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HomeMy WebLinkAbout99-04532 tA t 4 4 !4 Ei 1.4 E Itwo Ito ?4mdO a e#04' 414 . - In iffi as ? ? a ?w 4 P 4 a -? 4 a 4 -? a 64 44 a a tA 2?. 5 +? a to .Q i? Z- +C* SA?? 41 a a .s? IV Esi a ?t 64 z 9 5 .? two ? 0?4 4mo lt? too • 4°'? a 4 40# 4 tA r 4 ? a ?w 4 ? .4 or ? #q op a ,y a 4 ? tA to (94 .a tt a 'H 4 e 4 a .p tA tA CD f?. 4E po?o I Ad o?v 1 6NC Q/ u n yl,? ie.:? ? ?o r, ct. d/l 3 Y& -? ?kl EXHIBIT 9-28 ?4 =? S I ? #9 i , Name: FOLLOWING A TRIP TO FLORIDA ON A MAP Use the map and map scale below to complete the activities. For help, you can refer to pages G4-G11 in your textbook. 2. In Tampa the family rented a car and drove to Disney World, near Orlando. In which direction did they travel? ja r om Cape Canaveral, Mia and her mily drove to Miami. About how many miles is Miami from Cape Canaveral? At?out how many miles did they travel? 6' C rn.' 3. After visiting Disney World, Mia and her family drove to Cape Canaveral which direction did they travel? [O - 1,66 I . s Their friends took them to Everglades National Park. In which direction is the park from Miami? In 7. Then Mia and her family flew from Miami to St. Petersburg. In which direction is St. Petersburg from Miami? voc V. I.I z c t 2 United States Reviewing Geography Skills 1. Mia and her family visited Florida. In 4. About how many kilometers is Cape which part of the United States is Canaveral from Orlando? Florida? Name T 'G fya C C y '', Pmetwtc Correctly,, Read the sentences below. Add a period a question G?(2. mark (?), or an exclamation point (1) to the end of lJ each sentence. 1. Just wait a minute i- ?k Let's have a picnic on the weekend _a- I Why did the dog bark T 4. Joanne fixed the flat tire on her car 0? X Tomorrow I must weed my garden b. Look, a shooting star 8. Will you call me next Thursdc 9. Please sharpen your pencils I 10. What time does the show star 11. Should we take an umbrella _ 12. Ouch, that hurt 7. We rode the roller coaster four times o- u M ? .3 u ai e u ro u _I ro C. to O o O C ti N .n a Q' a) E O Z O O m ••? v -5: 4; s m m N 7 0 3 ? >+ d Y ? O ?O O L Cf) E =' C CU co v a? L U y to CU ? L Q .C O N o E C O »r v RE CD n ? v c O O Y C © .y. co u ?o V -' CV M =• In 16 1` Cd oz O R d d u ro u N v a? L 0 0 ttupp u r C O CV 0 M u N y O a? 4+ L CM q i o A u v L aau.uand Module #1 Quiz Section A Circle all the Polygons. bv `. q6& eami e ?lA" # I? Circle the lines that parallel. J nii Circle the lines that a perpendicular to each er. Draw one line of symmetry for each figure. B ?J D I ) "I Draw a Draw a pentaga Draw a hexagon. Draw a right angle % - Draw two congruent triangles. (ft them when you draw them) z \7 Draw ai Draw a parallelogram that is not a square or a rectangle. zf-7 Square. n Draw a rectangle. i I of eta .r Z n\-C) 1 I 1 i I I I 1 a, I I { i l OL1 "'h I y l cc fA o. 1-n I I ° SI S I d 3 I 1 I 1 ??)1 I 1 1 f I I 1 I y 0) d ? ?I I I1 I ?I I 0. Q.d I I yW I I I 1 I I 1 1 I ?I I In In jl ?I % _yl hl t ?1 CA) ? °'? c? I ?I VVV •L 3 d cc v m i w coo ^c3 °- d d c cc J b0 s d ° cc c 0 spQ p d L ca d d 4J 4? 110 ca 3? L 0 S- O ? S ?d d w cnv a - aLi s d oS '- ? L ? .e ? f9 U L \ L a u a o °' n 4-1 h -Ca u „ y d +? d >, o, o, d S „ E 3 u u ao L o `° i y N N ? Q J 0 ? Q d r-I N m d' t(1 tD f? 00 I 1 I I 1 I I I I 1 j 1 I I I 1 1 I ? 1 I I /,t ?O QI 61 ? ?l I `I V_ 1 l of \I I ?I ? I ` I ? ?• I I ?I ?11 I ? I I I I 1 1 I I ? I `' I I 1 I I ?I vll I I I `I ?1 I 1 d -? ^? VI QI ( I 1 d•? ?1 .yl ?I ll LI ? 1 v? C to Sb4 'C I ? ?d o c obi d In i a p E O m S ,p o ? 4' w 4-J -ca a. 0 4? C i i L3. 0- 0 E -0 E cc d o C \ i ca v> d S d m d ca o i o i i V) cn I - O .? N m a1 r-I r-f r-I i-I r-I *A I I y U IPA^ %ct 11-5 1 11 (' i1 L lr, ?ahC?ry I . OM4y(/ ? CC LC V?l /? 9. C 0 -?.CG?d DCCCc?rP? Name - 7-S.?ti461 \ To follow text page 271 n ?' Iv Points, Lines, and Segments ?N 5? Write the name for each figure. 1. A B C / D p61rat F 1; nee ? l 4. y 6. Q / IN X 1 L Write parallel or intersecting for each pair of lines. 7. a. :trFef- s Lr /?ora.llP L n -a 90. 11. /?C rR ! 1 ?nT?ale?f/{?g_ I,M) Pnr'ol.? .? ;,ter 8 J m x N Draw and name the figure. _ a N 13. EF 14.E A M { MN N O6 .0 102 Name Rays and /Angles Name each ray. E F Rag .. Name each angle. ALL. ro T, 4. S. X g, A\ ?r yn L B C Z I M `?? N Xrs Is the angle a right angle? Write yes or no. L? T E z a r T N N N 3 How many right angles does each polygon have? To tonow tent page 273 3. T rayfl cmmn 9. V >- 10. 11. 103 -# 2 Name ------ KD Cp2AtL a ? a o r £ N F G I I Write the correct letter or letters to answer each question. X' Which shapes are polygons? G CA E ' !' 2. Which shapes are quadrilaterals? Gce4 3. Which shape is a hexagon? r X. Which shape is a parallelogram? , 4* 14, 5. Which set of lines are intersecting but NOT perpendicular? 6. Which set of lines are parallel? 1 7. Which set of lines are intersecting AND perpendicular? k Which shapes are NOT quadrilaterals? Why? ?1, E„? ?,- • 4" s' ?i . I ?M 9. Draw a line of symmetry through the shape that is not a polygon. 10. Perpendicular lines make a R? A n f I I . p._ ./ . I --r - i __ _._- _. _.,__ A ?_ _?_ All About Me • cover i K a ® ® Ab®vt •o ? AL FK k;h?f O F6] O o?vhc'r- ? r roarr .A F9 ® I h d?r?d ® © roc?h??,? tei?rnr 01908 by EVAN-MOOR CORP. O O 40 7 More Than a Report EMC 558 All About Me . mntls Idl /1 Y 1 . ?.j 111 ( 1 1 r+? t. Y '. ?? p? ML .Derr y XP PC •1998 fly 01998 CORP. i `Oases wwl? j More Than a Report EMC 558 clue by kvf, Doing what I do best... AK WA MT NO ME OR MN ID SD WI ?, NY NV a NE IA CA OT co IL IN OH MD KS MO KY WV VA .w..m AZ OK TN 'NC NM AR SC. MS AL GA T% LA oe HI T ?' states I have lived states I have visited 9 Mon Than a Report EMC 558 Name 6 n 6? i -P . ,dr k Q 1 ¦ THINK AND PRACTICE a ?a ort sin sprin ¦ MDktt Oroups Write the list word that belongs in each group. 1, talk, shout, J 2. lump, run, J 3. fall, winter, , 4, to, with, M Word Meanings Write the list word that completes each sentence. 5. The word J means a safe place to stay. `` 6. The word V means to be in a game and to have fun, 7. The word _ means to give money to someone. 8. The word _ is the name of one time of year. STRATEGIC SPELLING: Using Steps for Spelling Now Words Look and listen carefully as you study words. Write these pairs of list words. Then follow these steps: Look, Say, Spell Aloud. Don't leave out any letters. T 9. for fort ` ------ - ---- --------- 10, sing spring --------------- _____ _______-_- -_- _ Tom 2. ? ' ------ -- ---- - - --- ----- ------ 4. - -------------- ------ - --- ----------- ------- 7. --- ---------- ??R)Tt ---------- s{?rir 0 N. Q C ¦ Word Wits Write the list word that contains each short word below. Ce:nd -r e ---------------- k ¦ Hidden We den list words. 7. tr f 10, *M44 cape' 8. rot fla 11. le am 9, lg ing, 12. irr e Make a new word b 'ting the letter that comes after each circle . It spells something good to eat. 7 8 9 10 11 12 ?J. s PC;. 4r- I i vqo? Ncune LASSO TitST ¦ 1 Find the word that is spelled correctly to com t each ntence. Fill in the circle to show the correctly word. e to _ the baby. h oled i ld rdhoof 1. It is for . This gift is you. ® deb ® a0 fer ® fo Q boad ® beb fro ® for 2. Please _ 'th me. Put your on. ® pla pl ap ® caap 0 plaee ay Q ce ® caep 3. We will _ y song. 9. Lay it _ o table. sing ®si ® flaat ® •. cQ s ug ® sng cQ flet ##flat 4. I h fun at summer Q 10. The new p ® faat app campe a camp ® carrunp fat ® fatt 5. After winter, co Can you your arm? as sr. ziab . spring bend ®bende g ® sping bened ® benned 0 00 00 6. He will _ for the toy, 12. An my is nearby. pay ®paI fo ®fourt c piae ® pauee Q for '0 fort w 1 B n i I I 14 IC Is Id 1 say the name of each picture. Print the letter for its ending sound. V- T -A- 1 - - - - - - - - - - - - - - - - - - - 9 b 7 4 I ------- ---------- j- 8 -------- ---------- 10 11 12 -------- ---- ---------- ------- 13 14 _,,dggll6 15 16 Idt R loy Lesson Final consonants: Phonemic awareness s t Say the name of each picture. Print the letter for its ending sound. Trace the whole word. 1 2 3 -dam 4 0 5 ? 7 cJ I j S u y ---- - 9 10 71 12 - Q-1 ----- ----- ------ ---- -- 13 14 1- Ow--[ -- G Lesson 2 Final consonants: Spelling 40 1 16 j Ask your child to name the pictures whose names have the some ending sounds. , I Nome 1 ¦ "VIEW a a &WO11d fort ing Ram la f at en ca ® Rhymes Write one or two list words that rhyme with each word, lamp ---------- - ---- ------------------- may -- port ---- 4,tC ? ? ring - - ----- ----- 33-. -flfl- - - - - ------- - - ---- -------------- ord to make a list ¦ Vowel Wado Ch Yd word. Write the list 7 -------- -- i0• fir a: - - - --- 1L..tlit . 12. fit??-9. k -- -------- ------- -10 - -------- ? dll •; ? ? Lam, ll. 3 -c J 12. 0 Q I 10 The Magic Wand Arithmetic Fun Find ten number problems here. Write the answer for each 11ne. +s 9 + 9 ?g 2 6 ; 5 + 6 6 + 5 = ? ? 8+8= 1G 7+5=Q 8 + 6 1I 7= 4+9+4=17 Name? p \ cj h Date 4 Copyright G 1996 by Troll Communications L.L.C. Marne 1' O (()b 1 0 LI CHALUNae ¦ S ??Words tt?? ¦ Write the Challenge Word that matches each clue. Use your Spelling Dictionary for help with the meanings. Then circle the letter or letters that make the /k/ sound. 1, A house may have this. --- - 1. -- --- - - 2. This is often eaten with eggs 3. This can happen to a zipper /This boy is calling to get help for his pet, Use one or more Mallenqe `W eti wri te what he might be saying. CW I6U . its . e X on{. 0 w • ¦ ¦ ¦ Does your home have an attic? Find out what an attic looks like. Draw a picture of one. 11 i Ncnne k 2 ¦ THINK AND PRACTICE can ecould Ind ,k sic ¦ Rhymes Write the list word that rhymes. 1. I want to look at a _. 1 2. The cat that was ton ate fish from the _, rm ----------- 3. I wanted to find a pet that was ¦ Context Write the list word that completes each sentence. ------- - -- - -- ---------- 4, The dog would _ a new home. 4. 5. A boy who stayed inside because he was _ wanted a pet. 6. The boy was nice and 7. The dog _ be his pet. ------ - -- --------- 6. STRATEGIC SPILLING: Seeing ?- Meaning Connections ! . elf boo tore --------- 8. 8. Write the list word that is part of each word in the box. 9. What is a place to buy books? 10. What is a place to put books? -- Ta_ -1` 1) •)I C 12 Name \ 9 ¦ REVIEW A 1? Word List &ec oul d ok n wo a too ack ac is ¦ Crossword Puxxle Write list words to complete the puzzle. ¦ Context Clues Write the list words to finish the story. Bill 7 up with a sore throat. Mom 8 his temperature. The thermometer showed he was 9 . Mom told Bill to get 10 - into bed. She gave him a good 11 to read. Then she opened a 12 of chicken soup. 7,? Ic 6t--- ----- --- - -- -- ------ lo. - r --------- 11. 12. - C r -------- - -- -------- 9. e> f)!' oil 14 Words That Go Across Words That Go Down 2. is able to 1. done with a foot 5. to put into a suitcase 3. to care about 6. comes after first 4. nice Nome ? Q 3 ¦ REVIEW ord List reak grade stand stick s et rav ro a rea ground Mate ing ¦ Picture Clues Write the list word that tells about each picture, 1.4. -- --- -- -- ------ 2. 5. t ------ 6 3. ¦ Word Meanings Write the list word that means the same as the phrase. 7. to not be scared 8. to take along 7 9. important, or famous 10, to rise to one's feet 8. 11. soil, or land 12. the boy who has the same parents as his sister A ?? • ?A • A, L v v? ,s i Q 1) 0 T s O J: Name Happy Harvest r167 Color the apple if the sum is 10 or more. 4.. 2 " ..?, ? 6?5. + 3 ti l° 15.- 4 + 3 Add. Name H0. 4 ¦ REVIEW Word List jump and friend went ask just bump land hand different desk must ¦ Word Parts Make list words. Draw lines to match the letters on the left with the ones on the right. Write each word. t 1. m and 5. e ump ----- - ------ - d 3. \ ust d- esk 4. ! Ump 8. 0 Riddlos Write list words to complete the riddles. 9. It rhymes with sand. 11. It begins like dog and ends like tent. A 4 - _tP__Nf_i 10. It rhymes with mask. 12. It is a six-letter word. -------- CRA ---------------------------- ------ -------------- H 0 J? 22 Name USSON TIST ¦ , 1. 0 0 0 ¦ Find the word that is spelled correctly to complete each sentence. Fill in a circle to show the correctly spelled word. Sample: We _ him t Grandma, ® tolk ook cQ tooke t k 1. Hit the ball with 7. Sh is big d_. ® stik (E) a breve ® have Q steck *s 'ck brave ® brav 2. In which - do yo live? What a ideal a0 stae ®st a great ® gnat 0 staat ® stet graet ® Beat 3. The apple is very 9. I ds . sweet swet a) bru a brother swee ® t e bo er otter 4. Do not the dis did you get _ brack gr d ® gradd 0 brak braek gr ''d grade 5. The 1 e ell to the 1 Will ou please _ up? 0 ® grond stmt ® stad ground ® grownd st ited ® stand b. Put the baby on the 12. _ it tomorrow. swiping ® swin g ® breing cQ suwwing # swing c irng ® breg 1 a I W a Name g MEASURING Happy Harvest Cut out the ruler. Measure each one. How many inches? 1. ?.r1,. I 2. 3. 4. W:P% 4 How would you measure a carrot that is 8 inches long? I I S a r m F i - jo ? t-,? ?,-, 'e" ,,, V1 _I_ Narne 4 ¦ THINK AND PRACTICE ump and vent as .. ¦ Missing Words Write the list word to finish each phrase, 1, good_ 2. _ to school 3. _ a question ¦ ABC Order Write these list words m alphabetical order. lust and ent frien --- -- ------------ V2 ---------- -- ------------ STRATEGIC SPELLING: Seeing Meaning Connections J?PY camper 1 8. Write the list word that is part of each word hz the box. Finish the sentences with words from the box. 9. My horse is a good 10. Noise makes my horse very_, 0 1);F M I 0 f frienJ just /Mobi - I ------------ ---- --------- 2. 20 R066 i (? Joc I? 15 Fq, i Iy ?qf erne e h) !94 9 _t ? { "x_15 it+?ltl=?5, _i ?.. More Addition a ;II O 41 Add to find the sums. A. 6 +5 = I B. 4 + 8 C. I + 3 = D. 4 +3 = i E. 4 + 9 = F. 2+7= G. 2+8= H. 9 + 8 = I 1 1. 