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Home My WebLink About99-02864b4 X 1 L??Y LN I J S.j lMi JS Ala 'f l%l i4: Jul-'27:-c00 13:11 shaphardstown fm pract P.02 DENISE I HOUGHS M.S.N, C.R.N.P. 261 WALNUT SKEET CARLISLE, PENNSYLVANIA 17013 (717) 243.7222 d&mFCalenix.net Objective Nurse Practitioner in Primary CareAVomen's Health, applying critical knowledge and technical skills gained throughout 7 years of advanced practice nursing. Summary orQualification% • Extensive hands-on nurse practitioner experience coupled with 28 years of general nursing knowledge • Quality standards demonstrated in patient care issues, essential in today's competitive managed care environment. Summary or Skills • Clinical - Physical exams including newborn/pedintrir/adolescenttadult populations, immunization management, women's health exams, counseling, and telephone triage. Minor surgical procedures such as removal of skin lesions, suturing, injection oFtrigger points, and endometrial biopsies. • Communication - Effective collaboration with physicians, fellow nurse practitioners, and office staff. Performance of educational inservices for ancillary staff. Development and maintenance of patient education materials. Skilled therapeutic communication and counseling techniques with clients of all ages. • Management - Active participation in weekly provider meetings to review budget/office/staff management issues and OSHA updates. • Office - Protocol development for: patient confidentiality, Depo Provera management, diabetes management, and telephone triage guidelines titr acute illness appointments. Current knowledge of office billing guidelines Proressional Experience 1996-Present Primary Care Family Nurse Practitioner Shepherdstown Family Practice, P.C. Mechanicsburg, PA Busy suburban practice, including 5 Physicians/2 Nurse Practitioners. 2,500 patient encounters monthly, 60% managed care. Managed acute/chronic illness evaluations for average of 250 patients per month, primary focus on women's health issues. 1999•Prescm Sexual Assault Forensic Examiner Cumberland County Sexual Assault Task Force (continued) "1L?81o?? (?1Cy Ju]-27_,00.13111 shaphardstown fm Pr-act P.03 DENISE J. HOLGH,:N.SX, C kN.P. Page two of three On-call availability for sexual assault victim assessment, evidence collection, STD and pregnancy prophylaxis, and emotional counseling and support in community emergency room settings, 1995-1996 Preceptor Widener University Nurse Practitioner Program Individual mentoring of student nurse practitioners to supervise patient encounters, assist in intervention planning, and teach complex medical management. 1993-1996 Primary Care Family Nurse Practitioner Rodney K. Hough, M.D., Willis Willard, M.D. and Lorraine McDonald, C:AXP, Carlisle, PA Medical evaluation and management of patients throughout the lifespan in busy primary care office. Additional Nursing Experience 1981-1991 Primary Care Family Health Nurse Rodney K. !lough, M.D., Willis Willard, M.D., Carlisle. PA 1988-1990 School Health Nurse Carlisle Area and Boiling Springs School Districts 1973.1975 Peri-Operative Staff Nurse M.S. Hershey Medical Center, Penn State University, I lershey, PA. 1971-1973 Peri-Natal [lead Nurse Columbia Hospital for Women, Washington, D.C Education 1993 M.S.N. University of Pennsylvania. Philadelphia, PA Primary Care Family Nurse Practitioner Program 1989 B.S.N. Thomas Jefferson University. Philadelphia, PA Honors: Summa Cum Laude Scholarship and Leadership Award Sigma Theta Tau International honor Society of Nursing (Delta Rho Chapter) 1971 Diploma, Nursing. Western Pennsylvania Hospital School of Nursing. Pittsburgh, PA 1947 Certification, Sexual Assault Nurse Examiner. University of Pennsylvania (continued) Jul-271 -Otl 13:12 shapharcistown fm ract p P.04 DENISE J. HL)llGH, M.S.N., C.R.N.P. Page three of three Professional Activities • Participation on Cumberland County Task Force. Addressing needs for and development of sexual assault response program in association with the local District Attorney's office, local police department and multiple other social service agencies. 1999 • Seminar presentation on Breast llealth. Sponsored by Y. W.C:.A., as part of a Women's Conference, I098 • Seminars presented on Women's Health Issues. Sponsored by Y. W.C A. as pan of Encore Plus, a community based program offering free mammogram services to low income women, 1999 • Participation in discussion panel on Professional Development. Nurse Practitioner Program, Widener University. 1997, 1998, 1999. • Participation in discussion panel on Professional Development. Nursc Practitioner Program, Penn State University, Hershey. 1997 Professional Associations Alliance of Advance Practice Nurses American Academy of Nurse Practitioners American and Pennsylvania Nurses Associations Association of Reproductive Health Professionals International Association of Forensic Nurses Network for Better Healthcare for Women Nurse Practitioners of Central Pennsylvania Sigma Theta Tau International Honor Society of Nursing Licensure and Certification t Nurse Practitioner, Pennsylvania. SP-003098-D • Registered Nurse, Pennsylvania. RN.181301 •L • Licensure process initiated with Maryland and Virginia State Boards of Nursing • NP-C, American Academy of Nurse Practitioners • C.S, American Nurses Association Credenlialing Center • S.A.NE.,University ofPennsylvania Name:-{?? b N r ---LG---- Phone Number: H. 5 (p 0,3 TltA kzxt ''Vi`i-jt(y?i rt'Lrnr,•C.,e? I =L(YC?_S.SJ_ /MW ??-`frr ("(s?wt Date Problem T Resolution Risk Factors 1'uhacro -- i -- CTOII ({ - I i i I ` Hospitalizations/Surgery = Allergies rv,=j, I I I I Active Problems II 6/97 I /?? MtUIUA I JUN L1511NU Patient Name x(17 b?-e!, (/p!V J Data (, d• Dana o a/Reno p `3 Data llG 6'U Dose ?ElJSfn J( /iL 15 Freq j`d plReflll Date Dose Freq n/Refill Date Dose Freq #/Refill Date Dose Freq k/Refill Date Dose Freq N/Refill Date Dose Freq R/Refill Date Dose Freq 41/Refill MEDICATION LISTING Page .,oi, I have read and understand the material and information explain- ing the risks and henefits of the immunization. The doctor has answered to my satisfaction any questions that f have. I consent that this immunization he given to me or to this patient of whom I Patient :. am the parent, guardian or other authorized rcorescnunive. j,_e Age Immunization pale/Initial Site ot#/Manufacturer Authorized signature Comments or Reactions if any DPT #1 4-, r.n,; DPT /f3 - •:. m DPT#4 I{irS ?•.'i's .i. t `11,1 i'' r<',4• t, F-xjj -DPT #5 TOPV#1 ?• -- TOPV #2 D,;r< jOPV #3 y TOPV #4 _ t ? v, _rb.,,S / . /; F• 1 i I ? Tb skin test PPD k^ c IftA T:. I t5mc MMR#1 1 7t?-9v nt• ? ?l- 'y" :!'n - ' -- MMR #2 'j < I dT or TT dT or TT H. flu #1 _ - H. flu #'_ H. flu #3 1 H. flu #d - 7 Rubella Measles - ?Y vn T T 7.(./l. 77 Pneumo Vac Flu Vaccine Flu Vaccine r Flu Vaccine ` I Hepatitis B #I :J-;; :'- _ r- I I ,?-J- _------- rig L IM #3 I it MUNIZATION PLOW SHEET Br.•wmansdale Family Practice r Sl pherdstown Family Pract':"C ? I KaceyCoun. Suite 101 y 2H0 Fisher Road Mechanicsburg, PA 17055 Mechanicsburg. PA 17055 Phone (717) 591.0961 Phone(717)766-1795 Name DOB Vital Signs Flow Sheet Date Ht. Wt. Temp. BP P/R LMP Chief Complaint MA PCP Pgtt .j.I Cry rl:J.l... LL"YI z 6'U 1 j h n i I ",a Srr"I o 1'nu•^I299I Bowmansdale Family Practice O I Kacey Court. Suite 101 Mechanicsburg. PA 17055 Phone (717) 591.0461 Shepherdstown Family Practice la 2140 Fisher Road Mechanicsburg, PA 17055 Phunc (717) 766.1795 Amber Hoch 02-13-95 Name: DOB: Seenar. BFP SFP 05-30-00 Date _- S: Here with her mother for a well child exam. Mother is aware that her insurance company will only cover one well child exam per year which was recently completed. Mother would like the patient to be in the office for a well exam to offset recent visits which were focused on questionable genital trauma. Mother reports that the most recent visit with father which was last Thursday evening seemed to go quite well with the children returning in a much more calmer frame of reference. Over the holiday weekend, mother dial not observe any abnormal behaviors which she was associating with increased stress in both children. Amber continues to have nightmares and does quite a bi.t of talking in her sleep, but otherwise, mother reports all. seems well at this point. 0: Patient continues to be shy and is not willing to answer any direct questions that are posed to her but often defers to her mother to answer for her and this is done in the way of whispering back and forth between mother and daughter. Clothes are clean and is dressed appropriately for today's weather. HEENT: Within normal limits. Neck is supple withoiut lymphadenopathy. Lungs are clear, heart RRR and without murmur. Abdomen: Soft, nontender, with no HS. Genital Exam: Does not reveal. any stool material, either on the perireal area or on undergarments. No evidence of vaginal discharge or redness. Extremities are without evidence of trauma, swelling, and peripheral pulses equal and full. Back straight without deformity and skin is clear. A: 1) Healthy five year old female. P: 1) Mother encouraged to continue healthy eating habits and li.mi.ti.ng TV time. 2) Encourage more outdoor play and return to this office in one year for her next well exam. PVU Denise Hough,CRNP/als ,! - , ?P lrF II 14.-I. u Bowmansdale Family Practice O I Kacey Court. Suite 101 Mechanicsburg, PA 17055 Phone (717) 591.0961 Sf epherdstown Family Practice '2140 Fisher Road Mechanicsburg. PA 17055 Phone (717) 766.1795 Name: Amber Hoch 02-13-95 DOB: Seen at: BFP S( FP Date 04-15-00 S: I was contacted by the patient's mother at 5:30 PM at home. Mother was concerned with the distressed and agitated behavior of both Amber and her younger brother. Mother had just retrieved the children after a scheduled visit with their father at his home from 9 AM to 5 PM. Mother was unable to soothe the patient who was crying, clinging to mother, and seemed very agitated. Mother had repeatedly asked Amber to•t•ell her why she was crying, but the child would not or could not offer an explanation. Mother was unsure what to do at this point, I advised her to follow-through with the usual evening routine to get ready for bed and to call me back if the child continued to be agitated, and mother agreed. At approximately 7:30 PM, the mother called again, and asked if I would please meet them at the office. Amber was still quite agitated and crying intermittently. Since coming home earlier this evening, Amber had two episodes of stool soiling in her underwear which mother reports had never happened before. She asked if I would please evaluate Amber for any possible sexual contact. Mother reported that her last regular bowel movement was one day earlier and it was normal without any recent constipation or diarrhea. Mother denies noting any dysuria, urinary frequency or urgency. U: The patient and her mother were seen in the office a few minutes after 8 PM. This is a 5 year old whi.te female who walked into the office with her mother. She appears calm, is talking freely with both mother and myself. It is noted that the patient does not resist following-through with an examination this evening which is not her usual demeanor. In the past, patient has been very fearful and required quite a bit of consoling and reassurance when completing any type of well child visit or illness visits. The patient is wearing a dress with white tights and underwear. She acreee to allow a genital evaluation, but insistent that her mother stand aside the examining table and hold her hand. She was not specifically asked if anyone had touched her in the genital region and no allegations were vo ced by the child. The abdomen is soft and nontender in all quadrants. No obvious redness, swelling, trauma Of labia majors, labia minora, clitoral region, urethral orifice, or vestibule. The posterior fourchette is beefy red, Pppears swollen with thick, clear secretions at the vaginal orifice. There is no evidence of any stool material noted. The labia were not retracted manually and therefore the hymen could not be visually inspected. A thin film of stool material is noted over the vulvar region and around the anus. No erythema is noted over this region. the anal spinchter is closed and intact with stool materiel present externally. A: I) Erythema and swelling of the posterior fourchette of unknown etiology. P: 1) A call was placee to the Curberlanc County Children and Youth Services and a report eiven to Jean Schott. Due to the uncertain nature of today's clinical findings, Children and Youth Pdv:ses formal intake and screeni.ne by a sexual assault nurse examiner at Harrisburg Hospital Emergency Recm which the mother agrees to. 2i Mother war advised sexual a55,'U:L 11urse, approx ima tel y 9:3,o pM as director. Denasa Hough,MFN,CRNP/.>1:= tc net a;lo'. „mher tc urinate until seen by the meth -atient and ru.thcr then left the office Pt Pnc'. m,l.de the.,, wsy to the Harrisburg Honp:tal. ER 14c" 11 h??C L'I'tf i - Page fl __? ?. ??6iB '1'P II Ie FCIWd -a 1.991 Bowmansdale Family Practice ? I Kacey Court, Suite 101 Mechanicsburg, fa. 17055 gqhone(717)591-0961 Name ' PYl hi ? I Vi" I I Shepherdstown Family Practice ? 2140 Fisher Road Mechanicsburg, fa 17055 Phone (717) 766.1795 1 DOB Seen at : BFP FP) Date 4 t 1 Age (,vcars.months) Interval Histom/Problems Health Problems/Concerns ? none I I-Q;nrl SEr{? f_': ?I'rr iin1,L._1Tkrin' lkff:.?. % C:i4L(4R'o;:crl Medications 4 none Allergies none Immunizations ? up to date 'al due for: {_?P % d IP/Pe Y Physical Exam L P v -a . Ht CIS ? „ 9(5)-°% f- fn", Wt Lil'4# ??s BP / Normal General ENT Eyes Neck Heart Lunes Chest Abdomen Genitalia -- Skm Assessment Rrell exam ( V20.?? ? Cleared to participate in all sports activities Plans ?--? Imn1LLnIZ: DaPT.IPV ??ijl Varcella Hepatitis II Labs: H /H PPD serum lead U/A Tests: vision/hearing Next well exam C /__ year(s) Well Child - 5 years Present in exam room - alone Mom Dad grandparent 0=nhserved R=rennrted N-nnt ahle to do 0 R N Develo ment (90%= cars.montlts) hole name .101 Address Phone# Recognizes 3 colors 4.11 Dresses self w/o help (5.0 Opposites (5.6) 1 Copies square 6.0) Draws person - 3 its 5.3) 5 ris(6.0 Ho c (5.01 q1-ins Balance 1 foot 5 sec 4.3 10 sec(S.l 1 + = is a problem/concern Pt Ed = patient = nnr a nrnhtem.rcnncem eduratinn dnne - + Pt Ed Diet Adequate fruits, veggies,grains LFLC, healthy snacks Flouride - in water, supplements Folate, calcium, iron Health Habits Tobacco in home Bowel, bladder concerns Exercise Seatbelts Helmets - bike, rollerblades Smoke/CO detectors Firearms safety Sun avoidance, sunscreens Dentist g6.12mo.,brushes,flosses, sealants, moutheuards Behavior School readiness ` Behavior problems ,. , Friends Family relationships After schoul care TV, computer, video games Activities I.l.i o i .9 - Page # lf? ; nMa;5( PIBFP FORM 12111199) Bowmansdale Family Practice Shepherdscown Family Practice ? i Kacey Court. Suite 101 i, '2140 Fisher Road Mechanicsburg. PA 17055 Wdianiesbuw. PA 17055 Phone (717) 591.0961 Phunc (717) 760-179 Amber Hoch ( c -) Name: DOB: `? 3 1 Seen ac BFP - SFP 01-10-00 Date S: Patient presents with a one day history of some intermittent mid abdominal pain occurring about every 45 minutes, lasting 5-10 minutes, no nausea or vomiting. Low grade fever. Eating has percipitated some abdominal discomfort.. 0: Active, alert white female child scampering ardu'nd the exam room, no acute distress. HEENT are negative. Lungs are clear. Heart is regular. No ectopy. Abdomen is soft, nontender, no masses, no organorregaly. A: 1) Intermittent abdominal cramping. P: 1) Nondairy low fat diet over the next couple of days. 2) Encourage good fluid intake. 3) Bentyl Syrup, 1 tsp. four times a day as needed for abdominal cramping. 4) CIW/NI/PVU Joseph Cincotta,MDals Pale tr _? Bowmansdale family Practice 0 I Kacev Cout. Sure 101 Mechanicsbug. PA 17055 Phone (717) 5910961 Amber Hoch She Pherdstown family Practice Z io tuber Road Mechanlcshurc. [?\ 17055 Plwn? (717) 760 795 02-13-95 err ? i Date 09-17-99 S: Mother brings the child in today for evaluation of a bruise on the left side of the face. Child reported to the maternal grandmother that she fell on some blocks that were on the floor while visiting her father last evening. Was scheduled to see her therapist today, but that appointment was cancelled by the therapist and will be rescheduled at a later date. Mother brings the child into the office for documentation of injury. O: Patient is unwilling to allow even visual exam of the face and offers no history of ?tQ etiology. An area of ecchymoses which is dark blue and deep red in color is noted over the left cheek and will be documented on the chart by diagram. No other facial injuries noted. A: 1) Bruise of the left cheek. P: 1) Ice or warm heat to the face for any discomfort, otherwise, mother will be following up with therapist in the near future. PVU Denise Hough,CRNP/als 17 race rr ----= Bowmansdale Family Practice 1 Kaccv i :our. unc 101 Mochanicsbwo. PA 17055 Phone (717) 59 0961 Name: hm&, ??GL }1 Date rj . /s I URI/Flu Progress Note S: C daf histurrul (cltcie if prescnr/pusmnc ? o n line out if ncganve/absend - facial pain now> _ stufh uvtc sore throat _ hoalsenes•, _ post nasal dl amagc _ ?z\pWu1C to ;tier, / ('J • r n _?ry -sputum _Wteezing _awa);cmatnieltt rlt- _ft% r pro _ headache -aching _ nausea _ lightheadedness ' _ patient in home _ smoking Home treatment cried _decongestams -lozenges _TyIenof/Ibuprofen O: ? if normal/absent. circle if abnormal. Ifabnormal. specifi• severity on scale of I (mild) to 4 (severe) to the right Appears ill _ _ E\ternal nose congestion _ discharge, amount purulent _ Ears discharge_ TMs Rj-ght red _ dull _ mobdlo: _ Left red _ dull _ mob!hn -Conjuncdsa Right red _ discharge _ Left red __ discharge Nose (internal) red_ Sinus tenderness frontal- R L maeillan_ R L Throat red _ swelling _ euwdate _ Neck nodes anterior- R L posterior- R L _Th)roid enlargement _ Pulmonarv _ labored respirations auscultation rales _ R L rhonchi _ R L t+iseezing _ R L PEFR(pr/predicted) _ -Abdomen hepatomegaly_ splenomegah _ A: URI(4659) Mralsyndromel07999) • Blonchim.(-04aY Pneumonia (486) Acuteootismedia(36200) OME(38I10) Sinusitis (4619) Phar\ngitis(462) Suep(0340) Mononucleosis (075) Conlunctidtis(37200) Smoker(3051) Cerumenimpaction (3S04) Influenza(4371) AllergicRhinrus(4779) Pt Dx Rapid Strep Throat culture Rc SUE) p iyn.