HomeMy WebLinkAbout99-02274 (2)
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the Father may have uninterrupted visitation of the
said minor child during the weekend and such contiguous
days.
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5. The parties shall alternate the following hOlidays:
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New Year's Eve/Day, Easter, Memorial Day, Fourth of
July, Labor Day, and Thanksgiving, such that those
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hOlidays will be broken into two segments. Segment A
will include New Year's Eve at 6 p.m. through New Year's
Day at 6:00 p.m., Memorial Day, and Thanksgiving.
Segment B will include Easter, Fourth of JUly, and
Labor Day. Mother shall have Segment A in even- numbered
years and Father shall have Segment B in even-numbered
years. Mother shall have Segment B in odd-numbered
years and Father shall have Segment A in odd-numbered
years. All holiday visitations, other than New Year's,
will be from 9:00 a.m. to 6:00 p.m. They may also be
contiguous with visitation or custodial period of the
previous or subsequent day(s).
6. The parties shall alternate the Christmas hOliday so that
the period will begin from December 24 at 9:00a.m. until
December 25 at noon, and from December 25 at noon until
December 26 at 6:00 p.m. Father shall have the first period
in all even-numbered years and the second period in all
odd-numbered years. Mother shall have the first period
in all odd-numbered years and the second period in all even-
numbered years.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMDERLAND
,
On this, theJ~ day Of~
notary public the undersigned officer,
-
1999, before
me a
personally appeared
Tami L. Noggle and Jonathan M. Deck. know to me ( or satisfactorily
proven ) to be the persons whose names are subscribed to the
within instrument, and acknowledged that they executed the
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same for the purpose therein contained.
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IN WITNESS WHEREOF, I have hereunto set my hand and notorial )
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NOTARY P "
r NOTARIAL SEAL
SO~IORA T NEFF. NOTARY PIlBLlC 1'I
CARLISLE BCRO. CUMBERLAND COUN .'
MY COMMISSION EXPIRES NOVEMBER 15. 1999
BY THE COURT,
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Ms. Tam! L. Noggle, pro se
Mr. Jonathan M. Beck, pro se
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TAMI L. NOGGLE,
Plaintiff/Rcspondent
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 99-2274
CIVIL TER.\1
JONATHAN M. BECK,
Defendant/Petitioner
: IN CUSTODY
PETITION FOR CONTEMPT AND MODIFICATION
Petitioner, Jonathan M. Beck, by and through his counsel, MidPenn Legal
Services, states the following:
1. DefendantlPetitioner, hereinafter referred to as Father, resides at 400 Seventh
Street, New Cumberland, Cumberland County, Pennsylvania 17070.
2. Plaintiff/Respondent, hereinafter referred to as Mother, resides at 117
Caldwell Lane, Winchester, Frederick County, Virginia, 22602.
3. The above-named parties are the natural parents of KaitIin N. Beck, born
January 20, 1996.
4. The current Custody Order is dated April 15, 1999, and was prepared by
Respondent. The parties entered into the agreement without representation.
The Order (attached hereto as Exhibit A), in pertinent part, grants Mother sole
legal custody and primary physical custody of Kaitlin. Father has periods of
partial physical custody from Friday at 12:00 noon until Sunday at 5:00 p.m.
Additionally, Father has one week of uninterrupted custody each month
during the summer. The Order also sets forth a holiday custody schedule.
5. Mother has willfully disobeyed the Order in ways including, but not limited
to, the following:
a. Refusing to pemlit Fathcr to excrcisc his periods of partial custody.
b. Refusing to allow Fathcr to have telcphonc contact with Kaitlin.
c. Moving to various states without noticc to Fathcr, thus interfcring with
his ability to cxcrcise his periods of partial custody.
