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Home My WebLink About99-07355s L u 0 .v. .a 114i 0'1!09/15°? 20::5 %3-1539413E FAIRCHILD T? n Theyath Lp,)f-rctfehit's D av DV Julianne Winterr Tnws the night before MoMer'r Day 05ett al! throagh the horns. Not a creature 10%71 stirring') 4-. EreeptJoraspause. PAGE 01 The bomb to"Ytr+verefhurg Around the poohidi %*h rare. lit hopes that the grandehildrtm .Soon "+otdd be there- "1111 Dah in her s+rvo And Pop-poplin trunksks, Thep reere ading like Childs" or Nws it lihe drunks' J/'' ?• ?? C *7*wt *"tiff the canal Jrut a lime bit later. 00 ortke "Iter Jumps a fora' foot gator! Then. ran to the boat And stood side kv sid4 she turned ho body tou+ d than And startedlo glide. The sun shone so brilliantly Off take Eustis and Lake Harris, taut they are so curious And never embarrassed. When ",hat to their Nanderitrg Eyes should appear. . (t?t71' N.''M?ijlk COs with a hnse sturdy. mother So bold ondso rhkk. They knew-right mrey They hod better think quirk! ,lore rapid than engler The babies they rame, Dah missed eft her grandkids .4ad Called them by "emit 4d L: 07!09/1°94 20:25 `i04539413E FAIRCHILD PAGE 01 Tt, at The Murht i fare MoO is Dav Dv Julianne WWdrs Twas the night before Mother's Dug• Nkett all through the koure. Sol a creature nas ttvringd Esceprfor a spouse, The beach ro"wLt merejbsng Around the poohide wick core. In hopes that the grandchildren Soon would be there. With Dah in her ss»vnauit And POP-POP/in, tnmks. E? Thry, • mere acting like children Or waskMedrtotks? /. ?• IC? Hken out in the canal 0A, Ant a &U- bit later ??/WWW Out ojrke were. Juntpr a jorty foot gotor! The roof to the boat And stood side bt• side. She turned ho Aodv towwrd them And started to glide. The sun shone to braudn* OffLoke Finds and Lake Haub. But they are so curious and never embarrassed. • Hkes what to their wandering Eyes should appear. &U ? , afore 1was • OS With a huge sturr(t• mother So bold and so rklck. They knew right rntxv Thet• had bcaer think quick! More rapid than eagles The babies they came. Dah m4red alt hergrandkids And called them b+• name. y PETInONFR'S D'6HIBIT •A •oo ucr YOST & LAVIDSON 727 WEST CHOCOLATE AVENUE P.O. BOX 437 HERSHEY. PENNSYLVANIA 17033-0437 JON A. YOST JOHNS DAVIDSON MARK A. HOYER April 11, 1995 Marilyn and John Fairchild 12541 Blue Heron Way Leesburg, FL 32748 Dear Mr. and Mrs. Fairchild: {f a? f` eJ r. TELEMNJN1. 717.333-5101 PAX 717-533.1293 I was contacted recently by your daughter, Julianne. Julie has asked me to write and advise you that when she moved recently from Langhorne she intentionally left no forwarding address information with you or any of her other family members since she wants to be able to live her life free of interference from her family. o in may know, Julie's er Langhorne Donald neighbors in a an attempt recently to visited obtain information concerning her whereabouts. Because of Donald's recent activity, Julie is concerned that you, Donald and the other family members may attempt to contact Julie and Cassandra. Because of Julie's concerns in this regard she has asked that I advise you that she does not want to have any contact with you and she does not want to have any contact with any other member of the family. Consequently, you are advised not to call, write, contact or attempt to contact Julie or Julie's daughter, Cassandra. Any such conduct on your part will be considered to be harassing in nature and without legitimate or lawful purpose constituting criminal conduct under the Pennsylvania Criminal Code. I trust that you will honor Julie's wishes and conduct yourself accordingly. Very truly yours, YOST 6 DAVIDSON J"n S. Davidson JSD/sat a r"u= VS _rkoL ..lil?t???r..Z...... . yet. tie r .. _l? t....9u ?..--- .._..... 1 e ?1e r S yeti ..W? ?-e ..... be c?k.-Cas5i? a.. _?_... a?? ??ne.,: .._:-?CQ._.?!1Q,?ben u?r?r ?ku .-_... .G.F nsccre_ .n? . s.t..??lhile-_._yiai,?.. ??? .??._lx??. . We ve- c a?? ... amt.. ht-W-. __. ??,r, o.?ntA .?lotl..?_._._??o?....?h?. _.?cbs.n-t.._.SAXbs_. . G w. any{. n e?So?1 LLSM.. .....?'?V ?? ? CSC :?L2?`- ?.?(1?._. ???.f..S:?...._?'SS'LLQ,.___??'-?+-'•I - (f Ile- . ... ? ??•5.__.?.,??nle.c?i?..._ .nai._.?.hi1t.?#-.Si... -Fo.4 ?_?O,.S.I. VC made _..?4 wee ?: ra v 11 n f?.?e ?cancL..s?__Y nt2?dl .? are I -----....... u?? ?? achy ?1....?Q`m?..-d??--?-•b ? ?? ?hE ? n,.?ht.?.?. i 4a 4. Macke Q now o ? C culdtl ?- 51 1 ?QrSka?..?g? ?'nr9 n??i}??Cel I 5_u„raer??g i?]? ? P w?-4?1?4ime i 1 C*'- 9&cEy>t -i -? { ANa S e D- Scc? .Carne ??Q1aV?r i?_ Slae.. A?e C-k'eMen--6CV a?,J tSin?15 -!nn ?L,?4e A Ai, C ..gLs_- Gc?di ?i c ll4 Q?._ c tl --` fl.?US.?aw?. . us _ L)er+Lt)elL_j.} r v.? mos 1.(.2.& Gee% now, he_...'Ls .?_..reast?n..? 5?._r?ea±s V--_,__- rk Le Lx iemP.,.C\.x -- -?.. ......?_?.. .rcaov-e ct .CymyuAf c- _ -4(on.. ..CakA;\eA?- CNn C. S 4a jo"k s1Ao 4\ ----.._.. _bc-???? c? ?ru?...._?.r_'?e? k?...?e-.? n• SAP .?__... -....---...._.....te.rlu.\ , L..?s --?,-...__._'.?c2_?lc,?c:icl0..._.?pfb.? ?cQU uv??11cQ 1? vr?;?-4- ?e ?-e _.?...._._... ?\eaSe \e?_. ms.._no?1.__ -???-? ro_... . :..CA?U. t C LS - n-uc,?.._GIS.... Ahalf_ .?_ l ov ed Cep ?,? ei t 11/23/1999 22:05 3525934135 FA1R_H1LD PAGE 03 In 1988 John and I moved to Florida; we rented a home for one year and Purchased a home the following year. From 1989 through 1993, John and I flew Julie and Cassie down twice for a vacation and flew Cassie down, sometimes alone-sometimes with a cousin, at least five times. It was also during this period of time that John and 1 paid for Julie's divorce from Trent Martin. In 1994 John and I were strictly on Social Security, due to John's retirement funds having been stolen from an account, and we could no longer afford to pay for the above trips. Through Mother's Day of 1994, everything seemed absolutely fine between Julie and us. On the phone. I would tell her how much I loved her and missed her, and Julie would say the same. 1 helievc we ended all our phone calls that way. lrl? , t. of I QQ went to New Jersey to visit my four children. They all lived close l'qy\1 enough to each other, so seeing them was no problem. Unfortunately, Julie and Sally had had a "falling out", and Julie refused to come over to Sally's house. Instead, Julie came and picked me up so that I could spend some time with her. Cassie was not with her! Julie and 1 went to breakfast by ourselves. She told me that Cassie was at a "sleep over" 1??l and just couldn't get up in time. What I did not know and was not told was the fact that J Cmsie was actually a student in the Hershey School at Hershey, PA. It was soon after that, around strnas of 1994, at Julie left Langhorne, PA. and moved to Campbelltown, PA. wit me, her sister or her two brothers. She just simply disappeared. It should be noted that all Christmas presents sent by us and by my sons and daughter to Julie and Cassie were received, as none were returned by the Post Office. In April of 1995, we, along with my two sons and daughter, received letters from an attomev in Hershey, PA. warning us that we were not to make any attempt to contact either Julie or t.aTe. tore has been no contact since that date until a couple of months ago, when C'assie contacted us on her own. She had gotten our phone number from her father who Round us for her through the use of his computer. When my mother died a couple of years ago, I found a letter from Julie among her personal items. There was a Campbelltown, PA. address on the envelope. I wrote a letter to Julie at that address. I did not hear from her-nor was my letter returned. Cassie has been E-mailing us and phoning us both "collect" and b t-a-pre-pato telephone :all, -nu lasreo_uple ofmonths. a vebeen E-mailingher regularly until we were advised by her father that Julie had taken Cassie out of their home and "put" her with a "tutor" in the "tutor's" home. This is something we cannot condone or understand. In Cassie's E•mails and on the phone, she had been telling us how she wants to live with her father, she does not want to live with her mother; ( her mother apparently told Cassie to go ahead and pack all her things, which she did-in anticipation of moving to her father's); she doesn't want to be continually yelled at; she doesn't want to PC, aE 11/23/1599 22:05 3525834136 FAIRCHILD have "things" thrown at her door by her mother, when her mother wants her to do someuung; snC Ww1U 11%G w cu. wuuu. ... - ---"- and boyfriend go out just about every night that is impossible -She-says she goes doom to MacDonalds, where she used to work, to see if there is something available for her to eat. It is our impression that Cassie is left alone in their home a great deal of the time. Cassie seems totally convinced that there is something wrong wtm nee tpossiuiy ruUh became that is what her mother has apparently been telling her for years. (We never saw any sign of this in Cassie in all the years we had her at home or visiting us here). We understand that the school does not agree with her mother's diagnosis of ADD either. We feel Cassie is an exceptionally bright child in desperate need of a normal home life. Cassie had to provide a friend's address in order for me to be able to send her letters. Cassie, at my request, received permission from her friend's mother for this to happen. When Cassie would call us, she would say how glad she was to be back in touch with us. She would tell us how much she has missed us and how much she loves us. She even rememhered how she used to love going to sleep in our home as she listened to tapes 1 made for her We have recently been in contact many, marry times with Cassie's father and her other grandmother We are absolutely convinced that Cassie should be living with her father and his famih They all love her, she loves them, and we ask you to please do everything you can to allow Cassie to spend the last few years before her adult life in a normal family situation---something she certainly does not have now nor has had for the past six or so years. Very truly yours, Marilyn S. Fairchild P.S. Here are addresses you requested of where Julie and Cassie have been living since Cassie's binh 1.Candlewick Drive, East Stroudsburg, PA (our former home) 2 255 E. Lincoln Hwy., Penndel, PA (lived with boyfriend) 3. 