• ui?Fl ds _Kes Elesare HOB Vaporizer saline nasal spray/gargles CBC Heterophde CXR OTC medications Psi e hednne _ mg q 4.6 h T%ienol _ mg q 4 6 h. lbuprofen _ mg q 4.6 h Side effects of prescription mcd catiowevewed 4 Call if worsening or not implo» n•; wthin dass .Patient/Pa ent verbalized undaStandina Sheplierdstown Family Practice 21401isltri Road \h..hanicsbwL. PA 17055 Phu nu (717) 766 795 DOB: Seen at: BFP I SFP? R\ medications t. Page 7r wnc srP Br P fora .? .2 991 Bowmansdale Family Practice O I Kacey Court. Suite 101 Mechanicsburg. PA 17055 Phone (717) 591.0961 Namp Amber Hoch Date epherdstown Family Practice ?I] 2140 Fisher Road Mechanicsburg PA17055 Phone (717) 706-1795 02-•13-95 DUB: Seen ar. 06-15-99 S: Bee sting of left foot last night. More swollen this morning. Seems to have pain with ambulation. Had temperature of 100 degrees F. 0: Left foot reveals a swollen erythematous area of the medial aspect of the foot in the arch. Minimal warnifh. Pt is combative and unable to evaluate tenderness. No lymphangitic streaks. There is no inguinal adenopathy. A: Bee sting. Do not believe there is an element of cellulitis. P: Reviewed natural hx of bee sting swelling, cool compresses, elevation, Benadryl p.r.n. Call for signs of infection. PVU. GMJ/cbc r Pape tl Bowmansdale Family Praaice O 1 Kacey Court. Suite 101 Mechanicsburg. PA 17055 Phone (717) 591.0961 Name: Amber I DOB: Date 05-26-99 Shepherdstown Family Practice 2190 Fishcr Road Mechanicsburg, PA 17055 Phone (717) 7661795 Seenac BFP SFP 1 5: Brought in by her mother with dysuria. This was reported last evening after returning from a supervised visit with her father in his home. The paternal grandparents are acting as the supervising adults during these visits as directed by Children's Services. The materna•1 grandmother received the child last evening while the mother was a school.) the patient had told the grandmother about her burning and when the grandmother looked at the vaginal area she reported to her daughter that it was red, swollen, and "looked like it had been stretched". The grandmother applied Desitin to the external vaginal area and put the child to bed, she slept through the night. Awoke this morning continuing to complain of dysuria with urination, mother noted some discharge on the underwear and decided to bring her in for evaluation. 0: Patient continues to be somewhat shy, although a bit more open and communicative today. The vaginal area is quite red with significant redness noted between the labia and majora and minora on the left side above the vaginal opening. There is questionable gray to green mucousy discharge noted externally at the vaginal opening, no drainage could be visualized coming from the vaginal canal. These secretions were cultured for chlamydia GC and a general bacterial culture. No other lesions or changes seen. The lower a abdominal region is soft and nontender on deep palpation. The patient was unable to give us a urine sample today. It is also noted that the underwear that the child is wearing shows a fairly moderate amount of dried yellow to light green discharge. A: 1) Dysuria, rule out UTI versus vaginal infection. P: 1) Mother will apply Desitin or Balmex externally, will irrigate the peroneal area with warm tap water during urination and push fluids. 2) Will notify the mother as cultures come back to the office, mother will try to obtain a urine sample at home and bring it in for analysis. PVU Denise Hough,CRNP/als Page a Bowmansdale Family Practice She ie'rdstown family Practice O 1 KaceyCourt,Suite 101 O' 2140 Fisher Road Mechanicsburg. PA 17055 MecharncsburP. PA 17055 Phone (717) 591.0961 Phunc (717) 7661795 Name: Amber Hoch DOB: 02-13-95 Seenat: B sm ) Dare 05-05-99 ?? S: Here with her mother who reports a two day history of dysuria and also blood on underwear today. Child was being watched by the maternal grandmother who called the mother at work to report what appeared to be vaginal blood on the underwear after going to the bathroom. Mother went home and questioned the child who stated that her daddy put his hand over the external vaginal area, told her grandmother that her daddy put his finger inside. Mother brings the child in today for evaluation, verbalizes concern that because of their impending divorce she is uncertain if she should pursue this or not do anything to "make him angry". 0: Patient is shy as usual but does seem to be a bit more relaxed today and is playing on the floor in the exam room with some toys, although was not willing to leave her mother so that we could talk privately. Vital signs are within normal limits and UA shows protein, trace blood, and some yeast, but otherwise, is clear. There was no blood or discharge on the patient's underwear, the vulva is somewhat red and shows an area of very well marked irritation along the lower vulva rim. Introitus is somewhat open and hymenal ring was not visualized. No digital penetration or exam was performed. The patient was somewhat willing to allow today's exam as long as her mother would stand beside and hold her hand, but otherwise, cooperated nicely. A: Dysuria with recent questionable vaginal. bleeding, rule out possible sexual contact. P: Patient and mother were directed to report to Harrisburg Hospital Sexual Assault Program for further evaluation. The mother was going to take the the hospital was also alerted to their arrival. PVU child over immediately, Denise Hough, CRNP/als/t t} ^-(r i rages )_-1- r % 4 YEAR VISIT Name Dale: 3laci ki S Ace: j 4, al, t J. SYSTEMS REVIEW J ?Flouride: water supplement Nutrition = 1 - ! `Toilet training/bowel habits Sleep i • ..•7' _:?.. Interval history DEVELOPMENTAI, SCREEN (O-observed. R-reported) i= Pcdals tricycle (3 yrs) Copy 11- Uses plurals (3.5 yrs) L Dresses themselves & Knows first and last names 14-- Knows holy parts C- plays cooperatively Hops on one foot Consider DDST PHYSICAL. EXAM N ABNORMALITIES N ABNORMALITIES I'I?`?t rr Ht. Heart Wt. IQ Abdomen BP genitalia Skin ti Back HEENT -- Extremities Teeth Neuro Nodes ('over, uncover test Chest -ROBLEMS AND PLANS I ?.1 RTC --TT TEACHING TOPICS Fine motor development Books/reading v _Seat hells -.-Discipline School readiness -Safety: sircei, eater, hicyclc JJ?Mt1NI7,AT10NS?nd?(.RI:I?N?'1_li}'1•ti; f__ _:_•?'.._c'-=lr..._'_-----_.------------- 3 YR VISIT H, 11 .u Name: 11?'\ bt (- Page--- Date/Vitals 2-19-99 Continued switching attorney since her divorce. Mother comes in today concerned about the number of bruises, feels that these represent more than the typical bruising that occurs with play on a regular basis. No other injuries that mother has noted ;since earlier today. Her daughter does„not offer much information !and her son will say nothing. It is noted that he too has started Ito cry when it is time to go to his father's which in the past he was always quite excited to do. Their biological father is living with the paternal grandparents and they usually are present over the !weekend as well. 0: Shy but somewhat pleasant and cooperative four year old female. Multiple bruises are noted on both the forearms and lower legs. Only one is a newer injury on the distal portion of the right tibia measuring 2x3 cm. with a deep blue purple color. All of the remaining bruises are the same color which are a medium to light brown. The tone without any yellowing. All of the bruises are circular to oval in shape and measure anywhere from 1 to 2cm. in width. No evidence of any other mechanical abrasions, scratches, cuts, other than lower arms and lower legs. A: Bruising of arms and legs, unknown etiology. P: Mother is encouraged to keep careful documentation of any future observations. Is advised to carefully check the children each time they return home and to of course observe for any tripping or falling while in the mother's care as well. Is to let us know if there are any further concerns, otherwise, simple observation, and mother will get back with us as needed. PVU Denise Hough,CRNP/als Date/Vitals r LSYw U ICI 05. Name: Page --- Continued' problem with intermittent constipation over the last. ,ear. She will have hard bowel movements for a period of relief t t-ime and :hen will seem to be f i.neor or the last a pfive days, eriod of time. Gets solace or Karo syrup. )owel movement. For the last two days, has had abdominal pain and mince last night has not had any significant amounts of food to aat. She has been drinking fluids. She also today has developed a =sore throat and now has a fever. D: Irritable and combative when examined. Throat is erythematous. Neck supple with no large nodes. Abdomen is soft and apparently nontender. No organomegaly or masses. Rectal reveals a mild perianal rash. Rectal vault is very dilated, and there is a large amount of formed but soft brown stool in the rectal vault which is heme negative. A & P: 1) Constipation. Reviewed bowel program of tories today, and then is to begin a program of glycerin supp BM in 24 hours and enema if no BM in 48 hours. To continue Colace or Karo syrup and high fiber diet as needed to keep stools soft. Stressed importance of continuing this for a good 3-4 months Funtil ever rectum will have a time to get b Will to normal alympsize. 2) tomatically and probably related to pharyngitis. watch. Discussed possibility of this being related to tier constipation, although, I think that is very unlikely. Mother to watch for worsening abdominal pain. PVU. GMJ/cbc I-?? cCr w ! fc:3C? T AC L I i Z? X /1 IiEENT are negative. LUngs are clear. Nodes, no adenopathy. A; Viral syndrome. P; Diet as tolerated, Tylenol or Advil for fever. Good fluid intake, recheck as needed. PVU Joseph Cincotta,MD/als a P Q? a r cl) ?Q Sz e ?Q -Skj o a w,. ? ? ? ?.? ??????? ? ?? ? ? ?? c ?? d?,? ?? ? , ?? ? ?? ?? ?? ? ? ? ?? ??? v L^ IzIr N 17055010 i17-766-1795 SHEPHERDSTOWN FM PRACTICE 2140. FISHER RD MECHANICSBURG PA 17055- i HOCH,AMBER i 167766522 717-432-5611 1 10046721 I KP816567P 10046721 SS#:167-76-6522 SmithKline Beecham OLD Clinical Laboratories LABORATORY REPORT FINAL CHLAMYDIA TRACHOMATIS DETECTION BY DNA PROBE CHLAMYDIA TRACHOMATIS NUCLEIC ACID RESULT: - NONE DETECTED THIS METHOD HAS BEEN VALIDATED USING ENDOCERVICAL, MALE URETHRAL, AND CONJUNCTIVAL SWAB SPECIMENS ONLY. PERFORMANCE WITH OTHER SPECIMENS HAS NOT BEEN ASSESSED. CULTURE. GENITAL SOURCE: STATUS: RESULT: CULTURE, NEISSERIA GONORRHOEAE SOURCE: STATUS: RESULT: Servicing Laboratory: KP Apa rPl-ry-aiuan ----------- -- -- '?i(Scx 4 I F iI HOUGH, DENISE i 14:0 05/26/199, 05/31/1999 16: KP VAGINAL FINAL GROWTH OF NORMAL VAGINAL FLORA VAGINA FINAL NO NEISSERIA GONORRHOEAE ISOLATED >> END OF REPORT << /pole till KP KP ? "?iJ -------------- Date/Vitals URINALYSIS Dale 10-9:7-79 Tech Name: n ft4_e L dbt?" Page _ Name flr?bt- MCC- Physician G-S Color/Clarity v S • c ?o a H / n Specific Gravity ?•0/f Itrite W.B.C. Protein - R.B.C. L Glucose - -Ep. Cells I Ketones - -Casts Urobilinogen Bacteria Bllirubin - Crystals Blood Leukocytes -h (Z4 t #24 "4 r URINALYSIS Dale ' S ' l ?l Tech ?,? Name l? t xhLS LO c ?1 PH e).o ° _SpecificGravity f •G Mitritw -- W.B.C. '?• + 3D A.B.C._ Glucose Ep. Cells Ketones - Casts _ Urobilinogen - Bacteria I Crvstals A 6.94 jet •{-h aIa Leukocytes 4AM {7(.-r2 'l'LLL/YLi.) li ? ?1ti'CC ox. ayazd c/gzWoemb 911rjloleyf?t 545 vc i .OxGUe, evaMlb ", 96MF4110700Y 717--737 8864 Psychological Evaluation Candace L. White v. Christopher L. Hoch Referred by: The Honorable J. Wesley Oler, Jr. , The Court of Common Pleas of Cumberland County Referral Reason: To conduct a psychological evaluation and home study to determine appropriate visitation arrangements for Amber R. Hoch DOB 2-13-95 and Austin S. Hoch DOB 8-16-96 Interviews: 1-05-00 - Candace L. White 1-31-00 - Candace - Testing 3-25-00 - Candace - Testing 1-10-00 - Christopher L. Hoch 2-02-00 - Christopher - Testing 3-18-00 - Christopher - Testing 3-08-00 - Amber R. Hoch 3 08-00 - Austin S. Hoch Home Study: 2-19-00 - Christopher, Amber, Austin, Terry and Judith Hoch 2-26-00 - Candace White, Amber and Austin Hoch 3-25-00 - Candace White, Amber and Austin Hoch, Deborah White Psychological Minnesota Multiphasic Personality Inventory 2 (MMPI-2) Testing: Thematic Apperception Test Bender Motor Gestalt Test Wechsler Adult Intelligence Scale-R- Comprehension Millon Clinical Multiaxial Inventory-111 (MCMI-Ill) Candace White Christopher Hoch Perception-Of-Relationships Test(PORT) Amber Hoch Austin Hoch ? s. 7? °0 Ax y Page Two - White v. Hoch Other Information: 3-03-00 -Phone Conversation -Austin's Therapist 3-06-00 - Phone conversation - Amber's Therapist 6-25-99 - Report of suspected child abuse received by Cumberland County Children & Youth Services, 5-05-99, regarding Amber R. Hoch determined unfounded All of the above sources of information are used in recommendations made in this report. BACKGROUND: Christopher Hoch and Candace White were married May 13, 1995. They lived with Candace's parents for three to four months and then purchased a condo at 10 Glenview Drive, Dillsburg. Both of them admit that there were difficulties in their marriage. Christopher left in May, 1997 and moved home with his parents in Mechanicsburg. Candace sold the condo and purchased a mobile home in Walmar Manor outside of Dillsburg. They were divorced 8-97. CANDACE L. WHITE: Candace is a 24 year old woman who works as an architectural drafter for SGS Architects and Engineers in Carlisle. She graduated from Cumberland Valley High School in 1994, worked for Shepherdstown Family Practice for about 2 years and then at Gannett Fleming, Inc. for about 8 months. She received an Associate Degree in Computer Aided Drafting in September, 1999. She says that she likes her job. Candace reports that she grew up in an intact family. She maintains a close relationship with her father, John, a barber, and mother, Deborah, an office worker, who live in the Dillsburg area. She has an older brother and a younger sister who also live locally. Candace was eager to proceed with the evaluation. She was cooperative in arranging and prompt in keeping appointments. She was pleasant and relaxed and gave serious thought to questions asked. In sessions, her affect was normal and appropriate to content of thought and verbalization. Articulation was clear and rate of speech normal Concentration and attention span were good, judgment and insight were adequate, and no cognitive impairments were shown. She appeared to be average or above in intellectual ability. She expressed concern about Christopher and what she called his dual personality. Page Three - White v. Hoch Candace's uppermost thoughts were centered on her children. She talked freely about her alarm when she believed Amber had been abused. She feels the children are secure when they are cared for during the day by her grandmother. She is not certain they are in a safe environment when they are with their father. Both children are now in therapy. Candace's MMPI-2 results are valid. She cooperated with the test administration and endorsed psychological symptoms. She is attempting to get help for her problems. There may be a tendency for her to be overly self-critical. She is passive-dependent in relationships and is easily hurt by others. Individuals with this profile are often unable to assert themselves appropriately and are frequently taken advantage of by others. They tend to t.iel quite tense and depressed and may need relief for their psychological symptoms. Candace reported that she has been seen by a mental health professional and is on appropriate medication. Results of the MCMI-1I1 are valid and support the MMPI-2 findings. She may be experiencing a general state of sadness and anxiety that may often make the ordinary stresses and responsibilities of her life seem excessively demanding. The total personality profile reveals intact perceptual and emotional functioning overall. There is no evidence of psychosis. No unusual anomalies were shown in test results. She tends to interpret situations appropriately and is generally well motivated and views the future optimistically. There may be unresolved self-esteem issues. Christopher L. Hoch: Christopher is a 27 year old man who has worked as a pressman for Reprographics offset for about 3 years. He graduated from Mech?nicc bur, High School in 1991. He served in the United States Army from 2-4-92 to 10-18-94 and was honorably discharged. He then fixed trailers for Acme Trail Works and was a pressman's helper for Fry Communications before taking his present job. Christopher lives with his parents in Mechanicsburg. His father, Terry, works for Keebler Company, and his mother, Judith, does day care for 3 children in her home. He has an older brother and a sister who live locally. Christopher was cooperative in setting and keeping appointments for the evaluation. He was pleasant and relaxed and freely told his side of the situation. In sessions, his mood seemed normal and sensoriunt was clear. Ilis affect was appropriate to content of thought and verbalizations. Judgment seemed good and insight adequate. General intellectual functioning appeared intact with at least average or above intellectual ability. No drug or alcohol problems were reported. w• Page Pour - White v. Hoch His greatest concern was to get things back to normal and have fun with his kids. As to the situation, he stated that Candace is pulling everyone into this she can. His concern was what she said he did to the kids. He emphatically said that he didn't leave the kids. He denied ever doing Amber any harm. Christopher's MMPI-2 results are likely to be a good indication of his personality functioning. He is quite depressed and feels very inadequate and pessimistic. Individuals with this profile may be mistrustful and shy and may avoid relationships because of vulnerability to hurt. He may have a great deal of resentment and anger about his loneliness and not be able to express it appropriately. According to this profile, he may need relief for his psychological symptoms and should consult a mental health professional for therapy and possibly medication. MCMI-III results are valid. They indicate a generalized anxiety disorder and adjustment disorder with depressed mood. His symptoms may arise in response to external precipitants and cause emotional, cognitive, and interpersonal difficulties. His depressive tone may evoke feelings of low self-esteem, unworthiness and uselessness. The total results indicate that he is capable of perceiving reality in conventional ways. There is no evidence of psychosis. No unusual anomalies were shown in test results. He is compliant and strives to overcome his feelings of helplessness and dependency. He may tend to interpret situations pessimistically and in an overly sensitive manner. Needs to build competence and strengthen attributes are apparent. AMBER AND AUSTIN HOCH: Both children were seen alone when brought for interviews by their maternal great- grandmother, Mrs. Pat Knecht. They were also observed with their mother and father during home visits. Austin is a 3-'/x year old who presents as a very active child who will focus quickly when a task is introduced. lie followed directions and