in his sides and his back 18 and smacking hirn on his back and wherever. 19 THE COURT: And where di_d that occur? 20 THE WITNESS: At my apartment. 21 THE COURT: Okay. And what had he done? 22 THE WITNESS: He wanted attention from her. 23 He was, you know, up at her trying to qet up on her lap or, 24 you know, whatever. Trying to get attention from her. You 25 know, she was at work all day. 54 • • 1 TF~E COURT : All right . 2 BY MS. TOMEO: 3 Q You stated that Ms. Harper suffers from anger 4 management issues and mental issues, correct? 5 A Yes, definitely. 6 Q Can you elaborate on that a little bit? ~ A She's always had anger issues. She has a 8 really, really short fuse, and she doesn't think about. what 9 she's doing. When she lashes out, she just lashes out. She 10 lies constantly. She created some really bad problems for 11 me and my family by lying, doing a lot of lying about me. 12 If you cross her, you need to look out 13 because she'll take away your privileges, like seeing your 14 -- you know, like Tony and Mariah. She's done that with my 15 parents. She's done that with Joey's ~~arents. And as far 1F as I know, I guess I was being 1_ied to about the whole Joey 17 wanting to see his kid thing. 18 I was told so many different things. We have 19 a family history of bipolar and depression, and she's got a 20 really good dose of it, in my opinion. We wouldn't know ?_1 professionally because, you know, we've been on her, my 2.2 parents have been on her, .you know, to L.r_y to get some help 23 because she's messing with the kids. 24 Q Are you aware of any instances where she has 25 sought any type of counseling or therapy'? 55 • • 1 A I know that she had counseling, but I don't 2 know if it was actual psychiatric counseling. It was like 3 counseling for -- I guess after her one divorce or 4 something. Something to do with her being abused. I 5 thought it was that kind of a counseling thing, but she 6 wasn't on medication or anything. She was supposed to be on 7 medication at one point actually, but she told me she wasn't 8 taking it. 9 Q And has she exhibited this behavior for her 10 entire life? 17- A Yeah, she has. It's like she has two _l2 different personalities. 13 MS. `I'OMEO: I have nothing further. 14 THE COURT: Thank you. Ms. Pinsker. 15 CROSS EXAMINATIOTd 16 BY MS. PINSKER: 17 Q Ms. Napolitan, when is ttre last time you 18 observed any interaction between your sister and Tony, 19 approximately? 20 A I don't know. I haven't. seen her since the 21 day of the conciliation hearing. 22 THE COURT: I'm sorry. I didn't hear how 23 long. How long has it been since you've seen them together? 24 THE WITNESS: Since the conciliation hearing, 25 was the last day I saw my sister. 56 • • 1 THE COURT: Well, I don't know when that was. 2 THE WITNESS: I don't know when it was. 3 THE COURT: Was it 3 years ago or was it -- 4 THE WITNESS: No. It was this year. 5 THE COURT: This year? 6 THE WITNESS: Um-hum. 7 BY MS. PINSKER : 8 Q Was it the last time you. were in court here? 9 A Well, I saw her, but I didn't interact with IO her then. The last time I interacted with her was at the -- 11 the day of the conciliation at my house. After it wa.s over, 12 at my house. 1.3 Q Okay. And was that this year? 14 A Yes. I said it was this year. 15 Q Did you observe her interacting with Tony? 16 A No. l~ Q So when -- my question was when was the last 18 time you remember seeing your sister interact with Tony? 19 R Well, I don't know. Probably a week before 20 the conciliation hearing when she used to bring him up. 21 Q Okay. So roughly when was that? 22 A I don't know. I don't have a clue. 23 Whenever the conciliation hearing was. I don't know. 24 Q You don't recall? 2.5 A No. I don't know. I don't remember dates. 57 • • 1 I don't remember months. 2 Q Well, that's interesting because you 3 testified that you recall an incident },~etween your sister 4 and Tony back in the summer of 2.004? 5 A Right. Well, that's kind of something that 6 you would remember. ~ Q Well, you just said you'r_e not good with 8 dates and times? 9 A No, I wasn't. I said it was two summers ago. 10 Q What was the interaction you observed between 11 your sister and Tony before the conci.l_iation conference that 12 you recall? 13 A I r_ecall_ that she told. me that she wasn't 14 being nasty to him anymore because s}ie was trying really 15 hard to be nice, that she didn't want t.n do that to him 16 anymore, but she still got nasty and s}iP still pushed him 17 around and she still smacked him in the head. 18 Q And you observed all of that happening? 19 A Yes. And so have my kids. 20 Q You also said that, you know, Stephanie is a 21 c}ood mom? 22_ A I said Stephanie tries to be a good mom. 23 Q And you've seen her being a good mom to Tony, 24 right? 25 A I've seen her be affectionate with him. 58 • • 1 Q And you've observed Tony being affectionate 2 to he.r? 3 A Yes. 4 Q He loves his mother, correct? 5 A It's his mother, of course. 6 Q Now, you said that you have a family history 7 of mental heal th issues? ~ A Um-hum. 9 Q Do you, yourself, suffer from any mental 10 health issues? 1_l A Yes. 12 Q What do you suffer from? 13 A I am bipolar. 14 Q Is that an official medical diagnosis? 15 A Yes. 16 Q Are you currently being treated for that? l~ A Yes, I am. 1~3 Q Do you see a doctor on a regular basis? 19 A Yes, I do. 20 Q Do you recall roughly when. you were 21 diagnosed? 22 A No, I don't. Early spring. 23 Q Of what year? 24 A Of this past year. 25 Q This past year. Are you on any medication 59 • • 1 for your disorder? 2 A Um-hum. 3 Q What are you on? 4 A Yes. Sorry. 5 Q What are you taking? 6 A I'm taking Prozac. ~ Q Do you have any children? 8 A I have five kids. 9 Q And what are their ages? Are they all over 10 18? 11 A I have four that live with me. One does not. 12 Q Are the four that live with you -- are they 13 under 18? Are they minors still? 14 A No. 15 Q Well, blow many are under 18? 16 A Three. l~ Q So -- and you said you -- there's one that 18 doesn't live with you? 19 A Right. 20 Q Where does that child live? 21 A Newville. 22 Q Who does that child live with? ?_3 A His father. 2.4 Q Do you visit that child? 25 A Yes, I do. 60 • ~ 1 Q Isn't it true that you, yourself, have had 2 involvement with Chi_ldrerz arld Youth? 3 A Yes. 4 Q And isn't it true that you have had children 5 --- your own children removed from your home by Children and 6 Youth? ~ A Yes. ~ Q Is it fair to say that you and your sister 9 have a strai ned relationship? 10 A We didn't because I was always there for her, 11 but this is too far. This is too much. 12 Q Okay. I don't think that's an answer to my 13 question. 14 A We have no relationship right now because she 15 didn't want to see me because she's mad because I'm _16 testifying a gainst her in court. 17 Q 1~Iow, you obviously know Joe Tressler'? 18 A Of course. 19 Q And he is the ex-husband of your sister, 20 correct? 21 A Correct. 22 Q And isn't it true that while they were 23 married, you were aware of the fact that Mr. Tressler abused 24 your sister? 25 A I was aware that my si_st:er told me that he 61 • • 1 did. 2 Q Were you aware that your sister had a PFA 3 against Mr. Tressler? 4 A Yes, I knew about that. 5 Q And that she was afraid of Mr. Tressler? 6 A I can't say that for sure. ~ MS. PINSKER: I don't have any other B questions, Your Honor. 9 THE COURT: Ms. Tomeo. 10 MS. TOMEO: I have no1._lii_ng further. 11 THE COUR'T': You may step down. Thank you. 12 MS. TOMEO: Your Honor, the next witness that 13 we have are going to be testifying via phone. 14 THE COURT: Well, you're welcome to keep 15 presenting your case. I'm not going to change the order.. 16 So you call your next witness. We'll take a short recess 17 and -- 18 MS. TOMEO: Your Honor, if I could just 19 converse with my client. He no longer wishes to present 20 this witness. 21 THE COURT: Okay. I'm not saying I'm going 22 to change it anyway, but I'm certainly not going to change 23 i.t at the end of the day without hearing from the other 24 side. 25 MS. TOMEO: I understand. 62 • • 1 THE COURT: Let's see, slid you want to move 2 the admission of your exhibit? 3 MS. TOMEO: Oh, yes. I would like to move 4 the admission of Defendant's Exhibit Number 1. 5 THE COURT: Ms. Pinsker_. ~ MS. PINSKER: Your Honor, may Ms. Tomeo and I 7 approach for a moment? 8 THE COURT: I']_1 meet yol_t in chambers. Do 9 youu have any objection to the admission of Defendant's 10 Exhibit 1? 