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HomeMy WebLinkAbout99-06578i? ;!. ;; i:.w .y:41 { .\. ??i i? T: 51 DEANNA POMPEO, :IN THE COURT OF COMMON PLEAS Plaintiff s :OF CUMBERLAND COMM, PENNSYLVANIA Va. RONALD DEAN POMPEO, Defendant .NO. 99 - A 1?71 CIVIL TERM :PROTECTION FROM ABUSE AND CUSTODY NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims not forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on t4 As matter is scheduled for the ? day of November, 1999, at ' vd a., in Courtroom No of the Cumberland County Courthouse, Carlisle, Pennsylvania. You MUST obey the Order that in attached until it in modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to 01,000.00 and/or up to six months in jail under 23 Pa.C.S. 16114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. 12265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. 52261-2262. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH MELON TO FIND OUT WHERE YOU CAN GET LEGAL HELD. IF YOU CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE. CUMBERLAND COUNTY EAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (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. DEANNA POMPEO, :IN THE COURT OF COMMON PLEAS Plaintiff VS. RONALD DEAN POMPEO, Defendant :OF CUMBERLAND COUNTY, PENNSYLVANIA sNO. 99 - CIVIL TERM s :PROTECTION FROM ABUSE AND CUSTODY Defendant's Name: Ronald Dean Pompeo Defendant's Date of Birth: 08/21/62 Defendant's Social Security Number: 168-48-2724 Name of Protected PersonK Deanna Pompeo AND NOW, this '.'dly of October, 1999, upon consideration of teattached Petition for Protection the court hereby enters the following Temporary Order: from Abuse, ® 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. ® 2. Defendant is evicted and excluded from the residence located at 1312 High Street, Boiling Springs, Cumberland County, Pennsylvania, a residence which is jointly owned by the parties and acquired during their common law marriage, or any other permanent or temporary residence where Plaintiff may live. Plaintiff is granted exclusive possession of the residence. Defendant shall have no right or privilege to enter or be present on the premises, except for the limited purpose of transferring custody of the parties' children. Defendant shall remain in his vehicle at all times during the transfer of custody. ® 3. Defendant is prohibited from having ANY CONTACT With Plaintiff at any location, including, but not limited to any contact at Plaintiff's place of employment located at the Sara Todd Nursing Home, Carlisle, Pennsylvania. Defendant is specifically ordered to stay away from the following locations for the duration of this order: Plaintiff's residence located at 1312 High Street, Boiling Springs, Cumberland County, Pennsylvania, a residence which is jointly owned by the parties, and any other residence Plaintiff may establish. ® 4. Defendant shall not contact Plaintiff by telephone or by any other means, including through third persons. ® S. Pending the outcome of the final hearing in this matter. Plaintiff is awarded temporary custody of the following minor children: Amber Pompeo born 11/24/87 and Chelsea Pompeo born 1/13/93. Until the final hearing, all contact between Defendant and the children shall be limited to the followings None O 6. Defendant shall immediately relinquish the following weapons to the Sheriff's office or a designated local law enforcement agency for the delivery to the Sheriff's Office: Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration of this Order. ® 7. The following additional relief is granted: The Cumberland County Sheriff's Department shall attempt to make service at Plaintiff's request and without pre-payment of fees, but service may be accomplished under any applicable Rule of Civil Procedure. This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this order to Defendant by mail. This Order shall remain in effect until modified or terminated by the Court and can be extended beyond its original expiration date if the Court finds that Defendant has committed another act of abuse or has engaged in a pattern or practice that indicates continued risk of harm to Plaintiff. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. ® S. A certified copy of this order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Pennsylvania State and Carlisle. ? 9. THIS ORDER SUPERSEDES ? ANY PRIOR PFA ORDER AND ? ANY PRIOR ORDER RELATING TO CHILD CUSTODY 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail. 23 Pa.C.S. 16114. Consent of Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. 