was cooperative. A speech problem, for which he is receiving therapy, is apparent. Intellectual ability appeared to fall within the normal range. Amber, age 5, displayed some verbal opposition to her great-grandmother. In the interview, she initially tended to withdraw and had difficulty deciding whether she would respond; however, a positive relationship was established and she was cooperative, followed directions, and was willing to try everything she was asked to do. Speech and language were clear and well structured. Intelligence appeared to be in the average or above range. Page Five - White v. Hoch Both children were administered the Perception-Of-Relationships Test to gain an understanding of their preferences and relationships with parents. Some parts of Austin's test were difficult to administer because of his age; however, in results obtained, Austin showed preference for his mother in 2 items, his father in 3 items, and equal preference in 1. Amber showed preference for her mother in 5 tasks and treated both parents equally in I . Both children attend a preschool program at Mountainview Nursery School. Amber attends Tuesday, Wednesday, and Thursday from 1:00-3:00 PM and Austin on Tuesday and Thursday from 9:00-11:30 AM Both children are in therapy at Inner Works. In phone conversations, both therapists reported that they are progressing. Both have difficulty separating from their mother when they come for sessions. HOME VISITATION: The Hoch home, where Christopher lives with his parents, is located at 525 Simpson Street Mechanicsburg. The two-story house consists of 7 rooms and 1 and %2 bathrooms. There is a swimming pool in the yard. The first floor consists of a kitchen, living room, dining room, a large family room, and a''A bathroom The children sleep in Christopher's bedroom on the second floor when they are there. The room contains two single beds, one for Christopher, one for Amber, and a crib for Austin. Many of the children's toys are also kept there. Christopher was playing with the children at the kitchen table. Both children were actively engaged and concentrating on what they were doing. Christopher allowed them to direct their play and contributed only at their request or when appropriate. Both children were contented, interested in what they were doing, and comfortable in their interaction with their father and grandparents. When a tumbler was accidentally knocked off the table, Christopher immediately took charge and insisted that the children stay safely on the bench until he had cleaned up the glass. They attended to the boundaries he set. Their grandmother occupied herself with unintrusive tasks and their grandfather watched television in the adjoining family room. Amber later engaged her grandmother in playing a game in the family room. The home was clean, adequately and tastefully decorated, and comfortable. The only hazardous condition noted was what appeared to be liquor bottles within reach of the children behind a bar in the family room. The swimming pool was covered for the winter and the grandmother said that she has extra help when the children are in the pool in the summer. Page Six - White v. Hoch Candace White lives with her children, 3 cats and a dog, in a mobile home in Walmar Manor, a mobile home park. The dwelling consists of a living room, kitchen, laundry room, 3 bedrooms, and 2 bathrooms. It was clean and adequately furnished and decorated. Amber and Austin were very excited to have a visitor. Both vied for attention and wanted to show their bedrooms and toys. They obeyed when Candace set boundaries and listened when she gave directions. She was caring, interactive with them, and sensitive to their needs. Austin concentrated on putting tracks together and running his train. Amber brought out a bag of toy horses and dolls and pretended they were having a race. There was a "For Sale" sign in the yard. Candace said she was going to move in with her parents in about 2 weeks. Candace moved to her parents' home at 1077 York Road, Dillsburg, March 11-12. The White's two-story house consists of 13 rooms and 3 'h bathrooms. The family pets include 13 cats (Mrs. White breeds' cats for sale and show.), 2 dogs, and 2 horses. (Candace's pets included.) Candace and Amber share a bedroom. The room contains two single beds. Austin sleeps in an adjoining room reached through a shared bathroom. The children were eager to show their new home. With supervision, they operated their grandfather's model trains and showed the kittens. Candace plans to build a house nearby. She hopes to move into it in about six months. CONCLUSIONS AND RECOMMENDATIONS: There is nothing in the psychological information that would exclude either parent from Amber's and Austin's lives. There is evidence that therapeutic intervention is warranted for both parents. Both are struggling with some anxiety and depression. In view of the evidence presented, it is recommended that Candace pursue some therapy in addition to the medication she now takes. It is also recommended that Christopher seek therapy and possibly medication for symptom relief. These actions are needed in order to resolve the painful set of circumstances with which this family has been struggling. Page Seven - White V. Hoch The father's visitation schedule in effect is Tuesdays and Thursdays from 5:30 to 8:30 and every other weekend from Friday from 5:30 to 8:30 and Saturdays from 9 to 5. This seems to be working except for overnights on weekends. If Christopher will get into therapy and deals with his difficulties, it is hoped that Candace's concerns about Amber's safety will subside. Upon report of successful participation and progress in therapy, unsupervised visitation and overnights on weekends can then be resumed. Amber and Austin are exhibiting some signs of difficulties that could be the result of the stressful situation between their parents. Amber appears to need help in her relationship with her father. The oppositional tendencies and separation problems observed may be symptoms of anxieties and insecurities caused by the parental disruptions and disagreements they have experienced. Continuation in therapy is recommended to aid in the clarification of their needs and provision of any intervention necessary for optimal development. Both parents need to establish an independent home for themselves and the children. The children need their own bedrooms and their own space for their possessions. Until recently, Candace has done this and plans to do so again in the future. Christopher should plan to do the same when possible. It is felt that Candace and Christopher are capable of reconciling their differences involved in the parenting of Amber and Austin. Both appear to do a relatively good job of meeting their mental, physical, and emotional needs when they are with them. Caution should be exercised in being so preoccupied with their own differences that the quality of their parenting deteriorates. It is imperative that they reduce the friction between them in the presence of the children. They need to recognize that decisions concerning the children that are made by mutual agreement usually are the best assurance for a favorable outcome. They should seek a family counselor's aid if they cannot resolve issues themselves. Date: GC?zti@ v vv ?l?eL' ?. /,-32dun/ Hazel J. Brown Licensed Psychologist Cumberland County Children & Youth Services May 9, 2000 TRW Christopher L. Hoch 4012 Seneca Drive Mechanicsburg, PA 17055 RE: CL#: 21-0005154 .?r?uxrv.'nJ ?axrri??u. Dear Mr. Hoch: In compliance with the Child Protective Services Law of Pennsylvania, Chapter 63, the Cumberland County Children and Youth Services is hereby notifying you that the report of suspected child abuse received by this Agency on Agency April 16, 2000 regarding Amber R. Hoch has been determined to be Administrator eW l.shNyASw "Unfounded" and your case with this Agency will be closed. According to the §6337 of the Child Protective Services Law, all "Unfounded" reports of child abuse shall be expunged as soon as possible but no later than 120 days after the one year period following the date the report was received since the case was not accepted for services. This determination does not reflect the status or findings surrounding any County police investigation. Whenever a referral has been made to police, you will need Cemmissloners Nancy A. Bach to contact the appropriate police department regarding the status and outcome of Earl R. Keller Richard R. L. Rovelino their investigation. If you have any questions regarding this matter, please contact me during regular business hours. If I am not available when you call, please leave your name and a telephone number where you can be reached and I will return your call. 'ncerely, ? ?cannc Schott Suite 200 Caseworker Human Services Building /jic 16 West High Street Carlisle, PA 17013.2961 (717) 240.6120 (717) 697.0371, Ext. 6120 (717) 532.7286, Ext. 6120 , NO Will r?ar?M? PL[ rt' 1? nY?t i? 1c?Y o? 5 i?A w K S' ....__ {t.No?? SYwKec?^- v u t > v ?o ??c_? 1 h4^^ ... -so wual ?4? 2 GU`s1 l J ?0L C? rJ CO? SfnreL S .?4... _.__.: _. ? [??, ?i? ?,?s .r.,?,,;?` ?-???..? ? ? r???. ??? k pis _ _ _.... .._?•.S s n? Sty aft?? i?A+J?J??S e o wl -CL -712,80 i aS ?? w 10 a ?oG? . 5 Vc?.J \Jac? ic y { \ l _ f' Q.N,/,.??w,? , .W[. S Da,ss t,1 ?? .?4 blo?? dos S?.aas ovL }1F?il,?? Gsl oti ?ti y ask. p ?:? 1 ..__._. ..10 CA TL7 ",4- e?-n ?2TON= p W2 L5?1'?.. ?Ql? I_ p I.N SO(VaL ?... ..T6... kefu_66070!- _ -6 f^ft-J, ns4 I,-b5 tzol,'U? t? ?S ?^ttan a aS?o?c? A??a a67t C¢t/Cn?. f Wez . la ?F i?ot? Lw, . ?LI S OLt -_....... _ ?,J`C Fon-- 5 v ?- aM?•.- ? ? N? ps+ nwel? , aC'?5'"t-? n? a ?e_ _ ..?e.Se?1?R R^?grdre a 3_Jy-yin-n•.A ?,c.?? Facr`?- p?rMCS ? ?JC?-{o.? ?- cap' ?om,?{.t ccw?t"o? .. \?- ?,c?`S Wo't'rJr`.ea3- 1'? Q„Nc?-C°i? ???'?U r' ?h{. -?•?u(0•n,2lGs_ y -s S?aySeJ? W,4v-, leA Z'LN'Jlh.1? r V?OQ.JV !r?7 Q s ? c, ISCe? ?O a? DL"- {a filK cCt cL ryth " C'U May 10, 1999 Ms. Diane Rupich, Atiomey-at-law 1017 North Front Street Harrisburg, PA 17102 Dear Ms. Rupich: I evaluated Amber Hoch for suspicion of sexual abuse on 7 May 99. Amber had disclosed, according to mom, that "Daddy put his finger there (indicating her vagina) and it hurt". After visitation with dad when, according to mom, this sexual abuse occurred, maternal grandma noted blood at the opening of Amber's vagina. At that time Amber complained of hurting when tier vulva was touched and burning when she urinated. During my and Teresa Smith's interview, absent mom, on 7n May, Amber disclosed that dad touched her vagina with his middle finger and that it hurt. Examination of tier hymen was normal. Penetration between the lips of the vagina, touching the opening of the vagina and/or hymen, hurts in young girls. Generally there is no injury to the hymen of a permanent nature when there is touching of the hymen by a finger penetrating between the labia, but not through the hymenal aperture into the vagina. Accordingly, lack of findings on Amber's exam does not preclude her disclosure. The historical details provided by Amber were accompanied by the appropriate emotional congruence and were reflective of her having experienced the disclosed contact. Very truly yours, Earl F. Greenwald, I Cc: Crystal White, mother Jill Albright, Cumberland County Children & Youth Caseworker 2601 Nonh Third Street • Harrisburg, PA 17110 (717) 782-2467 0 1-800-334-1007 ext. 2467 PLAINT'IFF'S EXHIBIT. SI - EXHIBIT "A" AUC 0 5 1999 "?'- CANDACE L. 1VlllTE :IN T11F. COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA Vs. :NO. 99-2864 Civil Term CHRhrOPHER L. IIOCFI :Custody DEFENDANT ORDER On now on this _day of , 1999 upon the Motion of Christopher L. I loch to remove restrictions on child visitation and it hereby ordered and directed as follows: I. This Courts Order of May 18, 1999 is vacated. 2. The terms of the York County order previously entered at No. 98-SU-00880- 021) are reinstated and shall remain in I1d1 force and effect. BY THE COURT.- A Wesley Oler, Jr, J. CANDACE L. WHITE PLAINTIFF VS. CHRISTOPHER L. HOCH DEFENDANT :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 99-2864 Civil Term :Custody MOTION TO REMOVE RESTRICTIONS ON CHILD VISITATION AND NOW comes the Defendant. CHRISTOPHER L. HOCH, by his attorney .IAI\1ES M. BACH and files the within Motion to remove restrictions on his child visitations: \Veslec .I. Oler..Ir...ludge of the Cowl of Contnwn Pleas of Cumberland County, issued an Order on May 18, 1999 placing restrictions on over night visits of the child involved in this case with their Father Christopher L. Hoch. A copy of the Order is attached hereto and marked as "Exhibit A". 2. Counsel has been required to notify the Court as to receipt of a completed investigation by Cumberland County Children and Youth Services. The report made by Cumberland County Children and Youth Services regarding the allegations nwde by Candace L. \4h4c against her former husband Christopher L. I loch in the nature of child abuse charges are "UNFOUNDED". See "Exhibit 13" 3. Christopher L. Hoch respectfully requests that any and all restrictions on his visitation with his children be removed. q%rd/r Sumbitteth DATE; ?-16-99 !ES M. BACII, ATTORNEYAT LAW South Sporting Hill Road •hruricshuru, PA 17055 (717) 737-2033 tnorncr ID tl18717 CANDACE L WHITE, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTOPHER L. HOCH, Defendant CIVIL AC'T'ION - LAW NO. 99-2864 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR EMERGENCY RELIEF ORDER OF COURT AND NOW, this 18th day of May, 1999, upon consideration of Plaintiff's Petition for Emergency Relief with respect to the parties' children, Amber Renee Hoch (date of birth February 13, 1995) and Austin Scott Hoch (August 16, 1996), and following a hearing, it is ordered and directed as follows pending further order of court: 1. Pursuant to an agreement of the parties, Defendant's periods of partial or temporary custody with the children shall be on Tuesday and Thursday from 5:30 p.m. to 8:30 p.m. and on alternating weekends on Friday from 5:30 p.m. to 8:30 p.m. and on Saturday from 9:00 a.m. to 5:00 p.m. 2. Defendant's periods of partial or temporary custody with the children shall be supervised by Defendant's parents, with one parent being in Defendant's presence at all times that he is with a child. 3. Counsel are requested to notify the court by motion for an amended order at such time as Cumberland County Children and Youth Services has completed its investigation of allegations of child abuse in this matter. 4. In all other respects, the terms of the York County order previously entered at No. 98-SU-0080-02D shall remain in full force and effect. ,Z5 Z-1 14? Cumberland County Children & `youth Services June 25, 1999 01 :?rnrrrui rr7 ,'}rnrr/iu. Agency Administrator awry 1. St". LSW Christopher L. I loch 525 W. Simpson Street Mcchmiiesburg. PA 17055 [)car Mr. I loch: In coniplialnce with the C'Inhid Protective Services Low ol'Penusyhvania, Chapter 63, the Cumberland County Children and Youth Services is hereby notifying you that file Ieport of suspected child abuse received by this Agency on May 5, 1999 regarding Amber R. I loch has been determined to be "Unfounded". According to file §6337 of the Child Protective Services Law, All "Unfounded" reports of child abuse shall be expunged As soon as possible but no later than 120 days After (lie one year period following the dale the report wns received. This dclerminalion does not reflect (lie status or Findings surrounding Any Police hnvesligation. Whenever a referral has been nnade to police, you will i need to contact the appropriate police department regarding the status and County outcome of their investigation. Commissioners Haney A. ar.ce i Ewl era Minds A. Myon. Whenever the Courtly Agency investigation reveals, within 60 days of receipt of Ilic report of suspected child abuse, that the report is unfounded but flint the subjects need services provided or arranged by the County Agency, County Agency may retain those records and shall specifically identify flint the report wns nn unfounded report of suspected child abuse. Ifyou have any questions regarding this matter, please contact me during regular business hours. I f I Am not Available when you call, please leave i your name and a telephone number where you can be reached and I will return your call Suite 200 Sincerely, Human Services Building . -4? 16 West High Street Jill Albright Carlisle, PA 17013-2961 Caseworker (717) 240-6120 (717) 697-0371, Ext. 6120 jlc (717) 532-7286, Ext. 6120 i i L, r c j?-- 0`' By the Court, J, Wesley O1 , Jr., J. Diane M. Rupich, Esquire 1017 North Front Street Harrisburg, PA 17102 Counsel for Plaintiff James M. Bach, Esquire ,452 South Sporting Hill Road Mechanicsburg, PA 17055 Counsel for Defendant :srs TRUE COPY FROM RECORD In T, ;I m^cry •. I; r.or, I h,rc unto set my hand and the sral of said Court at Carlisle, Pa. This .../..4.x?... day of.... l.Q.. 19?... ProthonotarY ?? Lfl ?.. e i:. ? ?. Vii:' (?i'; ? . ,1 ` i. _? ` L u. i .?. , C,, ?r iJ -J . ` CANDACE L. WHITE, Plaintiff V. CHRISTOPHER L. HOCH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2864 CIVIL TERM ORDER OF COURT AND NOW, this 14th day of October, 1999, upon consideration of Plaintiff's Motion Pursuant to Your Honorable Court's Order of May 18, 1999, and of Defendant's Motion To Remove Restrictions on Child Visitation, and pursuant to an agreement reached in open court among the parties and their respective counsel, Diane H. Rupich, Esquire, on behalf of the Plaintiff, and James M. Bach, Esquire, on behalf of the Defendant, it is ordered and directed as follows: 1. The visitation, as set forth in this Court's Order dated May 18, 1999, will remain in full force and effect. 2. The parties hereto will undergo a psychological evaluation to include a home study at the expense of Candace L. White, Plaintiff, in this case. 3. Halloween 1999 visitation, Thursday evening, will be with Candace L. White, Plaintiff, and the Defendant, Christopher L. Hoch, will receive another evening that week to make up for his Thursday. 4. Effective immediately, transportation to s I- SSC"7 I', 11 :ni rQ the home of Christopher L. Hoch, and from the home of Christopher L. Hoch, shall be provided by the Plaintiff, Candace L. white, at all times hereafter. 