6. Mother is not acting in Kaitlin's best intercst for rcasons including, but not
limited to, the following:
a. Mother has moved back and forth from Lancaster, Pennsylvania to
four other states, Georgia, Illinois, Missouri and Virginia, after
meeting men online. Mother does not discuss these moves with Father
and does not attempt to work out new custody arrangements to ensure
that he has timc with Kaitlin.
b. Mother's actions have interfered with Fathcr's ability to develop and
nurture a healthy father/daughter relationship with Kaitlin and that
does not serve her best interests.
c. Mother docs not allow Father to have reasonable telephone contact
with Kaitlin.
d. Mother does not communicate or attempt to cooperate with Father to
better co-parent Kaitlin and her refusal to allow Father to participate in
Kaitlin's life as a parent does not serve Kaitlin's best interests.
7. Father is entitled to modified periods of partial custody, which is in Kaitlin's
best interests, for reasons including but not limited to the following:
a. Father is eager to participate in Kaitlin's life. His inability to do so is
the result of Mother's actions in constantly moving from state to state
and interfering with Father's ability to exercise his pcriods of partial
custody,
b, Mother drafted the conscnt agreemcnt that is thc basis of thc currcnt
custody order. Father's rights were unrcasonably diminished undcr
this agrecment. Father cntercd into the agreement without knowing
the extcnt to which his access to Kaitlin would be limited.
c. Mother now lives in Winchester, Virginia and Kaitlin is in school,
making it difficult for either party to comply with the partial custody
schedule in the April 15, 1999, Order which starts Father's weekends
at noon on Fridays.
d. Father has a stable and safe home environment wherc he can provide
appropriate supervision and shelter for Kaitlin children during periods
of partial custody.
8. It is unknown whether Mother is represented and counsel for Father is unable
to request concurrence for the relief requested in this Petition.
WHEREFORE, Father respectfully requests that this honorable Court order the
following relief:
a. That Mother be found in contempt of the April 15, 1999, Court Order.
b. That this matter be scheduled for a custody conciliation to establish terms of a
modified custody schedule.
c. That Father immediately be permitted periods of partial custody on alternate
weekends until further order of the court and that the parties shall exchange
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Plaintiff
IN THE COURT OF
CUMBERLAND COUNTY, PENNSYLVANIA
APR 0 7 2006
</
TAMI L. NOGGLE,
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Defendant
NO. 99-2274 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
v.
JONATHAN M, BECK,
Hess, J.
ORDER OF COURT
AND NOW, this I ':!. day of April, 2006, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
This Court's Order of April 15, 1999 is VACATED and replaced with the following:
1. Leaal Custodv. The parties, Tami L. Noggle and Jonathan M. Beck shall have
shared legal custody of the minor child, Kaillin N. Beck born January 20, 1996. Each parent
shall have an equal right, to be exercised jointly with the other parent, to make all major
non-emergency decisions affecting the child's general well-being including, but not limited
to, all decisions regarding her health, education and religion, Pursuant to the terms of 23
Pa. C, S. ~5309, each parent shall be entitled to all records and information pertaining to the
child including, but not limited to, medical, dental, religious or school records, the residence
address of the child and of the other parent. To the extent one parent has possession of
any such records or information, that parent shall be required to share the same, or copies
thereof, with the other parent within such reasonable time as to make the records and
information of reasonable use to the other parent.
2. Phvsical Custodv. Mother shall have primary physical custody subject to
Father's rights of partial custody which shall be arranged as follows:
A. Effective April 7, 2006, on alternating weekends from Friday
at 6:00 p.m. until Sunday at 6:00 p.m.
B. In addition to the schedule defined above, the Father shall,
with one (1) week's notice to the Mother, have partial
custody of the minor child for a period of up to two (2) weeks
during the summer months. One (1) week may also be
scheduled during winter school recess. In the event that
such days are contiguous to a weekend, the Father may
have uninterrupted partial custody of the minor child during
the weekend and such contiguous days.
.
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NO, 99-2274 CIVIL TERM
C, Mother shall give Father notice of the child's cheer camp or
other sports camps scheduled in the summer before the
academic year is dismissed for purposes of Father planning
his summer custodial schedule with the child,
D. Father shall make a confirming telephone call to Mother on
the Wednesday evening before his custodial weekend to
confirm his intent to meet her on Friday evening to receive
custody of the child.