3+8= 7+3= ` 3+5=? 5+7 8 + I = 1 6 + 6 = 7 + 4 = 0 + 7 7 + 7 = 7 + 9 = a 3+6= ?/ 't 3+3= % 5+3= 6+8=L? 8 + 4 = 8+7= 9+4= ?- 4k `V 4 Skill: finding and writing sums C Awesome Aquarium I Name uainga map key Follow the directions on page 10 to complete this map. Aquarium Map I I . _ I 6 - - I I I - -- I` g I I i NI I ` ? ? I 1! I I _ 1 i- e Ine tuctional Fait 0 TS Danison Key 1 Ticket Office 2 restaurant 3 gift shop 4 whale 5 otter 6 seal 7 puffin 8 octopus 9 jellyfish 10 tropical fish 11 movie room 9 IPS199 MopAlllr Rg tj 0 PRACTICE ¦ 3 ¦ Way Parts Make list the left th the ones on g .. sw ¦ Rid es Write the 10 7, s like stamp Zymes with hand. I - Word J t t e ',stan d stic aat 9roun tat swing Draw lines t match the letters on he righ . rite eac word. _ gr that fi c 10. It : rh -------------------b d 3 v g 8. It begins like breeze and - 'rhymes with save. -- ---------- ------ ------- 9. It begins like brown and rhymes with steak. - -- ----------------..--- v W of clues. like bridge and with other. It begins'like grape and ymes `pith fade. 12. It begins bright and rhymes with sing. _____.•------------------------ iT Your Yardsfick Match these things to what they measure. Leavy something is trature outdoors ong or short something is Next, use small paper clips to measure the length alongside a hot dog. Then ask your child to write of a hot dog. the number of paper clips it took to reach from one Invite your child to place paper clips end to end end to the other end of the hot dog. 5. Ho ny paper clips long is this hot dog? t>?'•tF:. -'1' f•:n PS. Ti?CJJ?t't}lla 3?N'i7 S;rti 6. How many paper clips long is this hot dog? 7. Which hot dog is longer? Circle the longer hot dog. rl - Weekly Reoder Home connection Activities September 1999 5 1 1 Say the name of each plcture. Fill in the bubble the letter for the beginning sound of the word. 1 1. O b ®g O 0d ®y Say the name of each picture. the letter for the ending sound. 5. 6. 0b 0d ®1 Ox 40& OS ®g 3. 4. Ow ®w ® r 01 OM bubble b ®x i a u Om W ®p . 0b Say the name of the letter for the ture. Fill in the bubble sound. 9. 10. Or OC 41 OC Ot ®b ?r 11. N2. ®m Or On Od > 01 01 Lesson Initial, medial, final consonants: Checkup p a Circle the word that answers the riddle. Print it on the line. e sO - -- '-- --- -------- ----- 9. Jam goes in me. I am a ` car - farm O gas ll - 2. I rhyme with drum. I am du eb - - ------ --- well 00 3. A spider spins me. I am a wet ® big i -- - ?------------------ b 4. I say "oink." I am a fig seven ?. C19 Or 5. I come after six. I am ro 0 00 bag box b. I rhyme with fox. I am a el pet 7. You can write with me. I am a---q?h -- ----- - - - - peg - - , r %Mn- cabin agon 8. You can ride in me. Iam a le on 0 Lesson 7 With your child, take turns making up riddles using the r Initial, medial, final consonants: Checkup words on the page. i I ? , ,?. ? ? j ? ? ? ? j ? I ? , I I ' ' i I j , I ' I I ? ,? . . i ? ? i I ? ? i V TJ7 ? ? I? W I? I I? Q, I a; I I? I ' I i II , 1 1 ILI I < ?= I 1 i I s Q I , I , I ? I ? I , I , I , I I I , 1 , 1 , I 1 1 , I , ? I 1 1 I I I , I , I , 1 , I , I , 1 , I , I , I , 1 , I , I 1 1 , I , 1 , 1 , I , I , I , I , I , I , I 1 I 1 j I I I I , I I i I j ? \J I 1 ??v S,77 ?? I I ? I I ? 1 I I l I I \i 11 i ^ I ? i I 1 I I 1 ? ! cl? I I I 1 ? 1 I ?I I I I ' I I I I ' , I II I , ? ' I I I 1 I ? 1 i i I 1 1 I 1 u I 1 1 " I I j I ?. , M` i i i I I i i i I i i I I 'i J?t ?y ?I lc?I I. .Q 1 I I 1 1 1 I I I I i I ! I 1 ?j I 1 ? C) I I y 1 ? 1 ? I I r I I .. 1 1 ? I I . i I I 1 I i i i ? ' I I I 1 II 1 I 1 1 V I 1 ` ` d 11 ii i r i C ' NAME Write each number in standard form. 1. 4 thousands, 2 hundreds 2. 3 hundreds. 6 ones 3. 9 hundreds, 5 tens, 8 ones 4. 6 thousands, 8 ones OuIZ 1 Pages 52 2 - 56 3 o C? 5. 9 hundreds, 4 tens. 7 ones ?_7 6. ythousands, 7 tens 2 --- - Write the numbers of thousands, hundreds, tens, and ones in each number. thousands hundreds tens ones 7. 8.452 a B 904 Q L . --- 3 Q ? 9. 3,005 040 10 2 . , 599 4 L 11. . 7 - _- ° ? 12. 701 _?__ . - - Name: '? ry FOLLOWING A TRIP TO FLORIDA ON A MAP v Use the map and map scale below to complete the activities. For help, you can refer to pages G4-G 11 in your textbook. 1. Mia and her family visited Florida. In which part of the United States is Florida? /` I 2. In Tampa the family rented a car and drove to Disney World, near Orlando. In whjgh direction did they travel? Ab ut how many miles did they travel? j 3. after visiting Disney World, Mia and er family drove to Cape Canaveral. In which direction did they travel? 4. About how many kilometers is Cape Canaveral Orlando? l 7 5. from Cape Canaveral, Mia and her amily drove to Miami. About how many miles is Miami from Cape Canaveral? 0/ /`^6. heir friends took them to Everglades ?fJational Park. In which direction is the park from Miami? 7. Then Mia and her family flew from Miami to St. Petersburg. In which direction is St. Petersburg from Miami? 2 United States Reviewing Geography Skills Unit 1 MST: rthroat through thrM sentek- acream atmir- street at a aguare a pume A. Write the list word that matches each clue. 1. In baseball, a aflug and amiss is called thla. -fi t/ OI 2. If you catch a cold, this might get sore. kR4oa:dt tch, you might do this. 3. When yAo717/ /L 4. Do this to get juice from an orange. ? w??2n b. Some people do this when they are afraid. B. Write the Hot word that rhyme with each word. 8. do - 7. feet - lrfi S. bear - Q 444 :2C i 9. range - ?J 10. bill I r l/ Think ar Praetiee -c; A?l Q -r br+ a r F r I? 1 c Unit 1 What Is a Sentence? NAME For each pair, write the group of words that is a sentence. 1. Dinosaurs livedmillions ofyears ago. Were big animalsthat roamed the earth. # I 2. Some dinosaurs were over twenty-seven meters long. Weighed as much asthirty-five tons each. -I- 3. Had pads like elephant's feet. Today's lizards looksomethinglike dinosaurs. 4. Ate meat and eggs all the time. Some di nosaurs ate plants. 5. Dinosaurs had four legs. Walked on their hack legs only. ?.. ?? Unit 1 quiz for Lessons # S 8t # 4 NAME A. Choose the sentence that has the correct capital letter and end mark. Markyouranswer. 1. On. Is our pool big enough. O b. we have two plastic rafts. O c. I know Jack can swim well. 2. Oa. Here are the tomatoes? O b. There are carrots in the refrigerator. Oc. we have enough lettuce. S. K a Is farming hard work? . They get up early each morning? O c. ask the people who work on the farm. B. Choose the correct answer to each question. 4. Which sentence is a command ? On. Please wash your hands. O b. Who will set the table? Oc. What a delicious meal this Jal 8. Which sentence is an exclamation? gbh Ca. Is that your sister in the boat? O b. That sail has such colorful stripes! O c. I likesailboatstoo. C. Write the complete subject and the complete predicate in the space provided 7. Many people call them jeans. Complete subject Complete predicate S. The telephone is not a new invention. Complete subject J-'4/ fQl? Complete predicate NAME What d_, is _ 1. If today is Wednesday, what day is tomorrow? r- " 2. If today is Sunday, what day was yesterday? 3. If Friday is the 10th, what day is the 13th? 4. I Tuesday is the ®th, what day is 7 days later? o? 5. What day is two days before Friday? 0. What day is a week before Saturday? 7. What day is two weeks from Sunday Gl , Name: Use with pages 138-145 COLUMBUS'S EXPEDITIONS Use the map on this page to complete the activities below. For help, you can refer to pages 138-145 in your textbook. 1. Draw the route of Columbus's first 6. expedition to the Americas in red. 2. Why did Columbus make this expedition? 7. 3. Locate the group of islands Columbus reached on his first expedition. Color them green. Then label them. ( 4. yvhat did Columbus name the first stand he visited in the Americas? L t='?14 5. Draw the route of Columbus's second expedition in brown. What do historians call the movement of people, plants, animals, and germs that resul d from these expeditions? List two changes that occurred in the Eastern Hemisphere as a result of this exchange. 8. List two changes that occurred in the Americas as a result of this exchange. e ? i 32 United States Chapter 6, Lesson 1 0; h m i C3 'U C C O •S y 4 ? ? m u> ? C VJ O CU Q, CJ gy m, L - ' y c i^ 03 m 1 V1 W '' - E v '; r m ?T N J• 7 ? ! C a ^. V m l?; e y a U W ? z O .v ra d J a ? y I I I I 1 ?I ' i I i I I I I ? I I ? 1 I i I I I I i ! i I I ` I I 11 , ' I J I I i 1 i j I 1 N 00 O 00 ?O L L L t fp \ MI -1 `? M? G! av+ L ? ? ?0.. ?[ N ro-°3c 3 0 3E?I o v m o C O ~ O .C = g -0 '- N M1 R V1 IO C I_ tm a w 0. a 'C c 0 15 O tin 0 C) 3 t" ? rn o Ln o N rn o o g o 0 c a Cl v ;' E c, iv V1 G Y H C1 Z7 C m O O O E U Z Nv o L v E n. w v a+ N ? L h ?. 3 0 ?+e 0 Ln N m E N 3 3 0 a ? 4 0 0 E o 5 f° A ?$IIQM .d ra u e N m z N Y y.I 0 fp 3 ,L 3 Y ' 0 0 V01 U C O Y L ? Q .R ?O p? c m 0 as?Evr?? 0 y r- U m C O> L> N W= 0 3 GJ Cl .C .p L O +L,, .C 3 a N v y ate`-'°o°3°'E 3 C C o v n 0 3 ° o 0 11 Ln Ln N M r? 66 cS N m v C C U O t C o o a O L .D N ? .n s ? ro o E 3 0 Y? S Cd N n1 a N\ f N I+1 ? 11` r' N r N ? N A ^ r r m ' W V r b Q r a b Ci i O Unit 9 Think & Practice NAME cue brake pocket track because still' laughed photo enough alphabet -t- A. Write the list word that completes each sentence. 3. 4. 8. I lost my key because of a hole in my Jake did not have a in the world. Do you have D/17?v?/l money to buy a ticket? The bread is dry 4? 61 z ,,? O Dad baked it too long. Tens known the letters of the B. Write the fist word that belongs in each group. 6. camera, film, 7-- trails, rails, 1 7. 8. rigid, unbending. /2/V 9. anfled, giggled, i 10. car, stop, A M U) M N Z y ,Y co gW d Vl 0 .'V; Q c 0 _o d r Y} _b m U d t a? y N a) IS ?a V LL C 7 R Ql E .? c ? •E m c y U) Q y ? c •? O L a = m " C CZ a N d pMp?? pn r. VN? W M ? r N ?N O. ? pp N M ? r 00 r N N a O P A n P N ? ? 1( ? P PU r M ^^ r N p pN ?? r N N ?M r r N r ? s rM r r N M a r4 ch M FN VT 48 co J R a O r =O y O Qt C N L } 0 T pM? ^ V' V r N N rN N r T ?O ? N r ? ;M r ? N H N T er ry a .- ao v e^J ? XA14 pMp? '? Pa OD r rV N ^ p p ? N N f ; r N N a a -1 V PI N ?1 ? G Y O•D z? s o C N C V ' O / ? O E y ? c. a , y nL w co L.].• I f/1 •O o as -? m 3 N Mn L 7 Q C f .O - Y 'O -is v EN ?°' O d L O N j }E y L Y a> m 3 Cl O H 0 w 3 O _ V > N 8j E T6 O £ L ccG } (x C CV of ?f O N 4; N 8 ? C r G O c ,? L L d -0 O l ... z Y . O O ? 3 0 c (Q d ID 0 y c .& r. R V R{ t 3 «; p t 16 p o d a y Evy o?rn E3 c 3 v «- ? ?' ? m ? E f N L \ cO . yy 0 A .O `8 rC •G Y O N G N G 0 3 FL- E 3 O FL 3 m O r ii r fV a7 v Unit 2 Think & Practice NAME %l; /r it :1i?rs?. wrist wreck climb thumb A. Write the Hot word that belongs in each group. 1. elbow, knee, 1, < >, . 2. reading, spelling, ' ( % _, Z 9. shape, pattern. /,•t 4. hand, finger, /?Z6)/l/, ? S. tie, lace, ,c H. Write the list word that means the same as the underlined word or words. 8. Do you havethe facts about who broke the window? L % 7. "tpyour name at the bottom of the letter. 8. Let's gum the tree. 9. The song was notfamiliar, so we didn't sing. 10. Did the dog tginyour model plane? t: z Y N I W Z o 'WO C 7 ? E Z N E r r F14, E 7 C r I ?s 7 + CV V + t L M CV M c a V r, f') 9 CN M r T + N E + V Lo If N n co § 01 - 9 8 5 L E n $ E cV M w N v O r W r r 0 (D O © ® VI/ ,n C N c r cm M ui <d SO O N V V C 7 t CV 5 E N CO n V £ to E _ M + ? O + tV + C C 176 C6 ci O T C 0 .G 0 t _ 3 p t d. ? E 0 0 L ti 1=6 }R E 01 > r° 22 T ' (mow/.?\) F KY rn ? O M PA 1? m 01 0 T Unit 1 /Statements & questions # 2 NAME A. Write the correct end mark for each sentence. The write 8 for statement or 9 for question. 1. Did you ever help make a pot of stew r 2. I like to make stew with my uncle 3. Did I remember to tell you that we added water 4. We always keep a lid on the pot 5. Can you think of anythingmore delicious-./ B. WriteS for each statement and 9 for each question. The write each aentencecorrectly. 6. can Hilary make a meat pie l? il/J'l. Z?I?A w /t , })''? s` it A 7. she cooks some ground meat first 9. she baked it in the oven for over fifty minutes 8. did Hilary put the meat in the pie shell NAME ?L/_.'- ..._.. 3 ?Usipt? Political Map of the Southwest Use the map below to complete the activities. For help, YOU can refer to pages G4-GI 1 in your textbook. ;.yP. .: - o,.N.. ..... u:.- ..,.;. -. a.: y.; * State capital TuMa .. :? Santa Fe OKLAHOMA • Other city * AlWquerque homa Crzy O - Sate boundary ARIZONA NEW National bound *Ph anls Mexico o Tucson. Crum C.rf,bad El so TEXAS 4L Auxin * ,n ... Houston ' eSan Antonio .. t 3. .. `.. y a 9" Gul f of Mexico 1. Name one thing, other than its name, that tells you this map is political. 4. Name the two (2) countries that are located on the national boundary line. 2. Which four (4) states are shown in the subject area of the map? 5. Which city on the map is located on the border of the United States & A?exico? 4" - 6. Name the capitals of the following states: Texas - Arizona - New Mexico - J 7. Which river runs along the national boundary line? 3. Name the three (3) states that are located on the national boundary line. AUG - 6 1999,1 ROBERT E. JACK, : IN THE COURT OF COMMON PLEAS OF Plaintiff TERRI L. JACK, vs. Defendant : CUSTODY :CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4532 CIVIL TERM ORDER FOR CONTINUANCE AND NOW, this -Lf? day of August, 1999, upon agreement of counsel, the hearing scheduled for August 9, 1999, at 1:30 p.m. by this Court's Order of July 27, 1999, is hereby rescheduled to August 12, 1999, at 9:00 a.m. in Courtroom No. 1 of the Cumberland County Courthouse, Carlisle, Pennsylvania. Thomas S. Diehl, Attorney for Plaintiff 401 East Louther Street, Suite 103 Carlisle, PA 17013 Joan Carey, Attorney for Defendant LEGAL SERVICES, INC. ? 