11 MS. PINSKER: No, Your honor. 12 THE COURT: All right. Defendant's Exhibit 1 13 is admitted. 14 (Whereupon, Defendant's Exhibit No. 1 was 15 admitted into evidence.) 16 THE COURT': We'll take a short recess. 17 (Whereupon, a recess was t=aken at 3:06 p.m.) 18 AFTER RECESS ]-~ THE COURT: We will let the record indicate that 20 the Court has met in chambers with counsel and understands 21 that the Plain tiff has a number of witnesses to call, and 22 the Defendant has more witnesses whom he wishes to call 23 also. In the interest of putting the C'ou.rt in a position to 24 enter at least a temporary order at the end of the day, we 25 will move to t he witnesses of the Plaintiff, without 63 • • 1 prejudice to the Defendant's right to <~all additional 2 witnesses at a further day of hearing. Ms. Pinsker. 3 MS. PINSKER: I'd 1_ike to call Alisha 4 Flemister to the stand. 5 Whereupon, ~ ALISHA FLEMISTER 7 havin g been duly sworn, testified as follows: 8 DIRECT EXAMINA'T'ION 9 BY MS. PINSKER: 10 Q Could you please state your name for the 17_ record? ~-2 A Alisha Fiemister. 13 Q And are you employed? 14 A Yes, I am. 15 Q And what is your occupation? 16 A I'm a childcare provide- at the Little Rays 17 of Sunshine Daycare. 1B Q And how long have you been doing that? 19 A For about 5 years now. 20 Q And where is that daycare located? 21 A In Middletown at 149 Wilson Street. 22 Q How many children do you have in your 23 daycare? 24 A About 20 to 25. 25 Q And do you own the daycare? 64 • • 1 A Yes, I do. 2 Q How do you know Stephanie Harper and her son, 3 Tony? 4 A I know Stephanie Harper. She is a client of 5 mine. She's been a client for almost a year. November 12th h will be a year. Approximately a year. ~ Q Does Tony go to your daycare? 8 A Yes, he does. 9 Q And how long has he been at your daycare? 10 A Since November 12th of 2005. 11 Q How often was he at your daycare? 12 A Tony's at daycare Monday through Friday 13 from 7:30 to 4:30. 14 Q And has that schedule changed this year at 15 all? 16 A No. 17 Q But. is he in kindergarten this year? 18 A Yes, he is in kindergarten this year. He has 19 actually turn ed into a before and after school program 2.0 student. 2J_ Q What does that mean? 22 A That he comes there in the morning for 23 breakfast. We put hirn on the bus, and I don't see hirn again 24 until scho ol is over, and then Stephanie picks him up. 25 Q So you still see him every day, even though 65 • • 1 he's in kindergarten? 2 A Yes, I do. 3 Q Okay. Can you describe `:Pony for the Court? 4 What kind of little boy is he? 5 A `T'ony is a wonderful child. He's very social, h very independent, a whole lot of energy, very outspoken. 7 He's a. good kid. Overall a good. kid. No problems ever with 8 Tony. 9 Q And describe your interactions with Stephanie 10 as a client at your daycare? 11 A My interaction with Stephanie is pretty much 1.2 in the mornings I see her before she drops her son off. She 13 may brief me on, you know, anything t}iat, I need to know, if 14 he was sick, if he would be picked up by anybody besides 15 her, if he needs anything. In the afternoon I see her and I 7.6 pretty much update her on Tony's day, good or bad. That's l7 about it. 18 Q Is she on time with payment? 19 A Yes. Every Monday. 20 Q Have you ever had a pro},~lem with that? 21 A iJo problems . 22 Q And does Tony come to daycare in clean 23 clothes? 2.4 A Yes, he does. There's never been a time 25 where Tony came in dirty clothes. 6~ • ~ 1 Q Is he dressed appropriately for the weather? 2 A Yes, he is. 3 Q And does he seem clean, you know, groomed? 4 A Yes, he does. 5 Q And have you ever had t=}re opportunity in the 6 little -- almost a year of providing daycare to Tony to 7 change his diapers? A When he first came, yes, I did. Recently 9 he's been using a potty a lot better, and I don't get to, 10 you know, look at brim or, you know, see his body or change 11 hire at. all recently. There may have been a time in the 1?_ past, you know, month or so that maybe lre had an accident on 13 his clothes, but, you know, nothing like before when he was 14 getting potty-trained. 15 Q And have you ever had the opportunity to 16 change his clothes at daycare, you know, if he spilJ_s or 17 needs a fresh set of clothing? 18 A Yes. 19 Q Okay. Have you ever noticed any bruising on ?_0 Tony that caused you alarm? 21 A No, not anything particular. I do know that 2.2 Tony -- you know, like I said, he's a very active child. He 23 does have children that he does play with in the daycare. 24 Little boys can be rough, and they do rough play at times, 25 and, you know, besides, you know, a bruise or something from 67 • • 1 him playing, that I am aware of because he tells me, or his 2 mother informing me. You know, usually he plays with other 3 little boys. 4 Q So you've never_ been concerned that Antonio 5 was being mistreated? 6 A No, no. No signs at all. ~~ Q And isn't i_t true that based on state law 8 you're a mandatory reporter of suspected child abuse? 9 A Yes. As a childcare provider it is my duty 1.0 and responsibility that if I have any -- you know, am 11 suspecting of any child abuse or anything of foul play, I do 12 have to write a report and contact Children and. Youth. 13 Q So is it safe to assume that if you suspected "14 anything was going on with Tony that was inappropriate, that 15 you would contact the authorities? 16 A Yes. Yes. 1~ Q And you've never had. any suspicions? 18 A No, none. 19 Q Have you had the opport~.rnity to observe Tony 20 interacting with his mother? 21 A Yes. 22 Q How would you describe tl-rose interactions? 2.3 A Oh, wow, Stephanie is a very concerned 24 parent. Just, for instance, in the mot:ning when she drops 25 him off, she does kiss him good-bye. You know, she tells E8 • • 1 him to have a nice day. She informs hi.m. You know, if 2 she's not there to pick him up, you know she keeps us 3 .informed about everything. She does a very good job with 4 Tony. 5 Q Have you noticed during her interactions Tony 6 being affectionate to his mother? A Yes. He 1_oves his mother. He doesn't let 8 he r_ leave the center without giving her a hug and a kiss. 9 Q And did you have the opportunity to testify 10 in this courtroom in August of this year for a Protection 11 from Abuse hearing regarding `T'ony and her other child 12 Mariah? 13 A Yes. 14 Q And did you have the opportunity to wail in 15 the hallway before your testimony? 16 A Yes. 17 Q And can you tell the Court if -- while you 18 were waiting to testify in the hallway, if anything unusual 19 Happened in the hallway? 20 A In the trallway, I was otzt there with some 21 other witnesses, I guess, you know, farriily members and 22 friends, and I did overhear them speaking about Stephanie 23 and her counseling sessions and how she is a bad mother and 24 how they were going to do everything they could to make sure 25 that Tony was iri their custody. 69 • • ~- Q And do you know if Mariah, her daughter, was 2 present during these conversations? A Yes, she was present. She also was active in 4 the conversation. They were pretty much, you know, verbally 5 bashing Stepha nie, and she participated in the conversations 6 like she was a n adult. ~ Q I'm sorry. Like what? 8 A Like she was an adult. 9 Q Like she was an adult`? 10 A Yes. 11 Q Okay. So you overheard witnesses for the 12 Defendant talki ng very negatively in front of Mariah? 13 A Yes. 14 Q Did what you hear concern you? 15 A Yes. 16 Q Why did it concern you? 17 A Because Stephanie is a good parent. I mean, 18 like I said, I' ve known her for almost a year now, and once 19 `T'ony leaves my center, I have no worries about him because I 20 know Stephanie' s a good parent. Like I said, he comes to 21 daycare clean. He's fed. His needs -- she always meets his 22 needs. Like if. he would need extra clothes, if he would 23 need supplies f or daycare, she's there. And anything. Her 2_4 payments, she's never late, ever. 25 Q Does Tony seem like a Happy kid? 70 • • 1 A Tony seems like a happy kid. He is a happy 2 kid. 3 Q Is he a pleasant child? 4 A Yes, he is, very pleasant. 5 Q To you, does he appear well adjusted? 6 A Yes. ~ Q Why do you laugh when you say that? 8 A Because Tony -- when. Tony first came, it was 9 a little hard for_ him to adjust, but after, you know, him 10 getting used to the program and. meeting new friends, it was 11 just like he' s been there forever. Very well adjusted. 12 MS. PINSKER: Thank you. I have no further 13 questions, Your Honor. 