1476 Parkside Ave , Apt# 15, Ewing, N. J. (lived with one of Julie's brothers) 4. 3000 Ford Rd., Bristol, PA 5. 733 Timher Lane, Langhorne, PA (lived with different boyfriend) 6. Village Hotel, Route 322, Canpbelltown, PA 7. unsure-in a trailer park at South Londonary, PA or Palmayra, PA 9. 3050 Momingside Drive, Camp Hill, Pa (again a different boyfriend) 9, 123 Limestone Drive, Camp Hill, PA ( above boyfriend who is present boyfriend) ": Re: WOWSMAntlnllnllllllltlllllllllllllllln 1I ) Dale: 99.08-2416:0638 EDT ?.% From: sweaty1232®eneite.com (Cassandra Martin) To: JFFaIr®aol.com On Tue, 24 Aug 198814:16:07 EDT, JFFeir@aol.com wrote: Grandma 6 Pop-Pop, I reclismd your e-mail. I was told a lot of lhlrgs so far in my life that I can't even remember half of them. Prow Is John and Enca and Katherine and awyorw also? I am realty good. You know that the minute that I got your number I warted to call you but I couldn't because the fact that I needed to catch my plane beck here. My best trend said that she does not mind if you send letters to her house instead of hero because she goes through a lot of the sa=i45BIWWAksmIth s is: Okay? I lole you guys and 1 mi ss you so much. Oh, yeah Grer4rna(Dah) I passed an last year with a 991E a•srage. Of course I passed music,Chorus and Band with all 1100%'s. I tole you two and elerytne so much but I have to go. ro talk to you later. Lola, Cassandra J. Martin 06/01/2000 11:15 3512151:9=13F. FAIRCHILD PAGE Dale: 89-0&27 12:17:59 EDT From: sweety1232Qtdte.com (10433011411 Martin) To: JFFakoad.corm On Fit, 27 Aug 1999 06:06:01 EDT, JFFair@aoi.com wrote: " Dah and Pop-Pop. So1ry I didn't e-mail you yesterday. I went to Hersheypark and than when I got tome I was so tired I tali asleep br a lay long Ume.l hme to go to work In about half haa=( I will not be has for most of trio weokend Moeueo my malhor fo in perllao at o,.m olnm W1a1 OW JaY au 1110L 111/041151 hale go to my lulces house for the wookend. I am sorts mad at my mom because she is going to miss my firs', cheeneading game of the entire season and she promised me that she would be them=( Oh the (•ms is won't stop %tw school starts=) I am so happy I got in touch with you. I hawnl heard from Erika or anyone. Do you want me to send my pictures or deliver I" in person? Because if I deli%er them In person than it might be ewhlie until I see you to do that. Any way...... My mom started saying things about her sloe of the family eon and blaming my shyness as a chtild on Dah and Aunt Sally. I got rosily mad at her for judgir g people that she has lived her life with and it is her own mother and sister. I don't judge any one that is so very close to me. Plus I don't judge people. I know she's had a hard life and all but she shouldn't j.idW people just Diecause of either V%v looks or rallgion or because of their color or race. I really hale -net. I just thought atwut the picture thing H I send you a few of my pictures MI st In on. 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Fro har?iU mr°i m •-? ° m co •r?l ..?•? N m O u O t7 C U O 1 00 V) L 41 0 o U y an u a o E- CO QUC ti W W4J.CW to C -H co u =s 41 z y y iJ ? '•• Cn () b a •11 a) -4 C LL •-1 m i+'O y0 - roc] C•?roy UyEm UEro TOC Qz ro u a) co Ola O z 0 O Wa Lm 't ^ .7 fn z, .., LO Qx y F US aL UM y. TRENT K. MARTIN, VS. JULIANNE WINTERS, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-7355 CIVIL TERM IN CUSTODY PLAINTIFF'S ANSWER TO DEFENDANT'S MOTION FOR LEAVE OF COURT TO CONDUCT DISCOVERY NOW COMES Trent K. Martin, Plaintiff above, by and through his counsel, Flower, Flower & Lindsay, and answers the Motion for Leave of Court to Conduct Discovery filed by the Defendant as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied as stated. Cassandra was born after the parties' separation in 1984. Plaintiff then moved several times and Defendant lost track of his ex-wife and his daughter. By way of further answer, once Plaintiff located his daughter, he maintained communication with her and visited with her on several occasions. Cassandra has visited with Plaintiff for extended periods in Texas. 5. After reasonable investigation, Plaintiff is without information sufficient to form a belief as to the truth of the assertions in Paragraph 5 and they are therefore denied. 6. Denied. On the contrary, Defendant has cut off communication between Cassandra -, I and Plaintiff unless it ip,directly.supervisea by the Defendant and has forbidden communication between Cassandra and .ber.:materrral'AN paternal grandparents. After reasonable investigation, ?JG? martin plaintiffs answer to leave of court motion for discovery tjb May 5, 2000 Plaintiff is unable to determine any disparaging comment regarding Defendant made to Cassandra by Cassandra's grandparents. 7. After reasonable investigation, Plaintiff is without information sufficient to form a belief as to whether the grandparents have made any disparaging comment regarding Defendant to Cassandra, but upon information and belief, they have not done so. 8. After reasonable investigation, Plaintiff is without information sufficient to form a belief as to the truth of the allegations in Paragraph 8. 9. Denied. It is not in Cassandra's best interest to continue to invade her privacy by downloading her e-mail messages, or in this case, subpoenaing her communications with her grandparents. By way of further answer, upon information and belief, there are no communications at the excite@home provider between Plaintiff and the child. 10. Denied. By way of further answer, although Plaintiff believes that the granting of this Motion would not uncover more communications between him and the child, it might provide communications between the child and maternal grandparents and the paternal grandparents, both of whom have a privacy interest in their e-mail messages, and neither of whom are parties before this Court in order to object. By way of still further answer, Plaintiff believes and therefore avers that it is not in the child's interest to have her communications with her grandparents subject to subpoena. 11. Admitted. 12. After reasonable investigation, Plaintiff is without information sufficient to form a belief as to the delay occasioned by Defendant's request. 2 martin plaintiffs answer to leave of court motion for discovery tjb May 5, 2000 WHEREFORE, Plaintiff prays this Honorable Court to dismiss the Petition to obtain from excite@home by the use of a subpoena, e-mail transmissions made and received by Cassandra Martin as invasive of the privacy of Cassandra Martin and of her maternal and paternal grandparents who are not parties to this action. FLOWER, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: 4'[ Carol'J. Indsay, Esquire ID#44 3 11 East High Street Carlisle, PA 17013 (717) 243-5513 I I i 3 VERIFICATION The undersigned, Carol J. Lindsay, Esquire, avers that the facts set forth in the foregoing instrument, based upon information and belief, were developed from conversations with Plaintiff, Trent K. Martin and information gained in the investigation of this file, and this Verification is made for the reason that Plaintiff is outside of the jurisdiction of the Court, and that his Verification could not be obtained within the time allowed for the filing of this pleading, and this Verification is made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. FLOWER, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: arol . Lindsay, Esquire ID# 693 11 East High Street Carlisle, PA 17013 (717) 243-5513 martin plaintiffs answer to leave of court motion for discovery tjb May 5, 2000 TRENT K. MARTIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 99-7355 CIVIL TERM JULIANNE WINTERS, Defendant : IN CUSTODY CERTIFICATE OF SERVICE, AND now, this 91 day of 2000, I, Carol J. .11 Lindsay, Esquire, of the law firm of FLOWER, FLOWER & NDSAY, P.C., Attorneys, hereby certify that I served the within Plaintiffs Answer to Defendant's Motion for Leave of Court to Compel Discovery this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Keith Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE 44 West Main Street Mechanicsburg, PA 17055 Michael A. Scherer, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 FLOWER, FLOWER & LINDSAY Attorneys for Plaintiff By: u,", , ?. Ll.tarol J. L' dsay, Esquire I D # 44693 11 East High Street Carlisle, PA 17013 4 ti-. C) __ ?:: _• _ ``i :?;; i?! ;: •: -- c. , -,', = i i_:. . ,_?... ???iila LL... •t i_ ?? :) Tom... ....,'?,?.-??-r? TRENT K. MARTIN, Plaintiff VS. JULIANNE WINTERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7355 CIVIL TERM CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this day of Y 2 . /L t. , 2000, upon consideration of the attached Custody Conciliation R? ort, it is ordered and directed as follows: 1. A Hearing is scheduled in Courq Room # 7 , of the Cumberland County Court House, on the 7n day ofwill . , 2000, at'-1 30 o'clock, G. m. at which time testimony be taken. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the Hearing, and a summary of the anticipated testimony of each witness. These memoranda shall be filed with the Court at least ten days prior to the Hearing date. 2. Independent counsel shall be appointed to represent the interests of the Child, Cassandra Jeanne Martin, with the costs to be apportioned between the parties as determined by the Court. BY THE COURT, J. cc: Carol J. Lindsay, Esquire - Counsel f Fathers J7 Keith 0. Brenneman, Esquire - Counsel for Mother ,3-/'00 -B-K 3 y 1 1 , 3 tl, 1 .1 .n it U TRENT K. MARTIN, . IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7355 CIVIL TERM JULIANNE WINTERS, CIVIL ACTION - LAW Defendant CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Cassandra Jeanne Martin March 21, 1985 Mother 2. A Conciliation Conference was held on February 10, 2000, with the following individuals in attendance: The Mother, Julianne Winters, with her counsel, Keith O. Brenneman, Esquire, and the Father's counsel, Carol J. Lindsay, Esquire. The Father, who currently resides in Texas, did not attend the Conference. 