16113. Defendant is further notified that violation of this order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 D.S.C. SS 2261-2262. Any Protection order granted by a court may be considered in any subsequent Proceedings, including child custody i.roceedinas, under title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over Plaintiff's residence OR any locations where a violation of this order occurs OR where Defendant may be located. If Defendant violates Paragraphs 1 through 6 of this Order, Defendant may be arrested on the charge of indirect Criminal C Contempt. An arrest for violation of this order may be made without warrant, based solely on probable cause, whether or not f the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriff's office of the county which issued this Order, which office shall maintain possession of the weapons until further order of this Court, unless the weapon/¦ are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. Joan Carey Attorney for Plaintiff BY THE COURT, Judge DEANNA POMPEO, va. Plaintiff RONALD DEAN POMPEO, Defendant :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. 99 - 65' 1 f CIVIL TERM :PROTECTION FROM ABUSE AND CUSTODY Comm I 1. Plaintiff's name is Deanna Pompeo. 2. The name of the person who seeks protection from abuse is Deanna Pompeo. 3. Plaintiffs address is 1312 High Street, Boiling Springs, Pennsylvania. 4. Defendant is believed to live at the following address, 1032 Trindle Road, Carlisle, Pennsylvania. Defendants Social Security Number is 168-48-2724. Defendant's date of birth is 08/21/62. Defendant's place of employment is Fry Communications, Mechanicsburg, Pennsylvania. 5. Defendant is Plaintiff's common law husband. 6. Defendant has been involved in the following criminal court action: On approximately October 23, 1999, Defendant was arrested by the Pennsylvania State Police for simple assault, harassment, and possession of drug paraphernalia, after an incident involving the plaintiff. A preliminary hearing is scheduled for November 10, 1999, at 10:00 a.m. before District Justice Day. 7. Plaintiff seeks temporary custody of the following children: Name Address Birthdates Amber Pompeo 1312 High Street 11/22/87 Boiling Springs, PA Chelsea Pompeo 1312 High street 1/13/93 Boiling Springs, PA 8. Plaintiff and Defendant are the parents of the following minor children: Names 8gg Address Amber Pompeo 12 yrs. 1312 High Street Boiling Springs, PA Chelsea Pompeo 6 yrs. 1312 High Street Boiling Springs, PA 9. The following information is provided in support of Plaintiff's request for an order of child custody: (a) One child was born out of wedlock. (b) The children are presently in the custody of Plaintiff, Deanna Pompeo, who resides at 1312 High street, Boiling Springs, Pennsylvania. (c) Since their birth, the children have resided with the following persons and at the following addresses: Persons child Child's name lived with Address MM Amber Pompeo Plaintiff, North Carolina 1987-1989 Defendant, and Plaintiff's son Amber Pompeo Plaintiff, Mechanicsburg, PA 1989-1989 Defendant, and Paternal Grandparents Amber Pompeo Plaintiff, Carlisle, PA 1989-1989 Defendant, and Plaintiff's Amber Pompeo Plaintiff, Betty Nelson's 1989-1992 Defendant,and Trailer Park Plaintiff's son Amber Pompeo Chelsea Pompeo Amber Pompeo Chelsea Pompeo Plaintiff, Defendant, Plaintiff's son Plaintiff Parties' son Boiling springs, PA 1992- 10/23/99 Boiling Springs, PA 10/23/99- Present (d) Plaintiff, mother of the children, is currently residing at 1312 High Street, Boiling Springs, Cumberland County, Pennsylvania. (e) She is married. (f) Plaintiff currently resides with the following persons: Name Derrick McClain Amber Pompeo Chelsea Pompeo Relationehio Son Daughter Daughter (g) Defendant, the father of the children is Ronald Dean Pompeo, and he currently resides at 1032 Trindle Road, Carlisle, Pennsylvania. (h) He is married. (i) Defendant currently resides with the following persons: Name Jean Benson Ronald Pompeo Barbara Pompeo Relationehiv Step-Grandmother Father Stepmother (j) Plaintiff has not previously participated in any litigation concerning custody of the above mentioned children in this or any other Court. (k) Plaintiff has no knowledge of any custody proceedings concerning these children pending before a court in this or any other jurisdiction. (1) Plaintiff does not know any person not a party to this action who has physical custody of the children or claims to have custody or visitation rights with respect to the children. (m) The best interests and permanent welfare of the minor children will be met if custody is temporarily granted to Plaintiff pending a hearing in this matter for reasons including the fact that Plaintiff is a responsible parent who has provided for the emotional and physical needs of the children since their births, and who can best continue to take care of the minor children. 