14 THE COURT: Ms. Tomeo. 15 CROSS EXAMINATION 16 BY MS. TOMEO: 17 Q Ms. FI_emister, isn't it true that you and 18 Ms. Harper ar e personal friends? 19 A No, that's not true. If it's not during 20 business hour s, me and Ms. Harper usually don't speak. She 21 may ask me a question that has to do ol.rtside of work, but we 22. never speak a fter work. 23 Q Okay. And isn't it true that if Tony has no 24 bruising that -- let me rephrase that. Isn't it true that 25 if you're not changing his diapers and whatnot, that if 71 • • 1 there ar.e bruises on his body, that that would be covered by 2 clothing and you wouldn't be able to see them? 3 A That i_s true to a certain extent. 4 Q So you couldn't necessarily state whether or 5 not he's been coming in with no bruising if it's covered by 6 clothing, correct? 7 A Being that he is in daycare and things -- you 8 know, we do get messy sometimes. I do at least change him 9 once a week. His clothes, 1 could change them, like I said. 10 You know, we do get messy. So I do get to see him often. 11 It's probably not, you know, down to his -- you know, his 12 bottom like I would change him if he was being 13 potty-trained, but I do get to see hirn. 14 Q If you can recall -- you testified at the PFA 15 hearing that we had in August. Did you not state that it 16 had been at least a month since you had seen Tony without 17 any clothes on? 18 A I believe that was in July, but it is now 19 October, and like I said, I do get to see him often. 20 Q So now you get to see h_m on a weekly basis 21 whereas before i_t had been on a monthly basis? 22 A Well, everything that's going on with Tony is 23 really starting to take effect that I t-lave seen visually, 24 and like I said before, he was a lot more independent. He 25 did things on his own, but now, you know, things are 72 • • 1 starting to change as far as hi_s actions, and, you know, 2 things -- how he handles things, and I don't know if he's 3 being more careless than he used to be or he's craving 4 attention or -- but, you know, I do qet to see him more 5 often than on a monthly basis now. 6 Q Are you stating that he's having almost some 7 regression issues? 8 A I wouldn't say regressi_orY. More like just 9 craving f_or_ attention. 10 Q And do you believe that has anything to do 11 with the fact that Ms. Harper is his primary caregiver? 12 A No. T think that's dl_ze to everything in 13 general that's going on with him. He's seen and experienced 14 a lot of different things so... 15 MS. TOMEO: I have no further questions. 16 `t'HE COURT: Ms. Pinsker. 17 MS. PINSKER: Thank you, Your Honor. 18 REDIRECT EXAMINATION 7.9 BY MS . PINSKER: 20 Q Ms. Flemister, as you testified to, Tony 21 recently started kindergarten, correct? 22 A Yes. 23 Q That's a big change for a kid, correct? 24 A Yes, it is. 25 Q Have you noticed any changes in his behavior 73 • • 1 since he started kindergarten and the new schedule? 2 A Tony -- he's a little bit more distant, and 3 he's around different kids. He's not around the same kids. 4 You know, he's out of daycare. You know, 8 hours a day he's 5 in a different program, and he's being subjected to 6 different kids, different friends, and he may be picking up 7 a little bit, you know, bad habits, meaning he may not -- he 8 may not respond, you know, instantly like he used to. Like 9 if I as}c him to do something, you know, he'll probably wait 10 f_or a few minutes or, you know, think that -- or try to 11 ignore me. 12 Q And in your experience as a childcare 13 provider, is this typical? 14 A Yes. Very. 15 MS. PINSKER: Nothing further, Your Honor. 16 MS. TOMEO: One additional question, Your 17 Honor. 18 RECROSS EXAMINATION 19 BY MS . 'I'OMEO 2U Q In your experience as a childcare provider, 21 can these also be signs of possible abuse in the home? 22 A I can't say. I actually think that a child's 23 actions could not be predictable. I mean I have never, you 24 know, seen Tony act the way that he }ras, but... 25 Q Is it possible? 74 • • 1 A Is it possible? I think anything's possible. 2 MS. TOMEO: That's all I have. 3 THE COURT: Ms. Pinsker_. 4 REDIRECT EXAMINATION 5 BY MS. PINSKER: 6 Q But again, Ms. F'lemister, you have lrad no 7 reason to be concerned for Tony's physical safety since he's 8 been at your daycare'? 9 A No. 10 Q Cor rect? 11 A Not at alt. Correct. 12 Q And your testimony today is you have no 13 concerns? 14 A No. 7-5 Q You have no concerns of Tony being with his 16 mother full time? 17 A I have no concerns witl_r him being with his 18 mother_ full time. 19 MS. PINSKER: Thank yo~z. Nothing further, 20 Your Honor. 21 THE COURT: Ms. Tomeo. 22 MS. TOMEO: I have nothing further. 23 THE COURT: All rigYit. You may step down. 24 Thank you. May thi s witness be excused? 25 MS. PINSKER: Yes, Your Donor. 75 • • 1 2 3 ~~ 5 6 7 8 9 10 11 12 13 14 15 16 17 18 I9 2.0 21 2?_ 23 24 25 MS. TOMEO: I have no problems with that. THE COURT: You may stay or leave as you choose. Thank you. MS. PINSKER: I would like to call Cindy Keller, Your Horror_ . Whereupon, CYNTHIA KELLER having been duly sworn, testified as follows: DIRECT EXAMINAT:IOTI BY MS. PINSKER: Q Could you please state your name for the record? A Cynthia Keller. Q And where do you live`? A 124 Crestview Village, Middletown, PA. Q And are you employed? A Yes. Q Where do you work? A Allegheny Valley School. Q And what do you do there? A Home Manager Aide. Q What is that? A That's working with mentally-challenged adults. Q Okay. And how long have you been doing that? 76 • 1 A Five and a half years. 2 Q How do you know Stephan_i_e Harper? 3 A We work together. '~ Q And how long have you worked together? 5 A 'T'hree years . 6 Q And what does Stephanie do at the school, to 7 your knowledge? ~ A She goes out to houses in the morning -- 9 THE COURT: I'm sorry. I'm having trouble 10 hearing you. Could you speak right into the microphone, 11 please? 12 THE WITNESS: She i.s a program aide in the ]_3 room that I work i_n, plus she also goes out to houses in the 14 morning to h elp get residents ready to come into work. 15 BY MS. PINSK ER: 16 Q Do you know her son, Tory? 17 A Yes. 18 Q And how long have you known Tony? 19 A Like 3 years. 20 Q How do you know -- I mean how do you know 21 Tony? 22_ A Me and Steph do stuff to~.~ether outside of 23 work. We've gone to carnivals, amusement parks. We've gone 24 out to eat. We shoot basketball with them, and then I watch 25 him two nights a week when Steph works overtime. 77 1 2 3 4 5 h 7 8 9 10 11 12 7.3 14 15 16 17 18 1.9 20 21 22 23 24 2_5 U Q nights a week? A Q A Q they change? A Q watch him? • And how long have you been watching him two For 2 1/2 years, something like that. And how often do you do that? Every week for two nigt-its. Are they the same two nights a week or do They've been Monday and Wednesdays now. Okay. And what's the period of time that you A I pick him up usually anywhere between 3:30 and 4 and watch him until quarter after 9 at night. Q Okay. And then does Stephanie pick him up? A Yes. Q And do you provide him dinner when you watch him? A Yes. Q Okay. And do you give him a bath? A Yes. Q Do you give him a bath every time you watch him? A Mostly every time. I didn't at first, and then we started doing that so it was easier for Steph to get him home and get him ready for bed. Q What kind of kid is Tone'? How would you 78 • • 1 describe him? 2 A Tony's a very outgoing, Happy, healthy boy. 3 He's very ac tive. He loves just doing all kinds of 4 different st uff. He does Play Station. He loves being 5 outside just running around in the yard. Playing on the 6 swings. ~ Q And you said you give Tony a bath often, 8 correct? 9 A Yes. 10 Q Have you ever -- have you ever observed 11 anything out of the ordinary about Tony during a bath? Any 12 bruising or any marks that caused you concern? 13 A No. 14 Q Have you observed bruising on Tony? 15 A Just one time. 16 Q When was that? 17 A That was just a couple weeks ago. 18 Q And what did you observe'? 19 A A bruise on his butt. 20 Q Did you ask Tony about it? 2.1 A Yes. 22 Q What di_d he say? 23 A He said it didn't happen at home. I asked 24 him a couple other questions to see if he would answer. 25 When I asked him if it happened at school, he clammed up and 79 • • 1 didn't say anything, but a]_1 the other questions he answered 2 no. 3 Q So did you think he just didn't want to tell 4 you it ha ppened at school? 