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HomeMy WebLinkAbout99-04177 Id I .JUL - 9 19 RODNEY E. BRESSLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - CUSTODY NO. 99- 1117 7 CIVIL TERM DAWN M. BRESSLER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 'Dig 199 , upon consideration of the attached Complaint it is hereby directed that the parties and their respective counsel appear before 11 ?yC ? ?( ?f - , Es uire, the conciliator, at ! VIOTt i(h t?pR ((I ?{ Pennsylvania, on the oQ day of ) i 1999, at at I A. 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 entry of a temporary or permanent order. FOR THE COURT: By: y .3 > 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 HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 39J1? 13 ,y'dlA 7 -/3 • yr` ? RODNEY E. BRESSLER, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - CUSTODY DAWN M. BRESSLER, :NO. 99 - /177 CIVIL TERM Defendant : IN CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgement may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 RODNEY E. BRESSLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - CUSTODY NO. qq_ yl CIVIL TERM DAWN M. BRESSLER, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Rodney E. Bressler, an adult individual currently residing at 155 Salem Church Road, Lot 33, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Dawn M. Bressler, an adult individual currently residing at a Cumberland-Perry County Domestic Violence shelter in Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff is the natural Mother of the child, Joshua Michael Bressler, born October 21, 1987. 4. The child was not bom in wedlock. 5. In the past two years, the child has resided with the following persons at the following addresses: NAME Dawn Bressler and sister, Angel ADDRESS 201 3rd Street West Fairview, PA Dawn Bressler and sister, Angel 334 4th Street West Fairview, PA Dawn Bressler and sister, Angel Dawn Bressler 94 2nd Street West Fairview, PA Cumberland-Perry Domestic Violence shelter Carlisle, PA 6. The natural mother of the child is Dawn M. Bressler, who resides as aforesaid. She is not married. { 7. The natural lather of the child is Rodney L. Bressler, who resides as aforesaid. He is married. 8. The relationship of 1he PlaimifTto the child is that of natural Father. The Plaintiff currently resides with his wife, Stacey Bressler, and their two-Year-old son. 9. The relationship of the Defendant to the child is that of natural Mother. The Defendant currently resides with the child. 10. The Plaintiff has no information of a custod Y Proceeding concerning the child pending in any Court of this Commonwealth. i 11. The best interest and permanent welfare of the child will be served by granting the relief requested because the Plain6if is better suited to provide a stable environment to foster the child's well being. i 12. The Plaintiff does not know of any person not a party to the Proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order scheduling the Parties for a Custody Conciliation. Dated: - 0 - Respectfully submitted, Thomas S. Diehl Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 249-2407 - FAX VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. $ 4904, relating to unswom falsifications to authorities DATE: _?f ?' `I°j ? ?LCZ? RODN E. BRESSLER j U p CA ? u. U 4 4 G } CV C „- ?? <z . b CC) ? ? it 'lam Cl- p cr% U l? v `.J N ?? rf jl ? J U? ^v ri u n Sf SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-04177 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BRESSLER RODNEY E VS. BRESSLER DAWN M R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: BRESSLER DAWN M but was unable to locate Her in his bailiwick. He therefore returns the NOTICE AND COMPLAINT IN CUSTODY NOT FOUND , as to the within named defendant BRESSLER DAWN M RETURN NOT SERVED AS PER ATTORNEY ON 7/9/99. Sheriff's Costs: So answers- j Docketing 18.00 00 NotVFound 5.00 /rYY/fir'= Surcharge 8.00 R.7 Ihomas n , S eri $?a THOMAS DIEHL 07/09/1999 Sworn and subscribed--to before me this 9 tz day of 19 q? A. D. CL- o no ry RODNEY E. BRESSLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL DIVISION - CUSTODY DAWN M. BRESSLER, : NO. 99 - 1// 77 CIVIL TERM Defendant IN CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS, You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgement may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 RODNEY E. BRESSLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - CUSTODY DAWN M. BRESSLER : NO. 17i - vi 77 CIVIL TERM G L , Defendant : IN CUSTODY C__ i= -621 -;, Fn ?v eo `mac ??i .y. r) DTI COMPLAINT FOR CUSTOM I. Plaintiff is Rodney E. Bressler, an adult individual currently residing at 155 Salem Church Road, Lot 33, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Dawn M. Bressler, an adult individual currently residing at a Cumberland-Perry County Domestic Violence shelter in Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff is the natural Mother of the child, Joshua Michael Bressler, bom October 21, 1987. 4. The child was not born in wedlock. 5. In the past two years, the child has resided with the following persons at the following addresses: NAME Dawn Bressler and sister, Angel Dawn Bressler and sister, Angel ADDRESS 201 3rd Street West Fairview- PA 334 4th Street West Fairview, PA Dawn Bressler and sister, Angel Dawn Bressler 94 2nd Street West Fairview, PA Cumberland-Perry Domestic Violence shelter Carlisle, PA 6. The natural mother of the child is Dawn M. Bressler, who resides as aforesaid. She is not married. 7. The natural father of the child is Rodney E. Bressler, who resides as aforesaid. He is married. 