3, Holidavs. The following holiday schedule shall supercede the regular schedule:
A. Thanksalvina. Thanksgiving shall be defined as commencing on
the Wednesday before Thanksgiving at 6:00 p.m. and continuing
until 6:00 p,m. on the Friday following Thanksgiving. In even
numbered years, Father shall have the Thanksgiving holiday and in
odd numbered years, Mother shall have the Thanksgiving holiday.
B, Easter. The Easter holiday shall be defined as Good Friday at 6:00
p.m. until 6:00 p.m. the day before school resumes after Easter.
Mother shall have custody for Easter holiday in even numbered
years and Father shall have custody of the child for the Easter
holiday in odd numbered years.
C. Christmas. Each year, Mother shall have custody for the Christmas
holiday from the time school is out until December 26th at 6:00 p.m.
Each year, Father shall have custody from December 26th at 6:00
p.m. until 6:00 p.m. the day before school resumes.
4, Both parties shall have the right to reasonable telephone contact with the child during
the other party's period of custody. The child may initiate a telephone call to the non-
custodial parent upon their request. Neither party shall interfere with the other party's
telephone contact with the child. Each party shall make all reasonable efforts to promptly
return calls or messages left by the other party regarding the child.
5. Transportation. The parties shall share transportation incident to custodial
exchanges by meeting at Exit 3 off of 1-81 at the Comfort Inn near Greencastle,
Pennsylvania.
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ORDER/NOTICE TO WITHHOLD INCOME FOR SUPPORT
Slate Commonwealth of Ptmns\llvania
Co./City/Disl. o( CUMBERLAND
Date o( Order/Notice 04/18/06
Case Number (See Addendum for case summary)
EmpJoyerJ\VilhhCllcll'r's fl'der.lI [IN NumlX'r
UNITED STATES POSTAL SERVICE>
C/O PAYROLL BENEFITS BRANCH
2825 LONE OAK PKWY
EAGAN MN 55121-1551
3\1 \<::r\ 05.S \
0,(\,. ~\l.~ c:"'; \
RE: ERNE. ROCCO T.
'83\\()2.0~S
200 S .2000
o Original Order/Notice
<E> Amended Order/Nolice
o Termindle Order/Notice
Employer/Obligor's Nolrne (lasl, firsl. MI)
541-76-1400
Employee/Obligor's Soci.11 Security Number
8989100490
Employee/Obligor's Case Identifjer
(S('(> Addendum for plaintiff names
associoJred with cases on attachment)
CuSlodi.l1 PJrent's NJmc (last. First. Mil
See Addendum for dependent names and birth dates associated with cases on attachment,
ORDER INFORMATION: This is an Order/Notice to Withhold Income (or Support based upon an order (or support
from CUMBERLAND Counly, Commonweallh o( Pennsylvani". By law, you are required to deduct these
amounts from the above,named employee's1obligor's income until further notice even if the Order/Notice is not
issued by your State.
$ S99. 59 per month in current support
$ 0,00 per month in past-due support Arrears 12 weeks or greater? @yes 0 no
$ so. 00 per month in current and past-due medical support
$ 0.00 per month for genetic test costs
$ per month in other (specify)
for a total of $ 649.59 per month to be forwarded to payee below,
You do not have to vary your pay cycle to be in compliance with the support order. If your pay cycle does not match
the ordered support payment cycle, use the following to determine how much to withhold:
$ 149.91 per weekly pay period.
$ 299.81 per biweekly pay period (every two weeks).
$ 324.80 per semimonthly pay period (twice a month).
$ 649.59 per monthly pay period.
REMITTANCE INFORMATION:
You must begin withholding no later than the (irst pay period occurring ten (10) working days after the date of this
Order/Notice. Send payment within seven (7) working days of the paydate/date of withholding. You are entitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work state o( your employee for the
allowable amount. The total withheld amount, and your fee, cannot exceed 55% of the employee's! obligor's
aggregate disposable weekly earnings. For the purpose of the limitation on withholding, the following information is
needed (See #9 on page 2).