5. The Court's order of the 18th day of May, 1999, will remain in effect pending the home study and the psychological evaluation. By the Court, Diane M. Rupich, Esquire 1017 N. Front Street Harrisburg, PA 17102 For the Plaintiff James M. Bach, Esquire 352 S. Sporting Hill Road Mechanicsburg, PA 17055 For the Defendant wcy f 49 R(K E£OZ•1£1 6141) JAMES M. BACH ATTORNEY D COUNSELOR AT LAW 352 SOUTH PORTING HILL ROAD MECHANICSBURG, PENNA 17055 440LL VNN3d'E)un8S01NVH03W OVOH IIIH NUNS H.LnOS d4C MV'I 1V U013SNf100 OMFA3NH011V HOVE 'w s3wvr CANDACE L. WHITE Plaintiff V. CHRISTOPHER L. HOCH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-2864 Civil Term CUSTODY ANSWER TO PETITION FOR CONTEMPT OF COURT AND NOW, on this Day of January, 2000, comes CHRISTOPHER L. HOCH, by his attorney JAMES M. BACH, and files the within Answer to a Petition for Contempt of Court. 1. ADMITTED. 2. ADMITTED. 3. ADMITTED IN PART, DENIED IN PART. The initial case arose out of an allegation filed by the Defendant's ex-wife, accusing him of some sort of abuse of his children. A complete and thorough investigation was conducted by Children and Youth Services of Cumberland County. Same was found to be "UNFOUNDED". This matter was brought to the Court's attention, and the Court modified the pre-existing Court Order. 4. ADMITTED IN PART, DENIED IN PART. The underlying reasoning and rationale behind the Honorable Court's decisions in this regard was an accusation by the ex-wife of Christopher Hoch that he had committed some sort of child abuse. The investigation was conducted and completed by Children and Youth Services of Cumberland County, and Mr. ]loch was removed from any suspicion. The allegation was deemed to be "UNFOUNDED". 5. DENIED. The underlying motivation f'or the ex-wife of Christopher Hoch in this case is and has been to do and say those things on a regular basis, which will cause him to lose visitation and contact rights with his children. As she has stated on numerous occasions, she will do and say anything to prevent him seeing his children and/or see him in jail. 6. DENIED. The ex-wife of Christopher Hoch, on a regular basis, does not abide by the Visitation Schedule, and is contemptuous of Christopher Hoch in her appearance at all times. It is denied that Christopher Hoch said he doesn't have to be supervised any longer. It is admitted that he indicated that there are false accusations against him with Children and Youth Services that has been declared to be "UNFOUNDED". 7. DENIED. Strict allegation of this proof is denied at the time of the trial. If there is any contempt in this case at all, it is the contempt of an embittered ex-wife seeking to harm the reputation of the father of these children, and to do and say those things in an evil and mean spirited way to keep him away from conducting his lawful visitation rights with his children. 8. DENIED. This embittered and hostile ex-wife of Christopher Hoch continues to confront him and act in a matter that is not in the best interest of children. Her contemptuous behavior toward him in front of the children is not in the best interest of the children. Her repeated threats to him to see him in jail are not in the best interest of the children. This has been an embittered ex-wife who is so full of hatred that she will say or do anything to harm her ex-husband. 9. DENIED. This allegation is again, erroneous and misleading. On all periods of visitation with the natural father, Christopher Hoch, the children reside with Christopher Hoch's parents, that is, his Mother and Father. All visitations occur in the home of Christopher I loch's mother and father. 10. DENIED. This is Prayer for Relief and not an allegation that is ordinarily placed in Pleadings. It is a request to have the children visit away from the grandmother, grandfather, and father, same as deemed to be contrary to the best interest of the children. 11. DENIED. It is denied that the Contempt Petition was even necessary. There is no showing of any harm to these children at any time at all during the pendency of this entire case. This case is driven entirely by a hateful, spiteful, scornful, ex-wife who will say and do anything to destroy the relationship between father and child. WHEREFORE, Christopher Hoch, Respondent herein, respectfully prays that this Honorable Court will dismiss the Petition for Contempt of Court. Respectfully Submitted. DATE: January 17, 2000 JAi M. BACH, ATTORNEYat LAW 352 uth Sporting Hi/! Road Mechanicsburg, PA 17055 (717) 737-2033 Attorney ID#18727 ? d C) ?. [7 ?J.1.*, ? -? 1. ?_ (' )' L ' ll_? Cl_ .. L.; ?? ?i ..i : l ,i u. ?_i o Si (j CANDACE L. WHITE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW CHRISTOPHER L. HOCH, Defendant NO. 99-2864 CIVIL TERM ORDER OF COURT AND NOW, this `1 Aday of February, 2000, upon consideration of Defendant's Motion To Remove Restrictions on Child Visitation, the matter is referred to Michael L. Bangs, Esq., custody conciliator, to be heard at the same time as a contempt petition previously filed in this matter. Diane M. Rupich, Esq. 1017 North Front Street Harrisburg, PA 17102 Attorney for Plaintiff James M. Bach, Esq. 352 South Sporting Hill Road Mechanicsburg, PA 17055 Attorney for Defendant Michael L. Bangs, Esq. 302 S. 18111 Street Camp Hill, PA 17011 Custody Conciliator BY THE COURT, a-q-oo 9Ks Court Administrator CANDACE L. WHITE Plaintiff V. CHRISTOPHER L. HOCH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-2864 Civil Term CUSTODY MOTION TO REMOVE RESTRICTIONS ON CHILD VISITATION AND NOW comes the Defendant, CHRISTOPHER L. HOCH, by his attorney JAMES M. BACH and files the within Motion to remove restrictions on his child visitations: J. Wesley Oler, Jr., Judge of the Court of Common Pleas of Cumberland County, issued an Order on May 18, 1999 placing restrictions on over night visits of the child involved in this case with their Father, Christopher L. Hoch. A copy of the Order is attache hereto and marked as "Exhibit All. 2. Counsel has been required to notify the Court as to receipt of a completed investigation by Cumberland County Children and Youth Services. The report made by Cumberland County Children and Youth Services regarding the allegations made by Candace L. White against her former husband Christopher L. Hoch in the nature of child abuse charges are "UNFOUNDED". See "Exhibit B". 3. Christopher L. Hoch respectfully requests that any and all restriction on his visitation with his children be removed. Respectjrdly Submitted.• DATE: /- t 7- d w AT LAW p rnug Hrl! Rond Mechanicsburg, PA 17055 (717) 737-2033 Attorney ID#18727 JA S M. BAC1I, ATTORNEY 352 nutlr S n ' I .' , i 1'.. .. 1 ?`l _O c C=' w a a z w .u ? o w .H x ro ° a C x c U D H w j 3 ¢ z w z ? ~ a a Q < 4y o a 0 E U IS ? I.j > O w ? w o a z o ° o? U a> 1 < a? a co o w rn ° H H cQ y u U U $ Z 5 w O H V L z k CANDACE L. WHITE, Plaintiff VS. CHRISTOPHER L. HOCH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2864 ORDER OF COURT AND NOW, this Day of 1999, upon presentation and consideration of the Motion filed by Plaintiff, Candace L. White, it is hereby Ordered that this Court's Order dated May 18, 1999 shall remain in effect until completion of the investigation by the police department and the District Attorney's Office of Cumberland County. BY THE COURT: The Honorable J. Wesley Oler, Jr., J. Distribution: Diane M. Rupich, Esquire James M. Bach, Esquire I:n . C.. I lV ' LL !U I.i. U] 4 W a a, o 44 W C o O N •'q U ro O W (1) 41 0 z w O U > H x w O O 3 ¢ z 4 H Ol F 5 > y G. Z •> x W n < = y o x Z E Ix m i 0 O a ... n =a a' H C N > p' BOO, En UON ¢ o r - acs mm Z ,o w o a rn \ K z; Ua> co U ti a W.- < ?h as i o H w? wxr o z C4 co _ x W C11 a, Q O? C?R7 Z U U HO zow o Hva z ooz . ;, ;?.. N CERTIFICATE OF SERVICE I, Diane M. Rupich, Esquire, hereby certify that a true and correct copy of the within Motion has been served upon the following individual by first class, United States mail, postage prepaid, by depositing a copy of same at the post office in Harrisburg, Pennsylvania on the Z?-Aay of July, 1999, addressed as follows: James M. Bach, Esquire 352 S. Sporting Hill Road Mechanicsburg, Pa. 17055 Respectfully submitted, BY: 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 Date: July Z Z 1999 d CANDACE L. WHITE, Plaintiff VS. CHRISTOPHER L. HOCH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2864 Civil Term CUSTODY MOTION PURSUANT TO YOUR HONORABLE COURT'S ORDER OF MAY 18,1999 1. Your Honorable Court issued an Order concerning Plaintiffs Petition for Emergency Relief in the above captioneJ case on May 18, 1999. 2. Paragraph three required counsel to notify your Honorable Court as to the applicability of an amended Order upon receipt of a completed investigation by Cumberland County Children and Youth Services concerning abuse in this matter 3. Pursuant to said Court Order, counsel fir Candace L. White, Plaintiff; notifies your Honorable Court by this motion that Cumberland County Children and Youth has ruled said child abuse allegations as unfounded. 4. Notwithstanding the report of the Cumberland County Children and Youth, Plaintiff, Candace L. White, stands by her testimony before your Honorable Court that Cumberland County Children and Youth Services investigation has not reached a proper conclusion; in that the police investigation of the child abuse allegations is ongoing. The best interest of the child is served by the restrictions on visitation continuing until the police investigation has been completed. 5. It should be considered by your Honorable Court at the time of the hearing, that the Defendant did not testify under oath. 6. By letter dated July 19, 1999, Attorney James M. Bach requested that a Court Order be submitted indicating all restrictions placed on visitation and custody be removed. Counsel for Christopher L. Hoch has not filed a Motion pursuant to Paragraph three of your Honorable Court's Order dated May 18, 1999, and Candace -2- L. White, Plaintiff, cannot authorize and exceed to her attorney preparing any Order removing restrictions. WHEREFORE, it is respectfully requested that your Honorable Court's Order dated May 18, 1999 continue until the police investigation is concluded. Respectfully submitted, BY: A 2.?? iane . Rupich, Zs4uire 1017 N. Front Street Harrisburg, Pa. 17102 (717) 232-9724 I.D. No. 71873 -3- VERIFICATION The undersigned, Diane M. Rupich, Esquire, hereby verifies and states that: 1. She is the attorney for Candace L. White. 2. She is authorized to make this verification on her behalf. 3. This verification is made by counsel pursuant to Pa. R.C.P., Rule 1024(c). 4. The statements set forth in the foregoing Motion are true and correct to the best of her knowledge, information and belief 5. She is aware that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relatin"o unsworn falsif ti to authorities. M.'Rupich, Esquire Date: July 20, 1999 ?J1?'f?w.??I n'?k?????•aji JAMES M. BACH ATTORNEY AT LAW 352 S. SPORTING HILL ROAD MECHANICSBURG, PA 17055 Diane Rupich, Esquire 1017 North Front Street Harrisburg, PA 17102 CANDACE L. WHITE, Plaintiff V. CHRISTOPHER L. HOCH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2864 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR EMERGENCY RELIEF ORDER OF COURT AND NOW, this 18th day of May, 1999, upon consideration of Plaintiff's Petition for Emergency Relief with respect to the parties' children, Amber Renee Hoch (date of birth February 13, 1995) and Austin Scott Hoch (August 16, 1996), and following a hearing, it is ordered and directed as follows pending further order of court: 1. Pursuant to an agreement of the parties, Defendant's periods of partial or temporary custody with the children shall be on Tuesday and Thursday from 5:30 p.m. to 8:30 p.m. and on alternating weekends on Friday from 5:30 p.m. to 8:30 p.m, and on Saturday from 9:00 a.m. to 5:00 p.m. 2. Defendant's periods of partial or temporary custody with the children shall be supervised by Defendant's parents, with one parent being in Defendant's presence at all times that he is with a child. 3. Counsel are requested to notify the court by motion for an amended order at such time as Cumberland County Children and Youth Services has completed its investigation of allegations of child abuse in this matter. 4, In all other respects, the terms of the York County order previously entered at No. 98-SU-0080.-02D shall remain in full force and effect. rl? ?{?,, -`:ur^ Jr 1 Jl? .7 ' ,??.).?i?t? lJlifn ? ('1 Diane M. Rupich, Esquire 1017 North Front Street Harrisburg, PA 17102 Counsel for Plaintiff James M. Bach, Esquire 352 South Sporting Hill Road Mechanicsburg, PA 17055 Counsel for Defendant By the Court, cv D, J. Wesley Ol. , Jr., :srs ATTORNEYS AT LAW j` USAH 1017 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102 .7/le/& c?c ATTORNEYS AT LAW 1017 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102 ?5 ATTORNEYSATLAW 1017 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102 James M. Bach, Esquire 352 S. Sporting Hill Road Mechanicsburg, PA. 17055 1 I'' USA11 An?'Clttt Xttt f A, CANDACE L. WHITE, Plaintiff Vs. CHRISTOPHER L. HOCH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. q9-,2A`I , 1999 CIVIL ACTION-LAW ORDER OF COURT ?S 110 NCccsscl N- pkaSC s?«t ; ?r\;kic' AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the Conciliator, on , the day of 1999 at m. in the office of said conciliator located at for a pre-hearing custody conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a Temporary Order. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: Date: BY: Custody Conciliator YOU SHOULD TAKE THIS PAPER. TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Court House One Court House Square Carlisle, Pa. 17013 (717) 240-6200 CANDACE L. WHITE, Plaintiff vs. CHRISTOPHER L. HOCH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 9 9- e2 PGY &?,J emu" CUSTODY COMPLAINT TO MODIFY COURT ORDER AND NOW, this f I`-t"/Day of May, 1999, comes the Plaintiff, Candace L. White, by her attorney, Diane M. Rupich, Esquire, and respectfully requests the following: 1. The Plaintiff, Candace L. White, is an adult individual, who is represented by Diane M. Rupich, Esquire, 1017 N. Front Street, Harrisburg, Pennsylvania 17102. The Plaintiff resides at Lot 68, Walmar Manor, Dillsburg, York County, Pennsylvania. 2. The Defendant, Christopher L. Hoch, is an adult individual, who is represented by Attorney James M. Bach, 352 S. Sporting Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. The Defendant resides at 525 W. Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania, with his parents. 3. The Plaintiff and Defendant are the natural parents of two children; namely: Amber Renee' Hoch, born February 13, 1995; and Austin Scott Hoch, born August 16,1996. 4. The parties hereto were divorced in August of 1998, and as a result of said divorce, a custody agreement was made an Order of Court in the Court of Common Pleas of York County, Pennsylvania docketed to No. 98-SU-0080-02D wherein Plaintiff was granted primary physical custody and the Defendant has visitation every other weekend, and two evenings during the week, which are not overnights. 5. On May 5, 1999, the day care provider of the minor children contacted the mother at her employment and indicated that the child, Amber Renee' Hoch, was bleeding from her vagina. -2- 6. Mother immediately took the child to her family doctor who referred the Petitioner to the Harrisburg Hospital, where a rape kit examination was conducted of the minor child. This examination showed no penetration of the minor child. 7. Plaintiff was referred to and met with Earl F. Greenwald, M.D., and Teresa Smith, a social worker, in his office, on Thursday, May 6, 1999. 8. Cumberland County Children and Youth and the Mechanicsburg Borough Police Department were contacted and meeting with all parties and the minor child occurred on Friday, May 7, 1999. 9. Attached hereto and marked Exhibit "A" is a copy of a letter from Dr. Greenwald indicating that lack of penetration does not preclude the child's disclosure. 10. Cumberland County Children and Youth are continuing their investigation into this matter, and there has not been a formal finding. 11. However, during this investigation, Cumberland County Children and Youth have recommended supervised visitation in the Father, utilizing the father's parents as the supervisors. 12. The father has resided with and continues to reside with his parents since the date of separation, and all visitations have occurred in the home of the parents. 13. Your Petitioner believes that it is in the best interest of her children that an independent supervisor be utilized for the visitations, and that the overnight visitations of the father, be suspended, at this time. :t 14. Attorneys Diane M. Rupich and James M. Bach have conferred and have agreed that this matter be decided by your Honorable Court, the Court of Common Pleas of Cumberland County, and that this custody matter be heard by your Honorable Court, in that the Cumberland County Children and Youth Services and the Borough of Mechanicsburg Police Department have been involved with the investigation and are currently conducting the investigation. -4- 15. The Plaintiff's request to modify the current Order of Court is being presented to your Honorable Court through a Petition for Emergency Relief, and there is no need for a custody conciliation conference to be held in this matter; however, it was required of the Plaintiff that this Complaint be filed so that your Honorable Court could view the Petition for Emergency Relief. WHEREFORE, The Plaintiff, Candace L. White, by her attorney, Diane M. Rupich, Esquire, prays your Honorable Court to suspend the overnight visitations of the Defendant, Christopher L. Hoch, during the investigation and to order an independent supervisor, to conduct supervised visitation. Respectfully submitted , ( Lt . BY: 6 Diane M. R Pic , quire 1017 N. Front S et Harrisburg, PA. 17102 (717) 232-9724 I.D. No. 71873 VERIFICATION The undersigned, Diane M. Rupich, Esquire, hereby verifies and states that: 1. She is the attorney for Candace L. White. 2. She is authorized to make this verification on her behalf. 3. This verification is made by counsel pursuant to Pa. R.C.P., Rule 1024(c). 4. The statements set forth in the foregoing Complaint are true and correct to the best of her knowledge, information and belief. 5. She is aware that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relatin to unsworn falsifies to authorities. Dia9^4. K ' h, Esquire Date: May 11,1999 r , W W W E a z W c o O D\ •H b U J a c m 0? d-1 U E a O N W 3 Uy H (C x W H g wJ klz ?a o o a =y O o a a w Z E U H to ?