8. The relationship of the Plaintiff to the child is that of natural Father. The Plaintiff currently resides with his wife, Stacey Bressler, and their two-year-old son. 9. The relationship of the Defendant to the child is that of natural Mother. The Defendant currently resides with the child. 10. The Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth. 11. The best interest and permanent welfare of the child will be served by granting the relief requested because the Plaintiff is better suited to provide a stable environment to foster the child's well being. 12. The Plaintiff does not know of any person not a party to the proceedings who claims to have custody or visitation rights with respect to the child. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order scheduling the Parties for a Custody Conciliation. Respectfully submitted, Dated: Thomas S. Diehl] v Attorney for the Plaintiff 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 249-2407 - FAX TRUE GvPY IM -1 P C02D in Testimony whereof, I twre unta set my Nano and the seal ai said Court at Carlisle, Pa. This- " day o 19 9 Prothonotar VERIFICATION 1 verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsifications to authorities DATE: I- 7 - 1°I ?Q C G? RODN E. BRESSLER RODNEY E. BRESSLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - CUSTODY :NO. 99-4177 CIVIL TERM DAWN M. BRESSLER, Defendant/Respondent : IN CUSTODY AND NOW, this day of 1999, upon consideration of the attached Petition For Special Relief, a rule is issued upon the Defendant/Respondent, Dawn-M. Bressler, to show cause why the relief requested in said petition should not be granted. Said rule shall be returnable at a hearing scheduled for the day of 1999, at the Cumberland County Courthouse, Carlisle, Pennsylvania, in courtroom number _, at M. FOR THE COURT: J. 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 HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 of nIC (717) 249-3166 Q 1-800-990-9108 1 ` QT -?hL C1a-,b\i d'?io n C CRnC C' C- RODNEY E. BRESSLER, Plaintiff/Petitioner v. DAWN M. BRESSLER, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4177 CIVIL. CIVIL ACTION - CUSTODY AND NOW comes the Petitioner, Rodney E. Bressler, by and through his counsel, Thomas S. Diehl, Esquire, who respectfully represents the following: 1. The Petitioner, Rodney E. Bressler, is an adult individual currently residing at 155 Salem Church Road, Lot 33, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Respondent, Dawn M. Bressler, is an adult individual currently residing at an undisclosed location in Pennsylvania. It is known, however, through telephone contact with the Petitioner that the Respondent has been in contact with her parents, who reside at 12 Creekside Drive, Enola, Cumberland County, Pennsylvania, and with her boyfriend, Thomas Myers, who resides at 1609 North Front Street, Apartment R1, Harrisburg, Dauphin County, Pennsylvania. 3. The Parties are the natural parents of Joshua Michael Bressler, bom October 21, 1987. 4. There is an existing Order regarding the custody of the child which the Petitioner was aware of yet not in possession of prior to the filing of the Custody Complaint on July 8, 1999. The Complaint is being amended to reflect the existence of the Custody Order, attached herein as Exhibit `A.' 5. Until July 9, 1999, the Parties were adhering to a mutual and verbal agreement that allowed the Petitioner extended periods of physical custody of the child. 6. On or about July 2, 1999, the Respondent began residing at a Cumberland-Perry County Domestic Violence Shelter located in Carlisle, Pennsylvania alleging that her boyfriend, Thomas Myers, whom she and the child were residing with, had physically abused her. 7. The Respondent has not maintained any stable form of residence for the past several years, and during the Respondent's frequent relocations, it has become customary for the Petitioner to provide extended periods of physical custody of the child. 8. On or about July 10, 1999, the Petitioner expressed to the Respondent that, given her stay at the shelter as well as her continued contact with the alleged abuser, that he believed it to be in the child's best interest to reside with him until she could provide a more stable and nurturing environment. 9. On July 11, 1999, the Respondent and her mother contacted the Petitioner and informed him that they wanted to see the child and would be coming over to the Petitioner's residence. Anticipating a potentially hostile confrontation, the Petitioner called the Hampden Township Police and requested their presence at the Petitioner's residence. 10. On July 11, 1999, the Respondent and her mother appeared at the Petitioner's home where they informed the Petitioner that they would allow the child to remain in the physical custody of the Petitioner, and that they were there only to visit the child. The Petitioner obliged, and allowed the child to walk out onto the porch whereby the child was physically removed from the Petitioner's residence. 11. In an effort to quell the quickly escalating custody conflict, on or about July 12, 1999, the Petitioner's wife, Stacey Bressler, and the Respondent's mother came to a verbal agreement that the Respondent would return the child the evening of July 11, 1999 or, at the latest, July 12, 1999. 12. The Respondent did not subsequently return the child as agreed upon and, since July 11, 1999, the Petitioner has had no contact with the child either in person or by telephone. 13. Through telephone contact with the Respondent's mother, Sharon Fogal, on or about July 12, 1999, Mrs. Fogal informed Petitioner that she had not seen the Respondent or the child since July 11, 1999, and was not aware of their whereabouts. 