If remitting by EFT/EDI. please call Pennsylvania State Collections and Disbursement Unit (SCDU) Employer
Customer Service at '-877-676-9580 for instructions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P,O, Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Employee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED,
DO NOT SEND CASH BY MAIL,
Date o( Order: APR 1 8 2006
Service Type M
BY THE COURT:
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O,\lll No , U'170.111H
Form ~IL
Worker 10 21005
ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITHHOLDERS
o I( checked you arc required 10 p'pvi\le a copy o( this (orm to your employee. I( your employee work. in a S1ale Ihat i.
different from the !tlale th.u issue( Uus order..1 copy must b(' provlc1ed to your employee even If the box is not checked.
1. Priority: Withholding under this Order/Notice has priority OVl" ,my olhN Icg.1I process under Slolle ldw against the same income.
Fcderaltax levies in effect before receipt of this orciN h.wc priority. If Ihrr(' .HC F(l(ft'ral tax levies in e(ft'CI plcdse contJcllhe rcquesling
agency li.ted below.
2. Combining Paymenls: You e.lO combine withheld .lmounfs (rom morf' Ih,1/1 onr emflloy(>(>/ohli~or's income in a slngle payment 10
each agency requesting withholding. You must, however. !lep.1Ml('ly idC'nlify the portion of lht! single Ildymenlthat is Illlrlbutablc to each
employeeloblillor.
3. '-Reporting"the Paydate/Date of-Withholding: Youmu,t report the payd.le/dale o( wilhholding when ,ending the payment,-The-
paydaleldate-otwithholdingis-the date on which-ilmount was withheld (rom the employce','woges. You mull comply with Ihe law o( the
state of the employee's!obligor's principal place of employment with resp~ct to the time periods within which you must implement the
wilhholding order and (orward the .upport paymenl'.
4.' Employee/Obligor wilh Multiple Support Holdings: If there i. more Ihan one Order/Notice 10 Withhold Income (or Support against
this employee/obligor and you iJTe unllblc 10 hono! all SU1JPOn. Order/Notices clue to fcdcrdl or St.Uc withholding limits, you must (arrow
the law of the state of employec's/obligor's principal place of cmploymcrll. You must honor ,111 Orders/Notices to the greatest extent
possible. (See #9 below)
5. Termination Notification: You must promptly notify the Requesting Agency when the employee/obligor is no longer working for you.
Please provide the information requested and return a copy of this Order/Notice to the Agency identified below.
THE EMPLOYEE/OBLIGOR NO LONGER WORKS FOR: 4107600000
EMPLOYEE'S/OBLlGOR'S NAME: ERNE. ROCCO T.
EMPLOYEE'S CASE IDENTIFIER: 8989100490 DATE OF SEPARATION:
lAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. lump Sum Paymenls: You may be required to report and withhold (rom lump sum payments such as bonuses, commissions, or
severance pay. If you have any questions about lump sum payments, contact the person or authority below.
7. liability: if you (ail to wilhhold income as Ihe Order/Notice direct.. you are liable (or both Ihe .ccumulated amount you .hould have
withheld (rom the employee/obligor's income and other penalties set by Pennsylvania State law. Pennsylvania State law governs unless
the obligor is employed in anolher Stale. in which case the law of Ihe State in which he or .he i. employed governs.
8. Anti-discriminalion: You arc subject to a fine determined under State law fordischarging an employee/obligor from employment,
refusing to employ, or taking disciplinary action against any employee/obligor because of a support withholding. Pennsylvania State law
governs unless the obligor is employed in another State, in which case the law of the Slate in which he or she is employed governs.
9.' Withholding limits: You may nol withhold more than the lesser 0(: 11 the .mounts allowed by Ihe Federal Consumer Credil
Proteclion Act (15 U.S.c. ~1 673 Ib'l: or 2) Ihe amounl. allowed by the sl.le of Ihe employee's1obligor'. principal place o( employment.
The Federal limit applie. 10 the aggregate di.posable weekly earning. (ADWEI. ADWE i. the net income left after making mandatory
deductions such as: Stale, Federal, local taxes; Social Security taxes; and Medicare taxes. For tribal orders, you may not withhold more
than the amounts allowed under the law of the issuing tribe. For tribal employers who receive a slate order, you may not withhold more
than the amounts allowed under the law o( the state thaI issued the order.