8 Irvine Row Carlisle, PA 17013 By the Court, ? ? ?'1 ?. i?`i ROBERT E. JACK, : IN THE COURT OF COMMON PLEAS OF Plaintiff /Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - CUSTODY :NO. `?9? H53a CIVIL TERM TERRI L. JACK, Defendant/Respondent : IN CUSTODY AND NOW, this 2? t? day of 1999, upon consideration of the within Petition For Special Relief, a rule is issued upon the Defendant/Respondent, Terri L. Jack, 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 1:30 /- rh . 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 FOR THE COURT: 1 X11 CJi'_ Syr( Ory a, MAOL,d Az -C- 1a ?*t. ROBERT E. JACK, Plaintiff/Petitioner v. TERRI L. JACK Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- CIVIL CIVIL ACTION - CUSTODY PETITION FOR SPF,CIA1, REI.IF.F AND NOW comes the Petitioner, Robert E. Jack, by and through his counsel, Thomas S. Diehl, Esquire, who respectfully represents the following: 1. The Petitioner, Robert E. Jack, is an adult individual currently residing at 418 South Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania. 2. The Respondent, Terri L. Jack, is an adult individual currently residing at an undisclosed location in Michigan. The Respondent had resided with the Petitioner at 418 South Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania until June 5, 1999. 3. The Parties are the natural parents of Robert Mason Jack, born May 12, 1990; and Kayla Morgan Jack and Kory Robert Jack who are twins born on October 13, 1989. 4. There is not an existing Order regarding the custody of the children. 5. Contemporaneously with filing this petition, the Petitioner has filed a Complaint for Custody regarding the above children. 6. Until June 5, 1999, the Parties resided together in Mount Holly Springs with their children at the aforesaid address, and had lived as such for the previous six (6) years. 7. On June 5, 1999 the Respondent took the Parties' children to Michigan under the pretext of visiting her extended family for two (2) week vacation. 8. The Petitioner remained at home in Mount Holly Springs, Cumberland County, Pennsylvania due to employment obligations. 9. The Parties were not under any marital strife known to the Petitioner, and in fact had planned a camping trip together with their children which was to commence on June 19, 1999, upon the Respondent's return from Michigan. 10. On or about June 17, 1999, the Respondent contacted the Petitioner by telephone informing him that her stay in Michigan had to be extended due to an illness in her family. Therefore she and the children could not attend their previously planned camping trip. 11. The Respondent subsequently requested the Petitioner to send finances to her to absorb the costs of her extended stay in Michigan. In response, the Petitioner indicated that the Respondent could remove the requested money from their jointly held account. 12. On or about June 29, 1999, the Respondent informed the Petitioner that she was not ever returning to Pennsylvania. 13. The Petitioner has attempted unsuccessfully, through numerous telephone calls, to convince the Respondent to return to Pennsylvania with the children. 14. On or about July 19, 1999, the Respondent's sister, who also resides in Michigan, informed the Petition that the Respondent had acquired an attorney to establish custody of the children in Michigan. 15. On July 20, 1999, the Petitioner had direct tlephone contact with the Respondent's mother who stated that the Petitioner would, "never find the children never again." WHEREFORE, the Petitioner respectfully requests this Honorable Court to enter an Order granting the Petitioner Primary Physical Custody of the children pending the parties' Custody Conciliation. Respectfully submitted, Dated: / - 01? ' / el i omas S. Diehl Attomey for the Petitioner 401 East Louther Street, Suite 103 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 249-2407 - FAX VERIFICATION 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. § 4904, relating to unswom falsifications to authorities. Date ROBERT E. JAC CERTIFICATE OF SERVICE 1 hereby certify that a true copy of the foregoing Petition For Special Relief was served on the following person(s) in the following manner: POSTAGE PREPAID, CERTIFIED, RESTRICT DELIVERY, RETURN RECEIPT REQUESTED MAIL, & FIRST CLASS MAIL TERRI L. JACK C/O TUTTLE FAMILY 6278 E. RIVER ROAD TWIN LAKE, MI 49457-9748 TERRIL.JACK C/O MS. TUCKER 4913 PULLMAN AVENUE MUSKEGON, MI 49442 TERRI L. JACK C/O TIM TUTTLE 4833 PULLMAN AVENUE MUSKEGON, MI 49442 Dated: July 27, 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 kI, lIIll I 111 Thomas S Didil JUL z ? X999 1111 I+1 Lu11111C1 tip prl, tiWlt 101 \ 1'adnlc. 14,111,lemur 17011 m.re.... ovl:m.uxn r.IN nm:r?.: 1117 . Qdw-\ ck V. IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA Defendant : N0. i{SSa CIVIL 19 49 : CUSTODY VISITATION : CIVIL ACTION LAW And now, this 01 , upon consideration of the attached complaint, it is ?er_eb directed that the above parties and their respective counsel appear before n z \??,T-, Esquire, the conciliator, at 1 ?Q?n Pennsylvania, on the _'?3 day of 1999, a ?? 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 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: ?? ?\G1f(?e A ?P Custody Conciliator Iq•? 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 1 f ] / ? 11 Q" p r? ._.. ?.• ?, ROBERT E. JACK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL DIVISION - CUSTODY TERRI L. JACK, :NO. 99 -453;(CIVIL TERM Defendant : IN CUSTODY You, Terri L. Jack, have been sued in Court to obtain custody of the children: Robert Mason Jack, Kayla Morgan Jack, and Kory Robert Jack. You are ordered to appear in person at at _.M., for ? --- a conciliation or mediation conference. ? a pretrial conference. ? a hearing before the court. If you fail to appear as provided by this order, an order for custody, partial visitation may be entered against you or the court may issue a warrant for your attest. custody or 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 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. BY THE COURT: on J. l ROBERT E. JACK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - CUSTODY :NO. gq_453a CIVILTERM TERRI L. JACK, Defendant : IN CUSTODY 1. Plaintiff is Robert E. Jack, an adult individual currently residing at 418 South Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania. 2. Defendant is Terri L. Jack, an adult individual currently residing at an undisclosed location in Michigan. The Defendant has resided with the Plaintiff at 418 South Baltimore Avenue, Mount Holly Springs, Cumberland County, Pennsylvania until June 5, 1999. 3. The Plaintiff is the natural Father of the children, Robert Mason Jack, bom May 12, 1990; and Kayla Morgan Jack and Kory Robert Jack who are twins bom on October 13, 1989. 4. The children were born in wedlock. 5. In the past five years, the children have resided with the following persons at the following addresses for the following lengths of time: NOME ADDRFSS DATE Terri L. Jack with other Michigan June 5, 1999 to present unknown persons Robert E. Jack 418 S. Baltimore Ave. 1993 to June 5, 1999 Terri L. Jack Mt. Holly Sprgs, PA 6. The natural mother of the children is Terri L. Jack, who resides as aforesaid. She is married. 7. The natural father of the children is Robert E. Jack, who resides as aforesaid. He is married. 8. The relationship of the Plaintiff to the children is that of natural Father. The Plaintiff currently resides alone. 9. The relationship of the Defendant to the children is that of natural Mother. Though not known to the Plaintiff, it is presumed that she is currently residing with her extended family in Michigan with the children. 10. Other than a Petition for Special Relief filed contemporaneously with this Complaint, the Plaintiff has no information of a custody proceeding concerning the children pending in any Court of this Commonwealth. IL . The best interest and permanent welfare of the children will be served by granting the relief requested because the Plaintiff is better suited to provide a stable environment to foster the children'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 tights with respect to the children. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order scheduling the Parties for a Custody Conciliation. Respectfully submitted, Dated: I7- c? l ?L ^ Thomas S. Dieh 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 complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsifications to authorities DATE: 7 0 - ROBERT E. JACI I hereby certify that a true copy of the foregoing Custody Complaint was served on the following person(s) in the following manner: POSTAGE PREPAID, CERTIFIED, RESTRICT DELIVERY, RETURN RECEIPT REQUESTED MAIL, & FIRST CLASS MAIL TERRI L. JACK C/O TUTTLE FAMILY 6278 E. RIVER ROAD TWIN LAKE, MI 49457-9748 TERRI L. JACK C/O MS. TUCKER 4913 PULLMAN AVENUE MUSKEGON, MI 49442 TERRI L. JACK C/O TIM TUTTLE 4833 PULLMAN AVENUE MUSKEGON, MI 49442 Dated: July 27, 1999 Attorney for Plaintiff/Petitioner 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 240-0833 (717) 249-2407 - FAX ?J F_ I- 0 d -:j- 0 -TI c I AU t 411t'II 01' -Thomas-S. Dichl -101 liar! Louder Strect. Suite 1113 Carlisle, f ctms} vmm1 17013 relsphnm 1717) 24001113 MX (711, 149--2107 JUL 2 7 1999jX ") ROBERT E. JACK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. 99-4532 CIVIL TERM TERRI L. JACK, Defendant CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this 26th day of August, 1999, upon consideration of Plaintiff's complaint for custody which involves a relocation on the part of the Defendant issue, and the Plaintiff and his counsel having failed to appear in court for a hearing on this date, and Defendant having not appeared, but Defendants counsel having appeared and having indicated concurrence with this order, the hearing on Plaintiff's custody complaint will be rescheduled at the convenience of the Defendant and her counsel on an emergency basis at such time as the hearing is requested. This order is without prejudice to the Defendant which might arise from the delay in scheduling the hearing because such delay was not the fault of the Defendant. Thomas S. Diehl, Esquire Counsel for Plaintiff Joan Carey, Esquire Counsel for Defendant By the Court, J. s ey e J 3 I-9 9 r? :srs ?) J f.I Ir^I 1 S: 1R ,_ AUG 2 7 1999 615 ROBERT E. JACK, Plaintiff v TERRI L. JACK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4532 CIVIL IN CUSTODY COURT ORDER AND NOW, this 3j day of August, 1999, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom No. 1 of the Cumberland County Courthouse on the,,'?I/, day of 1999, at? #PA'.M. at which time testimony will be taken in the above c e. cc: Joan Carey, Esq. Thomas S. Deihl, Esq. / L ,. J ROBERT E. JACK, Plaintiff TERRI L. JACK, Defendant Prior Judge: J. Wesley Oler, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : N0.99-4532 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: Robert Mason Jack, born May 12, 1991; Kayla Morgan Jack, bom October 13, 1989; and Kory Robert Jack, born October 13, 1989. 2. A Conciliation Conference was I,eW on August 20, 1999, with the following individuals in attendance: Attorney Joan Carey on behalf of the Mother, Terri L. Jack; and the Father, Robert E. Jack, with his counsel, Thomas S. Deihl, Esquire. 3. At the Conciliation Hearing, the Conciliator determined that the case required an expedited hearing because of the relocation issues. The parties were unable to reach an agreement. The Conciliator arranged for a hearing date on August 26, 1999. Attorney Deihl indicated to the Conciliator after the Conciliation that he was not available and that he would advise the court to this effect. A hearing needs to be scheduled to accommodate the court's time, the pressing circumstances of this case and the availability of the attorneys. ?fa4 g? DATE Custody Esquire ROBERT E. JACK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. 99-4532 CIVIL TERM TERRI L. JACK, Defendant IN CUSTODY TRANSCRIPT OF PROCEEDINGS IN RE: PETITION FOR SPECIAL RELIEF Proceedings held before the HONORABLE J. WESLEY OLER, JR., J. Cumberland County Courthouse, Carlisle, Pennsylvania on Thursday, August 12, 1999, at 9:00 a.m., in Courtroom No. 1 APPEARANCES: THOMAS S. DIEHL, Esquire Attorney for Plaintiff JOAN CAREY, Esquire Attorney for Defendant ?,rr nom! yS OZ 83566 ytidlG3???:tc???,?? i0 1 n FOR THE PLAINTIFF Robert E. Jack FOR THE DEFENDANT Terri L. Jack Derrick G. Bonham INDEX TO WITNESSES DIRECT CROSS REDIRECT 3 21 27 31 46 62 68 2 56 70 RECROSS 28 59, 61 r 1 THE COURT: This is the time and place for a 2 hearing on a Petition for Special Relief filed by the 3 Plaintiff, Robert E. Jack, alleging that the Defendant, Terri 4 L. Jack, moved to the state of Michigan without advising him 5 that she was going to be there permanently and took the 6 parties' two children with her. We will let the record 7 indicate that the Plaintiff is present in court with his 8 counsel, Thomas Diehl, Esquire, and the Defendant is present 9 with her counsel, Joan Carey, Esquire. Mr. Diehl? 10 MR. DIEHL: May it please the Court, Your 11 Honor, I would like to request whether the Court intends to 12 proceed with the parties' testimony or, given that it's a 13 Petition for Special Relief, have the counsel of the 14 respective parties present the facts? 15 THE COURT: I couldn't make findings of fact 16 based on the counsel's representations unless there was a 17 stipulation. 