14. Since July 12, 1999, the Petitioner has attempted to contact the Respondent's mother on numerous occasions to determine whether she has had any contact with the Respondent and the child, or if she knew of the whereabouts of the child. On Monday, August 2, 1999, Mrs. Fogal advised the Petitioner that the Respondent and the child were at her home during the weekend, and that the child was "okay." Petitioner then asked Mrs. Fogal if she knew where the Respondent and the child were, and she responded, "I guess they are back in Carlisle." 15. The Parties, by way of the Custody Complaint, have recently received a Custody Conciliation date of September 24, 1999 at 8:30 a.m. 16. The Petitioner requests Special Relief prior to said date for the following reasons: (a) On or about July 8, 1999, the Petitioner became aware that upon leaving the abused women's shelter on or about July 7, 1999, the Respondent began residing once again with Thomas Myers, the same individual the Respondent alleged to have been physically abused by which resulted in her removing herself and the child to the shelter; (b) The Petitioner has cause to believe that the child may be exposed to physical abuse due to Respondent's continued relationship with the alleged abuser, Thomas Myers; (c) Throughout his schooling, the child has been enrolled in special education classes, and in order to prevent further obstacles in the child's education, the Petitioner believes that it is within the child's best interest that he be enrolled into school prior to the first day of classes, which occur prior to the conciliation date; (d) The child has stated that he wishes to remain in the custody and care of his father, the Petitioner. WHEREFORE, the Petitioner respectfully requests this Honorable Court to enter a rule to show cause why physical custody of the child should not be granted to the Petitioner pending the parties' Custody Conciliation, to award the Petitioner attorney's fees, and grant such other relief as the Court deems appropriate. Dated: t-' - I ? C7 pecrruuy suormueu, Attorney for the Petitioner 401 East Louther Street, Suite 103 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 249-2407 - FAX EXHIBIT A r.: Date Submitted: 2/3/94 d' SLM XXXXXX ORDER DAWN M. BRESSLF . IN THE COURT OF COMMON PLEAS sintiff DAUPHIN COUNTY, PENNSYLVANIA V. NO. 4808 S. 1993 RODNEY E. BRESSLER, , s CIVIL ACTION - LAW Defendant CUSTODY/VISITATION INSTRUCTIONS Xx_ Case settled - see attached Order Case continued -n Case not settled No Interim Order W = r; See attached Interim Order z n -r7 7 .70 Assign to Judge -< L Reassign to Judge i •/ DAWN M. BRESSLER, Plaintiff V. RODNEY E. BRESSLER, Defendant T g4} ?-H - 91 M1 IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 4808 S, 1993 CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, to wit, this day of 1994, the parties, having presented their position to the custody conciliator, Sandra L. Meilton, Esquire, and both having indicated that they had reached an agreement with regard to the best interest and welfare of their minor children, Joshua Bressler, born October 21, 1987, and Angel Bressler, born August 29, 1992, it is hereby ORDERED AND DECREED as follows: 1. Primary physical custody of Joshua Bressler and Angel Bressler shall be with Mother, Dawn M. Bressler. 2. Father, Rodney E. Bressler, shall have partial physical custody of Joshua Bressler, beginning Friday, February 11, 1994, and on alternating weekends thereafter, from Friday at 6:00 p.m. through Sunday at 6:00 p.m. 3. Father, Rodney E. Bressler, shall have partial physical custody of Angel Bressler, beginning Saturday, a February 19, 1994, and on alternating Saturdays thereafter, for a two to four hour period at specific times as mutually agreed upon by the parties. 4. The parties will share major holidays as mutually agreed between them with the understanding that the holiday schedule will take precedence over the regular custodial schedule. 5. The foregoing is deemed to be a minimum schedule of contact between Joshua and Angel and their Father, it being understood and stipulated by the parties that, upon their mutual agreement, an expanded or altered schedule may be agreed between the parties for and in the best interests of Joshua and Angel. BY THE COURT: AUG 0 3 019 -19- I hereby certify that the foregoing is a true and correct copy f the original fi4cd. PrMidnotery I verify that the statements made in the foregoing petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4404, relating to unswom falsifications to authorities. v-- RODN E. BRESSLER CERTIFICATE OF SERVICE 1 hereby certify that a true copy of the foregoing Petition For Special Relief and Contempt of Custody Order was served on the following person in the following manner: FIRST CLASS MAIL, POSTAGE PREPAID CUMBERLAND COUNTY BAR ASSOCIATION LEGAL SERVICES ATTN: SONVA LAWRENCE 2 LIBERTY AVENUE CARLISLE, PA 17013 Dated: August 13, 1999 Thomas S. Diehl, Esquire Attorney for Plaintiff /Petitioner 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 249-2407 - FAX I A4'I *HlI. 19 ' Thomas S. Dichl JU I biwt I l,w her Sir x9, Swtr 10i Cnrlislq Pcnnsclc;miu 17011 IckpMnw l7111!NHM\1 I'AX (717) 24-NMO AUG 16 19999 RODNEY E. BRESSLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - CUSTODY :NO. 994177 CIVIL TERM DAWN M. BRESSLER, Defendant/Respondent : IN CUSTODY AND NOW, this day of 1999, upon consideration of the attached Petition For Special Relief, a rule is issued upon the Defendant/Respondent, Dawn M. Bressler, to show cause why the relief requested in said petition should not be granted. Said rule shall be returnable at a hearing scheduled for the day of 1999, at the Cumberland County Courthouse, Carlisle, Pennsylvania, in courtroom number _, at M. FOR THE COURT: J. 