-7 > a O 0 a D O z , V W E a O c3 oc U a> W O Mr a n m N Ca Z ° rc W W. z to ? Froz v a a ?. z 5 W O U O U MAY 12 '999 CANDACE L. WHITE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW CHRISTOPHER L. HOCH, Defendant NO. 99-2864 CIVIL TERM ORDER OF COURT AND NOW, this .5jLday of August, 1999, upon consideration of Plaintiff's Motion Pursuant to Your Honorable Court's Order of May 18, 1999 and of Defendant's Motion To Remove Restrictions on Child Visitation, a hearing is scheduled for Thursday, October 14, 1999, at 9:00 a.m., in courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, J esley Ole b Jr._ Diane M. Rupich, Esq. 1017 N. Front Street Harrisburg, PA 17102 Attorney for Plaintiff James M. Bach, Esq. 352 S. Sporting Hill Road Mechanicsburg, PA 17055 Attorney for Defendant :rc CANDACE L. WHITE, Plaintiff V. CHRISTOPHER L. HOCH, Defendant IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2864 CIVIL TERM ORDER OF CO )RT AND NOW, this 's ?ay of May, 1999, upon consideration of Plaintiff's Petition for Emergency Relief, a hearing is scheduled for Tuesday, May 18, 1999, at 1:30 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, Diane M. Rupieh, Esq. 1017 N. Front Street Harrisburg, PA 17102 Attorney for Plaintiff James M. Bach, Esq. 352 S. Sporting Hill Road Mechanicsburg, PA 17055 Attorney for Defendant Wesley Ole rj•v4 :rc CANDACE L. WHITE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ? ` vs. NO. QQ, ae6 ?I l.. l o, t CHRISTOPHER L. HOCH, Defendant CUSTODY ORDER OF COURT AND NOW, this Day of ,1999, upon presentation and consideration of the within Petition, and after conferring with counsel, it is hereby Ordered that Christopher L. Hoch, may exercise supervised visitation in the supervision of an independent supervisor, with costs on Christopher L. Hoch. It is fi?rther Ordered that overnight visitation shall cease until completion of the investigation by Cumberland County Children and Youth and the Borough of Mechanicsburg Police Department. BY THE COURT: J. CANDACE L. WHITE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. CHRISTOPHER L. HOCH, Defendant CUSTODY PETITION FOR EMER ENCY RELIEF AND NOW, this Day of May, 1999, comes the Plaintiff, Candace L. White, by her attorney, Diane M. Rupich, Esquire, and respectfully requests the following: 1. The Petitioner, Candace L. White, is the Plaintiff above named, an adult individual, who is represented by Diane M. Rupich, Esquire, 1017 N. Front Street, Harrisburg, Pennsylvania 17102. 2. The Respondent, Christopher L. Hoch, is the Defendant above named, an adult individual, who is represented by Attorney James M. Bach, 352 S. Sporting Hill Road, j Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Your Petitioner and the Respondent are the natural parents of two children; namely: Amber Renee' Hoch, born February 13, 1995; and Austin Scott Hoch, born August 16,1996. 4. The parties hereto were divorced in August of 1998, and as a result of said divorce, a custody agreement was made an Order of Court in the Court of Common Pleas of York County, Pennsylvania docketed to No. 98-SU-0080-02D wherein Petitioner was granted primary physical custody and the Respondent has visitation every other weekend, and two evenings during the week, which are not overnights. 5. On May 5, 1999, the day care provider of the minor children contacted the mother at her employment and indicated that the child, Amber Renee' Hoch, was bleeding from her vagina. 6. Mother immediately took the child to her family doctor who referred the Petitioner to the Harrisburg Hospital, where a rape kit examination was conducted of the minor child. This examination showed no penetration of the minor child. 7. Petitioner was referred to and met with Earl F. Greenwald, M.D., and Teresa Smith, a social worker, in his office, on Thursday, May 6, 1999. 8. Cumberland County Children and Youth and the Mechanicsburg Borough Police Department were contacted and meeting with all parties and the minor child occurred on Friday, May 7, 1999. 9. Attached hereto and marked Exhibit "A" is a copy of a letter from Dr. Greenwald indicating that lack of penetration does not preclude the child's disclosure. 10. Cumberland County Children and Youth are continuing their investigation into this matter, and there has not been a formal finding. 11. However, during this investigation, Cumberland County Children and Youth have recommended supervised visitation in the Respondent, Father, utilizing the father's parents as the supervisors. 12. The father, Respondent, has resided with and continues to reside with his parents -3- since the date of separation, and all visitations have occurred in the home of the parents. 13. Your Petitioner believes that it is in the best interest of her cb;ldren that an independent supervisor be utilized for the visitations, and that the overnight visitations of the Respondentifather, be suspended, at this time. 14. Attorneys Diane M. Rupich and James M. Bach have conferred and have agreed that this matter be decided by your Honorable Court, the Court of Common Pleas of Cumberland County, and that this custody matter be heard by your Honorable Court, in that the Cumberland County Children and Youth Services and the Borough of Mechanicsburg Police Department have been involved with the investigation and are currently conducting the investigation. WHEREFORE, your Petitioner, Candace L. White, by her attorney, Diane M. Rupich, Esquire, prays your Honorable Court to suspend the overnight -4- visitations of the Respondent, Christopher L. Hoch, during the investigation and to order an independent supervisor, to conduct supervised visitation. Respectfully submitted, BY: 1017 N. Front Street Harrisburg, PA. 17102 (717) 232-9724 I.D. No. 71873 May 10, 1999 Ms. Diane Rupich, Attorney-at-law 1017 North Front Street Harrisburg, PA 17102 Dear Ms. Rupich: I evaluated Amber Hoch for suspicion of sexual abuse on 7 May 99. Amber had disclosed, according to mom, that "Daddy put his finger there (indicating her vagina) and it hurt". After visitation with dad when, according to mom, this sexual abuse occurred, maternal grandma noted blood at the opening of Amber's vagina. At that time Amber complained of hurting when her vulva was touched and burning when she urinated. During my and Teresa Smith's interview, absent mom, on 7n May, Amber disclosed that dad touched her vagina with his middle finger and that it hurt. Examination of her hymen was normal. Penetration between the lips of the vagina, touching the opening of the vagina and/or hymen, hurts in young girls. Generally there is no injury to the hymen of a permanent nature when there is touching of the hymen by a finger penetrating between the labia, but not through the hymenal aperture into the vagina. Accordingly, lack of findings on Amber's exam does not preclude her disclosure. The historical details provided by Amber were accompanied by the appropriate emotional congruence and were reflective of her having experienced the disclosed contact. Very truly yours, c-1 Earl F. Greenwald, D Cc: Crystal White, mother Jill Albright, Cumberland County Children & Youth Caseworker 2601 North 'Ihirdtitan • Itartishurg.l'A 1711() (717) 782-2467 • 1-800-334-1007 ext. 2467 EXHIBIT "A" VERIFICATION I verify that the statements made in this PETITION FOR EMERGENCY RELIEF are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA. C.S. Section 4904 relating to unsworn falsification to authorities. DATE: MAY 10. 1999 CANDACE L. WHITE ?' nl ?.. ti r:: c • .J ? V o ro .77 Ul W T UO N r z G7 N Z Wz z xa ° ow u. Zm O _ F N W < H H z z z 5w o z a a x E. U U W a W a I? i i l1 ATTORNEYS AT LAW ARTHUR K. DILS DIANE M. RUPICH 1017 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102 PHONE: (717) 233.8743 FAX: (717) 233.2567 May 11, 1999 TO THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ADDENDUM TO PETITION FOR EMERGENCY RELIEF Attorney James M. Bach and I conferred concerning the Petition for Emergency Relief this date and he indicated that the father, Christopher L. Hoch, was agreeable to suspend over night visitations until the completion of the investigation. Mr. Hoch desires that his parents be permitted to act as supervisors, as recommended by Children and Youth. Ms. White is requesting that an independent supervisor be utilized, based on the allegations in the Petition, or in the alternative, that her grandmother, the day care provider, will supervise Tuesday, Thursday and Friday evenings, in her home, and Ms. White will supervise every other Saturday. Mr. Hoch's weekend visitations end Sunday at 9:30 a.m. and since, it is agreed that there be no over nights, there would be no Sunday visits. Attached is an alternate Order of Court. DMR cc: James M. Bach, Esquire I CANDACE L. WHITE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. CHRISTOPHER L. HOCH, CUSTODY Defendant ORDER OF COURT AND NOW, this Day of May, 1999, upon presentation and consideration of the within Petition, and after conferring with counsel, it is hereby Ordered that Christopher L. Hoch shall exercise supervised visitations the evenings of Tuesday, Thursday and every other Friday in the home of the maternal grandmother, and every other Saturday in the presence of Plaintiff, Candace L. White, until Cumberland County Children and Youth and the Borough of Mechanicsburg Police Depa, u-nent have completed their investigation. It is further Ordered that there shall be no over night visitations at this time. BY THE COURT: J. W . l w 31 P rd +i 41 rd ro _ i w c a -q N u N H o c > H x x a a ? ?zY G+ z ,_ y 0 i O OV LL O a W W a H > a O a q z U r zm Ua> a a - as A o Q ca a r,+ ? H o Fez v zz a z5w o x U DILS & RUPICH BY: DIANE M. RUPICH, ESQUIRE Attorney I.D. No. 71873 1017 North Front Street Harrisburg, PA 17102 Telephone: (717) 233-8743 Attorneys for Plaintiff CANDACE L. WHITE Plaintiff, V. CHRISTOPHER L. HOCH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2864 CIVIL ACTION - LAW CUSTODY PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of CANDACE L. WHITE, the Plaintiff in the above-captioned matter. Date: June 6, 2000 By: uzl 11G Iva. f Urzl xx' u wai Attorney I.D. No. 718 1017 North Front Street Harrisburg, PA 17102 Telephone No. (717) 233-8743 Respectfully Submitted: DILS & RUPICH ? ?. , = ? ?: ?., _ ==;.,. ;_'. - :_ ;: - ?_ . ,_ _. ? :._ 'tp i1 Cam: t. .. ?: ? . + I LLI J.i [• -- .__ i CANDACE L. WHITE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-2854 Civil CHRISTOPHER L. HOCH, CUSTODY Defendant DRDER OF COURT AND NOW, this=;)(. Day of 2000, upon presentation and consideration of the within Petition, it is hereby Ordered that a hearing shall be held on the 1 r? day of 2000 at W' L.M. in Courtroom No. of the Cumberland County Court House, Earliste; Pennsylvania, at which time, the Defendant/Respondent shall appear and show cause, why if any, he should not be held in contempt of Court. BY THE COURT: Distribution: James M. Bach, Esquire, Attorney for Defendant/Respondent Diane M. Rupich, Esquire, Attorney for Plaintiff/Petitioner 4i Ali r• ) 1 ?'cAlA'S,1UA?UIq Aal e,-) CGC. C I,-t76 i? i:? a? z CANDACE L. WHITE, Plaintiff VS. CHRISTOPHER L. HOCH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2864 Civil CUSTODY PETITION FOR CONTEMPT OF COURT AND NOW, this Id Day of January, 2000, comes Candace L. White, by her attorney, Diane M. Rupich, Esquire and respectfully avers the following: 1. Your Petitioner, Candace L. White, is the Plaintiff above named, who is represented by Diane M. Rupich, Esquire, 1017 North Front Street, Harrisburg, Pennsylvania 17102. 2. The Respondent, Christopher L. Hoch, is the Defendant above named, and his represented by Attorney James M. Bach, Esquire, 352 S. Sporting Hill Road, Mechanicsburg, Pennsylvania 17055. 3. Attached hereto and marked Exhibit "A" is an Order of Court dated May 18, 1999, wherein your Honorable Court, The Honorable J. Wesley Oler, Jr. Ordered that Respondent's periods of partial or temporary custody with his children shall be "supervised by Defendant's parents, with one parent being in Defendant's presence at all times that he is with a child." 4. Attached hereto and marked Exhibit "B" is an Order of Court dated October 14, 1999, wherein by agreement of the parties, the visitation as set forth in the Court's Order dated May 18, 1999 will remain in full force and effect, i.e. The Respondent's continued visitation is to be supervised by one of his parents. 5. Since October 14, 1999, the Respondent has continually failed to abide by the Order of Court dated October 14, 1999, in that he continually and on a regular basis exercises his periods of visitation unsupervised. 6. When your Petitioner confronts the Respondent, he tells her that he does not have to be supervised any longer. -2- T Despite your Petitioner confronting the Respondent directly, and despite the Respondent being notified through the attorneys, lie has failed to comply with the Order of Court. 8. The Respondent has been confronted and has been informed of the requirement for supervised visitation, and continues to willfully and wantonly disregard your Honorable Court's Order. 9. Despite the testimony of the Respondent's mother at the time of the hearing held Mav I R. 1999 that the Respondent would be supervised, they have failed to provide s2i.l ciipervieion. 1f1. As a resnlt of the Resporldcnt's Wilful disregard of the order of Court, it is respectlidiy nqucsted that Respondent he required to exercise his supervised visitation, otilirinp a facilily such s; I lie Children's Playroom or Innerworks, and that he he i era=nn?ihlc for the cosk liar the s;nne. 1. 1l- As a result of the Respondent's wilful disregard of the Order of Court, your Petitioner has been required to expend the sum of $500.00 in connection with this contempt proceeding. WHEREFORE, your Petitioner prays your Honorable Court to find the Respondent in contempt of Court, and to Order all supervised visitation to continue in the presence of a facility equipped to conduct said visitation, and further, to Order the Respondent to pay Petitioner's counsel fees in the amount of $500.00. BY: 1017 N. Front Street Harrisburg, PA. 17102 (717) 232-9724 I.D. No. 71873 i t Respectfully submitted, CANDACE L. WHITE, Plaintiff. V. C14RISTOPIIER L. HOCH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'T'Y, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2864 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR EMERGENCY RELIEF ORDER OF COURT AND NOW, this 18th day of May, 1999, upon consideration of Plaintiff's Petition for Emergency Relief with respect to the parties' children, Amber Renee Hoch (date of birth February 13, 1995) and Austin Scott Hoch (August 16, 1996), and following a hearing, it is ordered and directed as follows pending further order of court: 1. Pursuant to an agreement of the parties, Defendant's periods of partial or temporary custody with the children shall be on Tuesday and Thursday from 5:30 p.m. to 8:30 p.m. and on alternating weekends on Friday from 5:30 p.m. to 8:30 p.m. and on Saturday from 9:00 a.m. to 5:00 p.m. 2. Defendant's periods of partial or temporary custody with the children shall be supervised by Defendant's parents, with one parent being in Defendant's presence at all times that he is with a child. 3. Counsel are requested to notify the court by motion for an amended order at such time as Cumberland County Children and Youth services has completed its investigation of allegations of child abuse in this matter. 4. In all other respects, the terms of the York County order previously entered at No. 98-SU-0080-02D shall remain in full force and effect. Diane M. Rupich, Esquire 1017 North Front Street Harrisburg, PA 17102 Counsel for Plaintiff James M. Bach, Esquire Jl52 South Sporting Hill Road tlMechanicsburg, PA 17055 Counsel for Defendant :srs By the Court, TRUF. copy mom RECORD In T- A nrnry h r nr, I h•rr unto set my hand and thu sral of said Court at Carlisle, Pa. zu llds ... ... day of...71.?..., 19V... ?(b Prothonotary CANDACE L. WHITE, Plaintiff V. CHRISTOPHER L. HOCH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2864 CIVIL TERM ORDER OF COURT AND NOW, this 14th day of October, 1999, upon consideration of Plaintiff's Motion Pursuant to Your Honorable Court-s Order of May 18, 1999, and of Defendant's Motion To Remove Restrictions on Child Visitation, and pursuant to an agreement reached in ppen court among the parties and their respective counsel, Diane H. Rupich, Esquire, on behalf of the Plaintiff, and James M. Bach, Esquire, on behalf of the Defendant, it is ordered and directed as follows: 1. The visitation, as set forth in this Court's Order dated May 18, 1999, will remain in full force and effect. 2. The parties hereto will undergo a psychological evaluation to include a home study at the expense of Candace L. White, Plaintiff, in this case. i 3. Halloween 1999 visitation, Thursday evening, will be with Candace. L. White, Plaintiff, and the Defendant, Christopher L. Hoch, will receive another evening that week to make up for his Thursday 4. Effective immediately, transportation to 4 the home of Christopher L. Hoch, and from the home of Christopher L. Hoch, shall be provided by the Plaintiff, Candace L. White, at all times hereafter. 5. The Court's Order of the 18th day of May, 1999, will remain in effect pending the home study and the psychological evaluation By the Court, Diane M. Rupich, Esquire 1017 N. Front Street Harrisburg, PA 17102 For the Plaintiff James M. Bach, Esquire 352 S. Sporting Hill Road Mechanicsburg, PA 17055 For the Defendant wcy i W s ey Ole , r., LEI ?? l .?Y VLE-B1EICAT10N verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA. C.S. Section 4904 relating to unsworn falsification to authorities. DATE: January 7, 2000 Candace Ti. White i 1, Diane M. Rupich, Esquire, hereby certify that a true and correct copy of the within Petition for Contempt has been served upon the following individuals by first class, United States mail, postage prepaid, by depositing a copy of same at the post office in Harrisburg, Pennsylvania on the 10th day of January, 2000 addressed as follows: James M. Bach, Esquire 352 S. Sporting Hill Road Mechanicsburg, PA. 17055 Res ectfully submitted! BY. vtu , Diane . Ru ' , squire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 Date: January 10, 2000 i i ? X71 ? 7 ' , . '.•LI 1 1 ._ iJ r? W W F? z ° O W yJ r W . C a Ce ?- m O .-( O 4J U ?! ; z F > •? ° a z 5 H> ^ ? W C H ¢ o y C U H f-t CJ U a N K Z HURCc ?a ao O U W 0.. H kD D C z co G; c? 6; Ga z 0 z Cz 04 ; (= , 5 a m z a z ^i2 N C O U H z x W U) C ¢ Vi H $ H cr z H C H H v, E znWCO x HUa< v U r? a . JAN W 'Cu-c 7a(e L. Wti'V?. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ChC? J cc L 1 1^ : CIVIL ACTION LAW Defendant :NO. D& ,CIVIL 19019 CUSTODY VISITATION ORDER OF COURT And now, this Q NiM , upon consideration of the attached complaint, it is hereby directed that the above parties and their respective counsel appear before MtC (I r l L Ror?a S Esquire, the conciliator, at rcm(3141 \ k - Pennsylvania, on the lC? day of V CC?-N , 2000, at L. 00 A.M./M for a Pre-hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: By:, c? 2 Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 CF r FILED-CrFrc ?? OhCrfd?Y co f-lil, , -2 Pti G: 10 CL7v;C?,;?a• - ?'cA'!?'S111?