5 A Yes. 6 Q Okay. Have you ever had any reason to be 7 concerned for Tony's safety while he's i_n the care of his 8 mother? 9 A No. 1.0 Q Never? 11 A Never. 12 Q Have you had the opportunity to observe 13 Stephanie interacting with Tony? 14 A Yes. 15 Q Okay. And what have yot.i observed? 16 A I observed a very caring, loving mother that 17 cares for her son a lot. She just loves and adores her son, "18 and. Tony l oves his mother. 19 Q Have you observed them f:~eing affectionate 20 together? 2_1 A Yes. Plenty of times. 22 Q Have you ever observed. Stephanie disciplining 2.3 Tony? 24 A She's put him in time-out a couple of times 25 when I've been around, but that is all I've ever seen her 80 • • 1 do. 2 Q Have you ever observed her inappropriately 3 disciplining P ony? 4 A No. `~~ Q Do you know Joe Tress_ler, Tony's biological 6 father? ~ A No. 8 Q Are you aware that he flas been visiting with 9 Tony recently? 10 A Yes. 11 Q Does Tony ever talk to you about the visits? 1.2 A N o . 13 Q He's never made any remarks? 14 A No. 15 Q So he doesn't even talk about his dad or 16 wanting to see his dad? 17 A No. 18 Q And are you aware that 'T'ony recently started 19 kindergarten? 20 A Yes. ?_1 Q Does he seem to like it? Has he spoken to 22 you about it? 23 A Yes. He talks about kindergarten and about 24 school. 2_5 Q Have you ever helped hi.rn with his homework? 81 • ~ 1 A Yes. 2 Q Does he seem to like i_t=? 3 A It's a little challenging to get him to do 4 his homework, but he eventually does it. 5 Q Do you think it's been somewhat of a change h for him? ~ A Going to school? 8 Q Um-hum. 9 A Yeah, it's a change. I:t's something 10 different in his life. 11 Q From your observations, does Stephanie seem 12 like a stable parent for Tony? 13 A Yes. 14 Q Is she a good co-worker'? 15 A Yes. 16 Q Does she do her job wel]_, i_n your opinion? 17 A Yes. 18 Q Have you ever had any problems with her at 19 work? 20 A No. 21 Q Okay. And you said slie cares for 22 mentally-challenged adults? 23 A Right. 24 Q Is that correct? 25 A Yes. &2 • • 1 Q And you've only observed her being 2 appropriate with the people that she cares for? 3 A What was that question? 4 Q And have you only observed her being 5 appropriate with the people that she takes care of? 6 A Yes. ~ Q Does Stephanie ever talk to you about her 8 kids? 9 A Yes. 10 Q Does she ever talk to you about this current 11 custody situation? 12 A Yes. 1.3 Q Has she ever talked to you about what her 14 concerns or fears are regarding this custody situation? 15 A Yes. 16 Q And what did she say they were? 17 A Her biggest concern is :Losing her kids. 18 Q Is she concerned about losing Tony? 19 A Yes. 20 MS. PINSKER: I don't 1-lave anything further 21 at this tune, Your Honor. 2.2 THE COURT: Ms. Tomeo. 23 CROSS EXAMINATION 24 BY MS. TOMEO: 25 Q Ms. Keller, you stated you had a conversation 83 • . 1 with Tony about the bruise on his bottom, correct? 2. A Excuse me? 3 Q You stated that you had a conversation with 4 Tony concerning the bruising on hi_s bottom, correct? 5 A Yes. 6 Q And you stated that he told you that it di_d 7 not. happen at home? 8 A Yes, that's correct. 9 Q Do you not believe that he would have been 10 more apt to te ll you that it had happened at school if it ]_1 didn't actuall y happen at school? ]-2 A No. 13 Q In your experience wit}i -- do you have any ]_4 children of yo ur own? 15 A No, I don't. 16 Q In your experience with, you know, 17 5 year old chi ldren or_ small children that you come in 18 contact with, do t}iey have a tendency to lie in general, 19 tell stories, fibs, whatnot? 20 A Children can. 21 Q So it i.s possible that }ie was lying to you 22 when you asked him where he received the bruise, correct? 23 A No, I don't think Tony was. 2.4 Q It's possible, correct? 25 A I don't think Tony was lying at all. If it 84 :7 • 1 had happened at home, he would have said so. 2 Q You're not answering my question. Is it 3 possible? 4 A No. 5 Q You're saying it's not ~~ossible? 6 A No. That he was lying about it'? Q Yes. 8 A No, I don`t believe so. 9 Q So you're stating 100 percent that. you 1.0 believe that he absolutely -- there's no possibility under 17_ the sun that he was fibbing or lying, you know, a 5 year 12_ old's sense of the truth, tellinq you a story? 13 A I believe he was telling me the truth that it 14 did not happen at home because I eventually asked him, and 15 he said no to t he question. I asked lli_m if it happened at 16 school and then he didn't say anything. 17 MS. TOMEO: Okay. That's all I have. 18 REDIRECT EXAMINATION 19 BY MS. PINSKER: 20 Q Ms. Keller, did you talk to Ms. Harper about 21. the bruise? 22 A Yes. She actually told me that day that he 23 had a bruise on him that she had seen the night before. 24 Q Was she concerned about the bruise? 25 A Yes, because she didn't know where it came 85 1 2 3 4 5 6 .~ 8 9 10 11 12 1.3 14 15 16 17 18 19 20 21 22 23 2_4 25 • from. • Q Did Tony recently express to you concerns he had for his mother's safety due to Mr. Tressler? A The one time when I was giving Tony a bath a couple weeks aqo, Tony came out and he said, my daddy better not ki1.1 my monuny. Q What dial you say? A I looked at him -- he said my daddy has a lot of guns, and he better not hurt my mommy. Q Was this out of the blue? A Yeah. I was just givi.rlg him a bath and he just came out and said that. Q Was -that the end of that conversation? A Yeah, because I just -- .C didn't know what to say to him, and I told Stephanie the next day at work what happened, you know, for her to ask him what he meant by that. Q Okay. Does Tony usually make comments like that? A No. That was the only tune he ever did. Q Were you concerned when he made that comment? A Yes, I was. MS. PINSKER: Nothing further, Your Honor. THE COURT: Ms. Tomeo. 86 • • 1 RECROSS EXAMINATT_OIJ 2 BY MS. TOMEO: 3 Q Ms. Keller, does it not surprise you that 4 Tony decides to tell you these stories and no one else? 5 A No, because I think when Tony thinks of 6 something he just comes out and says it:. You know, if he's 7 thinking about something, he will come out and tell, you 8 know, whoever's there at that point. 9 Q Do you not find it unusual that when he tells 10 you these things, you're the only one t: hat -- you're the 11 only one present, so there's no one to corroborate? 12 A No, because I think he would have said it if 13 there was other people around. 14 MS. TOMEO: That's all L have. 15 THE COURT: Ms. Pinsker. 16 MS. PINSKER: Nothing further of this 17 witness, Your Honor. 18 THE COURT: You may step down. Thank you. 19 May this witness be excused? 20 T1S. PINSKER: She may, Your Honor. 21 MS. TOMEO: No objection. 22 THE COURT: You may st=ay or leave as you 23 choose. Thank you. ?_4 MS. PINSKER: Your Honor, I can offer another 25 witness that should be brief in nature, if Your Honor would 87 1 2 3 4 5 6 7 8 9 10 11. 12. I3 14 1J 16 17 18 19 20 21 22 23 24 25 • like. • THE COURT: Well, I don't want to tell you how to present your case. You.'ll have to decide what you want to do. MS. PINSKER: I'm noticing the clock, and I certainly can present another witness. You know, I can certainly present her testimony in the amount of time that I have left. THE; COURT: All right. We can certainly conti.rlue until at least 4:15. MS. PINSKER: Certainly. I would like to call Joan Martin. Whereupon, JOAN MARTIN having been duly sworn, test.if_ed as fol.locas: DIREC`T' EXAMINATION BY MS. PINSKER: Q record`? A Q A A 4 Can you please state you r_ name for the Yes. I'm Joan Martin. And where do you live`? Middletown. And are you employed? Yes, I am. Where are you employed? 88 • • "1 A Allegheny Valley School. 2 Q And what do you do there? 3 A I work in the P.T. department. 4 Q What does that mean'? What do you do? 5 A I do physical treatments with the residents 6 that live there. 7 Q And how long have you been doing that? 8 A Eleven years. g Q Okay. Do you know Stephanie Harper.? ]_0 A Yes, I do. 11 Q How do you know her? 12 1~ From work. When she first started work 2, 13 2 1/2 years ago. 14 Q And do you ]chow her in a different context 15 now`? 16 A Yes, I do. l~ Q Okay. What is that context? 18 A She lives with my son. 19 Q And when -- how long has she been _living with 20 your son, app roximately? 21 A I think it was since May or June. 22 Q Of what year? 23 A Of this year. 24 Q So you knew her before she began dating your 25 son, correct? 