10. The facts of the most recent incident of abuse are as follows: On or about October 23, 1999, Defendant grabbed and pushed Plaintiff to the floor, causing her to hit and injure her elbow. When Plaintiff got up from the floor, Defendant assumed a fighting stance, put his fists up and taunted her, saying "Come on, Come on." Fearing for her safety, Plaintiff attempted to contact the police, but Defendant grabbed the phone from her, unplugged it, and hid it. Plaintiff ran upstairs, called for help, and remained there until the Pennsylvania State Police arrived. Defendant was charged with simple assault, harassment, and possession of drug paraphernalia. 11. Defendant has committed the following prior acts of abuse against Plaintiff: a. in or around the middle of September 1999,Defendant smashed Plaintiff's possessions and yelled at her, causing her to fear for her safety. The next morning while Defendant was cleaning up his mess, he told Plaintiff that she had better be glad that it was not her head he had smashed exacerbating her fear. b. Approximately three years ago, Defendant threw a hot cup of coffee at Plaintiff, grabbed her by the hair, pulled her up and slammed her against a wall. c. Throughout their marriage since 1992, Defendant has abused Plaintiff in ways including the following: taking Plaintiff's car keys so she could not leave, threatening to kill Plaintiff and bury her in the basement, pushing, punching, throwing, grabbing, and threatening her with a knife. 12. The following police departments or law enforcement agencies in the area in which Plaintiff lives should be provided with a copy of the Protection Order: Pennsylvania State and Carlisle. 13. There is an immediate and present danger of further abuse from the Defendant. 14. Plaintiff is asking the Court to evict and exclude Defendant from the residence at 1312 High Street, Boiling Springs, which is owned by the parties. 15. Defendant owes a duty of support to Plaintiff and the minor children. WHEREFORE, PLAINTIFF REQUESTS THAT THE COURT ENTER A TEMPORARY ORDER, AND AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: A. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff in any place where Plaintiff may be found. B. Exclude Defendant from the residence located at 1312 High Street, Boiling Springs, and prohibit Defendant from attempting to enter any temporary or permanent residence of Plaintiff. C. Require Defendant to provide Plaintiff and minor children with other suitable housing. D. Award Plaintiff temporary custody of the minor children. E. Prohibit Defendant from having any contact with Plaintiff, either in person, by telephone, or in writing, personally or through third persons, including, but not limited to any contact at Plaintiff's place of employment, located at the Sara Todd Nursing Home, Carlisle. F. Order Defendant to pay temporary support for Plaintiff and the minor children, including medical support and payment of the rent or mortgage on the residence. G. Order Defendant to pay the costs of this action, including filing fees, service fees, and surcharge of $25.00. H. Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc.'s funding sources for the cost of litigation in this case. I. Order the following additional relief, not listed above: a. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. C. Defendant is to refrain from harassing Plaintiff's relatives. J. Grant such other relief as the court deems appropriate. s. Order the police or other law enforcement agency to serve Defendant with a copy of this Petition, any order issued, and the order for Hearing. Plaintiff will inform the designated authority of any addresses, other than Defendants residence, where Defendant can be served. COUNT II CUSTODY UNDER PBNNBYLVANIA CUSTODY LA1P 16. The allegations of Count I above are incorporated herein as if fully set forth. 17. The best interest and permanent welfare of the minor children will be served by confirming custody in Plaintiff as set forth in paragraph 9(m) of the petition. WHEREFORE, pursuant to 23 Pa.C.S.S 5301 gJ, Sea., and other applicable rules and law, Plaintiff prays this Honorable Court to award custody of the minor children to her. Plaintiff prays for such other relief as may be just and proper. Respectfully submitted, ?J 6doan Carey Attorney for Plaintiff LEGAL SERVICES, INC. S Irvine Row Carlisle, PA 17013 (717) 243-9400 I verify that I am the Plaintiff as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.s. 54904, relating to unsworn falsification to authorities. Dated: /0 Deanna Pompeo, Plaintiff 13: rn cl) .