10. Additional Info:
'NOTE: If you or your agent are served with a copy of this order in the .tate that issued the order, you are to follow the
law of the state that issued this order with respect to these items.
11.Submitted By:
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O. BOX 320
CARLISLE PA 17013
I f you or your employee/obligor have any questions.
contact WAGE ATTACHMENT UNiT
by telephone at (717) 240-6225 or
by FAX at (717) 240,6248 or
by internet www.child.upporl.state.pa.us
Service Type M
Page 2 o( 2
Form EN,028
Worker ID 21005
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TAMI L. NOGGLE,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COl:-.!TY, PEN~SYL VANIA
v.
: NO. 99-2274
CIVIL TERM
JONATHA"J M. BECK,
Defendant/Petitioner
IN CUSTODY
PETITION FOR CONTEMPT AND MODIFICATION
Petitioner, Jonathan M. Beck, by and through his counsel, MidPenn Legal
Services, states the following:
I, Defendant/Petitioner, hereinafter referred to as Father, resides at 400 Seventh
Street, New Cumberland, Cumberland County, Pennsylvania 17070,
2. Plaintiff/Respondent, hereinafter referred to as Mother, resides at 117
Caldwell Lane, Winchester, Frederick County, Virginia, 22602.
3. The above-named parties are the natural parents of Kaitlin N, Beck, born
January 20, 1996.
4. The current Custody Order is dated April 15, 1999, and was prepared by
Respondent. The parties entered into the agreement without representation,
The Order (attached hereto as Exhibit A), in pertinent part, grants Mother sole
legal custody and primary physical custody of Kaitlin. Father has periods of
partial physical custody from Friday at 12:00 noon until Sunday at 5:00 p.m,
Additionally, Father has one week of uninterrupted custody each month
during the summer. The Order also sets forth a holiday custody schedule.
5. Mother has willfully disobeyed the Order in ways including, but not limited
to, the following:
.
a. Refusing to permit Father to exercise his periods of partial custody.
b. Refusing to allow Father to have telephone contact with Kaitlin.
c. Moving to various states without notice to Father, thus interfering with
his ability to exercise his periods of partial custody,
6, Mother is not acting in Kaitlin's best interest for reasons including, but not
limited to, the following:
a, Mother has moved back and forth from Lancaster, Pennsylvania to
four other states, Georgia, Illinois, Missouri and Virginia, after
meeting men online. Mother does not discuss these moves with Father
and does not attempt to work out new custody arrangements to ensure
that he has time with Kaitlin,
b, Mother's actions have interfered with Father's ability to develop and
nurture a healthy father/daughter relationship with Kaitlin and that
does not serve her best interests.
c. Mother does not allow Father to have reasonable telephone contact
with Kaitlin,
d. Mother does not communicate or attempt to cooperate with Father to
better co-parent Kaitlin and her refusal to allow Father to participate in
Kaitlin's life as a parent does not serve Kaitlin's best interests,
7, Father is entitled to moditied periods of partial custody, which is in Kaitlin's
best interests, for reasons including but not limited to the following:
a. Father is eager to participate in Kaitlin's life. His inability to do so is
the result of Mother's actions in constantly moving from state to state
and interfering with Father's ability to exercise his periods of partial
custody.
b. Mother drafted the consent agreement that is the basis ofthe current
custody order. Father's rights were unreasonably diminished under
this agreement. Father entered into the agreement without knowing
the extent to which his access to Kaitlin would be limited.
c. Mother now lives in Winchester, Virginia and Kaitlin is in school,
making it difficult for either party to comply with the partial custody
schedule in the April 15, 1999, Order which starts Father's weekends
at noon on Fridays,
d. Father has a stable and safe home environment where he can provide
appropriate supervision and shelter for Kaitlin children during periods
of partial custody,
8. It is unknown whether Mother is represented and counsel for Father is unable
to request concurrence for the reliefrequested in this Petition.