89 • • 1 A Yes. 2 Q And do you know Tony, her son? 3 A Yes, I do. 4 Q And how long have you known Tony? 5 A About since June. May or June. 6 Q Of what year? 7 A Of 2006. g Q Okay. What kind of interactions have you had 9 with Tony? 10 A Oh, I've been up there. I have my grandson 11 every Thursda y, and I go up with my g:t.~andson, and Tony's 12 always there, and those guys play together, and Tony's been 13 to my house . 14 Q You said your grandson. Does your son have a 15 child from an other marriage or another relationship? 16 A Yes. 17 Q Okay. And you said that that child visits 7.8 the house? 19 A Yes, he does. 2.0 Q Okay. And how old is that child? 21 A Four. 22 Q Okay. And do you have an opportunity to 23 observe your grandson and Tony interacting? 24 A Oh, yes, definitely. 25 Q Can you describe that interaction? 90 • • 1. A Well, they get along real. well. They enjoy 2 each other's company. 3 Q What have you seen therm doing? 4 A Riding bikes. They were just at my house 5 yesterday. T hey were playing with the trains that they have 6 at the house, the trucks. They have a lot of cars. 7 Q Okay. So they get along? 8 A Oh, yeah. They interact, real well. 9 Q Does Tony -- is he an active child? 10 A Yes. 11 Q Okay. You laugh when you say that. Why is 12 that`? 13 A Well, my grandson is too. He's a typical 14 5 year old ch ild. 15 Q Okay. So does he go outside a lot? 16 A Yes. 17 Q And play? 18 A Yes. 19 Q Based on your interactic-~n with Tony, does he 20 seem. like a h appy, well-adjusted child"? 21 A Yes. 22 Q And can you describe the interactions you 23 have observed between Tony and his mot}ler? 24 A Pretty much a typical Inc>ther child 25 relationship. 91 • 1 Q Okay. What does that mean? 2 A Well, you know, I have seen Tony come up and. 3 run and hug his mother and kiss his mother. I mean I don't 4 know what el se you want me to say. 5 Q Does he seem bonded to his mother? 6 A Oh, definitely. Oh, yea}r. .~ Q And obviously now your son is living in the 8 house? 9 A Yes. 10 Q And can you please describe the interaction 11 you've obser ved between your son and Tony? 12 A They seem to get along well together. 13 Q Okay. 14 A Corey's brought Torry down to my house, and 15 they seem to get along real well. 16 Q Does Tony seem to enjoy your son's company? ~-7 A Yes. Yes, very much so. Yes. 18 Q Why do you say that? Give me an example. 19 A Well, ]_et's see. Not too long ago, maybe a 20 week or so ago, they were down at the boouse, Steph and Tony 21 and my grandson, and Corey had to go somewhere, and Steph 22 was going to take the boys back to the blouse. Well, Tony 23 wanted to go with Corey instead of going back to the house 24 because he likes to be with Corey. 25 Q He likes to be with him? 92_ • • 1 2 3 4 5 6 .~ 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 ?_3 24 25 A Yes. Q Have you ever observed any interactions between Tony and Stephanie that caused you to be concerned? A No. Q Have you ever observed Stephanie disciplining Tony? A No, not really. Q And from your observations, is Stephanie a stable parent? A Yes. Q Do you have any concerns about your own grandson being in that household? A No, I do not. Q What would you do if you had any concerns? A I would probably not want him there at the House . Q But you said you don't have any concerns? A No, I don't. No. Q You did say that you work with Stephanie for two years, I believe? A Yes. Q What are your observations of her as a co-worker? A She's a very good worker, a hard worker. Q Does she seem to take good care of the 93 • • 1 residents? 2 A Oh, absolutely. Very conscientious, yes. 3 Yes. 4 Q To your knowledge, has there ever been any 5 problems with her at work? 6 A No, not to my knowledge. 7 MS. PINSK.ER: Thank you. I don't have any 8 further questions, Your Honor. 9 THE COURT : Ms . 'I'omeo . 10 CROSS EXAMINATION 11 BY MS. TOMEO: 12 Q Ms. Martin, I would dust like to clarify a 13 couple of things. You stated that you've known Tony since 14 I~Zay or June of 2006? 15 A Yes. 16 Q So you have observed interactions between 17 Ms. Harper and Tony dating back to only May or June of this 18 year, correct'? 19 A I have to say yes. 20 Q You don't know Tony very well then, correct? 21 A As well as you can know a 5 year o.1 d, you 22 know. 23 Q You haven't known him for that long of a 24 period of time? 25 A Well, that's true. Ttlat's true. 94 • • 1 MS. TOMEO: That's all I have. 2 THE COURT: Ms. Pinsker. 3 MS. PINSKER: Nothing further, Your Honor. 4 BY THE COURT: 5 Q What does your son do for a living? 6 A He is a forklift operator for Arnold 7 Logistics. 8 Q For what? `~ A For Arnold Logistics. 10 Q And he works full time'? 11 A Yes, he does. 12 Q How long has he done that'? 13 A Well, he's worked for Arnold Logistics a 14 coL1p1P_ years. I'm not sure how long. 15 I'HE COURT: Okay. You may step down. Thank 16 you. May this witrress be excused? 17 MS. PINSKER: She may. `Thank you. 18 MS. TOMEO: Yes, Your Honor. 19 THE COURT: You may stay or leave as you 20 choose. Thank you. 21 MS. PINSKER: Your Honor, at this point I 2?_ have two witnes ses left. One of them being my client, the 23 other being Cor ey Rosenberry, her current live-in boyfrienc~l, 24 and I can begin testimony, but it would. be interrupted 25 testimony since there i_s no way for me to complete the 95 ~_~ 1 2 3 4 5 6 .~ 8 9 10 t1 12 13 14 15 1.6 17 18 19 20 21 22 23 24 25 testimony. • THE COURT: Well, we cari at least start it. MS. PINSKER: I'm sorry, Your Honor, what? `I'.HE COURT: I would at least start i_t. We have 20 minutes. MS. PINSKER: Your Honor, I'd like to call Stephanie Harper to the stand. Whereupon, STEPHANIE; HARPER having been duly sworn, testified as follows: DIRECT EXAMINATIOP~ BY MS. PINSKER: Q Could you please state your name for the .record? A Stephanie Harper. Q And do you reside in Middletown, Pennsylvania? A Q A Q A Q A Q Yes, I do. And do you work? Yes, I do. Where do you work? I work for Allegheny Valley School. What do you do there? I work with the mentally handicapped. What do you do with the mentally -- what do 96 • ~ 1 you do for the mentally handicapped? 2 A We take care of their needs on a daily basis. 3 I'm sorry. I' m a program aide f_or a program structured in a 4 classroom sett ing with 15 residential clients. We take care 5 of them, makin g sure that they get fed and their 6 gastrostomies get hooked up, positioning the residents. We 7 do goals with them on a daily basis. 8 Q And how long have you worked there? 9 A Approximately -- almost 3 years. Well, 10 actually 3 yea rs. 11 Q Are you full time there? 1.2 A Yes, I am. 13 Q Are you currently married? 14 A Yes, I am. 15 Q And what is the status of that marriage? 16 A Just waiting for a divorce decree. 17 Q Okay. And how long have you been separated 18 from your soon to be ex-husband? 19 A We were separated in July 2004 when he went 20 to jail. 21 Q What was his name? 22 A Joseph I3arper. 23 Q Do you know why he went t;o jail? 24 A Yeah. He tried to kill me. 25 Q Okay. Do you know the charges that he went 97 • • 1- to jail on? 2 A There was 12 charges. A lot of them got 3 knocked of_f because he pled guilty. 4 Q Okay. And do you know -- to your knowledge, 5 what sentence di_d he r_eceive`? 6 A Four to eight years with additional -- when 7 he gets out of jail, he has to register as a sex offender. 8 Q Okay. And so when do yo~z anticipate your 9 divorce from him being final? 10 A I think the end of October, beginning of 11 September of this year. 12 Q So you're hoping soon'? 13 A Yes. -14 Q Okay. And do you have any children with 15 Mr. Harper'? 16 A No. "17 Q Can you state the names and ages of your 7.8 children? 19 A Marian Kaylee Tr_essler, born December 27th, 20 1994. She is 11. And Antonio Napoli.tan. fie is 5 years 21 old, and he was born August 20th, 2001. 22 Q And is it correct that Marian lives with her 23 father on a full--time basis? 24 A Yes. 25 Q And is it correct that Tony resides with you? 98 • ~ 1. A Yes . 2 Q And is it correct that you are currently 3 expecting your third child? 4 A Yes. 5 Q And who is the father o[- that child? 6 A Corey Rosenberry. Q And is he your current boyfriend -- or he's 8 your boyfriend '? 9 A Soon to be husband, I hope, at some time. 10 Q Do you anticipate marrying him once your 11 divorce is final? 12 A Yes, I do. 13 Q Okay. And are you currently living with him? 14 A Yes, I am. 15 Q And how long have you been living with him? 16 A Since -- I have known him since November. 