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 HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 RODNEY E. BRESSLER, PlaintifUPetitioner V. DAWN M. BRESSLER, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4177 CIVIL CIVIL ACTION - CUSTODY PLEITION FOR SPF.(JA1. RFLIF.F AND CONTEMPT OF C11STODV ORDER AND NOW comes the Petitioner, Rodney E. Bressler, by and through his counsel, Thomas S. Diehl, Esquire, who respectfully represents the following: 1. The Petitioner, Rodney E. Bressler, is an adult individual currently residing at 155 Salem Church Road, Lot 33, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Respondent, Dawn M. Bressler, is an adult individual currently residing at an undisclosed location in Pennsylvania. It is known, however, through telephone contact with the Petitioner that the Respondent has been in contact with her parents, who reside at 12 Creekside Drive, Enola, Cumberland County, Pennsylvania, and with her boyfriend, Thomas Myers, who resides at 1609 North Front Street, Apartment RI, Harrisburg, Dauphin County, Pennsylvania. 3. The Parties are the natural parents of Joshua Michael Bressler, bom October 21, 1987. 4. There is an existing Order regarding the custody of the child which the Petitioner was aware of yet not in possession of prior to the filing of the Custody Complaint on July 8, 1999. The Complaint is being amended to reflect the existence of the Custody Order, attached herein as Exhibit `A.' 5. Until July 9, 1999, the Parties were adhering to a mutual and verbal agreement that allowed the Petitioner extended periods of physical custody of the child. 6. On or about July 2, 1999, the Respondent began residing at a Cumberland-Perry County Domestic Violence Shelter located in Carlisle, Pennsylvania alleging that her boyfriend, Thomas Myers, whom she and the child were residing with, had physically abused her. 7. The Respondent has not maintained any stable form of residence for the past several years, and during the Respondent's frequent relocations, it has become customary for the Petitioner to provide extended periods of physical custody of the child. 8. On or about July 10, 1999, the Petitioner expressed to the Respondent that, given her stay at the shelter as well as her continued contact with the alleged abuser, that he believed it to be in the child's best interest to reside with him until she could provide a more stable and nurturing environment. 9. On July 11, 1999, the Respondent and her mother contacted the Petitioner and informed him that they wanted to see the child and would be coming over to the Petitioner's residence. Anticipating a potentially hostile confrontation, the Petitioner called the Hampden Township Police and requested their presence at the Petitioner's residence. 10. On July 11, 1999, the Respondent and her mother appeared at the Petitioner's home where they informed the Petitioner that they would allow the child to remain in the physical custody of the Petitioner, and that they were there only to visit the child. The Petitioner obliged, and allowed the child to walk out onto the porch whereby the child was physically removed from the Petitioner's residence. 11. In an effort to quell the quickly escalating custody conflict, on or about July 12, 1999, the Petitioner's wife, Stacey Bressler, and the Respondent's mother came to a verbal agreement that the Respondent would return the child the evening of July 11, 1999 or, at the latest, July 12, 1999. 12. The Respondent did not subsequently return the child as agreed upon and, since July 11, 1999, the Petitioner has had no contact with the child either in person or by telephone. 13. Through telephone contact with the Respondent's mother, Sharon Fogal, on or about July 12, 1999, Mrs. Fogal informed Petitioner that she had not seen the Respondent or the child since July 11, 1999, and was not aware of their whereabouts. 14. Since July 12, 1999, the Petitioner has attempted to contact the Respondent's mother on numerous occasions to determine whether she has had any contact with the Respondent and the child, or if she knew of the whereabouts of the child. On Monday, August 2, 1999, Mrs. Fogal advised the Petitioner that the Respondent and the child were at her home during the weekend, and that the child was "okay." Petitioner then asked Mrs. Fogal if she knew where the Respondent and the child were, and she responded, "1 guess they are back in Carlisle." 15. The Parties, by way of the Custody Complaint, have recently received a Custody Conciliation date of September 24, 1999 at 8:30 a.m. 16. The Petitioner requests Special Relief prior to said date for the following reasons: (a) On or about July 8, 1999, the Petitioner became aware that upon leaving the abused women's shelter on or about July 7, 1999, the Respondent began residing once again with Thomas Myers, the same individual the Respondent alleged to have been physically abused by which resulted in her removing herself and the child to the shelter; (b) The Petitioner has cause to believe that the child may be exposed to physical abuse due to Respondent's continued relationship with the alleged abuser, Thomas Myers; (c) Throughout his schooling, the child has been enrolled in special education classes, and in order to prevent further obstacles in the child's education, the Petitioner believes that it is within the child's best interest that he