-- ' _ 25 c. ; H V DEANNA POMPEO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 99-6578 RONALD DEAN POMPEO, ]R., Defendant COURT ORDER AND NOW, this 50, day of November, 1999, after conference with counsel for the parties in chambers, it is ordered and directed as follows: The hearing scheduled November 5, 1999 is continued generally. 2 The Protection From Abuse Order entered in this case on October 29, 1999 shall remain in effect subject to the modification that the Defendant, Ronald Dean Pompeo, jr., is no longer evicted and excluded from the residence at 1312 High Street, Boiling Springs, Pennsylvania. Mr. Pompeo may occupy that residence. Upon the release of Deanna Pompeo from the hospital and in the event she again desires exclusive possession of the mentioned residence, counsel for the Plaintiff shall notify Defendant's counsel at which time an order shall be presented to the court again excluding the Defendant from the mentioned residence and at the same time scheduling a hearing on the merits of the Protection From Abuse Petition. While Defendant occupies the residence, Defendant shall not damage or remove any real or personal property at the residence. In all other respects, the Protection From Abuse Order entered October 29, 1999 shall remain in effect. cc: Hubert X. Gilroy, Esquire Deanna Pompeo, Ronald Dean Pompeo, Jr., Defendant Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. 9?- 6578 CIVIL TERM PROTECTION FROM ABUSE AND CUSTODY ORDER OF COURT AND NOW, this a day of November, 1999, upon consideration of the attached Petition, the Temporary Protection order in the above-captioned case entered on October 29, 1999, is hereby vacated and the action withdrawn without prejudice to Plaintiff: A certified copy of this Order shall be provided to the Pennsylvania State Police by Plaintiffs attorney. By the Court; / C Joan Carey Attorney for Plaintiff LEGAL SERVICES, INC. Hubert Gilroy Attorney for Defendant BROU.IOS & GILROY (-.?..; :. [[11::'' 1?. ..r i,p.? ?.IY?? H,? J (((((? ? t;' ? r?? ,. ,; ? ;. ? : ,: , , 4 _ { ? t: ,.:_ .. ?". j _ " _. _ _ ?: bi M? 7 ) ? yyy ¢ !4 p9 .: ?? ti )W t .K ? ? - ? . ?.'. : " r .. ] Y „; ?? ,f , )?t ? M1 1 ? ? tti? ? ' n 3 ' S ( . . .. _ ' !F _ 'r;" t:?kf'? <?? .-:2?"., ,:y,1 ?? ;? a ? ?_, ??€, ' ?: yx ? Fnr Ftib? ? ? f ?} ?. ? ?' °t i + 1f v k`'? Deanna Pompeo, Plaintiff V. Ronald Dean Pompeo, Jr., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. 9?- 6578 CIVIL TERM PROTECTION FROM ABUSE AND CUSTODY PETITION TO VACATE ORDER AND WITHDRAW ACTION Plaintiff, Deanna Pompeo, by and through her attorney, Joan Carey, of Legal Services, Inc., requests that the Court vacate the Temporary Protection Order in the above-captioned case and that the action be withdrawn on the grounds that: 1. A Petition for Protection From Abuse was filed and a Temporary Protection From Abuse Order was issued by this Court on October 29, 1999 2. On November 5, 1999, the hearing was continued generally. As of this date, the parties are attempting a reconciliation. 4. Plaintiff requests that the Temporary Protection Order be vacated and the action withdrawn without prejudice to her. 5. A certified copy of this Order will be provided to the Pennsylvania State Police by the uttomey for Plaintiff. WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate ..c Joan Carey Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 r ,,, f ,x 4? VERIFICATION I verify that I am the Plaintiff as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Dated: j I I Q ?, , /I... ,_ Oe?,, Deanna Pompeo, Plaintiff I SHERIFF'S RETURN - REGULAR CASE NO: 1999-06578 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND POMPEO DEANNA VS. POMPEO RONALD DEAN HAROLD WEARY , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon POMPEO RONALD DEAN the defendant, at 17:22 HOURS, on the 29th day of October , 1999 at 1032 TRINDLE ROAD CARLISLE, PA 17013 CUMBERLAND , County, Pennsylvania, by handing to RONALD DEAN POMPEO a true and attested copy of the PROTECTION FROM ABUSE , together with & CUSTODY, NOTICE OF HEARING & ORDER, TEMPORARY , PROTECTION FROM ABUSE ORDER , and at the same time directing His attention to the contents thereof. Sheriff's Coate: So answers: Docketing 18.00 .?? Service 3.10 Affidavit .00 