17 His mother introduced me to hirn, but we've been living 18 together since April 29th of this year. 19 Q You're appearing very visibly upset at this 20 time? 21 A Yes, I am. 2.2 Q Can you please explain to the Court why 23 you're upset? 24 A For numerous reasons. I: risk losing my son, 25 you know, whom I love very much. 99 • • 1 Q Let's take a step back. When did you marry 2 N1r. Tress_ler? 3 A September 28th of 1987. 4 Q Okay. And when was your daughter born? A She was born December 27th, 1994. 6 Q And after she was born, who took care of her? 7 A Me. 8 Q Okay. Who made sure that she was fed and 9 clothed and diapered? 10 A Me. 11 Q Okay. Did at any point during your marriage 12 to Mr. Tressler. -- did you have the opportunity to file a 13 Protection from Abuse action against hi_m'? 14 A yes. 15 Q Do you recal_1 what year ghat was? 16 A 1999. 17 Q Do you recall what county that was in? 18 A Cumberland. 19 Q This county? 20 A Um-hum. 21 Q And do you recall whether or not you obtained 22 a final protection order against Mr. `I't:essler? 23 A yes. 24 Q Do you recall when you separate -- did you 25 separate from Mr. Tressler at that tune'? 100 • • 1 A Yes, we did. 2 Q How long were you separated for? 3 A I would say it was a year and a half that we 4 separated. fie told me he was getting anger management. He 5 said he did four months of it. 6 Q And was there a custody provision in that 7 final PFA? ~ A I'm sorry? 9 Q Was there a custody provision in that final 10 P FA ? 17- A Yes, there was. 12 Q Do you recall the ter_rns of that provision? 1-3 A I maintained primary physical custody of 14 Ma.riah, and he enjoyed three weekends a month. 15 Q And did you and Mr. Pressler reconcile at any 16 point after your first separation? -~ A Yes. 18 Q How long did you reconcile for? 19 A Let's see, I think l1e left after December, 20 after Christ mas. I think it was 2000 when he actually left. 21 So I would s ay we were together for like maybe 5 months, 22 h months, ma ybe not even that. 23 Q When you reconciled, you mean? 24 A Yeah, when I went back. 25 Q During the reconciliation, did you become 101 • 1 pregnant with Tony? 2 A Yes. 3 Q Okay. And were you arld Mr. Tressler 4 separated when you gave birth to Tony? A Yes. 6 Q Did Mr. Tressler, after- Tony was born, ever 7 ask for any visitation with him? 8 A No. 9 Q Did he ever have any contact with him? 10 A No. ~-1 Q What happened when you filed for child 12 support= for Tony? What did Mr. Tressler_ do? 13 A He demanded a DNA test. 14 Q Was there any doubt ire your mind that he was 1.5 the father? 16 A No. Absolutely none. 17 Q So what happened when rye asked for that DNA 18 test? 19 A They granted it to hire, and they requested 20 all parties, including the baby, Joey, and I to show up for 21 the DNA test ing at Domestic Relations. 22 Q Did you submit to that testing? ?_3 A Yes, I did. 24 Q To your knowledge, did P9r. Tressler submit to 2.5 that testing ? 102 • 1 A No, he did not. 2 Q Okay. What happened after that with your 3 support order? 4 A I'm sor ry? 5 Q At any point after that, did Mr. Tressler. h admit: patern ity? ~~ A Yes, he did. 8 Q On his own? `~ A Right. Afterwards. 10 Q Without DNA testing on 1l .is part? 11 A Rigtrt . 12 Q Was the support order entered for Tony? 13 A Yes. 7-4 Q And at that point did Mr. Tressler ever 15 request any visitation of_ Tony? 16 A No. ~-~ Q So from your recollection, did he request any 18 visitation p rior to filing this custody modification this 19 past summer? 20 A No. 21 Q So he never was a part of your son's life? 22 A No. 23 Q And was that because he did not request it? 24 A Right. 25 Q In the interest of time, I'm going to skip 103 • • -1 ahead a little bit, since we're going to be wrapping up 2 soon. As you know, we're here because Mr. Tressler filed. a 3 modification of custody, and he also filed a PFA? 4 A Ri glit . Q And that PFA order was entered in August, and 6 you are sti.11 obviously a]_lowed to have contact with your 7 children, your son. was not removed from your care. Have you 8 had any contac t with Mariah since the entry of that final 9 order? 10 A No, I have not. 7-1 Q Why not? "12 A Due to her testimony to the Judge. I do not I3 feel safe with the fact -- I feel she chid not tell the 14 truth, and I do not want to risk -- you. know, I'm pregnant. 15 I don't want to risk going to jail because my daughter lied. 16 Q Now, the PFA order suggested that you begin 17 parenting classes and anger management cl_asses`? 18 A That' s right . 19 Q Have you done that? 20 A Yes, I have. 2_1 Q Which classes have you. taken? 22 A Parenting. 23 Q Okay. When did you start the parenting 24 classes? 2.5 A Two weeks ago. 104 • ~ 1 2 3 4 5 6 7 8 9 10 17_ 12 13 14 15 16 17 18 19 20 21 ?_2 23 24 25 Q that? A 4 A Q A Q A Q classes? A No, not yet. Q Why not? A Because classes are at the same time on the same day. They're on a Saturday, and they begin at 10:00, and that is when my c)_asses are. So i_t. was impossible for me to take both classes at the same time. Q When you finish witYr the parenting classes, are you going to take the anger management classes? A Yes, I am. Q And have you ever been involved in any other counseling in the past? A Yes, I have. Q Cou)_d you please describe for the Court the nature of that counseling? Why didn't you start them any sooner than Because that's when the classes began. Where are you taking tlic:se classes? Through Parent Works. And how often do you have the classes? Every week. Once a wee]; on a Saturday. Do you know how many more classes you have? I have two more. Okay. And have you started anger management 105 • • ~- A I am still involved with domestic violence. 2 I still see a counselor. I've been seeing her for three 3 years, and I was a1_so in counseling with my mother for 4 issues of_ ab use that was afflicted upor~i me, with her 5 knowledge, b ack when I was 19 or 20. ~ Q Have you ever been diagnosed with a mental 7 health condi tion? B A I have -- I_'ve never bePrl diagnosed with. 9 bipolar, but -- I forgot what they ca11 it, something 10 depression. 11 Q Have you ever been treated for that 12 diagnosis? 13 A Yes. Oh, yes. 14 Q Describe to the Court trre nature of that 15 treatment. 16 A T~Iedication. 17 Q Okay. And are you currently on medication? 18 A Oh, no. 19 Q Why not? 2U A I'm pregnant. 21 Q Would you be on medication right now if you ?_2 we.r_e not pregnant? 23 A Yeah, I would still be on it. 24 Q You heard your mother and your sister testify 25 about your pr oblems with anger management? 1U6 • • 1 A Right. 2 Q Do you th-ink you have a p.r_oblem with anger 3 management? 4 A No, I don't. 5 Q Why would they testify to that? 6 A I don't know. The only thing 1 can think of 7 is revenge because I haven't seen them. I haven't spent any B time. I_ have a lot of issues with my mother, and I've 9 always liad problems with her. 10 Q Would you describe your relationship with 11 you r_ mother as strained or estranged? 12 A Yes. ~-3 Q Do you wish it were dif-[-e.rent than that? 14 A Yes. 15 Q Let's talk about Tony. Describe his _l6 personality t:o the Court. 17 A He's humorous. 18 Q What do you mean by that? 19 A A funny child. Just stuff he says, you know, 20 coming from a 5 year old. He's very fi_lnny, humorous. He's 21 a very active child. He's a very loving child. 22 Q Has he started kindergarten this year? 23 A Yes, he did. 24 Q Where is he at school? 25 A Reid Elementary. 107 • • 1 Q And when does he go to school? 2 A He's -- we11, I drop hurl off at daycare, and. 3 then the bus takes hirn from tie daycare to the school. 4 Q Is he in kindergarten for_ a half day or a 5 full day? ~ A He's in kindergarten for a full day. ~ Q What's the name of his eachers? 8 A Mrs. Coy. 9 Q Have you been in contact with his teachers? 10 A Yes. _11 Q Does Tony seem to like school? 12 A Yeah. It's a change for him because he's 13 used to a daycare atmosphere, and now rye actually has to 14 work so... 15 Q Cou]_d you describe to the Court what a 16 typical weekday :is like for Tony at your house? 17 A Yeah. Typical, normal, we get up in the 18 morning. I wake him up. I get myse LF ready for work. 19 Then I wake h im up last, get him dressed., give him a kiss. 20 We go to the bathroom, he brushes his teeth, and I do his 21 hair for hi_m, and then I qo to work -- or_ I drop him off at 22 daycare aroun d 7:00, talk to Ms. Alistla for a few minutes, 23 and just get a heads-up or whatever, or she'll give me a 24 heads-up, and then I go to work. And then sometimes it will 25 be me that pri cks him up or sometimes it will be Corey or 108 • • 1 Cynthia. 