be enrolled into school prior to the first day of classes, which occur prior to the conciliation date; (d) The child has stated that he wishes to remain in the custody and care of his father, the Petitioner. WHEREFORE, the Petitioner respectfully requests this Honorable Court to enter a rule to show cause why physical custody of the child should not be granted to the Petitioner pending the parties' Custody Conciliation, to award the Petitioner attorney's fees, and grant such other relief as the Court deems appropriate. Dated: Pccuuny summucu, -? i Thomas S. Diehl Attorney for the Petitioner 401 East Louther Street, Suite 103 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 249-2407 - FAX EXHIBIT A Date Submitted: 2/3/94 a SLM xxxxxx ORDER DAWN M. BRESSLy? r IN THE COURT OF COMMON ainti.ff DAUPHIN COUNTY, PLEAS PENNSYLVANIA V. NO. 4808 S. 1993 RODNEY E. BRESSLER, , CIVIL ACTION - LAW Defendant CUSTODY/VISITATION rNSTR:rrr ,"S xx Case settled - see attached Order Case continued ° -n • rJ Case not settled -!r -r CD -I.., ?. No Interim Order Zil M t v; r'7 See attached Interim Order z ? ?r 7 Assign to Judge -< L Reassign to Judge li. to rr {llI Ld t, 3',4'91 cJ DAWN M. BRESSLER, IN THE COURT OF COMMON^PLEAS Plaintiff DAUPHIN COUNTY, PENNSYLVANIA V. NO. 4808 S, 1993 RODNEY E. BRESSLER, CIVIL ACTION - LAW Defendant CUSTODY ORDER OF COURT AND NOW, to wit, this 2 _ day of? 1994, the parties, having presented their position to the custody conciliator, Sandra L. Meilton, Esquire, and both having indicated that they had reached an agreement with regard to the best interest and welfare of their minor children, Joshua Bressler, born October 21, 1987, and Angel Bressler, born August 29, 1992, it is hereby ORDERED AND DECREED as follows: 1. Primary physical custody of Joshua Bressler and Angel Bressler shall be with Mother, Dawn M. Bressler. 2. Father, Rodney E. Bressler, shall have partial physical custody of Joshua Bressler, beginning Friday, February 11, 1994, and on alternating weekends thereafter, from Friday at 6:00 p.m. through Sunday at 6:00 p.m. 3. Father, Rodney E. Bressler, shall have partial physical, custody of Angel Bressler, beginning Saturday, February 19, 1994, and on alternating Saturdays thereafter, for a two to four hour period at specific times as mutually agreed upon by the parties. 4. The parties will share major holidays as mutually agreed between them with the understanding that the holiday schedule will take precedence over the regular custodial schedule. 5. The foregoing is deemed to be a minimum schedule of contact between Joshua and Angel and their Father, it being understood and stipulated by the parties that, upon their mutual agreement, an expanded or altered schedule may be agreed between the parties for and in the best interests of Joshua and Angel. BY THE COURT: 9ZAd=2i:P- 17. AUG 0 3 1999 19 I hereby certify that Ifie foregoing is a true and correct copy f the original . f itC,d. / )-?) Pret_h notary VERIFICATION 1 verify that the statements made in the foregoing petition are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unsworn falsifications to authorities. D RODN@Y E. BPESSLER CERTIFICATE OF SERVICE I hereby certify that a true copy of the foregoing Petition For Special Relief and Contempt of Custody Order was served on the following person in the following manner: FIRST CLASS MAIL, POSTAGE PREPAID CUMBERLAND COUNTY BAR ASSOCIATION LEGAL SERVICES ATTN: SONYA LAWRENCE 2 LIBERTY AVENUE CARLISLE, PA 17013 Dated: August 13, 1999 Thomas S. Diehl, Esquire Attorney for Plaintiff/Petitioner 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 249-2407 - FAX RODNEY E. BRESSLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - CUSTODY NO. 994177 CIVIL TERM DAWN M. BRESSLER, Defendant/Respondent : IN CUSTODY AND NOW, this day of 1999, upon consideration of the attached Petition For Special Relief, a rule is issued upon the Defendant/Respondent, Dawn M. Bressler, to show cause why the relief requested in said petition should not be granted. Said rule shall be returnable at a hearing scheduled for the day of 1999, at the Cumberland County Courthouse, Carlisle, Pennsylvania, in courtroom number , at M. FOR THE COURT: J. 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 HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA :7013 (717) 249-3166 1-800-990-9108 RODNEY E. BRESSLER, Plaintiff/Petitioner v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4177 CIVIL DAWN M. BRESSLER, Defendant/Respondent CIVIL ACTION - CUSTODY PETITION 117 R SPFCIAI RFl IFF AND CONTFMPT nF CUSTODY ORDER AND NOW comes the Petitioner, Rodney E. Bressler, by and through his counsel, Thomas S. Diehl, Esquire, who respectfully represents the following: 1. The Petitioner, Rodney E. Bressler, is an adult individual currently residing at 155 Salem Church Road, Lot 33, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Respondent, Dawn M. Bressler, is an adult individual currently residing at an undisclosed location in Pennsylvania. It is known, however, through telephone contact with the Petitioner that the Respondent has been in contact with her parents, who reside at 12 Creekside Drive, Enola, Cumberland County, Pennsylvania, and with her boyfriend, Thomas Myers, who resides at 1609 North Front Street, Apartment R I, Harrisburg, Dauphin County, Pennsylvania. 19873. The Parties are the natural parents of Joshua Michael Bressler, bom October 21, . 