+' a ",\ t 1 1- E8 - 4 2000 p CANDACE L. WHITE, Plaintiff V. CHRISTOPHER L. HOCH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2864 CIVIL TERM ORDER OF COURT AND NOW, this`f day of February, 2000, upon consideration of Defendant's Motion To Remove Restrictions on Child Visitation, the matter is referred to Michael L. Bangs, Esq., custody conciliator, to be heard at the same time as a contempt petition previously filed in this matter. Diane M. Rupich, Esq. 1017 North Front Street Harrisburg, PA 17102 Attorney for Plaintiff James M. Bach, Esq. 352 South Sporting Hill Road Mechanicsburg, PA 17055 Attorney for Defendant Michael L. Bangs, Esq. 302 S. 18th Street Camp Hill, PA 17011 Custody Conciliator BY THE COURT, ,,11?ourt Administrator CANDICE L. WHITE, ) Plaintiff ) vs. ) CHRISTOPHER L. HOCH, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2864 CIVIL TERM CIVIL ACTION - LAW ORDER AND NOW, this Z3rj day of 2000, upon receipt of the Conciliator's Report, it is hereby ordered and directed as follows: 1. The parties shall reconvene for another custody conciliation before Michael L. Bangs, Esquire, on Thursday, May 4, 2000, at 4:00 p.m. The purpose for rescheduling the conciliation conference was that the psychological evaluation, including a home study, which was part of the Order of October 14, 1999, is not completed. Counsel believed that it should be completed within the next month. Counsel should make sure that the doctor who is completing the evaluation has this Order so that they can understand that it is absolutely necessary that it be completed prior to the next conciliation conference. This is specifically so because of the outstanding Petition for Contempt filed by te r., r) CD Mother and the Petition to Remove Restrictions filed by Father. The psychologi-'-' ? r " . should disseminate the recommendations to the parties' counsel as soon as possible. Diane M. Rupich, Esquire James M. Bach, Esquire mlb BY THE COURT, CANDICE L. WHITE, ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA VS. ) NO. 99-2864 CIVIL TERM CHRISTOPHER L. HOCH, ) Defendant ) CIVIL ACTION - LAW JUDGE PREVIOUSLY ASSIGNED: The Honorable J. Wesley Oler, Jr. CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child(ren) who is(are) the subject of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Amber Renee Hoch February 13, 1995 Plaintiff Austin Scott Hoch August 16, 1996 Plaintiff 2. A Conciliation Conference was held on March 16, 2000, and the following individuals were present: the Plaintiff and her attorney, Diane M. Rupich, Esquire; the Defendant and his attorney, James M. Bach, Esquire. 3. Items resolved by agreement: See attached Order. 4. Issues yet to be resolved: See attached Order. 5. The Plaintif'f's position on custody is as follows: See attached Order. 6. The Defendant's position on custody is as follows: See attached Order. 7. Need for separate counsel to represent child(ren): Neither party requested. 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. 9. Other matters or comments: The parties shall reconvene for another custody conciliation before Michael L. Bangs, Esquire, on Thursday, May 4, 2000, at 4:00 p.m. The purpose for rescheduling the conciliation conference was that the psychological evaluation, including a home study, which was part of the Order of October 14, 1999, is not completed. Counsel believed that it should be completed within the next month. Counsel should make sure that the doctor who is completing the evaluation has this Order so that they can understand that it is absolutely necessary that it be completed prior to the next conciliation conference. This is specifically so because of the outstanding Petition for Contempt filed by Mother and the Petition to Remove Restrictions filed by Father. The psychologist should disseminate the recommendations to the parties' counsel as soon as possible. Date: March 20, 2000 Michael L. Bangs Custody Conciliator r MAR ,2 ? 2nnn CANDACE L. WHITE, Plaintiff vs. CHRISTOPHER L. HOCH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO. 99-2864 CIVIL TERM CIVIL ACTION - LAW ORDER AND NOW, this 2r day of _ 1442-1 2000, upon receipt of the Conciliator's Report, it appearing that a hearing is necessary, it is hereby ordered and directed as follows: A HEARING is scheduled for the o?o X- day of 2000, at t1l 01 o'clock ?.M., in Court Room Number of the Cumberland County Court House, Carlisle, Pennsylvania. Both parties, through counsel, will provide each other and the court with a list of witnesses ten (10) days prior to the date of the hearing along with a statement as to their expected testimony. Additionally, both parties will submit their proposal for a resolution of the matter. Pending said hearing, the Order of May 18, 1999, shall remain in full force and effect, without modification, unless either party obtains a specific Order from this Court changing the terms of that Order. Diane M. Rupich, Esquire James M. Bach, Esquire mlb BY THE COURT"fJ. E Y OLEC ? 0 X, ly CANDACE L. WHITE, Plaintiff VS. CHRISTOPHER L. HOCII, Defendant JUDGE PREVIOUSLY ASSIGNED: IN TIME COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-2864 CIVIL TERM CIVIL ACTION - LAW The Honorable J. Wesley Oler, Jr. CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child(ren) who is(are) the subject of this litigation is as follows: NAME Amber Renee Hoch Austin Scott Hoch BIRTHDATE February 13, 1995 August 16, 1996 CURRENTLY IN CUSTODY OF 2. A Conciliation Conference was held on May 4, 2000, and the following individuals were present: the Plaintiff and her attorney, Diane M. Rupich, Esquire; the Defendant and his attorney, James M, Bach, Esquire. 3. Items resolved by agreement: None. 4. Issues yet to be resolved: See attached Order 5. The Plaintiff's position on custody is as follows: Plaintiff filed a Petition for Contempt indicating that the Father had violated the previous Order requiring him to have supervised visitation. The basis for this contempt was that Father's parents, as observed by a private investigator, did not supervise the children for a period of approximately thirty minutes. Also, at the conciliation conference, the Mother raised yet another allegation of sexual abuse. This sexual abuse again occurred with the oldest child, The investigation by Children & Youth is on-going. 6. The Defendant's position on custody is as follows: Father requested that the restrictions on supervision be lifted. He denies the new allegation of sexual abuse as he did the last allegation of abuse. 7. Need for separate counsel to represent child(ren): Neither party requested. 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. 9. A hearing in this matter will take four hours. 10. Other matters or comments: The Father has been operating under a supervised visitation Order dated May 18, 1999, based upon an allegation of sexual abuse involving the oldest child, Amber, who was 5 years old. Those original allegations, after investigation, were determined to be unfounded. The parties, by agreement which was memorialized in this Court's Order of October 14, 1999, agreed to keep the restrictions in place pending an evaluation and a home study to be completed. The matter then was sent back to the Conciliator. The parties originally were scheduled to appear before the Conciliator in March, 2000, but the evaluation was not completed. They again appeared on May 4°i at which time the parties had the evaluation report which was completed by Hazel Brown. I Iowever, by the time of the May 4, 2000, conciliation, another allegation of sexual abuse occurred and Mother ceased the supervised visitation, apparently suggested by Cumberland County Children & Youth. The Conciliator is very much concerned about the course that this case is taking. Father originally was subject to supervised visitation because of an allegation of sexual abuse upon his oldest daughter. The original allegation was proved to be unfounded, but pending the completion of that investigation, the parties agreed to undergo a custody evaluation and home study. Upon review of the custody evaluation and home study, the evaluator apparently completely reviewed the abilities of the parents and generally indicated that the parents' abilities were fine. However, for some reason, the evaluator suggested that the Father's custodial arrangement continue to be supervised until he underwent some therapy for depression. The depression of Father, however, was never an issue raised prior to the evaluation being completed that would subject him to supervised visitation and based upon the Conciliator's review of the evaluation, does not seem to be a reason to continue the supervised visitation. If Father truly has depression as a result of all of these things that are occurring, he certainly should deal with that depression, but it does not seem, to the Conciliator, that that should prevent him from having unsupervised visitation, particularly in light of the fact that that was never the issue or cause of him having supervised visitation in the first place. What is most troubling about this case is there is yet another allegation of sexual abuse. This allegation has conveniently come after the other investigation was completed and just prior to the next conciliation. While certainly the Court needs to always take seriously any allegations of sexual abuse, it is apparent that the Court needs to carefully scrutinize whether this allegation has any substance or not. What is even more troubling is that the Mother, apparently at the suggestion of Children & Youth, has ceased the supervised visitation with the rather, The Conciliator made it clear to the Mother that no one has the authority to interrupt this Court's Order, even Children & Youth. If Children & Youth in fact told Mother that she should stop visitation, they have put Mother in the position that she is in violation of the existing Court Order. The Conciliator was emphatic with the Mother that the existing supervised visitation Order shall be in place and be followed until this Court can have a full hearing, unless of course, this Court modifies its Order after hearing. This Court should not take very long to resolve this case. If the Mother can prove the allegations of sexual abuse, then the Court will have to deal with that appropriately and of course the Father will be subject to criminal liability. If the Mother in fact cannot prove the sexual abuse as alleged, then Father's visitation rights should be unsupervised. The only caveat with that is that the Court has to deal with the psychologist's statement concerning Father's depression and determine whether or not that really is a reason to keep the visitation supervised. Date: May 8, 2000 Z 4"-? ch el L. Bangs Custo y Conciliator MAY I Ut?? CANDACE L. WHITE, Plaintiff V. CHRISTOPHER L. HOCH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY No. 99-2864 CIVIL TERM IN RE: DEFENDANT'S MOTION TO REMOVE RESTRICTIONS ON CHILD VISITATION BEFORE OLER. J. ORDER OF COURT AND NOW, this 28th day of July, 2000, upon consideration of Defendant's Motion To Remove Restrictions on Child Visitation, with respect to the parties' children, Amber Renee Hoch (date of birth, February 13, 1995) and Austin Scott Hoch (date of birth, August 16, 1996), and following a hearing, it is ordered and directed as follows: 1. Legal custody of the children shall be shared by the parties. 2. Primary physical custody of the children shall be in the mother. 3. Temporary or partial physical custody of the children shall be in the father at the following times: a. On Tuesday and Thursday evenings from 5:30 p.m. until 8:30 p.m.; b. On alternating weekends from 5;30 p.m. on Friday until 9:00 p.m. on Sunday; c. On alternating federal holidays from 9:30 a.m. until 8:30 p.m.; provided, that the father shall have custody on July 4, and the mother shall have custody on Memorial Day. d. For one week in June, two weeks in July, and one week in August; provided, that during these periods, the mother shall have custody of the children on Tuesday and Thursday evenings from 5:30 p.m. until 8:30 p.m., and that during the two-week period in August, the mother shall have custody during the weekend in the middle of the period from 5:30 p.m. on Friday until 9:00 p.m. on Sunday. 4. Transportation for exchanges of custody shall be provided by the mother. 5. Father's first period of temporary or partial physical custody hereunder shall be on the weekend of July 28, 2000. This order shall supersede all prior custody orders, Nothing herein is intended to preclude the parties from varying the terms of this order by mutual agreement. By the Court, i / V J.i esley Oler, Jr., Debra Denison Cantor, Esquire For the Plaintiff James J. Bach, Esquire For the Defendant CoFttz 1 wcy CANDACE L. WHITE IN TITE COURTOF COMMON PLEAS OF PLAINTIFF CUMI3EIi1,AND COUN"1'Y, PI?NNSYLVANIA V. CHRISTOPHER L. HOCH DEFENDANT 99-2864 CIVIL. AC'T'ION LAW IN CUSTODY ORDER OF COURT AND NOW, this 19th day of February , 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Mclissa P. Greevy, Esq. , the concilial at 214 Senate Avenue Suite 105, Camp Hill PA 17011 on the 21st day of March , 2001, at 3:00 p.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age rive or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT. By: /s/ Melissgl, reeve. i Custody Conciliator*l; z: ' The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR A'I`FORNEI' A'r ONCE. If: YOU DO NOT RAVE AN ATTORNEY OR CANNOTAFFORD ONE, GO TO OR TELEPHONE 1-1IF OFF ICI, SE .- FORTH 13ELOW TO FIND OUT WIIERI YOU CAN GI'1' LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle. Pennsylvania 17013 Telephone (717) 249-3166 a ai•oi 6,1,1. Z h? 4g f 4 it I • REAGER & ADLER, P.C. ATTORNEYS AT LAW 2331 MARKET STREET CAMP HILL, PA 17011-4642 (717) 763-1383 I r: ?5. CANDACE L. WHITE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY CHRISTOPHER L. HOCH , Defendant : No. 99-2864 CIVIL TERM ORDER OF COURT AND NOW, upon consideration of the attached Petition for Modification, it is hereby directed that the parties and their respective counsel appear before Esquire, Conciliator, at the _ on the day of Pennsylvania, 2001, at m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or, if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary Order. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent Order. FOR THE COURT DATED: BY: Custody Conciliator CANDACE L. WHITE, Plaintiff V. CHRISTOPHER L. HOCH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY No. 99-2864 CIVIL TERM CONFORM WITH ACTUAL SCHEDULE FOLLOWED BY PARTIES AND NOW, comes Plaintiff/ Petitioner Candace L. White, by and through her attorneys, Reager & Adler, PC, and files this Petition for Modification of Custody Order of July 28, 2000 and in support thereof avers as follows: 1. Candace L. White, Petitioner/Plaintiff, is the natural mother of the children Amber Renee Hoch, born 2/13/95, and Austin Scott Hoch, born 8/16/96. 2. Respondent/Defendant Christopher L. Hoch is the natural father of Amber and Austin Hoch. 3. An Order of Court was issued on July 28, 2000 setting forth legal and physical custody rights of the parties in this action. 4. Since the entry of the July 28, 2000 court order, the parties have, by mutual agreement, modified the terms of the physical custody schedule to those set forth in the proposed custody order attached hereto as Plaintiffs Exhibit #1. 5. Since said date, Petitioner/ Plaintiff through her counsel has repeatedly attempted through contacts to Defendant/Respondent's counsel to reach a stipulated agreement to modify the court's order of July 28, 2000. 6. Defendant/Respondent Christopher L. Hoch has repeatedly refused to agree to modify the July 28, 2000 custody order in accordance with the attached proposed order. 7. Petitioner/ Plaintiff is of the belief, and therefore avers, that it is in the best interest and permanent welfare of the children that the July 28, 2000 court order for custody be modified to reflect the actual physical custody schedule the parties are currently following. She further believes that it is in the best interest and permanent welfare of the children that the additional standard proposed provisions set forth in the proposed order also be included in a modified custody order. WHEREFORE, Petitioner/Plaintiff Candace L. White respectfully requests this Honorable Court to modify its order of July 28, 2000 to the terms set forth in the attached proposed order. Respectfully submitted, REAGER & ADLER, PC Date: - ' 0 \ Joa Clough, Esgdird ID #36 1 i 2331 Market Street Camp Hill, PA 17011 717-763-1383 Attorneys for Plaintiff/Petitioner CANDACE L. WHITE, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL. ACTION - LAW IN CUSTODY CHRISTOPHER L. HOCH, Defendant : No. 99-2864 CIVIL TERM STIPULATION OF CUSTODY AND NOW, this _ day of _ 2000, the parties, CANDACE L. WHITE (hereinafter the "Mother") and counsel, Joanne H. Clough, Esquire and CHRISTOPHER L. HOCH (hereinafter the "Father") and counsel, James J. Bach, Esquire file the following Stipulation regarding custody, after due consideration of the best interest of their two (2) Children: namely, Amber Renee Hoch, born February 13, 1995, and Austin Scott Hoch, born August 16, 1996 (hereinafter "the Children"); and, WHEREAS, the parties wish to enter into an agreement relative to custody and visitation of the Children; and WHEREAS, both parties have been provided an opportunity to review the Agreement with the counsel of their choice prior to signing; and THEREFORE, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, and intending to be legally bound hereby, the parties agree as follows: 1. Legal Custody: The parties agree to shared legal custody of the said minor Children. The parties agree that major decisions concerning the Children including, but not necessarily limited to, the Children's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the Children's best interest. Each party agrees not to impair the other patty's rights to shared legal custody of the Children. Each party agrees not to attempt to alienate the affections of the Children from the other party. Each party shall notify the other of any activity or circumstance concerning their Children that could reasonably be expected to be of concern to the other, Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Children at the time of the emergency shall be permitted to snake any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. 