2 Q And then what happens in the evening at your 3 house? 4 A When we come home or I pick him up from 5 daycare, and we come home, and he gets the mail out of the 6 mailbox for_ me, and he'1]_ play for a little bit. We have a 7 huge bac k porch. He likes to hurry up and jump on his four 8 wheeler. Generally we have dinner about 5:30, 6:00. `~ Q Okay. 10 A He plays for a while. Right after supper 11 through h e works on his homework. He gets worksheets every 12 day that we have to work on so... 13 Q What time does he usually go to bed? 14 A Nine. 15 Q Much has been made today of allegations that 16 you have been. continuing to physically abuse your son. Have 1.7 you ever intentionally physically hurt your son? 18 A No. This is totally ridiculous. 19 Q Why is it ridiculous? 20 A I'm not hurting Tony. I'm not doing anything 21 to Tony. 22_ Q Well, then how do you answer Mr. Tressler's 23 allegations that Tony has bruising? 24 A I mean I can't -- I'm at work 8 hours a day. 25 I don't know how he gets -- I know he fell one time on a 109 • • 1 school bus because he had his shoes untied. Tony's a very 2 active kid. I mean he's constantly falling off his bike or 3 going for bike rides, you know, scraping his arm. You know, 4 this i_s -- this whole thing is ridiculous. 5 Q Has Children and Youth ever been involved 6 with you? ~ A Not up until this point., no. 8 Q When was the last time they had contact with 9 you? 10 A Whenever I guess Joey ca1_led Children and 11 Youth. 12_ Q Would that have been -- 13 A About these allegations. _l4 Q Would that have been this past summer? 15 A Yes. 16 Q And did Children and Youth open a case 17 against you? ]_8 A No. 19 Q Did they have any requirements for you to 20 fulfil]_ based on the allegations? 21 A No. 22 Q Were there ever any charges filed, to you r_ 23 knowledge? 24 A No. 25 Q You heard Mr. Tressler testify about a recent 110 • • 1 bruising that he saw that concerned him'? 2 A Right. 3 Q Were you concerned about the same bruising on 4 Tony? 5 A Well, of course. Every bruise he gets on him 6 now, you know, comes back on me, you know. And, you know, I 7 have to worry about being arrested for a bruise on my son R that I am not doing. Yeah, I noticed 1~e had a bruise on his 9 butt Monday ni ght when I bathed him, you know. I got very 7.0 uL-~set. Of cou rse, I'm going to be upset. I'm under a PFA. 11 Q Did you ask Tony about the bruising? 12 A Yes, I did. 13 Q And what did he say? 14 A He said that he fell off -- he was running 7.5 and fell on the bus because he was running from a kid from 16 daycare, and he was chasing him trying t,o beat him to the 17 bus. Tony fal ls a ]_ot. He does fal:1 a lot, you know. 18 Q But you never intentionally inflict bruising 19 on your son? 20 A No. 21 Q Do you love your son? 22_ A Yes, I love my son. 23 Q Do you think it would l:~e detrimental to Tony 24 to be removed from your home? 25 A Yes, I do. 111 • • 1 Q Why? 2 ~ I don't think Tony will do well at all. 3 Q Why not? 4 ~~ Without having me there. 5 Q Why not? 6 A He relies too much on me. We have too much 7 of a bond, my son and I. I'm a.11 that. he's had the past 8 5 years. 9 MS. PINSKER: May I approach the witness, 10 Your ~~onor? 11. THE COURT: Certainly. 12 (Whereupon, Plaintiff's Exhibit No. I was 13 marked for identificati_on.) 14 BY MS. PINSKER: 1.5 Q Ms. Harper, I'm handing you some pictures. 16 Could you plea se describe to the Court what's in the 17 pictures, who' s in them -- 18 THE COURT: Have these been marked as an 19 exhibit? 20 MS. PINSKER: They've }peen marked as 21 Plaintiff's 1, Your Honor, and Ms. Tomeo has had the 22 opportunity to review theme prior to coming into court this 2.3 afternoon. 24 THE WITNESS: It's Tony and `I'r_istan in Hoffer 25 Park. 112 • • 1_ BY MS. PINSKER: 2 Q Who' s ']'ristan? 3 A Tristan is Corey's son. 4 Q Do Tony anal Tristan get along? 5 A Yeah, they're inseparable. Tristan's four 6 and Tony's five so they're real close in age. This is a 7 picture of Tony riding his bike and 'Tristan not far behind. 8 This is hi_m going down the slide. TY~is is me helping him -- 9 I don't know what that thing is. What's that called? I 10 forget. Where you push them? And this is Tony and I'm 11 helping him across the rings. 12 I believe this one's at the fair, the 13 Hummelstown Fair. He's on a ride. Tony and Tristan were on "14 a ride at the fair. I believe that's at the fair. We've 15 gone to four parks this year. This is the front of our 16 home. This is -the closet, Tony and Tr.istan's closet. It 17 has all their books and stuff on the strelf and toys. 1.8 Q Does Tristan share Tony's room when he 19 visits? 20 A Yes. 21 Q Do the boys like shar_rig a room? 2_2_ A Yeah, they don't have a problem with it. ?_3 This is Tony's bed. This is the foyer when you first come 24 in the front, and then this is a picture of both the boys's 25 beds. Tony's is a race car. He's really into cars. He 11.3 • • 1 ]_oves cars. This is their bathroom, tt,e dining room, our 2 kitchen, part of our living room, another part of our living 3 room, pictures of the kids and. stuff in the living room. 4 This is our porch, and. this is Mariah's room, 5 and this is trer_ desk and computer, her. toys, and this is a 6 picture of Hoffer Park. Kid Castle is what it's called. 7 And this is the pool that they swam in this summer that's in 8 our development. This is an overall picture of the park. 9 Q Is Tony exited about leaving a new sister or 1.0 brother? 11 A Yeah. He kisses my stomach every chance he 12 gets. He pulls my shirt up. 13 Q Briefly, if you can qusickly describe to the 14 Court how these recent court appearances have affected you 15 and your family? 16 A It's totally encompassed our life. You know, 17 Corey's and I life completely. It's j~.ist -- this whole 18 thing is just absolutely ridiculous. :It's hard to have a 19 normal ]_ife, enjoy being pregnant, with everything that is 20 going on. It's caused. a lot of_ stress and strain. 21 Q Why do you think Mr. `Ir_essl.er brought these 22 allegations? 23 A I think a lot of it -- I mean why didn't he 24 bring the allegations with Mariah? I had Mariah for how 25 many years? Why weren't these allegations brought up with 114 • • 1 Marian? I think a lot of it is a revenge tactic. That's 2 how I feel-. We do not get along. 3 MS . PINSKER: Yoi_zr Honor, I don' t have any 4 further questions of my client at this time. However, when 5 we reconvene at the next hearing date I= am going to offer 6 additional testimony of_ my client. ~ THE CO[JRT: All right. Did you want to move 8 the admission of Plaintiff's Exhibit 1.? 9 P~1S. PINSKER: I would, Your Honor. I would 10 like to leave that rnoved as Exhibit 1. 11 THE COURT: Ms. ~['omeo, cJo you have any 12 objection? 13 MS. TOMEO: No. -l~ THE COURT: Pla.intiff's Exhibit 1 is 15 admitted. 16 (Whereupon, Plaintiff's Exhibit No. 1. was 17 admitted into evidence.) 18 THE COURT: You may stel_~ down. Thank you. 19 Oh, I did have one question. What school district is your 20 son in? 21 THE WITNESS: Middletown. 22 `i'HE COURT: Middletown Area School District? 23 ACHE WITNESS: Um-hum. Yes. Sorry. 24 TF~E COURT: And when was the Protection from 2.5 Abuse hearing? 115 • • 1 THE WITNESS: I think i.t was in August. 2 MS. PINSKER: It was August, Your Honor, of 3 this year. 4 7:'HE COURT: Well, I know, but I need a 5 wi-tness to say when it was. Was it August? 6 THE WITNESS: August, yF.s. ~ THE COURT: Of 2006? 8 THE WITNESS: Yes. I k_~eLieve August 10th. 9 TT~E COURT: And you're saying that you were 10 unable to get into either anger management or parenting 11 classes until two weeks ago? 12 THE WITNESS: That the parentinq classes just 13 began two weeks ago. That's when they started. They have 14 another ogle in the fall. They do it like every season or 15 something, but yeah. 16 THE COURT: And how abort anger_ management? 17 THE WITNESS: The anger management classes 18 are on a Saturday as well, and I can't do both classes at 19 tyre same time because they're both at 10:00. The parenting 20 classes start at 10, and they run until 12, and I believe 21 the anger management classes run from 7.0 to 11. 22 THE COURT: Couldn't you have taken the anger 23 management classes pending the parentinq classes? 24 THE WITNESS: I'rn sorry. What? 25 'I'HE COURT: Couldn't you get into any anger 7.16 • ~ 1 management classes prior to a week or so ago? 2 THE WITNESS: I could have, but I started the 3 parenting classes first. 