4. There is an existing Order regarding the custody of the child which the Petitioner was aware of yet not in possession of prior to the filing of the Custody Complaint on July 8, 1999. The Complaint is being amended to reflect the existence of the Custody Order, attached herein as Exhibit `A.' 5. Until July 9, 1999, the Parties were adhering to a mutual and verbal agreement that allowed the Petitioner extended periods of physical custody of the child. 6. On or about July 2, 1999, the Respondent began residing at a Cumberland-Perry County Domestic Violence Shelter located in Carlisle, Pennsylvania alleging that her boyfriend, Thomas Myers, whom she and the child were residing with, had physic-illy abused her. 7. The Respondent has not maintained any stable form of residence for the past several years, and during the Respondent's frequent relocations, it has become customary for the Petitioner to provide extended periods of physical custody of the child. 8. On or about July 10, 1999, the Petitioner expressed to the Respondent that, given her stay at the shelter as well as her continued contact with the alleged abuser, that he believed it to be in the child's best interest to reside with him until she could provide a more stable and nurturing environment. 9. On July 11, 1999, the Respondent and her mother contacted the Petitioner and informed him that they wanted to see the child and would be coming over to the Petitioner's residence. Anticipating a potentially hostile confrontation, the Petitioner called the Hampden Township Police and requested their presence at the Petitioner's residence. 10. On July 11, 1999, the Respondent and her mother appeared at the Petitioner's home where they informed the Petitioner that they would allow the child to remain in the physical custody of the Petitioner, and that they were there only to visit the child. The Petitioner obliged, and allowed the child to walk out onto the porch whereby the child was physically removed from the Petitioner's residence. 11. In an effort to quell the quickly escalating custody conflict, on or about July 12, 1999, the Petitioner's wife, Stacey Bressler, and the Respondent's mother came to a verbal agreement that the Respondent would return the child the evening of July 11, 1999 or, at the latest, July 12, 1999. 12. The Respondent did not subsequently return the child as agreed upon and, since July 11, 1999, the Petitioner has had no contact with the child either in person or by telephone. 13. Through telephone contact with the Respondent's mother, Sharon Fogal, on or about July 12, 1999, Mrs. Fogal informed Petitioner that she had not seen the Respondent or the child since July 11, 1999, and was not aware of their whereabouts. 14. Since July 12, 1999, the Petitioner has attempted to contact the Respondent's mother on numerous occasions to determine whether she has had any contact with the Respondent and the child, or if she knew of the whereabouts of the child. On Monday, August 2, 1999, Mrs. Fogal advised the Petitioner that the Respondent and the child were at her home during the weekend, and that the child was "okay." Petitioner then asked Mrs. Fogal if she knew where the Respondent and the child were, and she responded, "I guess they are back in Carlisle." 15. The Parties, by way of the Custody Complaint, have recently received a Custody Conciliation date of September 24, 1999 at 8:30 a.m. 16. The Petitioner requests Special Relief prior to said date for the following reasons: (a) On or about July 8, 1999, the Petitioner became aware that upon leaving the abused women's shelter on or about July 7, 1999, the Respondent began residing once again with Thomas Myers, the same individual the Respondent alleged to have been physically abused by which resulted in her removing herself and the child to the shelter; (b) The Petitioner has cause to believe that the child may be exposed to physical abuse due to Respondent's continued relationship with the alleged abuser, Thomas Myers; (c) Throughout his schooling, the child has been enrolled in special education classes, and in order to prevent further obstacles in the child's education, the Petitioner believes that it is within the child's best interest that he be enrolled into school prior to the first day of classes, which occur prior to the conciliation date; (d) The child has stated that he wishes to remain in the custody and care of his father, the Petitioner. WHEREFORE, the Petitioner respectfully requests this Honorable Court to enter a rule to show cause why physical custody of the child should not be granted to the Petitioner pending the parties' Custody Conciliation, to award the Petitioner attorney's fees, and grant such other relief as the Court deems appropriate. Dated: Ct _ 11- / Respectfully submitted, Thomas S. Diehl Attorney for the Petitioner 401 East Louther Street, Suite 103 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 249-2407 - FAX EXHIBIT A Date Submitteds 2/3/94 SLM XXXXXX ORDER DAWN M. BRESSLFaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA V. NO. 4808 S, 1993 RODNEY E. BRESSLER, ° ? CIVIL ACTION - LAW Defendant s CUSTODY/VISITATION iNSTRU amm _XK_ Case settled - see attached Order Case continued Case not settled 7! r_ C n No Interim Order: N C:? fry .., See attacked Interim Order Assign to Judge -< L Reassign to Judge iuVrt{?? ?-Ll Y DAWN M. BRESSLER, Plaintiff V. RODNEY E. BRESSLER, Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 4808 S, 1993 CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, to wit, this day of , 1994, the parties, having presented their position to the custody conciliator, Sandra L. Meilton, Esquire, and both having indicated that they had reached an agreement with regard to the best interest and welfare of their minor children, Joshua Bressler, born October 21, 1987, and Angel Bressler, born August 29, 1992, it is hereby ORDERED AND DECREED as follows: 1. Primary physical custody of Joshua Bressler and Angel Bressler shall be with Mother, Dawn M. Bressler. 