2. Physical Custody: The Mother shall maintain primary physical custody of the minor Children. Mother shall be entitled to two weeks of interrupted custodial time each year with thirty (30) days notice to Father. The Father shall have partial physical custody of the Children at the following times: a. On Tuesday and Thursday evenings from 5:30 p.m. until 8:30 p.m. b. On alternating weekends from 5:30 p.m. on Friday until 7:00 p.m. on Sunday during the school year and from 5:30 p.m. on Friday until 9:00 p.m. on Sunday during the summer months. C. On alternating federal holidays not otherwise outlined herein from 9:30 a.m. until 5:30 p.m.; provided, that the Father shall have custody on July 4"', and the Mother shall have custody on Memorial Day weekend. In even numbered years, Father shall have custody of the children on Trick or Treat Night and Amber's birthday. In even years, Mother shall have custody of the children on Easter, thanksgiving and Austin's birthday. The parties shall alternate this schedule on odd numbered years. Tile custodial periods shall be from 9:30 a.m. until 8:30 p.m. -''. C. For one week in June, two weeks in July, and one week in August as agreed to by the parties provided that during these periods, the Mother shall have custody of the Children on Tuesday and Thursday evenings from 5:30 p.m. to 8:30 p.m. and that during the two week period during July the Mother shall have custody during the weekend in the middle of the period from 5:30 p.m. on Friday until 9:00 p.m. on Sunday. Mother shall waive these periods of custody if Father is taking the Children away for vacation and provides Mother with the location and telephone number of said vacation spot. Father shall notify Mother of the dates intended to be exercise for these vacation periods by June V of each year. f Christmas: The parties shall alternate the Christmas holiday. Schedule A shall be from Christmas Eve at 9:00 a.m. to Christmas Day at 9:00 a.m.. Schedule B shall be from Christmas Day at 9:00 a.m. to the day after Christmas at 9:00 a.m. Father shall have Schedule B in even numbered years and Schedule A in odd numbered years. Transportation: Mother shall be responsible for providing transportation to the Broadstreet Elementary School or another mutually agreeable neutral site for exchanges of custodial periods. The parties agree to assure the children are safe from the elements during said transfers. 4. Travel: In the event that either parent intends to take the minor Children more than forty-five (45) miles from Harrisburg, Pennsylvania, each parent agrees to provide the other with the Children's location and provide a telephone number for contact, if possible Daycare Daycare arrangements will remain the same at all times so as to provide a constant daily schedule for the Children. Alcohol and Drugs: -3- During any period of custody or visitation, the parties shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and guests comply with this prohibition. 7. Death or Disability: In the event of either party's death or significant and long-term disability rendering the person incapable of caring for the Children, then custody shall automatically vest in the other party. 8. Address and Telephone Numbers of Parties: Both Father and Mother must keep each other informed of any changes of address or change of telephone number. Any changes in address or telephone number shall be immediately forwarded to the other party. 9. Notice of Whereabouts /Illness: Each party agrees to keep the other reasonably informed about the whereabouts of the Children while with the other party. If either party has knowledge of illness or accident or other serious circumstance affecting the welfare of either of the Children, he or she shall promptly notify the other party of said circumstances. 10. Telephone Contact with Children: Both parties shall have the right to reasonable telephone contact with the Children during the other parry's period of custody/visitation. Neither party shall interfere with the other party's telephone contacts with the Children. Each party shall make all reasonable effects to promptly return telephone calls or messages left by the other party regarding the Children. 11. Disparaging Remarks: -4- Neither Father nor Mother shall make any disparaging remarks regarding the other parent in the presence of the Children. Such as those that might tend to alienate the affections of the Children toward the other parent. Also, each parent shall inform relatives and friends to also refrain from making any disparaging remarks regarding either parent in the presence of the Children. 12. Supercedes of Prior Court Orders: This Stipulation shall be entered as a court order. This Stipulation shall supersede all prior Court Orders, Stipulations or Agreements. 13. Modification: Any of the provisions of this Agreement may be modified or deleted upon mutual consent/agreement of both parties or upon Petition to the Court for Modification. WHEREFORE, the parties intending to be legally bound thereby, and with the desire that this Agreement be entered as an order of court at the request of either party, hereby set their hand and seals and on the date first written above. CANDACE L. WHITE CHRISTOPHER L. HOCH DEBRA DENISON CANT012, ESQUIRE JAMES J. BACH, ESQUIRE -5- VERIFICATION I, Candace L. White, the above referenced Petitioner hereby verifies and states that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Candace L. White DATE: ?. r• ?; ;' :.? ?? - - ?..:: 1 ,,, ? . ? c i._; .; ? 4- :..7 __ i MAR 2 7 7001 CANDACE L. WHITE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 99-2864 CHRISTOPHER L. HOCH, : CIVIL ACTION - IAW Defendant : CUSTODY Oler, J., March 2.1 , 2001 ORDER OF COURT AND NOW, this day of March, 2001, upon consideration of the attached Custody Conciliation Summary Report, and considering that the parties have reached an agreement on some, but not all, of the issues regarding the modification of the present Custody Order, it is hereby ordered and directed as follows: A hearing is scheduled in Courtroom No. L of the Cumberland County Courthouse, on the 1i: day of 2001, at p. 30 o'clock .m., at which time testimony will be taken. For the p rpose of the hearing, the Mother, Candace L. White, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties and/or parties pro se shall file with the court and opposing counsel/party a memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. This memoranda shall be filed at least ten days prior to the hearing date. Issues before the Court are limited to those defined in the Custody Conciliation Summary Report with regard to drug and alcohol provision, additional time for Father in the summer, and choice of daycare provider during Father's summer custodial periods. Pending further Order of Court or agreement of the parties, the following shall remain in effect: 1. Legal Custody. The Mother, Candace L. White, and the Father, Christopher L. Hoch, shall share legal custody of the minor Children, Amber Renee Hoch, born February 13, 1995, and Austin Scott Hoch, born August 16, 1996. The parties agree that major decisions concerning the Children including, but not limited to, the Children's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, and with a view toward obtaining and following a harmonious policy in the Children's best interest. Each party agrees that they shall not impair the other party's rights to share legal custody of the Children. Neither party shall attempt to alienate the affections of the Children from the other party. Each party shall notify the other of any activity or circumstance concerning the Children that could be reasonably expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. Without regard to any emergency decisions which must be made, the l i. " ?^ 1 ? / i 4'„`i r.i r Ali it ,:??:? ?.. ,. ?R ?? ? r.,;, No. 99-2864 parent having physical custody of the Children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. 2. I?ical Custody. The Mother shall maintain primary physical custody of the minor Children. The Mother shall be entitled to two weeks of uninterrupted custodial time each year with a thirty-day notice to Father. Father shall have partial physical custody of the Children at the following times: A. On Tuesday and Thursday evenings from 5:30 p.m. until 8:30 p.m. B. On alternating weekends from 5:30 p.m. on Friday until 7:00 p.m. on Sunday during the school year and from 5:30 p.m. on Friday until 9:00 p.m. on Sunday during the summer months. C. On alternating Federal holidays not otherwise outlined therein from 9:30 a.m. until 8:30 p.m.; provided that the Father shall have custody on Independence Day and the Mother shall have custody on Memorial Day weekend. D. In even-numbered years, the Father shall have custody of the Children on trick-or-treat night and Amber's birthday. In even-numbered years, the Mother shall have custody of the Children on Easter, Thanksgiving and Austin's birthday. The parties shall alternate the schedule in odd- numbered years. The custodial period shall be from 9:30 a.m. until 8:30 p.m. E. For one week in June, two weeks in July, and one week in August, as agreed to by the parties provided that during these periods, the Mother shall have custody of the Children on Tuesday and Thursday evenings from 5:30 p.m. until 8:30 p.m. and that during the two-week period in July the Mother shall have custody during the weekend in the middle of the period from 5:30 p.m. on Friday until 9:00 p.m. on Sunday. Mother shall waive these periods of custody if Father is taking the Children away for vacation and provides Mother with the location and telephone number of said vacation spot. Father shall notify Mother of the dates intended to be exercised for these vacation periods by June 1" of each year. No. 99-2864 F. Christmas. The parties shall alternate the Christmas holiday. Schedule A shall be from Christmas Eve at 9:00 a.m. until Christmas Day at 9:00 a.m. Schedule B shall be from Christmas Day at 9:00 a.m. until the day after Christmas at 9:00 a.m. Father shall have Schedule B in even-numbered years and Schedule A in odd-numbered years. 3. Transportation. Mother shall be responsible for providing transportation to the Broad Street Elementary School or another mutually agreeable neutral site for the exchange of these custodial periods. The parties agree to ensure that the Children are safe from elements during said transfers. 4. Travel. In the event that either parent intends to take the minor Children for more than forty-five (45) miles from Harrisburg, Pennsylvania, overnight, each parent shall provide the other with the Children's location and provide a telephone number for contact, if possible. 5. Address and Telephone Number of the Parties. Both Mother and Father must keep each other informed of any changes of address or change of telephone number. Any changes in address or telephone number shall be immediately forwarded to the other party. 6. Notice of Whereabouts/Illness. Each party shall to keep the other reasonably informed as to the whereabouts of the Children while with the other party. If either party has knowledge of illness or accident or other serious circumstance affecting the welfare of the Children, he or she shall promptly notify the other party of that circumstance. 7. Telephone Contact with the Children. Both parties shall have the right to reasonable contact with the Children during the other party's periods of custody/visitation. Neither party shall interfere with the other party's telephone contacts with the Children. Each party shall make all reasonable efforts to promptly return telephone calls or messages left by the other party regarding the Children. 8. Disparaging Remarks. Neither Mother or Father shall make any disparaging remarks regarding the other party in the presence of the Children, such as those that might tend to alienate the affections of the Children toward the other parent. Also, each parent shall inform relatives and friends to refrain from making any disparaging remarks regarding either party in the presence of the Children. 9. This Order shall supercede all prior Court Orders, stipulations or agreements. 10. Modification. Any provisions of this agreement may be modified or deleted upon written mutual consent/agreement by both parties or upon petition to the Court for modification. No. 99-2864 BY THE COURT, J. esley Oler, J. Dist: Joanne Clough, Esquire, 2331 Market Street, Camp Hill, PA 17011-4642 James M. Bach, Esquire, 352 S. Sporting Hill Road, Mechanicsburg, PA 17055 oa t, CANDACE L. WHITE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 99-2864 CHRISTOPHER L. HOCH, : CIVIL ACTION - LAW Defendant . CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: ANTE DATE OF BIRTH CURRENTLY IN CUSTODY OF Amber Renee Hoch February 13, 1995 Mother Austin Scott Hoch August 16, 1996 Mother 2. A Custody Conciliation Conference was held on March 21, 2001, with the following individuals in attendance: the Mother, Candace L. White, and her counsel, Joanne H. Clough, Esquire; the Father, Christopher L. Hoch, and his counsel, James J. Bach, Esquire. 3. The parties reached an agreement on all but three issues. The agreements which were reached are contained in the form of an Order as attached. However, three issues remained which were unresolved. Therefore, the parties shall be in need of a hearing which it is anticipated shall take no more than two hours of the Court's time. The hearing shall be limited to the three issues which are: A. Whether Father shall be entitled to remove the Children from their present daycare arrangements during his summer custodial weeks with the Children when he is not taking them out of town for vacation; B. Whether Father shall be entitled to two additional weeks of summer vacation time beyond what was ordered by Judge Oler at the most recent custody hearing on July 28, 2000; and C. Whether there shall be a provision in the Custody Order which reads as follows: "Alcohol and drugs: During any period of custody or visitation, the parties shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise ensure, to the extent possible, that other household members and guests comply with this prohibition." No. 99-2864 4. Father's position on the issues in dispute is as follows: A. Daycare: This issue was not raised in the pleadings by Father prior to the Custody Conciliation Conference. However, it and the issue of additional time in the summer were issues that were raised verbally by his counsel at the time of the Custody Conciliation Conference. Father states that it is uncomfortable for him to take the Children to their present daycare provider, the Maternal Grandmother, because of past relationship problems with Mother's side of the family. Father acknowledges that Maternal Grandmother makes an effort to be amiable with him at the time that he sees her. Father believes that it is his "right" as a Father to choose who should provide daycare for his Children during his summer custodial period of time. It would be his preference that the Children be allowed to stay with his Mother, the Paternal Grandmother. Paternal grandmother is a private day care provider for three other children at this time. B. Summer Custody: Father is seeking additional custody in the summer beyond that which was ordered at the time of the most recent hearing, July 28, 2000. He wants more time because he states he "lost" three months of contact with his Children during the time that he was being investigated for child abuse. He states that he wants to "make up that bonding time" with the additional weeks of summer vacation. As a compromise, he offered to add one additional week this summer and one additional week the following summer. Father presently has two weeks of vacation available to him annually, through his employment. He presently works 8:00 a.m. until 5:00 p.m. Therefore, the additional time he seeks would be evening time and overnights during an additional week in June and an additional week in August. C. Drug and Alcohol Provision: Father states there is no point in putting this provision in the agreement because he doesn't feel the need to have something that constitutes "common sense" included in the Custody Order. He states that he is not "stupid enough" to do the conduct which would be prohibited by the paragraph. Father's counsel also has taken the position that he does not want to give Mother any additional ammunition through which she can bring Father back to Court on an issue of contempt. 5. Mother's position on the three issues is as follows: A. Daycare: Mother states that she is not comfortable with changing the daycare arrangements that the Children have presently because she wants them to have the consistency of the same daycare provider (in her Grandmother) as they have had since birth. She also states that there No, 99-2884 was an agreement that they made at the time of the divorce to provide this consistency, Mother does not want to use paternal grandmother as a daycare provider. Her objection to this is partly based on concerns about the Children's access to alcoholic beverages while in her care. She also states that during the marriage they had used his Mother to provide daycare for the Children but discontinued that because of other difficulties that they had with her providing their Children's care. B. Summer Custody: Mother's stand regarding additional weeks is that she will not give any additional custodial time beyond which Judge Oler provided to Father in his most recent Order. She states that during Father's periods of partial custody he takes the Children to his activities such as the flea market or bowling, and that he does not actually spend the time doing activities with the Children. She also states the Children have been having nightmares and have resisted going to their Father's for periods of custody. Mother declined to accept or negotiate with Father regarding his compromise offer of one additional week for the summer of 2001 and the second additional week being added in the summer of 2002. C. Drug and Alcohol Provision: Mother states that she feels this is an important provision to include in the Custody Order because Father has had a history of one "DUI". She states that if the provision isn't necessary, Father shouldn't object to having it included. Date Melis a Peel Greevy, Esquire Custody Conciliator P ' IN RE: CHRISTOPHER L. HOCH Defendant V. CANDACE L. WHITE Plaintiff ?1. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY No. 99-2864 CIVIL TERN ANSWER TO A PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW comes the Defendant, CHRISTOPHER L. HOCH, by his Attorney JAMES M. BACH and files the within ANSWER TO A PETITION FOR MODIFICATION OF CUSTODY ORDER: 1-3. ADMITTED. 4-7. DENIED. Strict proof of this allegation is demanded at time of trial. WHEREFORE, the Defendant herein, Christopher L. Hoch, natural father of the children, respectfully requests that this Court deny the PETITION FOR MODIFICATION OF CUSTODY ORDER except as set forth hereinafter in NEW MATTER. 