4 THE COURT: Okay. You may step down. Does 5 either counse]_ want a copy of the transcript filed from 6 today's proceeding'? 7 MS. TOMEO: Yes, Your Donor. S MS. PINSKER: Yes, Your FIOT7Or. 9 THE COURT: All right. We will enter this 10 orde.r_~ 11 AND NOW, this 9th day of October, 2006, upon 12 consideration of Defendant's request for modification of 13 custody with respect to the parties' clii_ldren, Mariah Kaylee 14 ~I'ressler (date of birth, December_ 27, 1994) and Antonio 15 Napolitan (date of birth, August 20, 2001.), and the parties 7.6 Craving agreed upon a custody order with respect to Mariah 17 Kaylee Tressler, which has been enterec_I of even date l~ herewith, and an initia]_ period of hearing having been held 19 on this date and not having been completed with respect to 2.0 Antonio Napolitan, it is ordered and directed that the 21 record shal_1 remain open, and a furtl~el period of hearing 22 with respect to custody of Antonio Napolitan shall be held 2.3 on Thursday, January 11, 2007, commencing at 1:30 p.m. 24 The Court wi_11 enter a temporary order with 25 respect to custody of Antonio Napolitan pending the further 117 • ~ 1 hearing in the matter. 2 Bottr counsel have requested that the 3 stenographer transcribe and file the notes of testimony from 4 today's proceeding. 5 It is noted that at the time of adjournment 6 on today's date neither party had comp7_et=ed the presentation 7 of his and her cases-in-chief, and at the time of 8 adjournment the Plaintiff was being su}~jected to direct 9 examination by her counsel. 10 It is noted further that.. as of the time of 11. adjournment Defendant's Exhibit 1 had been identified and 12 admitted, and Plaintiff's Exhibit 1 tiad been identified and 13 admitted. No other exhibits had been identified or 1.4 adrn.itted . 15 (End of order.) 16 THE COURT: Court is adjourned. 17 (Whereupon, the proceedings concl~.aded at 4:16 p.m.) 18 19 20 21 22 23 24 25 118 • CERTIFICATION I hereby certify that the proceedings are r_ontained fully and accurately in the t-cotes taken by me on the above r_.ause, and. that this is a correct transcript of same. ~ ` "`L~ cwt-`Lr.--, ~' Mi_chele A. Eline Official Court Reporter The foregoing record of the proceedings on the hearing of_ the within matter .is hereby approved and directed to be filed. J ~T1, l o L ~ ° ? -- ~ l~ Date J. e ey Ole Jr., J. Nii h Judicial District 119 STEPHANIE A. HARPER, (TRESSLER), PLAINTIFF v. JOSEPH TRESSLER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION-LAW NO.99-1086 CIVIL TERM PETITION FOR REINSTATEMENT OF CONTINUED CUSTODY HEARING AND NOW, comes the Petitioner, Stephanie Harper, by and through her attorney, Rachel Haynes Pinsker, Equire, and files this Petition for Reinstatement of the Continued Custody Hearing: 1. Petitioner in the above-captioned custody action is Stephanie Harper. 2. Respondent in the above-captioned custody action is Joseph Tressler, who is represented by Leslie Tomeo, Esquire. 3. Upon Respondent's request for modification of custody regarding the parties' children, Mariah Kaylee Tressler and Antonio Napolitan, a hearing was held on October 9, 2006. 4. At the October 9, 2006, hearing, the parties reached an agreement regarding custody of Mariah Tressler whereby the Respondent has primary physical custody and Petitioner has partial physical custody with periods of visitation as the parties shall agree. 5. The hearing was not completed on October 9, 2006, and a temporary custody order was entered regarding Antonio Napolitan whereby Petitioner maintained primary physical custody and Respondent had periods of partial physical custody. 6. Another hearing date was scheduled for January 11, 2007. 7. Since approximately November 24, 2006, Respondent has not exercised any of his periods of partial physical custody of Antonio, and does not wish to do so in the future. 8. Based on Respondent's lack of interest in pursuing his custody modification action, Petitioner's attorney submitted a custody stipulation to Respondent's attorney for his signature. 9. In light of the anticipated custody agreement, the hearing scheduled for January 11, 2007, was canceled and the action was continued generally. 10. Respondent refuses to sign the stipulation despite the fact that he desires to have no contact with Antonio Napolitan. WHEREFORE, Petitioner is respectfully requesting that the continued custody hearing be assigned a new hearing date and time. ~~~ >~~.,~~~.,, ~.L.,,.,.,,.,., 114 Walnut Street, 2°a Floor Harrisburg, PA 17101 (717) 724-0516, ext. 204 ,~ ~ ;;~, CJ -Y1 ^ ~ ~.,- • ~ G~ -~ ~~ r._ , _ - - fem. ~-= s ~~ ~_s~i . _ C~~ ~--- x:t :.~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA. CNIL ACTION-LAW STEPHANIE A. HARPER (TRESSLER), PLAINTIFF Vs. NO. 99-1086 CIVIL TERM JOSEPH TRESSLER, DEFENDANT PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Stephanie A. Harper, Plaintiff, to proceed in forma pauperis. I, Rachel Haynes Pinsker, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. i ~~~a hel Haynes Pinske ,Esquire A orney I.D.#83930 114 Walnut Street, 2"d Floor Harrisburg, PA 17101 (717) 724-0516 Date: , 2007 Attorney for the Plaintiff ORDER AND NOW, this day of 2007, pursuant to Pa.R.Civ.P. 240(d), upon presentation and consideration of the within Praecipe to Proceed In Forma Pauperis, said application is hereby granted. Prothonotary C 3 ~ C~~ Cr°. ~ ~'~:: '~`z ~ ,~ ~ ~~ :~ i'l i 3 --- J i r~i. ~.. ~-~ ~ y °'- ....-. ~ i, VJ .., .• ~ ~ ?v ~ b STEPHANIE A. HARPER, IN THE COURT OF COMMON PLEAS OF (TRESSLER), :CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF CIVIL ACTION-LAW v. JOSEPH TRESSLER, DEFENDANT NO. 99-1086 CIVIL TERM PRAECIPE TO AMEND TO THE PROTHONOTARY: Kindly amend the Petition for Reinstatement of Continued Custody Hearing, filed on March 8, 2007, by adding the following two (2) paragraphs: 11. The Honorable Wesley J. Oler, Jr., has previously ruled upon custody matters involving the above-named parties. 12. Opposing counsel, Leslie Tomeo, Esquire, is in concurrence with reinstating the continued custody hearing in the above-captioned custody matter. 'YWCA Domestic Violence Legal Clinic 114 Walnut Street, 2°d Floor Harrisburg, PA 17101 Attorney I.D.#83930 C? ~- c~ -r1 ~- u-s ~;~ ''~ ~, 3 :: J J, ~ ~ ~ I _ _ ~T ~ < ? V ~~ ~~ ~ M'AR 09 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW STEPHANIE A. HARPER, (TRESSLER) PLAINTIFF vs. JOSEPH TRESSLER, DEFENDANT NO.99-1086 CIVIL TERM IN CUSTODY ORDER AND NOW, this (5 ~ day of ~/~/l , 2007, the custody hearing in the above-captioned custody action is scheduled for ~~~ r , _ ~~m- 2007, at~~3~f., in Courtroom #~,(Cumber(land CTOUnty Courthouse, Carlisle J. ~Z' ~1C'~ ~i~r. ~1 f r S `~ r Pennsylvania, before tl}~ ~ es ~ ~;-~- BY THE COURT: ATTEST: Cc: achel Haynes Pinsker, Esquire, for Plaint YWCA Domestic Violence Legal Clinic 114 Walnut Street Harrisburg, PA 17101 eslie Tomeo, Esquire, for Defendant 155 South Hanover Street Carlisle, PA 171013 3~ ~Gc~'~ `~3.f w~t ~r, ,"1n.. ~, , 1 ~Z i ~ { ~~ ~ `i iJ~~ ~~U~ ~~~~ -~ v '~ STEPHANIE A. HARPER, (TRESSLER), . Plaintiff v JOSEPH TRESSLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99-1086 CIVIL TERM IN CUSTODY IN RE: CUSTODY AGREEMENT ORDER OF COURT AND NOW, this 11th day of July, 2007, upon consideration of Defendant's request for modification of custody with respect to the parties' children, Mariah Kaylee Tressler (date of birth, December 27, 1994) and Antonio Napolitan (date of birth, August 20, 2001), and the parties having previously agreed upon a custody order with respect to Mariah Kaylee Tressler, which was entered on a previous date, and counsel for the parties now appearing in open court and having agreed upon an order with respect to the custody of Antonio Napolitan, it is hereby ordered and directed with respect to custody of Antonio Napolitan as follows: 1. Legal custody of the child shall be in the mother. 2. Primary physical custody of the child shall be in the mother, with such periods of partial or temporary custody in the father as the parties may agree. By the Court, ~, _ cr. ,~ ~r'~ ;_ ~~- - - ., ~ ~,. = • - %_- ~~ ~ .. ~ 4 ~LT fr'''-' ~i .. '.. i_ : ' ~ 1~.. O r-- ~'- ~ ._; CV y A Rachel Haynes Pinsker, Esquire YWCA Domestic Violence Legal Clinic 114 Walnut Street Harrisburg, PA 17101 For Plaintiff Leslie Tomeo, Esquire ,~ ,y„u,,,~-.~ ?-f~•a7 155 South Hanover Street Carlisle, PA 17103 For Defendant :mae