18 MR. DIEHL: Very well, Your Honor. The 19 Petitioner's first witness will be Robert Jack. 20 ROBERT E. JACK 21 having been duly sworn, testified as follows: 22 DIRECT EXAMINATION 23 BY MR. DIEHL: 24 Q Mr. Jack, please state your name and address 25 for the Court. 3 r? 1 A My name is Robert Jack. I live at 418 South 2 Baltimore Avenue, Mt. Holly Springs, Pennsylvania, 17065. 3 Q Could you briefly describe the events of 4 June the 5th of this year? 5 A About what happened? 6 Q Yes. 7 A She planned a trip to go to Michigan for two 8 weeks. 9 THE COURT: When you say she, who are you 10 referring to? 11 THE WITNESS: Terri Jack. 12 BY THE COURT: 13 Q Maybe I could get some background 14 information. What is your age? 15 A I'm forty-two. 16 Q Your date of birth? 17 A 6/28/57. 18 Q You are married, are you? 19 A Yes, sir. 20 Q What was the date of your marriage? 21 A May 28th, and it was twelve years ago. 22 Q Nineteen eighty-seven? 23 A Eighty-eight. 24 Q Were any children born of the marriage? 25 A Yes, sir. 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A Q A Q A Q A background. child. child? Mason Jack, Jr. 1 ,1-?-. What are their names? Cory Robert Jack. How do you spell Kory? K-o-r-y. Kory's date of birth? October the 13th, '89. The other child's name? Kayla Morgan Jack. How do you spell that? K-a-y-1-a. Kayla's date of birth is the same? The same as Kory's, October the 13th, '89. Do you know Ms. Jack's date of birth? 7/11/62. THE COURT: That's all I need by way of MS. CAREY: Your Honor, there's another THE COURT: Oh, I'm sorry. Is that your THE WITNESS: Yes, Robbie Mason Jack. THE COURT: How do you spell that? THE WITNESS: Well, it's Robert, Robert THE COURT: His date of birth? 5 1 THE WITNESS: May 12th, 1990 or 191. He's 2 like a year and a half younger. 3 THE COURT: Thank you. Now, Mr. Diehl? 4 BY MR. DIEHL: 5 Q Picking up where you left off. You 6 currently reside in Mt. Holly. How long have you resided in 7 Mt. Holly Springs? 8 A Six years. 9 Q Back to June 5th of this year. 10 A She planned a trip to go to Michigan to see 11 her parents, and I told her it was okay. So, she planned a 12 trip. She left. Before she left, you know, she gave me a 13 hug and a kiss and everything. I kind of like told her -- I 14 said, you're not coming back. And she goes, yes, I promise 15 I'll be back, and she was all happy and everything. Then she 16 sent me a -- June 28th, she sent me a birthday basket, a 17 fruit basket from, you know, a place where you get flowers 18 and stuff. But anyway, she sent me that. Then after that, Y' 19 she told me she wasn't coming back. It was just that quick. 20 Q You're getting a little ahead of me. After Y, 21 the two weeks had come and gone and she didn't return -- 22 A Oh, yeah. Her grandfather was sick, and she 23 said that she had to stay longer. I said that would be fine. 24 I was a little upset, but then I said, okay, go ahead. She ?i 25 needed some extra money, so I told her to take it out of our `'. <a 6 1 joint account. 2 Q Approximately what date did she finally tell 3 you that she was not returning? 4 A After my birthday. 5 Q When is your birthday? 6 A My birthday was June 28th. 7 Q Are you aware of anything that would lead 8 you to believe that she planned this all along? 9 A No, I didn't, not at all. 10 Q So, you fully expected her to return? 11 A Yeah, for a camping trip we were supposed to 12 go on for the whole family. We even had it reserved. 13 Q Upon her return? 14 A Yes, sir. 15 Q When you tried to contact her whereabouts in 16 Michigan, did you experience any difficulties? 17 A Yes, I did, from her sister at first. That 18 would be Sherr y Woodrum (phonetic). 19 Q How did you eventually acquire her address? 20 A Well, she had this address book I looked at. 21 The addresses were tore out of it, but the phone numbers were 22 all there. 23 Q So, she tore the pages of the address book 24 out before she left? 25 MS. CAREY: Objection. 7 1 THE WITNESS: Somebody did, because they 2 were tore. The addresses were tore out, and the phone 3 numbers were right there. That's how I got all the numbers, II 4 except for her mom's. She did leave me the number for her 5 mom. 6 BY MR. DIEHL: 7 Q So, you had the phone numbers but not the 8 addresses? 9 A Right. 10 THE COURT: I notice that there is a child 11 in the courtroom. Is that related to this case? 12 MS. CAREY: Yes, Your Honor. I'm sorry. 13 That is Derrick, Ms. Jack's oldest son. His name is 14 D-e-r-r-i-c-k Bonham, B-o-n-h-a-m. 15 THE COURT: That's unrelated to this action? 16 MS. CAREY: He's the stepson. Do you want 17 him to -- 18 THE COURT: It's up to the parties. 19 MR. DIEHL: Your Honor, I'd request that any 20 of the children, stepchildren or the children at issue, be 21 removed from the courtroom. 22 THE COURT: I won't remove them. But if 23 counsel can agree that it wouldn't be appropriate for 24 children to be hearing this, that's fine. 25 MS. CAREY: Your Honor, I'm in agreement 8 n 1 that he will not be here, but I would like to call him as a 2 witness. 3 THE COURT: All right. We'll let the record 4 indicate that Derrick has left the room for the time being. 5 Mr. Diehl? 6 MR. DIEHL: Thank you, Your Honor. 7 BY MR. DIEHL: 8 Q Since your wife, Terri, moved to Michigan, 9 how often have you had contact with the children? 10 A Twice. 11 Q What type of contact was that? 12 A Very short. 13 Q Was it in person, telephone? 14 A Telephone. 15 Q Approximately when were those telephone 16 calls? 17 A When? 18 Q Yeah. 19 A I can't remember when. It was before, you 20 know -- it was around the middle of June, you know, before my 21 birthday. 22 Q Did you speak with all three children? 23 A I spoke with two. 24 Q With two of the children? 25 A Right, Kayla, and I think it was Robbie, 9 1 because Kory was somewhere else. 2 Q How long was the telephone call? 3 A About five minutes. 4 Q Why was it so brief? 5 A Well, they were -- they had to go out. They 6 were going somewhere to go swimming or something. That's 7 what my daughter told me. 8 Q What other telephone contact have you had? 9 A It was like a week after that, my -- I 10 called out there and talked to my daughter, and that's when 11 she told me that mom was packing and unpacking, packing and 12 unpacking, and she don't know what she wants to do. 13 MS. CAREY: Objection, hearsay. 14 THE COURT: Mr. Diehl? 15 MR. DIEHL: I'll withdraw. 16 THE COURT: That answer is stricken as 17 hearsay. 18 BY MR. DIEHL: 19 Q Had Terri, your wife, indicated when she was 20 going to return from Michigan? 21 A Yes. 22 Q When was that? 23 A She was supposed to be back the day before 24 the 19th. The 19th was on a Sunday, I think. That was our 25 camping trip. 10 1 Q Let me rephrase. After it was apparent that 2 she was going to stay out there for an extended period of 3 time, when was she going to come back? 4 A As soon as she got done taking her 5 grandfather back and forth to the hospital and that 6 everything was going to be, you know, okay with him. 7 Q Didn't she eventually indicate that she was 8 not going to return? 9 A Yes, that was after my birthday. She says, 10 I'm not coming back no more. I'm not coming home. 11 Q Did she indicate when you were going to have 12 future contact with the children? 13 A No, she didn't. 14 Q What did she say? 15 A She told me -- she says -- I said, when are 16 you coming back? She goes, I'm not coming back. I can't 17 really -- I'm trying to think. I do know she told me she 18 wasn't coming back. Then I guess I went into shock, I guess, 19 you know, because I couldn't believe what she told me. 20 THE COURT: Did you ask her about the 21 children? 22 THE WITNESS: Yes, I did, about the 23 children. Yeah. I asked her -- I said, look what you're 24 doing to the kids now. I said, you know, you did this to me 25 before. Now you're doing it again. Then I told her about 11 1 her car, and she just slammed the phone down and clicked me 2 off, cut me right off. She just slammed the phone down, 3 because I told her I dropped the insurance on the car and I 4 wasn't going to pay for the car that's out there that I'm 5 paying on. She slammed the phone down, and that was the end 6 of the last conversation with her. 7 BY MR. DIEHL: g Q How many times did you try to call and 9 communicate with her? 10 A Numerous times. I got ahold of her sister. 11 That was after she told me she wasn't coming back. I called 12 her sister, and she told me to go -- 13 MS. CAREY: Objection, hearsay. It 14 calls for -- the question calls for hearsay. The sister is 15 not here. 16 THE COURT: The only thing he said was he 17 called her sister. 18 MR. DIEHL: The question was how many times 19 he contacted her and, if his contacts weren't successful, why 20 they weren't. Not what somebody else said. 21 THE WITNESS: I have about sixteen phone 22 calls or better out there, trying to find out what was going 23 on. 24 BY MR. DIEHL: 25 Q Which were unsuccessful? 12 1 A Yes. 2 Q Why were they unsuccessful? 3 A Because her sister wasn't going to let me 4 talk to her at first, and then -- 5 MS. CAREY: Objection, Your Honor. 6 THE COURT: As a result of the conversations 7 with her sister, what did you do? 8 THE WITNESS: With her sister. I was trying 9 to find out where she was, you know, and what's going on. 10 Give me some idea, you know, why she's not coming back. She 11 didn't give me no reason. The only thing she said was, in 12 the conversation, that she didn't -- she's tired of being 13 yelled at. I said, is that it? But, see, I called numerous 14 times. 15 BY MR. DIEHL: 16 Q Mr. Jack, is it accurate to say that you did 17 not receive cooperation when trying to contact the children? 18 A Right. 19 Q You mentioned that you have lived in Mt. 20 Holly for six years? 21 A Yes, sir. 22 Q Your children have always resided with you 23 at that time? 24 A Yes, sir. 25 Q How far away is that from the school? 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A About a mile. Q Is that the only school they've ever attended? A No. I think -- yes, that's the only school they went to. Q To your knowledge, what are the living conditions of the children in Michigan? MS. CAREY: Objection. There's no foundation for that. He's not been to Michigan. MR. DIEHL: Let me lay a foundation. BY MR. DIEHL: Q Have you ever been to Michigan? A Yes, sir, I have. Q When were you in Michigan? A I was there two years ago on vacation. We always go out every year for vacation. Q What family members did you visit? A I visit all of them. They were -- we stayed at her mom's house. Q Terri's mother's? A Yes. Q Now, go ahead and describe the conditions of the residence. A Well, they're into racing out there, and they have all the car parts, I mean, laying around in the 14 I0?) /'\ 1 driveway where the garage is. I mean, it's like -- they've 2 got old tires in the back, snowmobiles. It's just -- 3 it's just -- somebody's going to get hurt around there. 4 Q What about the residence of Terri's sister? 5 A Terri's sister, well, I think she moved to 6 another trailer since then, but I've been over to her 7 trailer, too, and -- 8 MS. CAREY: Then if she moved, I would 9 object that he has no knowledge as to what her residence is 10 like. 11 MR. DIEHL: I'll withdraw that question and 12 ask one other question about the residence. 13 THE COURT: All right. 14 BY MR. DIEHL: 15 Q To your knowledge, how many people reside at 16 that residence? 17 A Well, there had to be eight of them in 18 there. Her sister is divorced and has two children, but 19 they -- I think they come just on the weekends. I don't 20 know. I don't know about that. But anyway, I do know that 21 she has two and that -- then my three and Terri. And then 22 I'm sure Derrick stays there a lot, too, because she's there. 23 He hasn't been with me for a year and a half. 24 Q How many total people, then, approximately? 25 A About eight. 15 1 Q How many bedrooms are in the trailer? 2 A About two, I guess. 3 MS. CAREY: Objection. He doesn't know. 4 THE WITNESS: Well, I don't go in 5 everybody's bedroom. It's a two-bedroom trailer, I'm 6 assuming. 7 BY MR. DIEHL: 8 Q It's the same trailer that you've already 9 seen before, just a new location? 10 A Yes, sir. I've been in that trailer. 11 Q How are the children doing in school? 12 A Super. 13 Q How so? 14 A Sir? 15 Q How so? 16 A Well, they've gotten letters from the 17 teachers. I've got them. They won a -- 18 MS. CAREY: Objection. Again, I'm sorry I 19 have to object, but this is hearsay. 20 THE COURT: It's just a statement as to what 21 the teachers said. It's not being introduced for the truth 22 of whether they're wonderful students or not, but just what 23 the parents have been told. 24 MR. DIEHL: Right. 25 BY MR. DIEHL: 16 ., r.,, 1 Q Please continue. 2 A They're doing very well. I've gotten 3 letters from their teachers, and they won -- Kory and Kayla 4 this year won first and second -- Kayla won first place and 5 Kory won second in a drug essay program. 6 Q It was an essay contest? 7 A Yes, it was. Kayla came in first and Kory 8 came in second. 9 Q Are their grades otherwise good? 10 A Their grades are great. They've got good 11 comments on everything. 12 Q How long have they been good? 13 A They've always been good. 14 Q When does the school year start this year? 15 A August 30th. 16 Q When is the date of your pending 17 conciliation, pending custody conciliation? 18 A I don't understand. 19 Q The school year starts August 31st. When is 20 the date of your custody conciliation? Is it September 8th? 21 A Oh, September 8th, right. I'm sorry. 22 Q Having lived here for six years, I would 23 imagine they have friends? 