2. Father, Rodney E. Bressler, shall have partial physical custody of Joshua Bressler, beginning Friday, February 11, 1994, and on alternating weekends thereafter, from Friday at 6:00 p.m. through Sunday at 6:00 p.m. 3. Father, Rodney E. Bressler, shall have partial physical- custody of Angel Bressler, beginning Saturday, February 19, 1994, and on alternating Saturdays thereafter, for a two to four hour period at sner_i.fic times as mutually agreed upon by the parties. 4. The parties will share major holidays as mutually agreed between them with the understanding that the holiday schedule will take precedence over the regular custodial schedule. 5. The foregoing is deemed to be a minimum schedule of contact between Joshua and Angel and their Father, it being understood and stipulated by the parties that, 1pon their mutual agreement, an expanded or altered schedule may be agreed between the parties for and in the best interests of Joshua and Angel. BY THE COURT: 9?? - a. AUG 0 3 1999 19 I hereby certify that Nye foregoing is a true and correct copy f the original filed. // Prothdnotary VERIFICATION I verify that the statements made in the foregoing petition are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unswom falsifications to authorities. RODN E.BRE e CERTIFICATE OF SERVICE 1 hereby certify that a true copy of the foregoing Petition For Special Relief and Contempt of Custody Order was served on the following person in the following manner: FIRST CLASS MAIL, POSTAGE PREPAID CUMBERLAND COUNTY BAR ASSOCIATION LEGAL SERVICES ATTN: SONYA LAWRENCE 2 LIBERTY AVENUE CARLISLE, PA 17013 Dated: August 13, 1999 Thomas S. Diehl, Esquire Attorney for Plaintiff/Petitioner 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 249-2407 - FAX AUG 16 199Q RODNEY E. BRESSLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - CUSTODY :NO. 99-4177 CIVIL TERM DAWN M. BRESSLER, Defendant/Respondent : IN CUSTODY AND NOW, this day of 1999, upon consideration of the Petition For Special Relief, a rule is issued upon the Defendant/Respondent, Dawn M. Bressler, to show cause why the relief requested in said petition should not be granted Said rule shall be returnable at a hearing scheduled for the day of 1999, at the Cumberland County Courthouse, Carlisle, Pennsylvania, in courtroom number , at M. FOR THE COURT: J. 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 HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 AUG 16 199, RODNEY E. BRESSLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - CUSTODY :NO. 994177 CIVIL TERM DAWN M. BRESSLER, Defendant/Respondent : IN CUSTODY AND NOW, this day of 1999, upon consideration of the Petition For Special Relief, a rule is issued upon the Defendant/Respondent, Dawn M. Bressler, to show cause why the relief requested in said petition should not be granted Said rule shall be returnable at a hearing scheduled for the day of _ 1999, at the Cumberland County Courthouse, Carlisle, Pennsylvania, in courtroom number at M. FOR THE COURT: J. 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 HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 AUG 16 191V RODNEY E. BRESSLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - CUSTODY :NO. 99-4177 CIVIL TERM DAWN M. BRESSLER, Defendant/Respondent : IN CUSTODY AND NOW, this day of 1999, upon consideration of the Petition For Special Relief, a rule is issued upon the Defendant/Respondent, Dawn M. Bressler, to show cause why the relief requested in said petition should not be granted Said rule shall be returnable at a hearing scheduled for the day of 1999, at the Cumberland County Courthouse, Carlisle, Pennsylvania, in courtroom number--, at M. FOR THE COURT: J. 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 HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 19CICI\ W RODNEY E. BRESSLER, Plaintiff/Petitioner V. DAWN M. BRESSLER, Defendant/Respondent AND NOW, this _ day of IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY NO. 99-4177 CIVIL TERM IN CUSTODY 1999, upon consideration of the Petition For Special Relief, a rule is issued upon the Defendant/Respondent, Dawn M. Bressler, to show cause why the relief requested in said petition should not be granted Said rule shall be returnable at a hearing scheduled for the day of 1999, at the Cumberland County Courthouse, Carlisle, Pennsylvania, in courtroom number , at M. FOR THE COURT: J. 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 HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 AUG 1 6 RODNEY E. BRESSLER, : IN'1'111 COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUN'T'Y, PENNSYLVANIA V. : CIVIL ACTION - CUSTODY :NO. 994177 CIVII.'rium DAWN M. BRESSLER, Defendant/Respondent IN CUSTODY iITf7 0111111 AND NOW, this day of 1999, upon consideration of the Petition For Special Relief, a rule is issued upon the DO'endant/Respondent, Dawn M. Bressler, to show cause why the relief requested in said petition should not be granted. Said rule shall be returnable at a hearing scheduled for the ____ day of 1999, at the Cumberland County Courthouse, Carlisle, Pennsylvania, in courtroom number _, at M. FOR TI [F COURT- J. YOU SIIOULD TAKE TI IIS PAPER TO YOUR LAWYER A'1' ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONI1, 60 1-0 OR TFLI PI IONE TI IE OFFICE SET FORTH BELOW TO FIND OUTWI IE'RF YOIJ CAN Gli'I' 11131.1'. '1'I Ili CUMBIRLAND COUN'T'Y BAR ASSOCIATION 2 1.113ERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-8O0-9900108 AUG 1 6 RODNEY E. BRESSLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - CUSTODY NO. 994177 CIVIL TERM DAWN M. BRESSLER, Defendant/Respondent : IN CUSTODY AND NOW, this day of 1999, upon consideration of the Petition For Special Relief, a rule is issued upon the Defendant/Respondent, Dawn M. Bressler, to show cause why the relief requested in said petition should not be granted. Said rule shall be returnable at a hearing scheduled for the day of 1999, at the Cumberland County Courthouse, Carlisle, Pennsylvania, in courtroom number at .M. FOR THE COURT: J. 