8. On two distinct and separate occasions, Candace L. White made unfounded allegations to Children and Youth Services accusing Christopher L. Hoch of abuse of his children. These allegations were deemed to be unfounded. During the period of investigation by Children and Youth Services, Christopher L. Hoch was denied any visitation with his children. Christopher L. Hoch lost substantial periods of visitation and is requesting that he receive two additional weeks of summertime visitation with his children. Not only to make up for the times that he was denied visitation, however to formulate an even more strong bond with his children. It appears that Candace L. White is brainwashing the oldest child, the young girl, to be spiteful and hateful toward her father. She does nothing to encourage a loving and caring relationship with the father and, because of this, the father needs additional time with his daughter. It is the conduct of the custodial parent, in this case, that is so spiteful and is using the child as a weapon or tool that requires an enlargement of the summertime visits by the father. Christopher L. Hoch lives with his mother and father, the natural grandparents of the children. Christopher L. Hoch's mother is a licensed daycare provider, and on numerous occasions, over the past several years, has provided daycare for the children. Christopher L. Hoch is seeking a Court Order wherein his mother would be allowed to provide daycare services for his children, her grandchildren, for those periods of extended summertime visitation when he is at work. He lives in the same house as his mother and it is certainly in the best interest of the children to remain in the house and be fed breakfast by the grandmother, a licensed daycare provider, during those hours when Christopher is at work. Repeated efforts to have the natural mother resolve her anger toward Christopher's mother have not been successful. It is believed by Christopher L. Hoch that the only reason that Candace L. White is making an issue about his mother as a daycare provider is because she is personally angry and upset with Christopher's mother, as they have had crosswords in the past and have not resolved their disputes or difficulties amicably. Lastly, the children love their grandparents and it would be detrimental to their best interest if Christopher could not use his own mother and the children's own grandmother as a daycare provider. Not only do the children love the grandmother, but Christopher has siblings who love the children as well. It makes no sense at all to advance the argument that Christopher Hoch could not use his own mother, who is a licensed daycare provider, as the daycare provider for his children. 9. Candace Hoch has insisted that an alcohol provision be placed in the Custody Order and her reason for this is because she has observed beer in Christopher Hoch's household. she believes that Mr. Hoch, the grandfather, drinks an occasional beer. There has not been any complaint, at any time, about Christopher L. Hoch, the father of the children engaging in alcohol or drugs or things like that when he has custody of his children. WHEREFORE, Christopher L. Hoch respectfully prays that this Court order and direct that he shall receive two additional weeks of vacation time with his children in the summer and that his mother be allowed to provide daycare services for those periods of time when he has physical custody of his children if the need arises for a daycare provider. RESFECTFULLYSUBMITTED: Aw- I 4=--t DATE:__ JAMES M. BACH, ESQUIRE Atiorne for the Defendant Attorney I.D. No. 18727 352 S. Sporting Hill Road Mechanicsburg, PA 17055 (717) 737-2033 r ui _ c.: ? . . : ? .. _i -`_, ? ? :::? • ? ? ,, __ r. ?,_ ... jlL( ? : _: .. _? ?? CANDACE L. WHITE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW CHRISTOPHER L. HOCH, Defendant NO. 99-2864 CIVIL TERM }} ORDER OF COURT AND NOW, this j7- day of May, 2001, upon consideration of the attached letter from Joanne Harrison Clough, Esq., attorney for Plaintiff, the hearing previously scheduled for June 1, 2001, is cancelled. BY THE COURT, / Z_/, 6 2' - / J 'esley OIeK, l ., , Joanne Harrison Clough, Esq. 2331 Market Street Camp Hill, PA 17011 Attorney for Plaintiff James M. Bach, Esq. 352 S. Sporting Hill Road Mechanicsburg, PA 17055 Attorney for Defendant V? :rc i i,. i" - ? 1 ..:' . . ? 1 ``1? :I1 _ Sent by: f .& ADLER PC- 717 730 7388; 05/25/01 13:55; Jetrax #717;Page 2/6 REAGER & ADLER, PC ATTORNEYS AND COUNSELORS AI' LAW 2331 MARKET STREET CAMP HILL, PENNSYLVANIA 17011.4642 717.701.1900 TELEFA%717-730.7366 WEBSITE: ReagerfterFCxom THCOGGpfx A. ADLER + DAVID. W. REAGER CHARLES B. MESKI LINLI H. FENICLE DEBMA'PFNISON CANTOR Wlllul''p?C!Mpu AtkLxxY; ?;wuylla3eyiannt May 25, 2001 Vita fntsi rile 040-6467) The Honorablc J. Wcslcy Olcr, Jr. Curnberland COuuty COUE1,11OUSC 1 Cquhhouse Square Carlisle, PA 17013 Re: Hoch v. White No. (N-2864 Dear. Judge Olcr: THOMAS 0. W ILLIAMS SUSAN H. CONFAIR JOANNE HARRISON CLOUGH. _.-_............ ......... ......... _. +Cfi&fim1 Trial S15W.'sliet I am happy to advise you that the parties in the above-referenced custody action were able to negotiate a resolution of the matter currently scheduled to be heard before you on June 1, 2001 at 1:30 p.m. I am enclosing a courtesy copy of a Stipulation for Joint Custody which has been signed by the parties., My office will have the original filed and a time-stamped copy forwarded to your chambers. Please be advised that you may clear your calendar for the June 1° hearing which was previously scheduled to hear my client's Petition for Modification of Custody. incer y, T anne.. Ha k JHC/ak Enclosure cc: James M. Bach, Esquire Candace White /,/qy CANDACE L. WHITE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY CHRISTOPHER L. HOCH, Defendant : No. 99-2864 CIVIL TERM ORDER OF COURT AND NOW, upon review of the attached Stipulation for Order of Custody executed by the parties, it is hereby ORDERED and DECREED that the parties' minor children, Amber Renee Hoch and Austin Scott Hoch shall be as follows: 1. Legal Custody. The Mother, Candace L. White, and the Father, Christopher L. Hoch, shall share legal custody of the minor children, Amber Renee Hoch, and Austin Scott Hoch. The parties agree that major decisions concerning the children including, but not limited to, the children's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, and with a view toward obtaining and following a harmonious policy in the children's best interest. Each party agrees that they shall not impair the other party's rights to share legal custody of the children. Neither party shall attempt to alienate the affections of the children from the other party. Each parry shall notify the other of any activity or circumstance concerning the children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. Without regard to any emergency decisions which must be made, the parent having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. 2. Physical Custody. The Mother shall maintain primary physical custody of the minor children. The Mother shall be entitled to two weeks of uninterrupted custodial time each year with a thirty-day notice to Father. Father shall have partial physical custody of the children at the following times: A. On Thursday evenings from 5:30 p.m. until Friday morning at 8:30 a.m. or at such other return time as agreed upon by the parties. Father shall provide return transportation to the children's school or Mother's home on Friday mornings. B. On alternating weekends from 5:30 p.m. on Friday until 7:00 p.m. on Sunday during the school year and from 5:30 p.m. on Friday until 9:00 p.m. on Sunday during the summer months. C. On alternating federal holidays not otherwise outlined herein from 9:30 a.m. until 8:30 p.m.; provided that Mother shall always have Custody on Memorial Day Weekend through the Memorial Day Holiday and Father shall always have custody on Independence Day/Fourth of July. In the event that Memorial Day weekend falls on Father's regular alternating weekend in any year, then Father shall receive a make-up weekend for the loss of this weekend at a time mutually agreed upon by the parties. D. In even-numbered years, the Father shall have custody of the children on trick-or-treat night and Amber's birthday. In even-numbered years, the Mother shall have custody of the children on Easter, Thanksgiving and Austin's birthday. The parties shall alternate the schedule in odd- numbered years. The custodial period shall be from 9:30 a.m. until 8:30 p.m. E. For one week in June, two weeks in July and one week in August, as agreed to by the parties, provided that during these periods, the Mother shall have custody of the children on Tuesday and Thursday evenings from 5:30 p.m. until 8:30 p.m. and that during the two-week period in July, the Mother shall have custody during the weekend in the middle of the period from 5:30 p.m. on Friday until 9:00 p.m. on Sunday. Mother shall waive these periods if Father is taking the children away for vacation and provides Mother with the location and telephone number of said vacation spot. Father shall notify Mother of the dates intended to be exercised for these vacation periods by June 1" of each year. F. Christmas. The parties shall alternate the Christmas holiday. Schedule A shall be from Christmas Eve at 9:00 a.m. until Christmas Day at 9:00 a.m. Schedule B shall be from Christmas Day at 9:00 a.m. until the day after Christmas at 9:00 a.m. Father shall have Schedule B in the even- numbered years and Schedule A in the odd-numbered years. 3. Transportation. Mother shall be responsible for providing transportation to the Broad Street Elementary School or another mutually agreeable neutral site for the exchange of these custodial periods, except as set forth in paragraph 2. The parties agree to ensure that the children are safe from elements during said transfers. 4. Travel. In the event that either parent intends to take the minor children for more than forty-five (45) miles from Harrisburg, Pennsylvania, overnight, each parent shall provide the other with the children's location and provide a telephone number for contact, if possible. S. Address and Telephone Number of the Parties. Both Mother and Father must keep each other informed of any changes of address or change of telephone number. Any changes in address or telephone number shall be immediately forwarded to the other parry. 6. Notice of Whereabouts/ Illness. Each party shall keep the other reasonably informed as to the whereabouts of the children while with the other party. If either party has knowledge of illness or accident or other serious circumstances affecting the welfare of the children, he or she shall promptly notify the other party of that circumstance. 7. Telephone Contact with the Children. Both parties shall have the right to reasonable contact with the children during the other party's period of custody/visitation. Neither party shall interfere with the other party's telephone contacts with the children. Each party shall make all reasonable efforts to promptly return telephone calls or messages left by the other party regarding the children. 8. D_isparagine Retnarks. Neither Mother or Father shall make any disparaging remarks regarding the other party in the presence of the children, such as those that might tend to alienate the affections of the children toward the other parent. Also, each parent shall inform relatives and friends to refrain from making any disparaging remarks regarding either party in the presence of the children. 9. Modification. Any provisions of this agreement may be modified or deleted upon written mutual consent/ agreement by both parties or upon petition to the Court for modification. BY THE COURT: J. CANDACE L. WHITE, Plaintiff V. CHRISTOPHER L. HOCH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY : No. 99-2864 CIVIL TERM STIPULATION FOR JOINT CUSTODY ORDER AND NOW, this day of May, 2001, the parties, Candace L. White and Christopher L. Hoch each agree the custody of the two minor children, Amber Renee Hoch, bom February 13, 1995 and Austin Scott Hoch, born August 16, 1996, shall be as follows: 1. Legal Custody. The Mother, Candace L. White, and the Father, Christopher L. Hoch, shall share legal custody of the minor children, Amber Renee Hoch, and Austin Scott Hoch. The parties agree that major decisions concerning the children including, but not limited to, the children's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, and with a view toward obtaining and following a harmonious policy in the children's best interest. Each party agrees that they shall not impair the other party's rights to share legal custody of the children. Neither party shall attempt to alienate the affections of the children from the other party. Each party shall notify the other of any activity or circumstance concerning the children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. Without regard to any emergency decisions which must be made, the parent having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. 2. Physical Custody. The Mother shall maintain primary physical custody of the minor children. The Mother shall be entitled to two weeks of uninterrupted custodial time each year with a thirty-day notice to rather. Father shall have partial physical custody of the children at the following times: A. On Thursday evenings from 5:30 p.m. until Friday morning at 8:30 a.m. or at such other return time as agreed upon by the parties. Father shall provide return transportation to the children's school or Mother's home on Friday mornings. B. On alternating weekends from 5:30 p.m, on Friday until 7:00 p.m. on Sunday during the school year and from 5:30 p.m. on Friday until 9:00 p.m. on Sunday during the summer months. C. On alternating federal holidays not otherwise outlined herein from 9:30 a.m. until 8:30 p.m.; provided that Mother shall always have custody on Memorial Day Weekend through the Memorial Day Holiday and Father shall always have custody on Independence Day/July 4°i. In the event that Memorial Day weekend falls on Father's regular alternating weekend in any year, then Father shall receive a make-up weekend for the loss of this weekend at a time mutually agreed upon by the parties. D. In even-numbered years, the Father shall have custody of the children on trick-or-treat night and Amber's birthday. In even-numbered years, the Mother shall have custody of the children on Easter, Thanksgiving and Austin's birthday. The parties shall alternate the schedule in odd-numbered years. The custodial period shall be from 9:30 a.m. until 8:30 p.m. E. For one week in June, two weeks in July and one week in August, as agreed to by the parties, provided that during these periods, the Mother shall have custody of the children on Tuesday and Thursday evenings from'5:30 p.m. until 8:30 p.m. and that during the two-week period in July, the Mother shall have custody during the weekend in the middle of the period from 5:30 p.m. on Friday until 9:00 p.m. on Sunday. Mother shall waive these periods if Page -2- Father is taking the children away for vacation and provides Mother with the location and telephone number of said vacation spot. Father shall notify Mother of the dates intended to be exercised for these vacation periods by June V of each year. F. Christmas. The parties shall alternate the Christmas holiday. Schedule A shall be from Christmas Eve at 9:00 a.m. until Christmas Day at 9:00 a.m. Schedule B shall be from Christmas Day at 9:00 a.m. until the day after Christmas at 9:00 a.m. Father shall have Schedule B in the even-numbered years and Schedule A in the odd-numbered years. 3. Transportation. Mother shall be responsible for providing transportation to the Broad Street Elementary School or another mutually agreeable neutral site for the exchange of these custodial periods, except as set forth in paragraph 2. The parties agree to ensure that the children are safe from elements during said transfers. 4. Travel. In the event that either parent intends to take the minor children for more than forty-five (45) miles from Harrisburg, Pennsylvania, overnight, each parent shall provide the other with the children's location and provide a telephone number for contact, if possible. 5. Address and Telephone Number of the Parties. Both Mother and Father must keep each other informed of any changes of address or change of telephone number. Any changes in address or telephone number shall be immediately forwarded to the other party. 6. Notice of Whereabouts/Illness. Each party shall keep the other reasonably informed as to the whereabouts of the children while with the other party. If either party has knowledge of illness or accident or other serious circumstances affecting the welfare of the children, he or she shall promptly notify the other party of that circumstance. 7. Telephone Contact with the Children. Both parties shall have the right to reasonable contact with the children during the other party's period of custody/visitation. Neither party shall Page -3- interfere with the other party's telephone contacts with the children. Each party shall make all reasonable efforts to promptly return telephone calls or messages left by the other party regarding the children. 8. Disparaging Remarks. Neither Mother or Father shall make any disparaging remarks regarding the other party in the presence of the children, such as those that might tend to alienate the affections of the children toward the other parent. Also, each parent shall inform relatives and friends to refrain from making any disparaging remarks regarding either party in the presence of the children. 9. This Order shall supercede all prior Court Orders, stipulations or agreements. 10. Modification. Any provisions of this agreement may be modified or deleted upon written mutual consent/agreement by both parties or upon petition to the Court for modification. Candace L. White JoaMe Harrison Clough, Counsel for Candace L. tes M. Bach, Esquire ounsel for Christopher L. Hoch Page -4- -, -. > , . - a _ ,: Iv . CANDACE L. WAGGONER, F/K/A CANDACE L. WHITE, Plaintiff/Respondent Vs. CHRISTOPHER L. HOCH, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA 99 - 2864 CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this - +f? day of Au vs y 2010, upon consideration of the joint praecipe for entry of a Custody Order, the Agreement and Stipulation dated August 20, 2010 attached hereto as Exhibit "A" is hereby incorporated as an Order of Court. 11 Andrew C. Sheely, Esquire Att rney for Defendant/Petitioner Candace L. Waggoner, formerly known as Candace L. White, Pro Se Plaintiff/Respondent ?E-!;; M-kE& e4 g Irv ?r1l i C r+?r" 1 ? 03 C-- c- c-n