Surcharge 8.00 , 11/01/1999 ``.. by 7??G? W-•, 5 Sworn and oubscribed to before me this /3 C%, day of 199 A.D. ??T?4 PaCYfa7S6C - DEANNA D. POMPEO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 99-6578 RONALD D. POMPEO, JR., : PROTECTION FROM ABUSE AND Defendant : CUSTODY COURT ORDER AND NOW this Jalay of January, 2000, upon consideration of the attached Petition for Special Relief, it is hereby ordered and directed as follows: The Following temporary custody order is entered: A. The Father, Ronald D. Pompeo, Jr., and the Mother, Deanna D. Pompeo, shall enjoy shared legal custody of Amber R. Pompeo, born November 22, 1987 and Chelsea A. Pompeo, born January 13, 1993. B. The Mother shall enjoy primary physical custody of Chelsea. C. The Father shall enjoy primary physical custody of Amber. D. Absent further order of this Court, neither parry shall take any action to remove Amber from the Commonwealth of Pennsylvania. 2 Within five (5) days of the date of this Order, Father's counsel shall file a Custody Complaint to have this matter referred to a Custody Conciliator for a Conciliation Conference. We will schedule a hearing to modify the terms of this temporary Order If requested by either parry. Any such hearing will be scheduled within ten (10) days of its request. BY THIS COU 7. cc: Hubert X. Gilroy, Esquire JYWALa Deanna D. Pompeo I X0.0 0 loan Carey, Esquire RIGS (w F^'yttr;t;L' 00.I16i11i20 All II=; 2 Cl m n?dl? (;GUim FcNiJS'(LVA: J'J1 DEANNA D. POMPEO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 99-6578 RONALD D. POMPEO, JR., : PROTECTION FROM ABUSE AND Defendant : CUSTODY PETITION FOR SPECIAL RELIEF Petitioner, Ronald Dean Pompeo, Jr., by his attorneys, Broujos 8t Gilroy, P.C., sets forth the following: The above captioned action was originally filed by Deanna D. Pompeo at which time she sought a Protection from Abuse Order and a Custody Order. This action was filed in November of 1999. 2 By agreement of the parties, the temporary Protection Order entered in this case was vacated by Order of November 17, 1999. 3 The parties had reconciled in November of 1999. 4 Shortly before January 1, 2000, Deanna D. Pompeo left the marital home with Ronald D. Pompeo, Jr. and moved to North Carolina. At that time, she took with her Chelsea A. Pompeo born January 13, 1993 and left in the custody of Petitioner Amber R. Pompeo, born November 22, 1987. 5 Petitioner has maintained primary custody of Amber since the end of December of 1999. 6 Deanna D. Pompeo has recently returned to the Cumberland County area and has attempted to take Amber from school and has attempted to remove Amber from Pennsylvania and move Amber back to North Carolina with the Petitioner. 7 The Petitioner requests that the status quo be maintained pending the scheduling of a Custody Conciliation Conference to resolve these matters. 8 Petitioner and Deanna D. Pompeo are the natural parents of the two mentioned minor children. WHEREFORE, Petitioner requests the court ordered relief as set forth In the attached proposed Order. Respectfully submitted, Hubert X. Gilroy, Esquire Attorney for Plaintiff Brou)os & Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 (717) 243-4574 C, r- ?z 21 v o U ti DEANNA D. POMPEO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMEBRLAND COUNTY, PENNSYLVANIA NO. 99-6578 CIVIL ACTION - LAW RONALD D. POMPEO, A., Defendant AND NOW, this \--\ day of of the attached Complaint, it is here appear before ??x1 S. S-r ORDER OF COURT , 2000, upon consideration parties and their respective counsel Esquire, the Conciliator, at S- day of L) { l 120001 at ' A.M., for a Custody Conciliaddn Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter Into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By:-C? Custody Conciliator ?J( . YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 conferences or hearing. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 717-249-3166 :ui il: (iq r f r Od IAN '- s DEANNA D. POMPEO, Plaintiff v RONALD D. POMPEO, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMEBRLAND COUNTY, PENNSYLVANIA NO. 99-6578 CIVIL ACTION - LAW PETITION FOR SCHEDULING OF CUSTODY CONCILIATION CONFERENCE Defendant, Ronald D. Pompeo, Jr., by his attorneys, Brouios & Gilroy, P.C., sets forth the following: The above matter was originally Instituted by the filing of a Protection from Abuse action by Plaintiff Deanna D. Pompeo. That action was withdrawn by an agreement of the parties. 2 Plaintiff, Deanna D. Pompeo, is an adult Individual residing at 1369 Church Road, Nelan, NC 28451. 