24 A Yes, they do. 25 Q Have any of the friends contacted you? 17 I A Yes. They've all been -- they're always 2 coming to the house. The kids from Mt. Holly are always 3 coming to the house and asking about Kayla and Kory, if they 4 can come out and play, and when are they coming back from 5 their vacation. 6 Q What is your current work schedule? 7 A Right now, I work from 3:30 to 11:30 at 8 night, but I will be -- I've got another job. 9 Q Have you discussed that with your employer? 10 A Yes, sir, I have. 11 Q What hours are available to you? 12 A Seven to three. 13 Q Seven a.m. to three p.m.? 14 A Yes. 15 Q What time do the kids get home from school? 16 A 3:40. 17 Q What arrangements, if any, have you made 18 regarding the approximate forty minutes in which your 19 children would be home before you? 20 A I've got over ten people that's going to 21 help me. 22 Q Well, specifically -- 23 A My next-door neighbor said that she would 24 get them on th e bus and she would get them off the bus. And 25 the days she i sn't there, I have three other people that 18 n 1 would volunteer to come over and watch them till I get home. 2 Q What is your next-door neighbor's name? 3 A Jeanette Morris. 4 Q Has Jeanette ever baby-sat the children 5 before? 6 A Lots of times. 7 Q Does Jeanette have children of her own? 8 A She's got three of her own. 9 Q Do they go to the same school? 10 A They go to the same school. They're about 11 the same age a s our kids, except for the little one she's 12 got, the daugh ter. She's a little younger. 13 Q Has Jeanette ever put your children on the 14 bus before? 15 A Lots of times, yes. 16 Q Have you ever put Jeanette's children on the 17 bus before? 18 A Yes, we have. We alternate, help each other 19 out. 20 Q How long have you been doing that? 21 A Okay. They've been in school -- they'll be 22 in fourth. About three years. 23 Q Prior to today, are you aware of any 24 allegations of abuse on your part? 25 A No, sir. I'll break a cup now and then, but 19 1 ? /'\ 1 no physical contact, beating or nothing like that. I never 2 touched her. I don't believe in hitting women like that. 3 Q Ever any pushing and shoving in arguments? 4 A Maybe a push, but not no -- like that 5 (indicating). She would always stand in front of me when I'm 6 trying to get away from her. 7 Q Is Terri still welcome back in the house? 6 A Yes, she is. 9 Q Would you like to seek counseling? 10 A Yes, sir. 11 Q Have you ever sought counseling in the past? 12 A Yes, sir, I have. 13 Q How long ago? 14 A That was about -- the last time she left. 15 That was about eight years ago. 16 Q So, she has left in the past? 17 A Yes, sir. 1S Q Where did she go? 19 A Well, I took her -- we -- I couldn't keep up 20 with -- you know, I lost my job, and I couldn't keep up with 21 the rent, so I took her out to her aunt's until I got a job 22 and got a house or whatever to bring them back. 23 Q Did her aunt also live in Michigan? 24 A Yes, sir. 25 Q How long ago was that? 20 '`` n 1 A That was about eight years ago. 2 Q Then what happened? 3 A Well, when I came back and got a job and got 4 an apartment an d everything, she told me she wasn't coming 5 back. 6 Q But she eventually returned, obviously? 7 A Right. 8 Q When did she come back? 9 A About a year and a half later, a year, year 10 and a half. 11 MR. DIEHL: Nothing further, Your Honor. 12 THE COURT: Ms. Carey? 13 CROSS-EXAMINATION 14 BY MS. CAREY: 15 Q In terms of that counseling that you went 16 to, you stopped that counseling, correct? 17 A That's because they told me I didn't -- I 18 was wasting thei r time and my time, too. 19 Q Didn't they tell you that you should remove 20 yourself from the house because of the -- 21 A No, sir. 22 Q -- tension that was being created in the 23 house? 24 A No, sir. No. I've never been told that. 25 Q You didn't storm out of that counseling 21 1 session, the last one? 2 A When was this? 3 Q During the counseling that you all went to. 4 A That wasn't counseling. That was the 5 church. That was from church, that I left from there. 6 Q And you stormed out of the counseling? 7 A That wasn't counseling. 8 THE COURT: Wait. This is too hard on the 9 stenographer. You have to let Ms. Carey finish her question, 10 and then start your answer. 11 BY MS. CAREY: 12 Q So, you walked out on that counseling 13 session? 14 A It wasn't counseling. It was a church 15 group. It was from church. It was a church thing. It 16 wasn't counseling counseling. 17 Q It was held at Carlisle Area Counseling, 18 correct? 19 A No. I do not -- I don't recognition (sic) 20 anything like that. I haven't been there. 21 Q Myron Manasgarsky, the counselor, do you 22 remember him? 23 THE COURT: You'll have to spell that for 24 the stenographer. Myron, M-y-r-o-n? 25 MS. CAREY: M-y-r-o-n. 22 /'*11 1 THE COURT: Ms. Carey, how do you spell the 2 last name? 3 MS. CAREY: We are not absolutely certain, 4 but M-a-n-a-s-g-a-r-s-k-y. He was a counselor through -- 5 THE COURT: Well, you'll have to bring that 6 out through witnesses. 7 BY MS. CAREY: 8 Q Do you recall going to counseling with Myron 9 Manasgarsky, family counseling? 10 A How long ago was this? 11 Q Approximately four or five years ago. 12 A Where is the location where I walked out? 13 THE COURT: No, wait. The question was, do 14 you remember going to that counseling? 15 THE WITNESS: No, I don't. I do not 16 remember going to any counseling like that. 17 BY MS. CAREY: 18 Q So, the children went to school in Michigan 19 when you said that they left for approximately a year and a 20 half -- 21 A No, they didn't leave. 22 THE COURT: Wait, wait. You have to let Ms. 23 Carey finish the question. Now, we're really short on time. 24 MS. CAREY: I'll withdraw that question. 25 THE COURT: Okay. 23 n 1 BY MS. CAREY: 2 Q Now, you said that you had a conversation 3 with Ms. Jack regarding insurance. Is it true to say that 4 you dropped the insurance on her car? 5 A That's not her car. 6 Q But you did drop the insurance on the car; 7 you dropped the insurance on the car that she has? 8 A Yes. I told her that I was dropping the 9 insurance and that I was not paying for the car for her being 10 out there. 11 Q And she was concerned about that since -- is 12 it fair to say she was upset about that? 13 A She slammed the phone down. That was the 14 end of -- that 's the last time I talked to her. 15 Q You also told her everything you sent her -- 16 everything she sent you in the basket was stale and no good? 17 A No, I didn't say everything that was in the 18 basket. Only the cookies were stale. 19 Q So, the conversation was short, a short 20 conversation w ith her at that point, after your birthday? 21 A Yes, it was a -- yes, it was very short. I 22 tried to talk to her, but she slammed the phone down. 23 Q okay. She never refused you phone contact 24 with the children, correct? 25 A No, not her. Her sister. 24 1 Q But she never did? 2 A And her mother. 3 Q But she never did? 4 A Well, she was never around. 5 Q Did she ever refuse you? That was my 6 question. Did she ever refuse you phone contact with your 7 children? 8 A I'm trying to think. No, she didn't. 9 Q Okay. 10 A Could I say something about that now, about 11 the last quest ion? 12 Q I think you've answered the question. You 13 said that your youngest son is a junior. He really is not 14 junior, is n't that right? He's not a junior? 15 A Well, I am Robert Jack, and he's Kory -- I 16 mean he's Robe rt Jack, too. 17 Q But your middle names are different, so he's 18 really not a j unior? 19 A Well, okay. 20 Q You said that there was no violence. You 21 picked up a cup and threw it, maybe. Isn't it correct that 22 you threw obje cts periodically? 23 A Not objects, object. Only one object. 24 Q Hard enough to put holes in the walls? 25 A No. There's holes in the wall. No, I have 25 1 not put a hole in the wall. I put a hole in the door with my 2 foot. 3 Q That was kicking the door? 4 A Yes, and I replaced it. 5 Q You're saying that there's no other damage 6 in the house from you? 7 A Not from me. It was all from my kids. The 8 holes in the wall, they're from my kids. The screen's all 9 tore. But it's all fixed now. I fixed it. 10 Q So, you don't remember putting a hole in the 11 wall with a cup that you threw? 12 A Yes, the cup, but nobody was around when I 13 did that. Nobody was around. None of the family was around 14 when I put that cup into the -- because I spilled hot coffee. 15 I spilled hot coffee on me, and I went like that with the 16 cup. It wasn't throwing like that (indicating). It was 17 pitching it. 18 Q Okay. The job that you said you have 19 currently, where do you work? 20 A I work for Penske Truck Leasing. 21 Q That's the 3:30 to 11:30? 22 A Yes, ma'am, for right now. 23 Q So, you still have that job? 24 A Yes, ma'am, I sure do. 25 Q You are going to keep that job? 26 1-111 ,0?N 1 A Well, no. I'm going to get another -- I'm 2 getting a day j ob. I want to get off nights because I'm 3 never home. 4 Q So, you haven't gotten the day job yet? 5 A Yes, I have the day job. I just have to 6 wait for two weeks to get, you know -- 7 Q When do you start the day job? 8 A I could start Monday if I want to. 9 Q But when do you want to? 10 A Well, it depends on what goes today. it Q What's the day job? 12 A 7:00 to 3:30. 13 Q What company? 14 A It's D&D Automotive. 15 Q And you never worked with them before? 16 A No, ma'am. I also have an interview for 17 Friday for Truck Tech, too. I could go there and work there, 18 too. That's 7 to 3:30 there. I just want -- because I'm 19 never home. 20 MS. CAREY: I have no other questions. 21 THE COURT: Mr. Diehl? 22 MR. DIEHL: Yes, one brief follow-up. 23 REDIRECT EXAMINATION 24 BY MR. DIEHL: 25 Q Regarding telephone calls that you've made, 27 1 you had indicated that Terri had not denied you access to the 2 kids. How often did Terri pick up the phone? 3 A Never. It was always two days getting back 4 to me when I called out there. It was always like a day or 5 two days to get back to me when I wanted to talk to the kids. 6 Q Who answered the phone? 7 A Her sister. I talked to her sister and her 8 mother. 9 MR. DIEHL: I have nothing further, Your 10 Honor. 11 MS. CAREY: Just one question. 12 RECROSS -EXAMINATION 13 BY MS. CAREY: 14 Q You said that they did get back to you, but 15 in -- 16 A A couple of days or so, two or three days. 17 MS. CAREY: I have nothing else. 18 THE COURT: Mr. Diehl? 19 MR. DIEHL: I have nothing further for this 20 witness, Your Honor. 21 BY THE COURT: 22 Q One of the most troubling allegations you 23 make is that on July 20, 1999, the Petitioner had direct 24 telephone contact with the Respondent's mother, who stated 25 that the Petitioner would, quote, never find the children 28 n ? 1 ever again, end quote. Did that happen? 2 A Yes, sir. She told me that I would never 3 see the kids again or Terri and that I wouldn't find them. 4 Q What was the day that Ms. Jack left your 5 house? 6 A June 5th. 7 Q You said to her, you're not coming back, are 8 you? Why would you have said that if you didn't think 9 anything was wrong? 10 A It was only a joke, you know, because this 11 happened before. It was only a joke. But she gave me a big 12 hug and a kiss and told me, I promise I'll be back, honey. I 13 never thought about it. I never thought about that ever 14 again, you know, until -- it was a shock when she told me she 15 wasn't coming back. 16 Q What kind of a house do you live in? 17 A I live in a three-bedroom ranch, full 18 basement, an acre of land. 19 Q Who owns the house? 20 A Terri and I do. 21 THE COURT: Any further questions by 22 counsel? 23 BY MS. CAREY: 24 Q Isn't it correct that you told her you were 25 filing a divorce? 29 1 A No, ma'am, never. I didn't say I was ever 2 filing a divorce. Does it look like -- if I was going to 3 make a divorce, would I still be wearing my wedding ring? 4 Q I'm just asking if -- 5 A No, ma'am, I never said that. 6 Q And the conversation you had with her 7 mother, you were threatening her mother, correct? 8 A No, ma'am, I never threatened her mother. 9 Q You weren't threatening that you were going 10 to -- 11 A No. 12 Q -- file kidnapping charges? 13 A No, ma'am. 14 THE COURT: Let Ms. Carey finish her 15 question. What was the question? 16 BY MS. CAREY: 17 Q Isn't it correct that you were threatening 18 that you were going to file kidnapping charges? 19 A No, ma'am, I didn't threaten her mother at 20 all. 21 Q Her mother what? 22 A I did not threaten her mother at all, never. 23 I never would threaten her mother. 24 Q Okay. Thank you. Did you tell her mother 25 that you were going to have her arrested? 30 n I A No. I said if she don't bring my children 2 back she might be arrested. That's what I said. I have that 3 on tape. 4 MS. CAREY: Nothing further. 5 THE COURT: Mr. Diehl? 6 MR. DIEHL: Nothing further, Your Honor. 7 THE COURT: You may step down. Thank you. 8 Mr. Diehl? 9 MR. DIEHL: Mr. Jack is our only witness to 10 present today. 11 THE COURT: Ms. Carey? 12 MS. CAREY: I call Terri Jack. 13 TERRI L. JACK 14 having been duly sworn, testified as follows: 15 DIRECT EXAMINATION 16 BY MS. CAREY: 17 Q State your name for the record, please. 18 A Terri Jack. 19 Q You are married to Robert Jack? 20 A Yes, I am. 21 Q How long have you been married? 22 A Eleven years. 23 Q You were in the courtroom when he testified, 24 correct? 25 A Um-hum. 31 1 Q You have the three children that he told the 2 Court? 3 A Yes. 4 Q And their birthdays were accurate? 5 A Robbie is 191. I believe that -- I'm not 6 sure if -- 7 Q He said 190 or 191. Robbie was born 8 5/12/91? 9 A Yes. 10 Q Where did you reside when you were here in 11 Carlisle? 