WHEREFORE, Father respectfully requests that this honorable Court order the
following relief:
a. That Mother be found in contempt of the April 15, 1999, Court Order.
b, That this matter be scheduled for a custody conciliation to establish terms of a
modified custody schedule.
c. That Father immediately be permitted periods of partial custody on alternate
weekends until further order of the court and that the parties shall exchange
custody at a point halfway between )iew Cumberland, Pennsylvania and
Winchester, Virginia.
d. That Father immediately be permitted reasonable telephone contact with
Kaitlin while she is in Mother's custody.
e. Any other reliefthis Court finds just and proper.
Respectfully submitted,
JessiciH st, squire
Attorney for Defendant/Petitioner
MidPenn Legal Services
401 E. Louther Street, Suite 103
Carlisle, P A 17013
(717) 243-9400
I ~ .
VERIFICATION
The above-named PETITIONER, JONATHAN M. BECK, verifies
that the statements made in the above petition for Contempt
and Modification are true and correct. Defendant
understands that false statements herein are made subject
to the penalties of 18 pa. C.5, 94904, relating to unsworn
falsification to authorities.
Date;.~ (J ')((It;;
M. Beck
TAMI L. NOGGLE,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COCNTY, PENNSYLVANIA
v,
: t-iO. 99-2274
CIVIL TERM
JONATHAN M. BECK,
Defendant/Petitioner
IN CUSTODY
CERTIFICATE OF SERVICE
I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for Petitioner, Jonathan M.
Beck, hereby certify that I have served a copy ofthe forgoing Petition for Contempt and
Modification on the following date and in the manner indicated below:
V,S. First Class Certified Mail, Return Receiot, Restricted Deliverv
Tami L. Noggle
117 Caldwell Lane
Winchester, VA 22602
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Jessisxi<<~l~, ~~quire
Counsel for Plaintiff
MidPenn Legal Services
401 E. Louther Street, Suite 103
Carlisle, PA 17013
(717)243-9400
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TAM I L. NOGGLE,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COlTNTY, PE]\'l"SYLV ANIA
v.
NO. 99-2274
CIVIL TERM
JONATHAN M, BECK,
Defendant/Petitioner
IN CUSTODY
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Jonathan M. Beck, Petitioner, to proceed in forma pauperis,
I, Jessica Holst, 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.
~.
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JesiIca t'rolst, Esquire
MidPenn Legal Services
401 E, Louther Street, Suite 103
Carlisle, PA 17013
(717) 243-9400
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TAM I L. NOGGLE
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
99-2274 C1VIL ACTION LAW
JONATHAN M. BECK
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Friday, February I7,200~.___, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa p, Greevy, Esq. , the conciliator,
at MDJ Manlove's, 1901 State St., Camp Hill, PA 17011. on ___.Frida~, Marc./I}...!,}OO~..___._ at 11:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to dctine 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 penn anent order.
The court hereby directs the parties to furnish any IInd 1111 existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin~,
FOR THE COURT,
By: .3'~_Melissa P. Gre~,JJ~,-.___~_
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD l' AKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN (JET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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APR 0 7 2006
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IN THE COURT OF C~,i.1etJ FL[A3 of
CUMBERLAND COUNTY, PENNSYLVANIA
TAMI L. NOGGLE,
Plaintiff
NO. 99-2274 CIVIL TERM
v,
CIVIL ACTION - LAW
JONATHAN M, BECK,
IN CUSTODY
Defendant
Hess, J,
ORDER OF COURT
AND NOW, this It' day of April, 2006, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
This Court's Order of April 15, 1999 is VACATED and replaced with the following:
1, LeQal Custody, The parties, Tami L. Noggle and Jonathan M. Beck shall have
shared legal custody of the minor child, Kaitlin N, Beck born January 20, 1996. Each parent
shall have an equal right, to be exercised jointly with the other parent, to make all major
non-emergency decisions affecting the child's general well-being including, but not limited
to, all decisions regarding her health, education and religion, Pursuant to the terms of 23
Pa. C, S. ~5309, each parent shall be entitled to all records and information pertaining to the
child including, but not limited to, medical, dental, religious or school records, the residence
address of the child and of the other parent. To the extent one parent has possession of
any such records or information, that parent shall be required to share the same, or copies
thereof, with the other parent within such reasonable time as to make the records and
information of reasonable use to the other parent.