3 Defendant, Ronald D. Pompeo, Jr., is an adult individual residing at 1312 High Street, Boiling Springs, Pennsylvania. 4 Plaintiff and Defendant are the natural parents of Amber R. Pompeo, born November 22, 1987 and Chelsea A. Pompeo, born January 13, 1993. 5 The minor child Chelsea is currently In the custody of the Mother and the minor child Amber is currently in the custody of the Father. 6 By Order of Court dated January 20, 2000, this Court entered a temporary Custody Order in the above matter pending the scheduling of a Custody Conciliation Conference. A copy of said Custody Order is attached hereto and marked Exhibit "A". 7 Petitioner desires that this matter be set for a conference with the Custody Conciliator for purposes of obtaining a permanent court order. WHEREFORE, Petitioner requests your honorable court to schedule this matter for a conference with the Custody Conciliator. Respectfully submitted, Brou)os & Gilroy, P.. 4 North Hanover Street Carlisle, PA 17013 (717) 243-4574 DEANNA D. POMPEO, Plaintiff v RONALD D. POMPEO, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6578 : PROTECTION FROM ABUSE AND : CUSTODY COURT ORDER AND NOW this -0-20-3ay of January, 2000, upon consideration of the attached Petition for Special Relief, it is hereby ordered and directed as follows: The Following temporary custody order is entered: A. The Father, Ronald D. Pompeo, Jr., and the Mother, Deanna D. Pompeo, shall enjoy shared legal custody of Amber R. Pompeo, born November 22, 1987 and Chelsea A. Pompeo, born January 13, 1993. B. The Mother shall enjoy primary physical custody of Chelsea. C. The Father shall enjoy primary physical custody of Amber. D. Absent further order of this Court, neither party shall take any action to remove Amber from the Commonwealth of Pennsylvania. 2 Within five (5) days of the date of this Order, Father's counsel shall file a Custody Complaint to have this matter referred to a Custody Conciliator for a Conciliation Conference. EXHIBIT rrA„ 3 We will schedule a hearing to modify the terms of this temporary Order if requested by either party. Any such hearing will be scheduled within ten (10) days of its request . BY THIS COURT, : Hubert X. Gilroy, Esquire Deanna D. Pompeo loan Carey, Esquire V Y• C Sti'}?? 0 ' h Lf I +lav . !Y Y t 4 }y . i 6rrr nh9 .•a my hand' In Tca and cite s"ni 0? `-t ?? 6wrt Carlisle, Pa.? DEANNA D. POMPEO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 99-6578 RONALD D. POMPEO, JR., : PROTECTION FROM ABUSE AND Defendant : CUSTODY PETITION FOR SPECIAL RELIEF Petitioner, Ronald Dean Pompeo, Jr., by his attorneys, Broujos 8r Gilroy, P.C., sets forth the following: The above captioned action was originally filed by Deanna D. Pompeo at which time she sought a Protection from Abuse Order and a Custody Order. This action was filed in November of 1999. 2 By agreement of the parties, the temporary Protection Order entered in this case was vacated by Order of November 17, 1999. 3 The parties had reconciled In November of 1999. 4 Shortly before January 1, 2000, Deanna D. Pompeo left the marital home with Ronald D. Pompeo, Jr. and moved to North Carolina. At that time, she took with her Chelsea A. Pompeo bom January 13, 1993 and left in the custody of Petitioner Amber R. Pompeo, born November 22, 1987. 5 Petitioner has maintained primary custody of Amber since the end of December of 1999. 6 Deanna D. Pompeo has recently returned to the Cumberland County area and has attempted to take Amber from school and has attempted to remove Amber from Pennsylvania and move Amber back to North Carolina with the Petitioner. 7 The Petitioner requests that the status quo be maintained pending the scheduling of a Custody Conciliation Conference to resolve these matters. 8 Petitioner and Deanna D. Pompeo are the natural parents of the two mentioned minor children. WHEREFORE, Petitioner requests the court ordered relief as set forth in the attached proposed Order. Respectfully submitted, Hubert X. Gilroy, Esquire Attorney for Plaintiff Broulos & Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 (717) 243-4574 MAY -1 200Q DEANNA D. POMPEO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 99-6578 CIVIL TERM CIVIL ACTION - LAW RONALD D. PCMPEO, JR., Defendant IN CUSTODY ORDER OF COURT AND NOW, this 21st day of April, 2000, the Conciliator, being advised by Plaintiff's counsel that the parties have reconciled, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for April 25, 2000 is canceled. FOR THE COURT, !_Y CcR.i Darn S. Sunday, Esqu re Custody Conciliator ' ? ?._) ' ' _ ? 1 f ; 1 ?' ??.1 1 ?? .?? :::f 1 _ 1 1?? :L -? ?D C?