12 A With my husband and my children at 418 South 13 Baltimore. 14 Q Was it your three children or all four of 15 your children? 16 A Just the three children lived with me at 17 that time, with us. 18 Q Where was Derrick living? 19 A In Michigan. 20 Q Why did Derrick go to live in Michigan? 21 A Derrick had a lot of problems, and his 22 relationship wit h Bob wasn't great. 23 Q In terms of his relationship with Bob, why 24 wasn't it great? What was happening? 25 A Bob was mean to Derrick, and he screamed and 32 1 hollered at Derrick a lot. There was a lot of tension and 2 strife. 3 Q So, you decided that he should go with his 4 father? 5 A Yeah. Derrick was having a really hard 6 time, especial ly in school, and he didn't get along well with 7 Bob, and I let him go to live with his father in Michigan. 8 Q Directing your attention to this summer, 9 June, approximately June 5th, did you take the children to 10 Michigan? 11 A Yes, I did. 12 Q Would you tell the Court the circumstances 13 of that? Why did you do that? 14 A I went to visit my family. I only got to 15 see them once a year. So, this year I took the kids by 16 myself so that we could go for two weeks instead of just one. 17 Q Was it your intention to come back? 18 A Yes. 19 Q Then what happened when you got out there? 20 A When I got out there, my grandfather became 21 ill, and they found out that he had cancer and that he -- 22 they gave him less than six months to live. 23 Q Did you contact your husband and talk to him 24 about that? 25 A Yes, I did. 33 1 Q What happened? Did he agree that you stay? 2 A Yes, he agreed. I asked him if it was okay 3 if I stayed a little longer to help. He had to go to the 4 hospital every day for radiation and -- 5 Q You were helping in that? 6 A Yes, and just to be with my grandma. She 7 was having a hard time. 8 Q Then what happened? How long did you stay, 9 I guess I should say? How long was your grandfather needing 10 your help, and how long did you stay to help him? 11 A It was a couple more weeks, I guess, that he 12 had the radiation every day. 13 Q Now, your husband's birthday came. Did you 14 send him something for his birthday? 15 A Yeah. I ordered him a basket of goodies for 16 his birthday, had it delivered to the house. 17 Q Did he respond when he received it? 18 A Yeah. He had called me, I believe it was 19 the next day -- I'm not real sure -- and he told me that it 20 was -- that he had to throw the whole thing away, that it 21 wasn't any good, that it was all stale. 22 Q How did you feel? 23 A Well, just -- it felt -- it just brought a 24 lot of things back, a lot of memories, the way things were 25 before I left, and that it just -- when I was in Michigan, it 34 n ? 1 was -- it just felt so good to be away from the strife and 2 someone screaming and hollering at me all the time and never 3 being able to be good enough. The phone call just -- it just 4 made me realize that -- just the way things are. 5 Q So, at that point, you were considering the 6 possibility of staying there? 7 A Yes. At that point, I -- it just -- I just 8 didn't want to come back. 9 Q Now, let me direct your attention to, let's 10 say, the last several months, being here in Carlisle at the 11 marital residence with the children and your husband. You 12 talked about strife. What kinds of things occurred that 13 caused you to experience strife? 14 A There was always strife. That's all it was. 15 Q What did he do? 16 A I never did anything right. 17 Q Did you do things the way -- 18 A I tried. I always tried, but it was never 19 good enough. That's all he did was holler and complain and 20 tell me how worthless and how stupid I was. 21 Q Did he do this in front of the children? 22 A Yes. 23 Q How did he treat the children? Was it the 24 same yelling with the children? 25 A Yeah, grouchy and complaining. 35 r-'IN 1 Q Was there any physical violence to you? 2 A Yes. 3 Q What did he do? 4 A Well, a couple of months ago, he was in the 5 basement throwing my stuff around, and I had gone down to the 6 basement to find out what was going on, and he threw a 7 ceramic vase at me and hit my hand. 8 Q What happened to your hand? 9 A It -- the knuckle and my middle finger was 10 all swelled up. I thought that my finger was broken. 11 Q Had there been any other violence that he 12 perpetrated upon you? 13 A Yes. 14 Q What else did he do? 15 A Well, the -- he pushed me. 16 Q Where would he push you on your body? 17 A Just pushed me. He pushed me against the 18 stove one time a nd bruised my back. 19 Q Was there other pushing periodically? 20 A Yeah. 21 Q When he was pushing you, how did he appear? 22 A Enraged. 23 Q Was there any other violence in the past? 24 Let me rephrase that. He testified that you went to 25 counseling. 36 e?s I A Yes. 2 Q When did you go to counseling? 3 A It was about four or five years ago. 4 Derrick was having a hard time in school, and the counselor 5 suggested that we go to family counseling, that all of us get 6 counseling. 7 Q Who was that with? 8 A Myron Manasgarsky. 9 Q What happened? Did that counseling -- 10 besides helping Derrick with school, was there supposed to be 11 benefit to the whole family? 12 A Yes. 13 Q What happened at the counseling? 14 A The counselor suggested that it was my 15 responsibility to provide my children with a safe and secure 16 environment and that he felt with Bob in the home that that 17 wasn't the case, so his recommendation was that Bob leave the 18 home. 19 Q What was Bob's response? 20 A Bob was furious, and he flew out of the 21 counselor's office. 22 Q Were the children there for this? 23 A Yes. 24 Q So, you went back and tried to work it out 25 without the counseling after that? 37 1 A Yes. 2 Q Did you ever file for protection? 3 A No. 4 Q Why was that? 5 A Well, I was told by one of the counselors at 6 one point that it was better if -- it was better for me if I 7 didn't try to get one and not attain one, that that wouldn't 8 be good. 9 Q Were you afraid of him? 10 A Yes. 11 Q What did you do in order to make sure the 12 violence stayed at a minimum? 13 A I did my best to make everything perfect for 14 him. 15 Q What was his response? 16 A It never was. 17 Q Now, he testified that when you left you 18 were smiling and you hugged him and you kissed him and said 19 goodbye. Is that true? 20 A Yes. 21 Q Was it your intention to come back? 22 A Yes. 23 Q At this point, do you feel it's best for you 24 and the children to come back here? 25 A No. 38 1 Q Why? 2 A Because if -- when I did everything perfect 3 and he could still tell me something like, if you don't 4 straighten up I'm going to put a bullet through your head, 5 then what -- then definitely not pleasing him at this point. 6 Q When did he threaten to put a bullet in your 7 head? 8 A It was about two or three weeks before we 9 left for Michigan. 10 Q Does he have guns, to the best of your 11 knowledge? 12 A Yes. 13 Q When you went out to Michigan -- do you have 14 family there? 15 A Yes. 16 Q Who is there in your family? 17 A My whole family is there, my parents and my 18 grandparents and my sisters and my brother and my cousins and 19 my aunts and uncles. 20 Q So, in terms of the family support, you have 21 a good relationship and the children have a good relationship 22 with that whole family? 23 A Yes. 24 Q Did the children see them while you were 25 there for the summer? 39 1 A Yes. 2 Q Did your son, Derrick, move in with you as 3 soon as you went out there? 4 A Yes. 5 Q In terms of housing, when you were visiting, 6 who did you stay with? 7 A Well, initially, I was at my parents' house. 8 Q How big is their house? 9 A I believe it's four bedrooms. 10 Q Then where did you go? 11 A Then I went to my sister's for a while. 12 Q How big was that? 13 A It's a two-bedroom trailer. 14 Q How did you work the sleeping there? 15 A Sherry, my sister, had her bedroom, and the 16 two boys -- the two older boys shared a bedroom, and my -- 17 the three little ones and I slept in the living room. 18 Q Did you make it so it was comfortable for 19 them in the livi ng room? 20 A Sure. Yes. u 21 Q Now, you are asking the Court to let you 22 maintain primary custody and move to Michigan, correct? ' f 23 A Yes. . 24 Q What housing have you looked into or have "rp ,r 25 you secured for the children? 40 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I have a three-bedroom trailer. Q Did you purchase that trailer? A Yes. Q When did you do that? A The day before I left to come out here. Q So, just recently? A Yes. Q You're planning to move into that with your children? A Yes. Q Is there schooling that they can attend there? A Yes. Q Have you looked into that? A Yes. I already went in and talked -- the 18th is registration for their school. Q When do they start school? A The 30th. Q Did you ever refuse to let the children have contact with their father? A No. No, I did not. Q To the best of your knowledge, when he called out there, did the children find out and then they called him, or how did that work? A No. We -- we called him. Mostly when Bob 41 1 called out there, he didn't ask to talk to the children. He 2 called to tell me what he was going to do. 3 Q What did he tell you he was going to do? 4 A He told me that he had already filed for 5 divorce and that he was going to take the kids away from me. 6 Q What about your car? What did he do, if 7 anything, to your car? 8 A Well, he told my son that he had the car 9 refinanced, that he had the title put in his name and 10 reported it as stolen. 11 Q Whose name was it titled in? 12 A It was in my name. 13 Q Did he remove the insurance or cancel the 14 insurance? 15 A Yes, he canceled the insurance. 16 Q So, what did you do? 17 A I went and got my own insurance. 18 Q In terms of the children, you talked about a 19 lot of violence that occurred in the residence. Were the 20 children there for much of that? 21 A Sometimes. 22 Q What is their attitude toward their father? 23 A Well, he's their father. I'm sure that they 24 love him. And they miss him, I'm sure. 25 Q Do you have any concerns regarding him being 42 1 violent to them? 2 A I don't think he would hurt the kids, not 3 physically, an yway. 4 Q You have concern about emotionally? 5 A Yes. 6 Q If there were no emotional abuse, do you 7 have a problem with him having regular contact with the 8 children? 9 A No, I don't. 10 Q Do you have the children with you now? 11 A Yes. Well, I don't have them here with me. 12 Q Excuse me, in town? 13 A Yes. 14 Q What would you propose? What would you ask 15 the Court to do? 16 A I don't mind leaving the kids for a visit 17 for two weeks, and then I could come back out and get the 18 kids. That would be like about five days before they start 19 school. That would give them time to get settled and ready 20 for school. 21 Q You want to maintain primary custody? 22 A Yes. 23 Q Who has been the primary caretaker of the 24 children? 25 A I have. 43 1 Q Who went to the school meetings? 2 A I did. 3 Q Who took them to doctors? 4 A I did. 5 Q Who put them on the bus and got them ready 6 for school? 7 A Well, usually I did.. 8 Q Did you work at all? 9 A Yes. 10 Q When did you work, I mean what hours during 11 the day; while they were in school or -- 12 A While they were in school. 13 Q Who took care of the children when you 14 worked? 15 A They were in school. When they weren't in 16 school, I took them with me. 17 Q Was it a part-time job? 18 A Yeah. 19 Q Did he ever baby-sit for them or care for 20 them while you were at work on a regular basis? 21 A No. once in a while. 22 Q You are asking the Court that you have 23 primary custody of the children. In terms of his contact 24 with the children, would it be acceptable to you if he had 25 time if they have a Christmas break or a spring break? 44 1-1\ n 1 A Of course. 2 Q And time in the summer? 3 A Of course. 4 Q Oh, do you have employment? 5 A Yes. 6 Q What hours would you work? 7 A From nine to about quarter to three. 8 Q Would you be able to get the children ready 9 for school and pick them up? 10 A Yes. 11 Q Is that a Monday-to-Friday job? 12 A Yes. 13 Q Doing what? 14 A Waitress. 15 Q Would you be able to pay for the lot rent 16 for your trailer? 17 A Yes. 18 Q Basically, do you think life will be 19 substantially i mproved for you and your family if you move to 20 Michigan? 21 A Yes, I do. 22 Q How far is it from here to Michigan in the 23 car driving? 24 A It's twelve hours it takes. 25 Q Would you ask the Court to have the 45 1 transportation for the transfer of custody shared? 2 A Yes. 3 Q Do you know his income? 4 A He makes approximately $525.00 a week. 5 Q He said that he was never home. Is that 6 pretty accurate? 7 A Yes. 8 Q So, you provided for the children? 9 A Yes. 10 Q What's your income going to be? 11 A Approximately $175.00 a week. 12 Q But you would still be willing to try to 13 share transportation? 14 A Yes. 15 MS. CAREY: I have nothing else at this 16 point. 17 THE COURT: Mr. Diehl? 18 CROSS-EXAMINATION 19 BY MR. DIEHL: 20 Q Mrs. Jack, prior to your leaving June 5th, 21 is it accurate that you displayed affection with Mr. Jack, 22 hugs, kisses and the like? 23 A Yes. 24 Q You also indicated that you sent him a fruit 25 basket from Michigan? 46 1 A Yes. 2 Q You also mailed him a Father's Day card? 3 A I don't believe I did, no. 4 Q So, he had no indication at that time 5 whatsoever that you were not going to return? 6 A No. Bob never believed that there were any 7 problems. Everything was fine. 8 Q Your testimony was approximately two weeks 9 before you left he threatened to put a bullet in your head? 10 A Yes, he did. 11 Q Prior to today, have you ever shared those 12 accusations with any authorities? 