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 HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 THOMAS S. DIEHL, ESQUIRE 401 EAST LOUTHER STREET SUITE 103 CARLISLE. PA 17013 IIIIIII 40111 H I I I I I III IIIIIII CI IM13ERLAND COUNTY BAR ASSOCIATION T'GAL. SERVICES A FIN: SONYA LAWRENCE P LIBERTY AVENUE CARLISLE. PA 17013 _ r. i THOMAS S. DIEHL, ESQUIRE 401 EAST LOUTHER STREET SUITE 103 CARLISLE, PA 17013 33LUSA, ? R ODNEY E BRESSLER 1 55 SALEM CHURCH ROAD LOT 33 MECHANICSBURG, PA 17055 i I, 1111111111111111111111 dh III III THOMAS S DIEHL ESQ 401 EAST LOUTHER STREET SUITE 103 CARLISLE, PA 1 701 3 t SEP1999t?2 DAWN M. BRESSLER, Plaintiff RODNEY E. BRESSLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 99-4177 CIVIL IN CUSTODY COURT ORDER AND NOW, this day of ?? , 1999, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: J A hearing is cheduled in Courtroom Noj of the Cumberland County Courthouse on the /ay ofAIMJ 1999, atkLy2M. at which time testimony will be taken in the above case. At this hearing, the Father, Rodney E. Bressler, shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the court and opposing counsel a memorandum setting forth the history of custody in this case, a detailed listing of the issues currently before this court, a list of witnesses who will testify on behalf of that party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least 7 days prior to the mentioned hearing date. 2. Pending further order of this court, the Dauphin County Order of February 3, 1994 at Docket No. 934808 (Dauphin County) shall remain in effect. BY THE C T, -*t4 J. cc: Thomas S. Diehl, Esq. n?? t`t ?q y y Joan Carey, Esq. ?. 0`' 1 DAWN M. BRESSLER, Plaintiff RODNEY E. BRESSLER, Defendant Prior Judge: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N0.99-4177 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Joshua Bressler, born October 21, 1987; and Angel Bressler bom August 29, 1992. 2. A Conciliation Conference was held on September 24, 1999, with the following individuals in attendance: The Mother, Dawn M. Bressler, with her counsel, Joan Carey, Esquire; and the Father, Rodney E. Bressler, with his counsel, Thomas S. Diehl, Esquire. 3. There is a prior custody order form Dauphin County in 1994. The parties then both moved to Cumberland County. Mother has primary custody under the order with Father having alternating weekends and other periods of custody under the order. Father now expresses concern because Mother recently entered into a domestic shelter as a result of problems she was encountering with her boyfriend. Father wants to obtain custody of Joshua. There has not been a history of Father seeing the younger child Angel and Father is not seeking custody of Angel. The parties are unable to reach an agreement and a hearing is required. 4. The Conciliator recommends the entry of an order in the form as attached. a qq DATE Hubert X. Gilt' y, Esquire Custody Conciliator RODNEY E. BRESSLER, Plaintiff/Petitioner V. DAWN M. BRESSLER, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4177 CIVIL CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this day of IJR'uN?'" 1999, upon consideration of the attached Petition, it is ordered and directed that the hearing previously scheduled for December 15, 1999 at 8:45 a.m. and the underlying custody action are hereby discontinued. The Dauphin County Order of February 3, 1994 at docket number 93-4808 S (Cumberland County Order at docket number 99-4749) shall remain in effect. BY THE COURT: -110 J. .? H ?. q l?li,,n,"," i??ll?;':? ?I:.??C., RODNEY E. BRESSLER, Plaintiff/Petitioner V. DAWN M. BRESSLER, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.99-4177 CIVIL CIVIL ACTION - CUSTODY PETITION TO DISCONTINUE AND NOW, comes the Petitioner, Rodney E. Bressler, by and through his counsel, Thomas S. Diehl, Esquire, who asserts the following: On or about July 8, 1999, the Petitioner initiated a Complaint for Custody of the parties' child, Joshua Michael Bressler, born October 21, 1987. 2. Subsequently, the parties' attended a Custody Conciliation Conference, and ultimately had a Custody Trial scheduled for December 15, 1999 at 8:45 a.m. 3. The Petitioner has contacted his counsel, and advised that he no longer wishes to pursue this action, and accordingly desires to remove the scheduled trial from the Court's docket. 4. The Petitioner therefore requests that the prior Dauphin County Order of February 3, 1994 at docket number 93-4808 S (Cumberland County Order at docket number 994749) regarding the custody of their children remain in effect. 5. The Respondent's counsel, Joan Carey, Esquire, has been given notice of this petition and has received a copy of the same, and does not oppose its contents. WHEREFORE, the Petitioner requests this Honorable Court to enter an Order discontinuing the above action. Respectfully submitted, Dated: I ?- - l Attorney for Petitioner 401 East Louther Street, Suite 103 (717) 240-0833 (717) 240-0893 - FAX 01 ? C)- ) L: C) !il .J Gx `? IW"I1N1.I lluunas S Dichl ?^I I .ni I,.mLa svnn. tinny In; Id"o DECapmg