2, Physical Custody, Mother shall have primary physical custody subject to
Father's rights of partial custody which shall be arranged as follows:
A. Effective April 7, 2006, on alternating weekends from Friday
at 6:00 p.m. until Sunday at 6:00 p.m,
B, In addition to the schedule defined above, the Father shall,
with one (1) week's notice to the Mother, have partial
custody of the minor child for a period of up to two (2) weeks
during the summer months. One (1) week may also be
scheduled during winter school recess, In the event that
such days are contiguous to a weekend, the Father may
have uninterrupted partial custody of the minor child during
the weekend and such contiguous days.
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NO. 99-2274 CIVIL TERM
C. Mother shall give Father notice of the child's cheer camp or
other sports camps scheduled in the summer before the
academic year is dismissed for purposes of Father planning
his summer custodial schedule with the child,
D. Father shall make a confirming telephone call to Mother on
the Wednesday evening before his custodial weekend to
confirm his intent to meet her on Friday evening to receive
custody of the child,
3, Holidays, The following holiday schedule shall supercede the regular schedule:
A Thanksoivino, Thanksgiving shall be defined as commencing on
the Wednesday before Thanksgiving at 6:00 p.m, and continuing
until 6:00 p,m. on the Friday following Thanksgiving, In even
numbered years, Father shall have the Thanksgiving holiday and in
odd numbered years, Mother shall have the Thanksgiving holiday.
B. Easter. The Easter holiday shall be defined as Good Friday at 6:00
p.m, until 6:00 p,m. the day before school resumes after Easter.
Mother shall have custody for Easter holiday in even numbered
years and Father shall have custody of the child for the Easter
holiday in odd numbered years,
C. Christmas. Each year, Mother shall have custody for the Christmas
holiday from the time school is out until December 26th at 6:00 p,m.
Each year, Father shall have custody from December 26th at 6:00
p.m, until 6:00 p.m, the day before school resumes,
4, Both parties shall have the right to reasonable telephone contact with the child during
the other party's period of custody. The child may initiate a telephone call to the non-
custodial parent upon their request. Neither party shall interfere with the other party's
telephone contact with the child, Each party shall make all reasonable efforts to promptly
return calls or messages left by the other party regarding the child,
5. Transportation. The parties shall share transportation incident to custodial
exchanges by meeting at Exit 3 off of 1-81 at the Comfort Inn near Greencastle,
Pennsylvania.
. , -...
NO, 99-2274 CIVIL TERM
6.
Upon mutual agreement of the parties, Father's Petition for Contempt is DISMISSED.
Dis!:
BY THE COURT:
--At- /If/-
II Kevin A, Hess, J,
Aessica Holst, Esquire, 104 E. Louther Street, Suite 103, Carlisle, PA 17013
.;rami l. Noggle, 117 Caldwell Lane, Winchester, VA 22602
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Plaintiff
\ I\FR) . 2ull\)
IN THE COURT OF ~fqRfr\i'P'LE.AtoV
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 99-2274 CIVIL TERM
TAMI L. NOGGLE,
v.
CIVIL ACTION - LAW
JONATHAN M, BECK,
IN CUSTODY
Defendant
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1, The pertinent information concerning the child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN THE CUSTODY OF
Kaitlin N. Beck
January 20, 1996
Mother
2. A Custody Conciliation Conference was held on March 31, 2006 following
Father's filing of a Petition for Contempt and Modification on February 13, 2006, The last
Order entered in this matter was April 15, 1999, That Order was entered upon mutual
agreement of the parties following a Custody Conciliation Conference. Attending the
conference were: the Mother, Tami L, Noggle, who participated pro se; the Father,
Jonathan M, Beck, and his counsel, Jessica Holst, Esquire,
3. The parties reached an agreement in the form of an Order as attached.
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Date r Melissa Peel Greevy, Esquire
Custody Conciliator
:272592