13 A No. 14 Q In fact, you never sought out a PFA for any 15 of the allegations you made today? 16 A No. 17 Q I believe the rationale you gave was that 18 you were advised not to do so by a counselor, is that 19 correct? 20 A The counselor had told me -- this was 21 several years ago -- that it was better for me if I didn't 22 try to get one and be denied. 23 Q That was the same counselor who was 24 approximately four to five years ago, from your testimony? 25 A No. 47 1 Q Which counselor was that? 2 A I honestly don't remember. 3 Q But you said it was several years ago? 4 A Yes. 5 Q To your knowledge, has Mr. Jack ever been 6 convicted of any crimes? 7 A Yes. 8 Q What were they? 9 A I know that he was -- I'm not sure if there 10 was a conviction , but I know he was arrested for marijuana in 11 Florida. 12 Q How long ago was that? 13 A I'm not sure how long ago. 14 Q Years ago? 15 A Yes. And I know that he, according to what 16 he told me, spen t six years in prison in Michigan. 17 Q The marijuana charge, is that while he was a 18 teenager? 19 A No. It was -- I think it was shortly before 20 I met him. 21 Q Has he ever been charged with any crimes of 22 violence? 23 A No. 24 Q Was his testimony correct that the kids are 25 currently doing well in school? 48 1 A Yes. 2 Q They have recently won awards? 3 A Yes. 4 Q Academic awards? 5 A I'm not sure what awards they actually won. 6 They were sent in the mail. 7 Q So, they won awards, but you don't know what 8 they were? 9 A Right. They were sent in the mail. Bob had 10 told me over the phone that he received some things in the 11 mail. 12 Q Did you read what was sent in the mail? 13 A I didn't have the opportunity to do that 14 yet, no. 15 Q When did they receive the awards? 16 A Apparently they came in the mail while we 17 were in Michigan. 18 Q You mentioned that your biological son, Mr. 19 Jack's stepson, Derrick -- who is currently what age? 20 A Fifteen. 21 Q -- approximately a year and a half ago 22 started living in Michigan? 23 A Yes, with his father. 24 Q Was he having trouble in school, 25 specifically discplinary problems in school, prior to going 49 M. 1 back to Michigan? 2 A Before he -- oh, yes. Yes. 3 Q Since relocating in Michigan, has he also 4 gotten in trouble with the law? 5 A Yes. 6 Q So, his problems actually continued in 7 Michigan? 8 A Yes, they did. 9 Q They have actually gotten worse in Michigan? 10 A Well, I don't know if I would consider it 11 worse. 12 Q But he has gotten in trouble with the law? 13 A Yeah, he has gotten in trouble in Michigan. 14 Q Did you regularly answer the phone when Mr. 15 Jack tried to call you in Michigan? 16 A Not normally I didn't answer the phone. I 17 didn't answer the phone at my sister's house or at my 18 parents' usually. My mother answers it. 19 Q So, you wouldn't know if your mother or any 20 other members of your family was denying him contact with the 21 children? 22 A They wouldn't do that without -- 23 Q You have no knowledge of that? 24 A No. 25 Q why didn't you answer the phone? 50 1-11 n 1 A Well, it wasn't my house. 2 Q Did you know Mr. Jack was trying to call? 3 A Excuse me? 4 Q Did you know Mr. Jack was trying to call and 5 contact you? 6 A Well, he called, yes. I don't understand. 7 Q Were you avoiding his telephone contact? 8 A No, not until after he started calling out 9 there making threats. 10 Q I think you testified that the threats were 11 regarding the return of the children, correct? 12 A No. The threats were -- the first time it 13 was, if you don't come home, I'm going to take the children 14 away from you, that he needed a family. 15 Q You are claiming that he threatened to do 16 that, but you actually did do that, in other words, remove 17 the children from him? 18 A It was after -- when I had told Bob that I 19 didn't want to come home, that was when he told me if I 20 didn't he was going to take the kids away from me. 21 Q Did you discuss any of these problems with 22 Mr. Jack before leaving for Michigan? 23 A I have tried. We have tried counseling. We 24 have tried -- I have tried to talk to him, but every -- we 25 never made any progress. 51 ,,N 10"? 1 Q Just for clarification, you did not talk to 2 Mr. Jack directly about relocating to Michigan, correct? 3 A Oh, no. I didn't -- when I left for 4 Michigan, I left for vacation. It wasn't my intent to stay 5 there. 6 Q Did you remove the pages from the address 7 book before leaving for Michigan? 8 A I have no idea what Mr. Jack is talking 9 about. 10 Q Did he have your mailing address in 11 Michigan? 12 A Did I have a mailing address? 13 Q Did he have your mailing address in 14 Michigan? 15 A I really don't know. I'm sure that -- I 16 have phone numbers and addresses all over the house, but 1 17 have no idea what Mr. Jack is talking about, pages torn out 18 of anything. 19 Q Is it correct you said you purchased a 20 mobile home the day prior to returning to Pennsylvania? 21 A Yes. 22 Q What day was that? 23 A It was the day or two before I came back 24 here, yes. 25 Q When did you return back here? 52 I A Yesterday. Well, actually it was -- 2 yesterday was Thursday. It was Thursday morning that I got 3 in, early Thursday morning. 4 Q So you purchased it this week? 5 A Yes. 6 Q Have the kids even seen it? 7 A Yes. 8 Q You indicated you were employed while living 9 in Mt. Holly? 10 A I helped a friend out, yeah, at her -- 11 Q The business was called Vetter's? 12 THE COURT: Called what? 13 MR. DIEHL: Vetter's. 14 THE COURT: Vetter's, V-e-t-t-a-r-s? 15 THE WITNESS: F-e-t-t-a-r-s. 16 THE COURT: F-e-t-t-e-r-s. 17 MR. DIEHL: I'm sorry. 18 THE WITNESS: She had a business. 19 BY MR. DIEHL: 20 Q What type of business was that? 21 A It was fruit and produce and flowers and 22 gifts, that kind of thing. 23 Q Was it uncommon for you to work there from 24 9:00 in the morning till 9:00, 9:30 p.m.? 25 A Not normally. Just before I left for 53 1 vacation, I had increased hours so that I could earn a little 2 extra money. She needed extra help. 3 Q You would have, in fact, worked well beyond 4 the children's school hours? 5 A Well, I would normally leave and go pick the 6 kids up, and we would come back if I needed to. 7 Q You would work, then, from -- you would work 8 until 9:00 or 9:30 p.m., correct? 9 A I don't think so, as far as I recall. 10 Q How late would you work? 11 A It seems to me like they closed at six. 12 Well, I guess later in the -- closer to the time that I left, 13 I think she did start staying open until eight. 14 Q Till eight? 15 A Yeah. 16 Q So, you never worked until nine? 17 A I'm not saying I never worked until 9:00. 18 That just wasn't a nornial thing. 19 Q Did you work Monday through Friday? 20 A Sometimes. 21 Q Sometimes weekends, as well? 22 A Um-hum, sometimes. 23 Q In fact, did you work full time regularly? 24 A Not regularly. Like I said, it had 25 increased before I had went on vacation. She was short of 54 -, 1 help, and I needed the extra money for vacation. 2 Q You said you have a waitressing job in 3 Michigan? 4 A Yes. 5 Q When did you acquire that job? 6 A Well, my sister had -- they had had an 7 opening for someone to help them out every once in a while, 8 and I had started that a couple of weeks after I had got out 9 there. I worked a couple of days to help her out. 10 Q Was that before you told Mr. Jack that you 11 weren't returning? 12 A Yes. Bob knew that. I was going to help 13 Sherry out at the restaurant for some extra money while I was 14 out there. It wasn't a full-time job. I was just -- I just 15 helped out. 16 Q Since you have been in Michigan since early 17 June, have you resided primarily with your mother? 18 A No. I guess I have been at my sister's a 19 little longer than my mother's. 20 Q Have you lived at each of those residences? 21 A I stayed with my parents at first, yes, and 22 then I had went in to my sister's. 23 Q Have you stayed anywhere else? 24 A No. 25 Q Did you inform Mr. Jack when you were 55 -, r 1 staying at your parents' and when you were staying at your 2 sister's? 3 A Yes. I told him that I was going to 4 Sherry's house. 5 Q To live? 6 A Well, at the time, I was just going in there 7 to visit my sister. 9 Q So, you never told Mr. Jack where you were 9 living? 10 A He knew where I was, yes. 11 Q How did he know if you didn't tell him? 12 A He called me there at that phone number. 13 I'm assuming he knew that's where I was. 14 Q He called several times at both residences, 15 correct? 16 A Yes. 17 MR. DIEHL: Nothing further, Your Honor. 18 THE COURT: Ms. Carev? 19 REDIRECT EXAMINATION 20 BY MS. CAREY: 21 Q After his phone calls to -- let's say to 22 your mother, was there ever any indication to you that your 23 mother had been upset by his phone call? 24 A Yes. 25 Q What did you see? 56 1 A Well, one day when I was at work, he had 2 called my mother, and he told my mother that he was going to 3 have me arrested for kidnapping, and he made several 4 accusations. I'm not sure if I could quote them quite, but, 5 yes, she was very upset after she had -- when Bob was 6 finished talking. 7 Q Was it ever your intention to keep the 8 children from him? 9 A No. 10 Q You told him what you were doing, where you 11 were going? 12 A Yes. 13 Q In the past, you had stayed in Michigan with 14 the children for a year, isn't that correct? 15 A Yes. 16 Q That was approximately how long ago? 17 A It was about approximately eight years ago. 18 Q Then you came back and tried to make good of 19 it again for eight years? 20 A Yes. 21 Q Did you ever put the children in any danger 22 with the condition of any of the houses that you were staying 23 at, your relatives' houses? 24 A No. 25 Q How about your parents' house, is there a 57 1-1) r-, 1 danger there, as he testified to? 2 A No. The kids -- no. There are race cars 3 there, but they are -- it's not anything different than they 4 have at the home, at our home. My husband is a mechanic. 5 Q So, there is stuff around your home? 6 A It's not anything that would endanger my 7 children. 8 Q Does your mother have a swimming area for 9 the children? 10 A Yes. 11 Q A swimming pool? 12 A Yes, she does. 13 Q Is Derrick doing well at this point, in 14 terms of school and his life in general? 15 A Life in general is better, yes. School 16 however, his grades aren't very good. 17 Q Do you feel it's in the best interest that 18 he stays with you at this point? 19 A Yes, definitely. 20 Q You said he came with you when you went out 21 there. Did you consider bringing him back here with you? 22 A That was part of the reason I went to 23 Michigan, was to get Derrick and to bring him back home. 24 Then I had to consider if that was the best thing for Derrick 25 or not, if I could put him back into that situation. 58 I Q When he was in the situation before, had he 2 threatened to run away? 3 A All the time. All the time. He would get 4 so angry at Bob. 5 Q So, part of your reason for wanting to stay 6 in Michigan is to have Derrick with you? 7 A Certainly, yes. e Q Does he have a good relationship with his 9 brothers and sisters? 10 A Yes. 11 MS. CAREY: Nothing else. 12 THE COURT: Mr. Diehl? 13 RECROSS-EXAMINATION 14 BY MR. DIEHL: 15 Q Mrs. Jack, you indicated just now that part 16 of the reason that you were going to Michigan was to bring 17 Derrick back to Mt. Holly? is A Yes. 19 Q This is back to the same environment you 20 were claiming was violent? 21 A Right. But it was a consideration. It was 22 a choice, a decision that I had to make, whether that would 23 be good for Derrick or not. 24 Q Because he's not doing well in Michigan? 25 A Right. He's doing well now. Derrick has 59 1 been through a lot of things. 2 Q You mentioned that, in your estimation, the 3 residence of your parents' is safe. It does have disabled 4 vehicles about it, though, correct? 5 A Pardon? 6 Q There are disabled vehicles around your 7 parents' home, junk cars? 8 A There might be a few. There's race cars. 9 They race. My sister and my brother race. Their race cars 10 are there. They are not parked in the front yard or 11 anything. There's a place where they belong. 12 MR. DIEHL: Nothing further, Your Honor. 13 THE COURT: Ms. Carey? 14 MS. CAREY: I have nothing further. 15 BY THE COURT: 16 Q Did you file a complaint for custody in 17 Michigan? 18 A No, I did not. 19 Q Did you tell Mr. Jack that you were going to 20 be bringing Derrick back when you left? 21 A Yes. 22 Q How are you able to support yourself and 23 buy a trailer and so on in Michigan? 24 A Well, I have -- really, it's a miracle, but 25 I have a job now. It's not making a lot of money, but it's a 60 I start. And the trailer, I'm going to make payments on the 2 trailer as part of the lot rent. The trailer is owned by the 3 people who own the trailer park. 4 Q So, you haven't paid -- or are you renting 5 the trailer there? 6 A But I will own it, yes. 7 Q There is no down payment required? 8 A No. I'm going to help clean it up. 9 THE COURT: Any other questions by counsel? 10 If not, you may step down. 11 MS. CAREY: One other question. 12 REDIRECT EXAMINATION 13 BY MS. CAREY: 14 Q During the next two weeks that the children 15 stay here with dad, was it your intention to go back to 16 Michigan and work on the trailer? 17 A Yes, definitely, get it ready. 18 Q Do you have arrangements made to get 19 electricity turned on? 20 A Yes, the electricity will be turned on 21 tomorrow. 22 Q Then you are going to make sure that it's 23 ready for the family when they come? 24 A Absolutely. 25 Q One other thing, just for the record. Since 61 I you left to visit, you didn't take things with you. Are you 2 asking that you can get back in the house and get some of 3 your belongings, your clothing and things? 