3. The Father filed this Petition for primary physical custody of the Child. The parties were not able to reach an agreement at the Conference and it will be necessary to schedule a Hearing. 4. The Father's position on custody is as follows (as expressed by the Father's counsel): The Father believes that it is in the Child's best interest to move to Texas to reside with him. According to the Father, the Child had visited him for at least one week last surtmer and has expressed a desire to live with the Father on an ongoing basis. The Father believes the Mother has cut-off ties between the Child and the extended families on both the Mother's and the Father's side and the Child has expressed an interest in getting to know these relatives in Texas. The Father also requested a period of partial custody over the Child's Spring break, unimpeded communication with the Child both by telephone and E-Mail and approval for the Father's family to have contact with the Child without interference from the Mother. 5. The Mother's position on custody is as follows: The mother expressed concern that the Father had not in the past shown a desire to develop a relationship with the Child. The Mother believes the motive behind the Father's request for custody at this time is either to avoid paying child support or to obtain custody on behalf of the Child's maternal and paternal grandmothers who reside in Texas. The Mother acknowledged that she is not permitting any unsupervised contact between the Father and the Child, including telephone communications, and stated that her intervention is necessary to prevent the Father from further poisoning the relationship between the Mother and the Child. The Mother strongly objects to a change in primary custody. The Mother adamantly opposed the Father's request for partial custody over the Child's Spring break pending resolution of this matter by the Court. 6. Based upon the conciliator's assessment of the circumstances involved in this matter and upon a request by the Father's counsel, the Conciliator recommends that independent counsel be appointed for the Child, with the cost to be apportioned between the parties as determined by the Court. The Conciliator recommends entry of an order in the form as attached scheduling a Hearing in this matter. It is expected that the Hearing will require 1 day. YP.?iN[t?a / % "XWd ..a_-21" Date VDawn S. Sunday, Esquire Custody Conciliator TRENT K. MARTIN, . IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA VS. 99-7355 CIVIL CIVIL ACTION-LAW JULIANNE WINTERS, Defendant CUSTODY ORDER AND NOW, this /'-' day of March, 2000, continued hearing in the above matter is set for Thursday, May 18, 2000, at 9:30 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. Pending the hearing, the parties hereto shall share legal custody of the child, Cassandra Jeanne Martin, and both parties shall have access to the child's school and medical records including those of any psychologist or any other therapist. Michael A. Scherer, Esquire, is appointed to represent the child, Cassandra Jeanne Martin, with his costs and fees to be initially advanced by the plaintiff. BY THE COURT, Carol J. Lindsay, Esquire For the Plaintiff Keith 0. Brenneman, Esquire For the Defendant Kevin Hess, J. 00 3'???LS Michael A. Scherer, Esquire For the Child 77 } C wF , ... 7 r^ _ n ? ;Jo- C:D U ° TRENT K. MARTIN, Plaintiff VS. JULIANNE WINTERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-7355 CIVIL CIVIL ACTION - LAW CUSTODY ORDER AND NOW, this 2.1. day of March, 2000, hearing in the above matter set for Thursday, May 18, 2000, is continued to Wednesday, June 7, 2000, at 9:30 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. Carol J. Lindsay, Esquire For the Plaintiff Keith 0. Brenneman, Esquire For the Defendant Michael A. Scherer, Esquire For the Child prl- BY THE COURT, P;: 3: c'7 IN rl PENNSYL"tii\14 `a ,I APR 2 5 TRENT K. MARTIN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. JULIANNE WINTERS, Defendant 99-7355 CIVIL CIVIL ACTION - LAW ORDER AND NOW, this 2 0- day of /4/0 h'/ , 2000, upon consideration of the Defendant's Motion For Leave of Court to Conduct Discovery, a RULE is hereby issued upon Plaintiff and counsel for Cassandra Martin to show cause, if any they should have why the relief requested in the above-referenced Motion should not be granted. RULE RETURNABLE within Ten (10) days of service of this Order upon Plaintiff's counsel and counsel for Cassandra Martin. BY THE COURT: r (? J r?C??LCPi. J. Le 'a) q LAW OFFICE6 SNELOAKER, BRENNEMAN & SPARE ?? m TRENT K. MARTIN, Plaintiff VS. JULIANNE WINTERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-7355 CIVIL CIVIL ACTION - LAW DEFENDANT'S MOTION FOR LEAVE OF COURT TO CONDUCT DISCOVERY Defendant Julianne Winters, by her attorneys, Snelbaker, Brenneman & Spare, P. C., submits this Motion For Leave of Court to Conduct Discovery in this custody proceeding as follows: 1. Defendant Julianne Winters, Movant herein, is the natural mother of Cassandra Martin, who was born March 21, 1985. 2. Defendant has had primary physical custody of Cassandra Martin since Cassandra's birth. 3. Plaintiff is the natural father of Cassandra Martin. 4. For the first ten years of Cassandra's life, Plaintiff did not see Cassandra and made no effort to see her. The only contact he had with Cassandra was six or seven telephone calls. 5. Defendant believes and therefore avers that Plaintiff initiated this custody action due to Defendant obtaining support from Plaintiff and at the insistence of Cassandra's maternal and paternal grandparents who live in Florida and Texas. 6. Defendant believe that beginning in at least August, 1999, Plaintiff and Cassandra's LAW OFFICCS SNELOAKCR. maternal and paternal grandparents have engaged in a concerted effort to alienate Cassandra BRENNEMAN & SPARE from Defendant by making various and repeated communications to Cassandra disparaging to Defendant in an effort to persuade and convince Cassandra to live with Plaintiff in Texas. 7. Cassandra maintained an e-mail account through Excite rr home, through which Cassandra sent and received numerous e-mail transmissions believed to be relevant to the efforts of Plaintiff and the maternal and paternal grandparents to disparage Defendant and persuade Cassandra to live with Plaintiff in Texas. 8. Defendant's counsel has been advised by a representative from Excite n home that if a subpoena is provided to Excite(@home, copies of all e-mail transmissions on Cassandra's account can be released and obtained by Defendant. 9. The e-mail transmissions are relevant to the best interests and welfare of Cassandra, in that they reveal the motivations of Plaintiff in initiating this custody action and his bona fides in seeking primary physical custody. Further, such transmissions are believed to have a bearing on Plaintiffs fitness as a custodial parent and are relevant to Plaintiff's purported efforts to provide contact to maternal and paternal extended families of Cassandra. 10. Even if not at this time believed to be relevant by this Court, the discovery of the content of the e-mail transmissions is reasonably calculated to lead to the discovery of admissible evidence. 11. Pa.R.C.P. 1915.5 provides that there shall be no discovery in a custody action unless authorized by special order of court. 12. A hearing on this matter has been scheduled for June 7, 2000; therefore, disposition of this Motion by this Court and allowing discovery for the limited purposes of obtaining the LAW OFFIC[9 SNELBAKER. BRENNEMAN -2- & SPARE e-mail transmissions as identified above will not delay the hearing in this case. WHEREFORE, Defendant requests this Court to: A. Issue a Rule upon Plaintiff to show cause, if any he should have, why the relief requested by Defendant in this Motion should not be granted; B. Authorize Defendant to obtain from Exciteftome by the use of a subpoena issued through the Court of Common Pleas of Cumberland County the e-mail transmissions made and received by Cassandra on her account; C. Due to the submission of this discovery matter by Motion of the Defendant, with an opportunity to be heard by the Plaintiff, order that the requirements upon service of a subpoena to a person not a party to an action with respect to prior notice and the opportunity of a party to object thereto not be required; and D. Grant such other and further relief as this Court in its discretion deems appropriate under the circumstances. SNELBAKER, BRENNEMAN & SPARE, P. C. BY: I ??- Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Defendant Julianne Winters Date: April 25, 2000 "W OFFICES I -?- SNELOAKER. BRENNEMAN & SPARE CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Motion to be served upon the person and in the manner indicated below: FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Carol J. Lindsay, Esquire Flower, Flower & Lindsay 11 E. High Street Carlisle, PA 17013 Michael A. Scherer, Esquire O'Brien, Baric & Scherer 17 West South Street Carlisle, PA 17013 ?/6u«s, Keith 0. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Defendant Julianne Winters Date: April 25, 2000 LAW OFFICES SNELBAKER. BRENNEMAN & SPARE lii:fm TRENT K. MARTIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 99 - 7355 CIVIL TERM JULIANNE WINTERS, Defendant IN CUSTODY PLAINTIFF'S PRE-HEARING MEMORANDUM The parties in this case are parents of Cassandra Martin, born March 21, 1985. At the time of Cassandra's conception, the parties were married and both were in the military. They separated when Mother was two months pregnant and Father was discharged from the military. The separation became permanent. Mother returned home to live with her parents and then lived in several other places over the intervening years and Father lost track of her and his daughter until 1990 when he located them and was permitted to speak with his daughter for the first time. She was five years old at the time. After Mother moved, Father again lost contact of his daughter and after an extensive search, including trips to New Jersey, was able to locate Mother and daughter in the spring or early summer of 1995. He traveled to Pennsylvania to visit her and was permitted to keep her for a week. At that time, the daughter had been enrolled in Milton Hershey School. Upon information and belief, she was a student there from September, 1994 until March of 1998. Thereafter, the child was permitted to visit her father in Texas over Thanksgiving holiday in 1995, for a week to two weeks in the summer of 1996 and for the Christmas break in the same year, and for similar periods of time in 1997. In 1998, Father purchased a ticket for the child to visit him martin pre-trial memo tjb May 26, 2000 for Christmas as agreed to by the parties. Mother refused to permit the child to visit. However, in the summer of 1999, she was permitted to travel by herself to Texas to visit with her father. At Christmas, Mother refused to permit her the trip. In the fall of 1999, the child indicated a desire to live with her father in Texas. Discussions were held between Mother and Father and Mother agreed to the move. The child's belongings were packed. Then, Mother refused to permit her to go without explanation. Father commenced the instant action with a Complaint for Custody on December 7, 1999. A conciliation was held and a conciliation report issued. A hearing is set for June 7, 2000 at 9:30 a.m. The child is represented by Michael A. Schoror, Esquire. Father will present the following witness: Trent Martin: Trent Martin Is the Father. He will testify regarding his relationship with Cassandra, the particulars of his living situation, his employment and his relationship to Cassandra's extended family. Sherri Martin: Ms. Martin Is Father's wife. She will testify with regard to her relationship with the child and her understanding of the length and duration of the child's desire to reside in her household. z marlin pre-trial memo ljb May 26, 2000 Marilyn Fairchild: Ms. Fairchild is the maternal grandmother. She will testify with regard to her relationship to the child, the circumstances surrounding an estrangement between her and her daughter, the mother in this case, and the rest of the mother's family, and her desire and ability to maintain her relationship with her granddaughter. Ms. Fairchild will testify by telephone since she resides in Florida. Deanna Stevens: Ms. Stevens is the paternal grandmother and will testify regarding her relationship with Cassandra. Ms. Stevens resides in Missouri and therefore will testify by telephone. Peter Gurt: Mr. Gurt is a counselor at Milton Hershey School where Cassandra was enrolled for approximately four years. Mr. Gurt will describe the child's academic progress and respond to any claims of a learning disability anticipated to be alleged by Mother. Mr. Gurt will also testify regarding the circumstances of the child's admission to Milton Hershey and her withdrawal therefrom. Rene Space: Ms. Space is a therapist with Guidance Associates and she has been counseling with the child for some time. She will testify regarding the strength and duration of the child's resolve to reside with her father and the maturity of that resolve. Ms. Space is also anticipated to be able to testify to ongoing difficulties the child has experienced in the mother's home. Aaron Walters: Mr. Walters is the Guidance Counselor at Cedar Cliff High School where the child attends. He will testify with regard to the child's academic progress, allegations of drug abuse and learning disabilities anticipated to be made by Mother. 3 martin pre-trial memo tjb May 26, 2000 II. FATHER'S POSITION ON CUSTODY Father believes that the child's best interest would be served by residing with him in Texas and that he can provide well for her physical, emotional, educational and spiritual wellbeing. He anticipates liberal visits with Mother during the child's school holidays. Respectfully submitted, FLOWER, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: ilil'(. L ? Carol J. Lindsay, Esquire ID#t,44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 martin pre-trial memo tib May 26, 2000 TRENT K. MARTIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JULIANNE WINTERS, NO. 99 - 7355 CIVIL TERM Defendant IN CUSTODY CERTIFICATE OF SERVICE AND now, this Jb day of 2000, I, Carol J. Lindsay, Esquire, of the law firm of FLOWER, FLOWER 8=1NDSAY ,P.C., Attorneys, hereby certify that I served the within Plaintiffs Pre-hearing Memorandum this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Keith 0. Brenneman, Esquire Michael A. Scherer, Esquire SNELBAKER & BRENNEMAN O'BRIEN, BARIC & SCHERER 44 West Main Street, P. 0. Box 318 17 West South Street Mechanicsburg, PA 17055 Carlisle, PA 17013 FLOWER, FLOWER & LINDSAY Attorneys for Plaintiff By: Carol J. Lin ay, Esquire ID # 44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 f ?O irk <-' O CJ ?I (I .l 1 t 1 ly :t I I i f IC i .7x U rc < L U r. ?u-> E?.,r?? o?;=y 30_° r I s ? C i F i ? S ' F I , O Q `f ?1 c L i cy) Y U ? '• cn .- z a Z N J = Q 0 EL 2 00 0 Fn 1 ` ? c t c o t i t l? ? t ? f i ? i I ? r r i r I , r i marlin petition for discovery qb May 1, 2000 TRENT K. MARTIN, VS. JULIANNE WINTERS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-7355 CIVIL TERM Defendant IN CUSTODY ORDER OF COURT AND Now, this . day of 2000, upon consideration of the within Petition for Discovery, a Rule is issued upon the Defendant to show cause why the relief requested should not be granted. day of May, 2000, in Courtroom RULE returnable at a hearing set for the o'clock • m• No. 4 of the Courthouse at Carlisle, Pennsylvania, at By the Court, J. martin petition for discovery tjb May 1, 2000 TRENT K. MARTIN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. JULIANNE WINTERS, Defendant CIVIL ACTION - LAW NO. 99-7355 CIVIL TERM IN CUSTODY r7 O r r? v.n tW*, Ftgwer < to PETITION FOR DISCOVERY NOW COMES Trent K. Martin, Plaintiff above, by and through his & Lindsay, and petitions this Honorable Court as follows: 1. The parties hereto are the parents of Cassandra Martin, born March 21, 1985. 2. On December 7, 1999, Plaintiff filed the Complaint for Custody, seeking primary physical custody of Cassandra, age 15, who wishes to reside with her father. 3. At the conciliation conference, Defendant averred that the child suffered from learning disability and drug involvement. Defendant further averred that she had downloaded the child's e-mail messages which contained evidence of the attempts of the Plaintiff to turn the child against Defendant. 4. At the conciliation conference, Plaintiff asked for the names of any therapists with whom the child had counseled, copies of the e-mail to which Defendant referred and evidence of any drug problem or treatment therefor. Defendant refused to provide any such information. 5. On March 27, 2000, the undersigned addressed a letter to Defendant's counsel seeking the same information. No response has been forthcoming. 6. The case is set for a hearing on June 7, 2000. 7. In order to properly prepare for the hearing, Plaintiff needs to know the names of all of those who have evaluated the child, receive copies of the evaluations, and know the names of martin petition for discovery tjb May 1, 2000 those with whom the child has treated. Further, Plaintiff believes and therefore avers that the e- mail from the child to her father and grandparents, which is in the possession of Defendant, should be provided to Plaintiff so that he can prepare his case. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to provide the discovery requested. FLOWER, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By Carlisle, PA 17013 (717) 243-5513 VERIFICATION The undersigned, Carol J. Lindsay, Esquire, avers that the facts set forth in the foregoing instrument, based upon information and belief, were developed from conversations with Trent K. Martin and information gained in the investigation of this file, and this Verification is made for the reason that his Verification could not be obtained within the time allowed for the filing of this pleading, and this Verification is made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. FLOWER, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff 11 East High Street Carlisle, PA 17013 (717) 243-5513 martin petition for discovery tjb May 4, 2000 TRENT K. MARTIN, VS. Plaintiff JULIANNE WINTERS, Defendant AND now, 2000, I, Carol J. Lindsay, Esquire, of the law firm of FLOWER, FLOWER & LINDSAY, P.C., Attorneys, hereby certify that I served the within Petition for Discovery this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Keith Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE 44 West Main Street Mechanicsburg, PA 17055 FLOWER, FLOWER & LINDSAY Attorneys for Plaintiff By: G Carol J. Lindsay, Esquire ID # 44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-7355 CIVIL TERM IN CUSTODY Lain Offices r' 093RIEN, EARIC & SCHERER 17 II'est South Street Carlisle, Pennsylvania 17013 Robert L. O'Brien David A. Boric Michael A. Scherer May 31, 2000 VIA HAND DELIVERY Honorable Kevin A. Hess Court of Common Pleas Cumberland County Courthouse One Courthouse Square Carlisle, Pennsylvania 