4 A Yes. 5 Q Did he change the locks, to the best of your 6 knowledge? 7 A It was -- someone told me that, yes, he 8 changed the lock s. 9 MS. CAREY: Nothing else. 10 THE COURT: Mr. Diehl? 11 MR. DIEHL: I have nothing further. 12 THE COURT: You may step down. Thank you. 13 MS. CAREY: Your Honor, I'm going to get the 14 fifteen-year-old. 15 THE COURT: All right. 16 DERRICK GARNER BONHAM 17 having been duly sworn, testified as follows: 18 DIRECT EXAMINATION 19 BY MS. CAREY: 20 Q State your name for the record, please. 21 A Derrick Garner Bonham. 22 Q Spell your last name. 23 A B-o-n-h-a-m. 24 Q You currently reside with your mom? 25 A Yes. 4 t ?r 62 1 Q Have you been with her since June? 2 A Yes. 3 Q Prior to that, who did you live with? 4 A My father. 5 Q Your natural father? 6 A Yes. 7 Q Approximately how long have you been in 8 Michigan? 9 A Almost two years. In March it will be. 10 Q In March it will be two years. So, about 11 one and a half now? 12 A Yeah. 13 Q Prior to that, did you live with your 14 stepfather, Robert Jack, and your mom, Terri Jack? 15 A Yes. 16 Q Would you tell the Court why you left and 17 went to live with your natural father? 18 A Things were hard. It was a lot of 19 frustration. It was a lot of arguing going on. 20 Q Who was doing the arguing? 21 A Mostly Bob, and it was just hard to live 22 with. 23 Q Did you see any violence to your mom? 24 A Just mostly mental violence. 25 Q What did you see? What kind of -- was it 63 ? n 1 stressful to the family? 2 A Oh, yeah. 3 Q What did you see? 4 A Screaming, name calling. 5 Q How did he appear when he was screaming and 6 name calling? 7 A Very angry. 8 Q Were you in the middle of that? 9 A Most of the time, yes. 10 Q How did it affect you? 11 A I don't know. It just made me feel 12 uncomfortable and uneasy a little bit. 13 Q Did you ever say you were going to leave? 14 A Yeah. 15 Q Did it spill over into school? 16 A Oh, yeah. 17 Q What happened in school? 18 A I got into a lot of fights in school. I got 19 fined for one of them. 20 Q Did you see any throwing of things or any 21 pushing or shoving, anything like that? 22 A Yeah. 23 Q What did you see? 24 A I seen a lot of -- well, not a lot of 25 pushing, but I seen pushing. 64 ? n 1 Q Who pushed whom? 2 A Bob pushed my mom. I've seen that. 3 Q How did your mom appear? 4 A I don't know. She was just upset. 5 Q Were your brothers and sisters there for 6 these encounters? 7 A They were sleeping at the time. 8 Q Were they there for the screaming and 9 yelling, to the best of your knowledge? 10 A Yeah. 11 Q How did it affect them? 12 A I don't know. They would always ask me 13 what's going on. I would just tell them, I don't know. 14 Q Did they hear things? 15 A Oh, yeah. 16 Q They would come to you? 17 A Um-hum. 18 Q Now, when your mom and dad made an 19 arrangement that you would go out there to Michigan, 20 initially, when you first went out, did you get into some 21 trouble? 22 A Yes. 23 Q What was the trouble? 24 A I got in trouble for driving without a 25 license and failure to report an accident. 65 ? r-?, 1 Q Is that a misdemeanor? 2 A Yeah. 3 Q Is that off your record? 4 A Completely. 5 Q That was when you were in eighth grade, 6 right? 7 A Ninth, the beginning of my ninth year. 8 THE COURT: Instead of a misdemeanor, do you 9 mean a summary offense? 10 MS. CAREY: Summary offense. I'm sorry. A 11 summary offense. 12 BY MS. CAREY: 13 Q So, was it a summary offense? 14 A (No response.) 15 Q You're not sure? 16 A They just said it was two misdemeanors. 17 Q Is it off your record? 18 A Yep. 19 Q So, have things been better out there in 20 terms of your stability? 21 A Yeah. 22 Q Do you do better in school? 23 A oh, yeah. 24 Q At this point, do you want to go back and 25 live with your mom? 66 1-1? r` 1 A Yeah. 2 Q Would you feel comfortable coming back here 3 and living with Bob? 4 A I don't know. Probably not. 5 Q Why would you not want to live with Bob? 6 A It's hard. I don't know. 7 Q Okay. Have you seen the residence that your 8 mother has worke d out to buy in Michigan? 9 A Yes. 10 Q How do you feel about living there? 11 A Pretty good. 12 Q How about living with your brothers and 13 sister? 14 A Good. 15 Q You have been with them all summer, you 16 said. Has there been any problem where your mom had you 17 staying? 18 A No. 19 Q Were things safe and good? 20 A Yes. 21 Q In terms of family support out there, is 22 there a lot of f amily support? 23 A Oh, yeah. 24 Q Who lives out there? 25 A My aunts, my uncles, my grandmas, grandpas. 67 I Q Are you happy that your mom is contemplating 2 staying out there? 3 A Yeah. 4 Q Do you want to come back with her? 5 A Yeah. 6 MS. CAREY: I have nothing else. 7 THE COURT: Mr. Diehl? 8 CROSS-EXAMINATION 9 BY MR. DIEHL: 10 Q Just for clarification, Derrick, you haven't 11 lived in the area, Pennsylvania, for approximately a year and 12 a half? 13 A Yeah. 14 Q When you moved to Michigan to live with your 15 biological father, did you live with anybody else other than 16 your biological father? 17 A Yes. I lived with my aunt. 18 Q Your aunt would be Mrs. Jack's sister? 19 A Yes. 20 Q Who did you live with first, your biological 21 father or your aunt? 22 A I lived with my father and then kind of went 23 back and forth to my aunt. I lived with her during school 24 weeks and went to him on the weekends. 25 Q Why was that? 68 ? n 1 A Because I wasn't getting along with my 2 cousins up there. I got in a little bit of trouble. I just 3 figured it would be best if I moved. 4 Q Where are you residing right now in 5 Michigan? 6 A With my mother. 7 Q So, when did you move from your aunt's to 8 your mother's? 9 A When she arrived in Michigan. 10 Q Approximately in June of this year? 11 A Yeah. 12 Q So, did you have disputes with your father, 13 your biological f ather? 14 A No. 15 Q When your mother arrived in Michigan, were 16 you intending to come back to Mt. Holly? 17 A Yes. 18 Q Did you believe at that time that living in 19 Mt. Holly was pre ferable to living in Michigan? 20 A I don't know. I don't understand. 21 Q Why did you want to return to Mt. Holly? 22 A To visit with my mother for the summer. 23 Q When you lived in Mt. Holly approximately a 24 year and a half a go, did Mr. Jack ever discipline you? 25 A Yeah. 69 1 2 3 4 Holly? 5 6 7 8 9 truck? r^ Q Were some of the disputes over smoking? A No. Q Did he permit you to smoke while in Mt. A No. Q Do you currently smoke now? A Yes. Q Were you arrested in Michigan for stealing a 10 A Yes. 11 Q Whose truck was it? 12 A My grandfather's. 13 Q Your grandfather's. So, is it accurate to 14 say you have had legal problems even within your family? 15 A Yeah. 16 MR. DIEHL: Nothing further, Your Honor. 17 REDIRECT EXAMINATION 18 BY MS. CAREY: 19 Q The incident about the truck, is that the 20 incident that you already testified to that is off of your 21 record at this point? 22 A Yes. 2.3 MS. CAREY: Nothing else. 24 MR. DIEHL: Nothing further, Your Honor. 25 THE COURT: What is your address now in 70 1 Michigan? 2 THE WITNESS: I'm not sure. My mom has it. 3 MS. CAREY: You don't know the address of 4 the trailer? 5 THE COURT: I mean the one where you are 6 living now, the place you are living now with your mother and 7 her mother and sister, I guess. 8 THE WITNESS: Oh, it's 3699 Topper. 9 THE COURT: How do you spell that? 10 THE WITNESS: T-o-p-p-e-r. 11 THE COURT: Topper Street. What town is 12 that? 13 THE WITNESS: Muskegon, Michigan. 14 THE COURT: Any further questions? is MS. CAREY: No, Your Honor. 16 MR. DIEHL: None, Your Honor. 17 THE COURT: You may step down. Thank you. 18 Any further witnesses, Ms. Carey? 19 MS. CAREY: No, Your Honor. 20 THE COURT: Mr. Diehl, any further rebuttal 21 testimony? 22 MR. DIEHL: No, Your Honor. 23 THE COURT: We'll take a brief recess, and 24 I'll see counsel in chambers. 25 (A brief recess was taken.) 71 /`Ikl 1 (The following Order was entered by the 2 Court:) 3 "AND NOW, this 12th day of August, 1999, 4 upon consideration of Plaintiff fIs Petition for Special Relief 5 with respect to the parties' children, Robert Mason Jack 6 (date of birth May 12, 1991), Kayla Morgan Jack (date of 7 birth October 13, 1989) and Kory Robert Jack (date of birth 8 October 13, 1989), and following a hearing, it is ordered and 9 directed as follows: 10 "l. Legal custody of the children shall be 11 shared by the parties. 12 "2. The children shall be returned to their 13 home in Mt. Holly Springs, Cumberland County, Pennsylvania, 14 pending the custody conciliation conference. 15 113. The custody conciliator is requested to 16 conduct an expedited custody conciliation conference. 17 "Nothing in this order is intended to 18 indicate a determination on the part of the Court as to 19 whether a relocation of the children to Michigan by the 20 mother will ultimately be determined to be in the best 21 interests of the children." 22 THE COURT: I have tried to preserve what 23 was the status quo before all of this happened, and I'll ask 24 counsel to ask Mr. Gilroy, the custody conciliator, to 25 reschedule the conference for an earlier date, if possible. 72 1 Court is adjourned. 2 (Court was adjourned at 11:10 a.m.) 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 73 r? CERTIFICATION I hereby certify that the proceedings are contained fully and accurately in the notes taken by me on the above cause and that this is a correct transcript of same. OG?F11 1L i ?'?-'" V Susan Rice Stoner official Stenographer The foregoing record of the proceedings on the hearing of the within matter is hereby approved and directed to be filed. o O S/ __r f Dat 7 CC/L? Wesley e J J. 74 ROBERT E. JACK, Plaintiff V. TERRI L. JACK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-4532 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this 29th day of September, 1999, upon consideration of Plaintiff's complaint for custody in the above-captioned case, and following a hearing, the record is declared closed, and the matter is taken under advisement. By the Court, - rr;ll Wesley er, J. Thomas S. Diehl, Esquire Suite 103 401 East Louther Street Carlisle, PA 17013 Attorney for Plaintiff Andrea J. Levy, Esquire Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 Attorney for Defendant :srs .h r „Q LO i-7 LJ rcZ WeLiT AA- C > i ROBERT E. JACK, Plaintiff V. TERRI L. JACK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-4532 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this 29th day of September, 1999, upon consideration of Plaintiff's complaint for custody with respect to the parties' children, Robert Mason Jack (d.o.b. May 12, 1991), Kayla Morgan Jack (d.o.b. October 13, 1989) and Kory Robert Jack (d.o.b. October 13, 1989), and the Court finding (a) that Defendant's relocation to the state of Michigan is likely to significantly improve the quality of life for Defendant and the children, (b) that the move was not motivated by a desire to frustrate the visitation rights of Plaintiff or to impede the development of a healthy relationship between the children and Plaintiff, and (c) that substitute visitation arrangements can be ordered which will ensure a continuing, meaningful relationship between the children and Plaintiff, 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 Defendant mother. 3. Temporary or partial physical custody of the children shall be in Plaintiff father at the following times: each summer for a period commencing one week after the end of school and concluding one week prior to the beginning of school, with the exception of a one-week period in the middle of the summer; during Christmas vacation from December 26, 1999, until r the day prior to the resumption of school; and during any spring vacation from one day after the end of school until one day prior to the resumption of school. 4. Nothing in this Order is intended to prevent the parties from making other custodial arrangements by mutual agreement. By the Court, Thomas S. Diehl, Esquire Suite 103 401 East Louther Street Carlisle, PA 17013 Attorney for Plaintiff Andrea J. Levy, Esquire Legal Services, Inc. B Irvine Row Carlisle, PA 17013 Attorney for Defendant :srs I Vy C?f c' w iriri Q. m al0 o 31 U ROBERT E. JACK, Plaintiff V. TERRI L. JACK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY 99-4532 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this 12th day of August, 1999, upon consideration of Plaintiff's Petition for. Special Relief with respect to the parties' children, Robert Mason Jack (date of birth May 12, 1991), Kayla Morgan Jack (date of birth October 13, 1989), and Kory Robert Jack (date of birth October 13, 1989), and following a hearing, it is ordered and directed as follows: 1. Legal custody of the children shall be shared by the parties. 2. The children shall be returned to their home in Mt. Holly Springs, Cumberland County, Pennsylvania, pending the custody conciliation conference. 3. The custody conciliator is requested to conduct an expedited custody conciliation conference. Nothing in this Order is intended to indicate a determination on the part of the Court as to whether a relocation of the children to Michigan by the mother will ultimately be determined to be in the best interests of the child reh By the Court, i r , J. Wesley 0 r, J ., J. Thomas S. Diehl, Esquire 401 East Louther Street Suite 103 Carlisle, PA 17013 Attorney for Plaintiff Joan E. Carey, Esquire Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 Attorney for Defendant Hubert X. Gilroy, Esquire 4 North Hanover Street Carlisle, PA 17013 Sheriff :srs ?b