17013 RE: Martin v. Winters No. 99-7355 Civil Term In Custody Dear Judge Hess: h (717) 249-6873 Fax (717) 249-5755 E-mail. obs@obslaw.com direct: mscherer@obslaw.com As you recall, you appointed me to represent Cassandra Martin in connection with the above-captioned custody matter. Keith Brenneman, Esquire, represents the mother and Carol Lindsay, Esquire, represents the father. A discovery dispute has arisen in this case whereby the parties are at issue over whether certain emails sent by my client will be shared among all parties and whether certain communications made privately to her therapist will be disclosed to all involved. A hearing has been set in this matter for Thursday, June 1, 2000 at 2:00 p.m. in your courtroom. Having just returned from vacation, I now realize that I have for some time been scheduled to be in Perry County for a custody conciliation at 1:00 p.m. on June 1, 2000. My attendance at the hearing before you would therefore be impossible. I have met with Cassandra and have written a detailed summary of Cassandra's desires with respect to this case and my views of the preferences she expressed to me. I have also explained to both counsel that Cassandra sent the various emails and had discussions with her therapist with an expectation of privacy, and she would prefer to keep those matters private. She assures me that if this information is disclosed that it will only serve to reinforce what she has explained to me. Honorable Kevin A. Hess 05/31/00 letter page 2 I plan to confirm with counsel that my absence from the hearing before you on June 1, 2000 will not create a problem, and if it does not, I would request to be excused by you from the hearing. Very truly yours, O'BRIEEN, BA,RIIC& SCHERER %lo/ ?(- ?? Michael A. Scherer MASQI cc: Keith Brenneman, Esq., VIA FACSIMILE: (717) 697-7681 Carol Lindsay, Esq., VIA FACSIMILE: (717) 243-6510 Cassandra Martin File mas.d i r/letters/cmarti n l itr martin conciliation order tjb December 7,1999 TRENT K. MARTIN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. JULIANNE WINTERS, Defendant CIVIL ACTION - LAW NO. 99 - 735 CIVIL TERM IN CUSTODY ORDER OF COURT AND now, this day of \?CPrnce( 1999, upon consideration of the ;d Motion, it is here) y directed that the parties and their respective counsel appear before „ the conciliator, at u v on the ?? day of ?Q 1n.? Fg9?, at \ •00 o'clo k - m. for re-hearing custody conference. At such conference, an effoR will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. For the Court, By: am Custody , fat l YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU GO 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. Office of the Court Administrator Courthouse, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County, Pennsylvania, 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. By the Court, Date: J. Yti1,`.J. 1-2 y Trent Martin (custody) November 12, 1999 TRENT K. MARTIN, Plaintiff VS. JULIANNE WINTERS, Defendant NOW comes Trent K. Martin, by and through his counsel FLOWER, FLOWER & LINDSAY and states as follows: 1. The Plaintiff is Trent K. Martin who resides at 5002 Chase Mountain Drive, Bacliff, Texas 77518. 2. The Defendant is Julianne Winters who resides at 123 Limestone Drive, Camp Hill, Pennsylvania 17011. 3. The Plaintiff seeks custody of Cassandra Jeanne Martin, born March 21, 1985, age 14 who resides at 123 Limestone Drive, Camp Hill, Pennsylvania, 17011. The child was not born out of wedlock. The child is presently in the custody of the mother, Julianne Winters who resides at 123 Limestone Drive, Camp Hill, Pennsylvania 17011. During the last five years the child has lived with the following persons at the following IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 . 7.3 y -':( CIVIL TERM IN CUSTODY COMPLAINT IN CUSTODY addresses: NAME ADDRESS FROM/TO Milton Hershey School Hershey, Pennsylvania (Grades 4, 5, 6, 7`h and part of 8`h) June 1994 - June.1 998 Julianne Winters & Bruce Walmer 123 Limestone Drive, Camp Hill, PA June 1998 -Present Trent Martin (custody) November 12, 1999 The mother of the child is Julianne Winters, currently residing at 123 Limestone Drive, Camp Hill, Pennsylvania. She is single. The father of the child is Trent Martin, currently residing at 5002 Chase Mountain Drive, Bacliff Texas. He is married. 4. The relationship of the Plaintiff to the child is that of father. The Plaintiff currently resides with his wife Sherri and their one year old child at 5002 Chase Mountain Drive, Bacliff, Texas. 5. The relationship of the Defendant to the child is that of mother. The Defendant currently resides with her boyfriend, Bruce Walmer and the child, Cassandra Jeanne Martin at 123 Limestone Drive, Camp Hill, Pennsylvania. 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation concerning the custody of the child in this or another jurisdiction. 7. The Plaintiff has no information of a custody proceeding concerning the child pending in a court of the Commonwealth. 8. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 9. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) The child, age 14, wishes to live with Plaintiff. b) The Plaintiff can best care for the child physically, emotionally and intellectually. c) The Plaintiff can provide the child with contact to both maternal and paternal extended families. Trent Martin (custody) November 12, 1999 10. Plaintiff is a loving father who can provide guidance to the child during her adolescent years. 11. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, the Plaintiff requests this Court to grant primary physical custody of the child to the Plaintiff. Respectfully submitted, FLOWER, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff V By: arol indsay, Esquire 693 11 East High Street Carlisle, PA 17013 (717) 243-5513 Date: 12 j?af f f VERIFICATION I, hereby verify that the statements made in the within instrument are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. By ren K. Martin Date: I ?- 22 , 1999 >- _- C? iillU LJ n marlin petition for discovery tib May 1, 2000 TRENT K. MARTIN, VS. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-7355 CIVIL TERM JULIANNE WINTERS, Defendant IN CUSTODY ORDER OF COURT AND Now, this cI r? day of 2000, upon consideration of the within Petition for Discovery, a Rule is issued upon the Defendant to show cause why the relief requested should not be granted. tGA-C-? RULE returnable at a hearing set for the _ ILt. day 4WaY, 2000, in Courtroom No. 4 of the Courthouse at Carlisle, Pennsylvania, at c-) % O'D o'clock --A-. M. By the Court, 4-6,a-,O) /a. J S-is--oo --RK3 f ^ir RY v'J,i1 X11, m' 0f martin petition for discovery tib May 1, 2000 TRENT K. MARTIN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. JULIANNE WINTERS, Defendant CIVIL ACTION - LAW NO. 99.7355 CIVIL TERM IN CUSTODY PETITION FOR DISCOVERY NOW COMES Trent K. Martin, Plaintiff above, by and through his counsel, Flower, Flower & Lindsay, and petitions this Honorable Court as follows: 1. The parties hereto are the parents of Cassandra Martin, born March 21, 1985. 2. On December 7, 1999, Plaintiff filed the Complaint for Custody, seeking primary physical custody of Cassandra, age 15, who wishes to reside with her father. 3. At the conciliation conference, Defendant averred that the child suffered from learning disability and drug involvement. Defendant further averred that she had downloaded the child's e-mail messages which contained evidence of the attempts of the Plaintiff to turn the child against Defendant. 4. At the conciliation conference, Plaintiff asked for the names of any therapists with whom the child had counseled, copies of the e-mail to which Defendant referred and evidence of any drug problem or treatment therefor. Defendant refused to provide any such information. 5. On March 27, 2000, the undersigned addressed a letter to Defendant's counsel seeking the same information. No response has been forthcoming. 6. The case is set for a hearing on June 7, 2000. 7. In order to properly prepare for the hearing, Plaintiff needs to know the names of all of those who have evaluated the child, receive copies of the evaluations, and know the names of martin petition for discovery tjb May 1, 2000 those with whom the child has treated. Further, Plaintiff believes and therefore avers that the e- mail from the child to her father and grandparents, which is in the possession of Defendant, should be provided to Plaintiff so that he can prepare his case. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to provide the discovery requested. FLOWER, FLOWER & LINDSAY, P.C. Attornevs for Plaintiff By Carlisle, PA 17013 (717) 243-5513 VERIFICATION The undersigned, Carol J. Lindsay, Esquire, avers that the facts set forth in the foregoing instrument, based upon information and belief, were developed from conversations with Trent K. Martin and information gained in the investigation of this file, and this Verification is made for the reason that his Verification could not be obtained within the time allowed for the filing of this pleading, and this Verification is made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. FLOWER, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff 11 East High Street Carlisle, PA 17013 (717) 243-5513 martin petition for discovery tjb May 4, 2000 TRENT K. MARTIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 99-7355 CIVIL TERM JULIANNE WINTERS, Defendant IN CUSTODY AND now, 2000, I, Carol J. Lindsay, Esquire, of the law firm of FLOWER, FLOWER & LINDSAY, P.C., Attorneys, hereby certify that I served the within Petition for Discovery this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Keith Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE 44 West Main Street Mechanicsburg, PA 17055 FLOWER, FLOWER & LINDSAY Attorneys for Plaintiff By: , Esquire ID #44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 Lr. (T?Ic- U :' Lt- U o `i <J { f! Ii Julie, Hello. Well, it has been a long time since we last spoke. I hope that all is going well. I really hope that this letter reaches you as I just recently got the address from someone who lives in that area that said that this is where I could find you. I know that the address sounds familiar, so, I hope that you are still theWFirst off I would like to apologize to you and our daughter for being the person that I was when we were nt9rried and as far as that goes, the person that I was up until a few years ago. God, I don't know how I ever lived like that. I guess it takes some people longer than others to really grow up and face life. Now that I have, I don't know where I ever found the time to do all of the crazy things I used to do. It seems now that I hardly have time for the things that have to get done. I know that things for you and Cassie must have been very hard and there is no way for me to tell you how sorry I am for not being there. I truly don't know where my head was. I don't blame you for not wanting Cassie around me or knowing me at that time. Since we last spoke, I have made a lot of changes in my life-all for the better. I went to college and received my Associates Degree in computer science. I'm still taking classes from time to time to try and get my Bachelors. The education that I received really helped me in more ways than you will ever know. I actually started believing in myself and got the self confidence that I didn't have before. It really changed my life. I found that I didn't need anything to make me feel better any longer because I was OK with myself. I am now working in an entry-level position in my field and am really enjoying it I was remarried in September of last year to a woman from Brooklawn, N.J. (I don't know what it is about you yankee women), and things are going really well. The only thing about my life that bothers me at this point is that my daughter does not even know that I am alive or that I am her father. I want her to know who I am and that I am here. I didn't want to write to her or try to reach her without your pemtission-I owe you that much-but I would really like to have some contact with her. If you would write to me or call me and let me know something, I would appreciate it Sincerely, Trent Martin 3428 Cove View Blvd. #404 Galveston, TX. 77554 (409) 740-4160 3 PETITIONER'S EXHIBIT .;.w; I J.;11 <)o jOJ 1181HX3 S183N011113d t a?i 'U O C pro 3,`"c C o iu ° o?^A s O op d a .x .. G ,. s o ?'°3? ?0 t2 C? is y_ C44i y V 0 .x.. ? 6 N2o =0,.?3 o ? ?'' ? • V Fi N 3 J ? TAO C T >+ d E > C H r .C ? C U W H °^ 3s c 00. r N " ° o o a °c'oE d?"o t ? M a? a? E 3a°'is0o 7 t > .D H d .00 0 ?Ta?i? 3 3 ? e o y c A m N .C C „y N ?. y 7 y y 7 ed -0.0 4 t.. is r T U T ti U .d A ? ? ::: c>?g >. ?\\\ ` ® ®w t; ,,. ?... - `. !'^? ??\ /kQ k .. b ? a F ?. j `???y ?-,? S? N.? a %t-A ?J ? - -47 `) -' zir- a3A ?ro a (11 0 1 J1 1 r? ?: ?I Jt f ij 1*I ? 12108/1399 13:,32 794-6062 SLEH INFO TECH PAGE 03 W, I zh 41 ? ? -°?K°??,y ? :off ' ? e?! ?_.?C ??! ? ?!? sc:?l?p..yy...a6 -?'`l'I'?°?='-'1. ? ?• er COL It* V ?5. 4c??~.'z of :. $-?oa..t sly !?c f OL a .? 10 SQC?, ve! ho "' s'1g All ds t al?ir' h '?' rail a S Sa •weu ru ?P5 j'"aS-? 2ar ow Q V* 4-a move 4V o ,p 4-••h-e jw) of w%T, ® J ,mow 5r? ?a?d' "? l "" •ti and •»?Mr fat nd. x ?o tv ? ,? ?? F ra?Yrl?il and e u2 go ; V-l 20. 4w F;pf of t? '+ e0 o ??! ?.? ?? ?? V* oo®? .tae a? 2 PETMOMEW$ EXHIBIT .-7<co L Ill 1 -? 11 2'09!1339 13:32 7911-6062 SLEH INFO TECH PAGE 011 iw 'L ! a r1 .?k , t h ?+ ' weeds ?.-. _. tt :Cho - tee rA t = 4 41 vilick loft Ong k d'?. a Std . •? rho- tt k e r •:, ?: : ?USS'? P ' ? gyp: .. ..:..... :. Contii Help _ _.._.. __w_.._._ _ ..__...__ ..;.._ _ ..._ .............. _ _.. . _ _.._... H ` Reply Reply all Forward Move Delete ? Download All headers Next>> orI Date: Tue, 07 Dec 1999 07:53:03 -0600 From: "Kenneth Martin" <kmartin@sleh.com> Subject: Re: Call To: tweetys_girl@mailcity.com Add to Address Book Add To Spam Block List 1217199 7:50 PM Hey you, I keep trying to call but it either rings and rings and rings and rings and rings or there is an answering machine. I have left a couple of messages but I haven't gotten a call back. I need to know FOR SURE that your mother is letting you come down for Christmas so that I can get you ticket. I need to get it no later than this week so I need for you to get her to call me to confirm that she is going to get you to the airport this year. I hope everything is going ok there. Everything here is fine and everyone says Hi. We love you and look forward to you coming down. Love ya bunches, Dad >>> "Cassandra j Martin" <tweetys a_irl@mailcity.com> 12/05 9:15 PM >>> Dad I've been trying to call you and I can only talk right now. It's Sunday I need to talk to you but I can't until next sunday now. I love you and love Dallas and Sherri too. talk later, Cassie Get your FREE Email at httm://mailcity.lvcos.com Get your PERSONALIZED START PAGE at httn://my.lycos.com ',.'Reply ' t Reply all ' Forward Move ;Delete "Download "All headers I Next» ©1995-1999 WhoWhere? Inc. All Rights Reserved. Copyright © 1998-1999 Lysos, Inc. All Rights Reserved. Lycose is a registered trademark of Carnegie Mellon university. erms and Conditions Standard Advertising Terms and Conditions IPm j j Date: Mon, 13 Dec 1999 07:58:00 -0600 From: "Trent Martin" <prod(gus@evl.net> Add to Address Book Add To Soam Block List Subject: RE: Call To: <tweetys_girl@mailcity.com> Reply To: <Trent_Mart1n@b1gfoot.com> Hoy Cass, a chance to Well, I finally checked my email this morn.=.ng• I didn't get check it all weekend due to shopping on Saturday and working on Sunday. I actually didn't get off until after 1:00 a.m. this morning. I'm realy tired. Yes, you are correct. I obviously wanted to talk to you but I also needed to find out if your mother was letting you come down for Christmas as she had previously agreed. I'm sorry that she isn't going to let you. Do you know why? And what's up with the supervision stuff she is talking about? hmmmrrm=..... Everyone is sooooooco sad that you are not going to be here again this year. We should have all this stuff cleared up in a few months. I know it's not easy for you. Hang in there..... I was so happy to hear that you're doing well in school. Keen these grades up... T_ guess you'll be taking drivers ed. next year. I'll try to get you some information on the school down here. You know, school colors etc.... Well, I have to go to work now. T- really enjoyed our talk last night. Is the 9:30 your time thing going to be the sett' tine from now till you come down here, Just let me know in an email You can al:vays call me collect if you wart. That goes for your grandma too. Whenever you reed to talk....... Love ya, Dada --Original Message----- From: Cassandra j Martin (mailto:twe?rg5 girl@mailcity.com) Sent: Saturday, Derenber 1.1., 1.999 10:34 PM To: Trent Martin Subject: Call Hey Dad, I, i1 call you at 9:30pm my time on Sunday. My mom says to stop calling me but I have a feeling your calling for her. Guess what? I have a boyfriend! His name is Travis. He is really sweet. He just brought me back from meeting his parents at his house (he drives)! His parents are really nice. 1711 talk tomorrow. Love You Dad! -Cassie- P.S. I have violat eyes now. On Thursday I an getting my blue contacts. Love ya. -Cassie- LYCOShop is now open. on your mark, get set, SHOP!!! htto://shoo.lvccs.com/ 12J13199 11:55 M7 I cf2 Inbo > Fwd: Nope -.? ............... ........ ............... . (] 11 rt<DIY ? 11 PeDIY to all Forward FF O y;u Delets J 1 ti: Move move message to Draft < Previous I Nast > un ]an 2 2000, 2:14 PM PST _ Date: I _ _ _ ........................... ..................._................ . o: ub ject:? uleglrlC?go: corn r Fwd: Nope Forwarded Message DATE: Sat, 01 Jan 2000 23:15:41 From: "Cassandra] Martin" <tweetvs girl(@mailc!tv.com> To: 'Trent Martin" <Trent MartlnQ8-,clf00I c0m> Hey dad, I didn't get your email but I am going to scan a picture sometime really soon so t at you can see a picture. I will actually send you two pictures, one of my school pictures and one of my homecoming pictures. Maybe I will also send a picture of my boyfriend. When I talked to someone they said that you were concerned that my boyfriend is black and that You were worried that I would change my mind about moving because of him. 1) he's not black. 2) 1 do want to move. 3) But I do really like him.... well I have to email him now. I will talk to you tomorrow......... I love you! -Cassie- LYCOShop is now open. On your mark, get set, SHOP!I! hgMLgho0mI End Forwarded Message ---- LYCOShop is now open. On your mark, get set, SHOPIIl tun- lshop_ Ivcml 3?'T t H Move Move message to Draft 0 N ReD1Y ?') 11. geDly to all Forv.ard H O M EE < Previous I NeM > V4100 1:22 PM of 2 ? Help © Sign out Home > Mail mail GOcom i Home > Mail mcaU Bills to pay? Inbox > Fwd: RE: Nope 41 Reply J 44 Reply to all Forward tt 211 R 0elets Move message to! _.Draft.. J_ "Move ? r... .. ` FREE :.... ::rrmcr Click Here 3 Help Qe sign out < Previous I Next > 'Date: Sun Jan 2 2000, 2:12 PM PST ......_;........._ .............._..._....................................................................................................................................................................... ................ ........... ..._............................................ o• yulegirl@go.com ubject: Fwd: RE: Nape Forwarded Message DATE: Sun, 2 Jan 2000 08:58:31 From: "Trent Martin" <orodigus(a?evl.net> To: <tweetvs girl(@mailcitV com> I can't believe that you didn't get my last email.. It was a good one too. Well, I guess we can see if you get this one. I can't wait to see the pictures. Actually, you were only half right on your info., I wasn't concerned on whether or not he was black at all. It didn't even cross my mind. I was concerned about you changing your mind but at the time 1 didn't realize why we weren't speaking as openly on the phone as usual. I do understand now the situation you are in and know that you are unable to speak to me as openly as we had in the past. We love you and want you to be happy. Looking forward to talking to you today............ Love ya, Dad, Sherri, & Dallas -Original Message- From: Cassandra j Martin Imailto:tweetys girl(rDmailcitv.coml Sent: Saturday, January 01, 2000 10:16 PM To: Trent Martin Subject: Nope Hey dad, I didn't get your email but I am going to scan a picture sometime really l? I? 1 0r2 2/4100 1:27 PM . .?2i- i•: l•. :?.- :? .. c1a?. ..._....11112 !'7? ..".?. ?i .'. '!'.?i1 ?f7? MILTON HERSHEY SCHOOL CANDIDATE FOR ADMISSION CONFIDENTIAL - FOR PROFESSIONAL USE Cassandra Martin' 03-21.86 Monoe?County. PA F -Student's legal name is Cassandra Martin, however she uses Cassandra Winters. School records are in the name of Cassandra Winters. SCHOOL GRADES LAST TWO YEARS School Grade Enalish Moth Reading Spelling S.St.idlee Science Conduct Herbert Hoover ES 3(10) A• - A B+ A - 2 B A B - B C ?/+ 1 Good oumandinaGood ouwr,ndwg Good Good + 2nd grade teacher writes: "Casale's poor work habits have hindered her progress and effected her schoolwork. She should show more interest in learning and complete assignments on time." SPECIAL INTERESTS AND ABILITIES Cassie is not involved in any activities at her school, but she takes gymnastics classes at the YMCA and Is Involvaf in cheerieading for the community little league. If enrolled at MHS Casale would like to pursue choedeading, Ice Skating and tumbling. In her he time Casale likes to play with her ferret and her dog. She also plays with her We and her Nintendo. At home Casale Is responsible for cleaning her room. She also helps out in the kitchen. She will often cook an entire dinner for her mother and herself since her mother Is recuperating from an Injury suffered L'nree years ago in an automobile accident. STANDARD TEST P R LE V T PERCENTILES (PAST TWO YEARS) TEST DATE READING r eru_r.Lraa_F_ m6m JP-UL ITS$ 12192 46 40 84 CAT 10191. 48 66 COMMENTS FINANCIAL STATUS ............. S supported by mothers boyfriend • mother divorced. BEHAVIOR .................... 3 CDI .10; acceptable, 0X7.56; acceptable. Mother reports no significant behavior problems. Cassia does not have a dlsoiplinary record at school. MOTIVATION FOR ENROLLMENT ... 3 Cassle wants to attend MHS because she thinks It will be run. Fier friend Alexis Neal already attends MHS. If enrolled, Crisis plans to remeln at MHS until graduation from high school. When she grows up she wants to be a teacher. FAMILY SUPPORT .... . .... .... 3 Ills. Martin Is supportive, but her mobility is limited unless she is on pain killers as a result of a 1980 car accident Though she appeared to have no problems at the time of the Interview, her mobility may affect her ability to visit whish she acknowledged. INTERVIEWER'SPROONCSIS ... .3 SCG Coanrudq ?Klpw• ADDITIONAL COMMENTS Casale is an adorable young lady, but she spoke at length about the children in her neighborhood who do not dress as nicely or cleanly Be she does. She referred to these children as 'hashbage". She has a definite "class consciousness. She Is a good student. Her mother appears to be a bit overprotective. Siblings: Casste does not hsve any brothers or sisters. Interviewer. TAQlr`'? Date: 12-17-93 Referral Source: Alexie Neal (a current MHS student) is a fdend CW g PETITIONER'S F,t7()gIBIT .- .pC1 TU: PERSONAI. SUMMARY in ' the Student's legal name is Cassandra Martin, however she uses Cassandra Winters. School records are name Of Cassandra Winters. Casale arrived for her interview wearing a light blue and white knit skirt and matching top. She wore white stockings and black dress shoes, Her dark hair was just below her shoulders. Castle brought a stuffed dog with her to her Interview. Though not out of fear, she clutched her dog throughout the interview, Casale was accompanied by her mother and her mothers boyfriend. Cattle is an adorable young lady, but she spoke at length about the children in her neighborhood who do not dress as nicely or cleanty as she does. She referred to these children as "trashbags". She has a definite "class consclousness". She is a good student. Her mother appears to be a bit overprotective. Casale has attended Herbert Hoover Eta in Langhorne, PA since let grade. She attended kindergarten at Albert Schweizer ES In Pendel, PA. She switched schools because the family moved. Casale's favorite subject in school is spelling because she likes to write. She also Is quite fond of math and social studies. Cassie's least favorite suoect is science because it is herd, Casale's grades have been A, S. C, good, and outstanding. Casale does not have a disciplinary record at school. Castle la not involved in any activities at her school, but she takes gymnastics classes at the YMCA and is involve in oheerleading for the community little league.. If erroiled at MHS Casale would like to pursue cheerleading, lea skating and tumbling. In her free time Csssle likes to play with her ferret and her dog. Sne also playa with her doll: and her Nintendo. At home Castle is responsible for cleaning her room. She also helps out in the kitchen. She will often wok an entire dinner for her mother and herself since her mother is recuperating from an injury suffered three years ago In en automobile accident, Cassle wards to attend MHS because she thinks it will be fun. Her friend Alexia Neal already ettends MHS. If enrolled, Casale plans to remain at MHS unfit graduation from high school. When she grows up she wants to be a teacher. The following information was provided by Ms. Julianne Martin (Casale's Mother): Casale was born In East Stroudsburg (Monroe County), but has lived most of her life in Langhomo (Bucks County). Cassia's father abandoned the family before Castle was born and she has never met him. Ms. Martin's boyfrend lives with Casale and her mom. Ms. Martin described Casale as "ell girl', affectionate, kind, and soft spoken. She said that Casale likes to be hugged. In a group castle is not a leader, but is not necessarily a follower either. When she Is ang,y she will either Isolate herself or confront the individual she identifies as the source of her anger. Sometimes she gets "snotty" when she is angry. She is most often angered by teasing. MN- 'When Punishment Is warranted Cassia is sent to her room, She used to get smacked, but Ms. Martin does not feel this Is effective. Cassia acknowledged that she used to get spanked with a belt, but that it doesn't happen so much anymore. Cassia Is very good at making friends and Ms. Martin has never been concerned over the friends Cassia chooses. Cassle has never witnessed or exaerisnoed any form of physical, sexual or emotional abuse. She is depressed on occasion over her mother's illness. They are currently In counseling (both mother and daughter), and documentation has been forwarded to MHS. Casale has not expressed suicidal Ideation and Is not at risk for the use or abuse of alcohol or drugs. Ms. Martin 18613 Cassia will make a quick adjustment to MHS if enrolled. Cossie does not have any brothers or sisters. The candidate was informed of the highiy structured student home environment and the chore program during the Interview. This information war. also provided through the a & A video and the Program Information Fact Sheet. The candidate and sponsor were both Informed that H enrolled at MHS specific home placement could not be guaranteed. omas , orm ey, , Admissions Counselor a:i' -'iJ ... c•.. ?? .: ttti: ..CLr. 11- ,e t• -ti MILnTON HERSaHGEY SCq?OL SIDEMAL StudenlNat:c; (... n \. l.. , t Date' \.a.t , . . s s ?•.'1 SuidemHome; J1''vit ) Grade: The purpose of true Residential Progress Report is ;o summadte}nur child's progress b our residential sewing wida regard to the School's Nsired Results. It is our hope that yuu review dds infonnation so that sve can discuss I;uw xe can work together to encore the success o1•your child. Please feel free to contact us ifyou have any gite' \ stioac ar Hoasepar . l-k -Excellent 3-VervGood 2-,Adequate 1=Poor 1. Communication WIN. Cummems: i -ate t 4 3: , K' r 2 r. 1 . `mac ... ?- ..' ,.. • i ?' ? ?• ? - 2. Understandutg gAmj respect for the commonalities and diversities of other people and cultures. 4 3 2 1 3. Participation inrSchopl/Communityservice. 4 3 2 ! umtmnus: ., . 4. Participation in School activities, such as co-curricular, learning clubs, visual and performing arts, and student home activities/- ! 4 3 2 i Comments.: ?'- ' . 5. Healthy intcpc rural relationships. t 74 f 3 2 1 6. Responsibilit IsTtf; fan ly School, and community, 1 4 3 2 conuncatc ?. Hmithyand p,oWd'nvelifestyles. L 4 3 2 1 COSmants: - \?_- - 8. Ability to make,,yiritual, ethical, and moral decisions. r' 4 3 2 9. Detnonsuares respect cooperation, and self-di:Fiplinc? 4 '3 2 1 Commentr. V\" 1 10. Coal seeing, problem solving, and responsible decision making. 4 i 3 2 Whin - Syu ta' Ydivs - Houukwant Pink - S:wlurr Ple -- i1?.??f (_. L(: i '. t ,... .. L. i'c. , -¢? C..iC_ \t C-r ....\.. (C. t? . i c l .::r::*1 ..CLC .:'!t. Q; I. .:.1. al'. 1 i (.?'i7 •:' F. ` `?ILTON HERSHEY SCHOOL 66 STUDENT HOME PROGRESS REPORT it ~ - -"firStud:nt Home) (Grade) St dent s , am Dear ParcntiSponsor: The mission of the Residential Division Is to teach our children life skills and val.'es in a stable, nurturing environment. Our houteparenti are, therefore, the key to teaching these skills and values that we feel em so important in order to provide out students with every opportunity for success. The Student Home Progress Report Is designed to give our houseparents the opportunit, to communicate your child's pro- gtess in the student home. Although there are many life skills and values which we feel are important and attempt to teach, this report will review your child's progress in three basic areas - appearance, behavior, and work habits. All students are encouraged to maintain a neat appearance. Good grooming, personal hygiene, and care of clothes are all important aspects of one's appearance. There are several essential qualities or behaviors which we feel are important as we attempt to guide our children to live suc• cessfully with themselves and each other. Honesty, self-control, respect far others and their property, a positive aaitude, man. hers, sportsmanship, clean language, initiative,, punctuality, and cooperation are examples of positive behaviors we strive to develop. Success In today's society Is often determined by one's work habits. Through our student home orogram, we attempt to teach appreciation for responsibility, understanding of teamwork, development of an efficient approach to assigned tasks, and appreciation and respect for honest work. In the space provided below our houseparents have the opportunity to share with you your child's progrcKs in the areas of appearance, behavior. and work habits. We encourage your support and the opportunity to work together toward a common goal - the successful development of your child. Key for Student Progress G = Good Progress S = Sadsfactory Progress N = Needs Improvement ).APPEARANCE Comments: COMMENTS: A = Listens well and follows directions B M Shows improvement C = Works to his/her ability D = Demonstrates neatness and organization E = Uses time wisely F d is courteous and well-mannered G = Works well with others H = Demonstrates leadership I = Does not listen or follow directions ] = is capable of better work K = Demonstrates Carelessness and disorganization L = Does not use time wisely M = Is discourteous and disruptive N = Does not work well with others O = Acts inappropriately P = Does the minimum to get by D,_BHHAVIOR Comments: Q WORK HABITS Comments: Additional Comments: - _ 7/- • / `- 1 (Houselterent's Name and iclcpli3ne Number ? We welcome the opportunity to meet with you or speak with you about your child's progress. WTiW •PUMYNIO?• N9YM1Fntnl 9in$ •SICNnil I-W FIRM Rib 119! I. J IF - I U. ? o U ? a •? 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J 0 C ¢ 0 + 1 a 0 c 0 X ° or F, C4 u c O V ° o .= o I;LE MILL] U 4 In u .G .G aj en d u y F li7 ie v c v a v ? v v v s v u a 'u v c v =• `' •o ' •p oo v c c E u v? u 1 GI! •p 04 v ` O _ 4 N c p ell O O o n c u c II II II `ed ? (7 Q) II II w 0 ?p?rnrn`o oc l"D 3 8 8 . o a, oor ? < m U A w L yC v 1?3 o ° I- • 73 E ' J d... .. v .i '? r C ;MP ? j v ,• ' , 7 •r Cry 4 ??v' N - ? 1 ? .S C V (C t 3 ) 1 + }- + 1 I + I y- . + 7 I F 1 N j (n F t i •a T v T C x "= 1 0 y ? ,o p a - ' 5 ell •-• .C 'a v m a E 6 0 w v u a U a .p .r v c r N 'O N ° N ed %. H u u O F v y N. 1-. '^ y 'c C [.., u Ou N Ca v. ?+ v s v V c W c u E a E Cb p C o 'u v v of u . T 0 CO ° E 'C CL i COL. ti w v . . .N u O ° A° 3 3 ti a a 3 z i° c -- - - - - - - - - - - 1 N G N 1 N 2 L L ?. O s c 11 E N u 'c {p U .c •? v N ell E N e F s ; c 3 3 ° N v J E E x c u v N E oo . F Q A c V 1 3' , 'O U C C 9 o •v L .V u C t° NU E :C v] V 'u o. U %. L v N (.Lt V l C C' ° t .p v v N '^ - 'v uvli a u N U 4 Q v 3 rVi a F 0 ° u u a 773 v o o c o f a u `o v N °' na: A w `>: n u .o n c •? 00 !. N Vi N C 04 M N •? N P. N V u1 / O y to u U E 2 °_ v '- v a °= G c E o e c aN o E 0 n 4 ¢ ¢ = y < ¢ a U° 1° G a A u w ¢ u° PROGRESS REPORT VIILTON HERSHEY SCHOOL senooLrEAR P.O. Box 870 96/97 HERSHEY. PENNSYLVANIA 17037 STUOENTNO. ORAOE SECRON NAME 771 _ t COURSE CREDIT IM QUAR TER 7b OUAR 7ER COMMENt A JN OUM E C TER COMMEM FINAL EXAM FINAL AVERAGE STUDENT ER NUMBER VALUE TEApI A C COMMENT o A E C d A SUH A A JKH C B MA H 02205 .13 A A A GKO K B WELSH LANGUAGE ARTS 01205 .26 C 8 A K r 8 8 A GK B B A GKL B ADAMS SOCIAL STUDY 6 04205 .13 A B A GK 8 B A K B A A K C B CONNER C B A B B A C B A 8 B A KL B SCIENCE 6 03205 .13 2ABOLOTNY A A A 0 C A W D D A W B SPANISH 6 04605 .05 B B A EBERSOLE C B A C 0 A SY B A A C D A SY C PHYS.FIT/ACT.6 06202 .06 HOST/HISSI C B A 8 C A A 8 p B HEALTH 61 06302 .04 B A A LOSER CAREER EXPL 61 09202 .10 A A A GIK C 3 A B B A C B B 8 CAREER/STA g p A GK B ART 61 07502 .10 SCHELHORN B C A A B A A DRAMA 61 07602 .05 WALLER A p p p p p A MUSIC 61 07702 .OS LAPPANO CADET BAND 07801 .07 A A A A A A A A A A A A A COPENHAVER p p p A A A A CHORUS 08001 .OS WALLER 9 .9 .0 3.0 MARK POINT AVG .9 . 5 1 EFFORT CONDUCT .7 _ S . SPECIAL SUBJECT A. ACHIEVEMENT E+v=CRT C. ccvoccT JULIE WINTERS 3050 MORNINGSIDE OR CAMP HILL PA17011 Y 4 O TT.AI' T• A C CA hinz A .I DEER PARK MILTON HERSHEY SCHOOL P.O. BOX LID HERSHEY. PENNSYLVRNUL TT07J TUOENT Na GRACE SEL 68457 07 V SC"OOLYEAR 97/98 ?. ?... .... ....__?.----- - .C0IRi7E CREPT * •? i.i.T•..rtN:: .: "ri•??':' '•'?:?;;'1•. .:: .?RR?1' •.VALLE A to WA E C ATER COWENT A yn OIAV C UEA MAFIR CO A yyOUA E C RIER omomr A •Jm OUA E C RM COMMENT FML. 7GM 'NIAL AVENGE LSN,.ARTS 7 01708 .14 C C B C C A KUY - CAMPBELL COMM 7 OlaOB .07 A 8 5 JM C 8 A K NALEP MATH 7 02208 .14 B C B 0 0 R SW QUEEN SCI.7 03707 .14 A B B C C C TREDINNICK WORLD ST-7 04707 .14 0 0 C UW 0 0 0 M DOHNER8 SPANISH 7 05604 .07 B A B C C B SCHUSTER PHYS.FIT/ACT.7 06408 C4 B C B 8 8 A HOSTETLERR ML EALTH 7 06508 .03 C C A D D A SY HISSICK FAM/C0NS.SCI.7 06608 .03 C C B C C A ROG°_RS A-T 7 07206 .10 C C B KU SCHELHORN ORA4A 7 07506 .05 T:tGXELL P..USIC 7 07806 .05 LAPPANO B&G BAND 08001 .07 A A A A A A COPENHAVSR CHOIR 08201 .05 A A A A A A LAPPANO PIANO 06501 .02 8 8 A B B A LAPPANO CARER EXPL.T 0E707 .10 B A A K A A A K BARE MARK POINT AVu .8 .I EFFORT COtI:)UCT :COCURSETYPES A .AOVANCEO PLACENEMT S . SPECIAL SUBJECT JULIE WINTERS 3050 MORNINGSIDE OP. CAMP HILL PA17011 A.AMEVEALENT E. EFFORT C.COH000T 1-7 MILTON HERSHEY SCHOOL 1998 COUNSELING SUMMARY STUDENT NAME. Cassandra Martin-Winters STUDENT HOME: Deer Park GRADE:7 DATE REFERRED: 8194 COUNSELOR NAME: Karen R. Streeter, PhD. DATE: 2111 198 WHO REFERRED STUDENT FOR COUNSELING?: Informal ADA Plan DATE DROPPED FROM COUNSELING: Mid Year Summary-1997/98 NUMBER OF COUNSELING SESSIONS: 15 WHY WAS STUDENT REFERRED FOR COUNSELING?: • Enrollment at MHS with prescription for Rltalfn Hyperactivity an issue SUMMARIZE WHAT HAPPENED IN COUNSELING: At the beglrni,ng cf this school year. Cassia expressed a desire to switch to a new ;herap:st. She was not able to articulate wny she wanted this request but was consistent In her desire to switch to a new therapist. A new therapist was found for CaSslo In January of this year and she will be transferred to Matt Campbell, a psychotherapls:In Catherine Hall. Cassle was taken off Ritalin during the summer by the pediatrician due to some question of emotional issues being combined with her ADHD symptoms. Cassle has since been referred to the psychiatrist to further Investigate any evidence of depression and/or ADHD. Cassle continued to straw problems wti being passive, especially with peers, and interpersonal problems with father over breaks. Cassie will continue to be assessed by the psychiatrist whh the help of Matt Carnpbe!I and a psychological evaluation to be performed by Karen Streeter this marking period. CASE WAS CLOSED BECAUSE: M N/A O Problem Reeavac EI Withdrawal from MHS O Other (Exp'ain) STUDENT SEEN FOR: Q Group Courseling 21 Individual Counseling gn. ure or f sychologl Ccunseln: ko( ,'', ' MILTON HERSHEY SCHOOL 1998197 SUMMARY OF COUNSELING STUDENT NAME: Cassar dra Martin COUNSELOR NAME: Karen R. Streeter, MS STUDENT HOME: NP DATE: 6/11197 GRADE: 6 DATE REFERRED FOR COUNSELING: Transferred from Cindy Kern, MI-1-original referral date-6/94 WHO REFERRED STUDENT FOR COUNSELING? Informal ADA plan DATE DROPPED FROM COUNSELING: WA-on-going NUMBER OF COUNSELING SESSIONS:9 WHY WAS STUDENT REFERRED FOR COUNSELING? • Involvement at MHS with prescription for Malin, hypotactNlty an issue SUMMARIZE WHAT HAPPENED IN COUNSELING Cassie continued to take her Ritalin on a daily basis, and was monitored by Dr. Thuma. Therapy focused on relationships with peers and student home issues as well as being assertive. In January, Cassie's mother took her from the student home and refused to bring her back until a meeting could be scheduled to talk about transfer to a new student home or possibly withdrawal from the School. This appeared to cause Cassia, some anxiety. A result of that meeting ended with an agreement that Cassie would stay at MHS in the current student home. Mrs. Martin-Winters and Mrs. LaFrance, the houseparent, would also actively pursue a closer and more open relationship as it relates to Cassie and that Cassie would participate in a social skills group at Catherine Hall. Cassie did participate appropriately in the group, however, upon completion of the group, Cassie was still having problems with peer relations as well as communication with the houseparents at the student home. Casale did not appear to be using the skills covered in the social skills group which included assertiveness training. It was agreed that Cassie would go back Into Individual therapy with becoming more assertive as a goal for next year. CASE WAS CLOSED BECAUSE: STUDENT SEEN FOR, H WA M Group Counseling O Problem Resolved ® Individual Counseing M Wdhdrawae, from MHS ? Other Sigfat re of PsycnotogisUCoundelor MILTON HERSHEY SCHOOL SUMMARY OF COUNSELING STUDENT NAME Cassandra Martin-Wieners COUNSELOR NAME: Cynthia A. Kern. MA STUDENT HCME: Parks-E4 (NP) DATE. Juno 15, 1996 GRADE: 5 DATE REFERRED FOR COUNSELING: August, 1994 WHO REFERRED STUDENT FOR COUNSELING? Informal ADA Plan DATE DROPPED FROM COUNSELING: Erd of year summary - 1995 -1998 NUMBER OF COUNSELING SESSIGWS: 41 WHY WAS STUDENT REFERRED FOR COUNSELING? Enrolment at MHS with prescr ptior !or Rilal:n - hyperactivity an Issue. SUMMARIn WHAT '-IAPPENED IN COUNSELING: Cassia continued to taKe her Ritaiin on a daily basis during the school hours only and was monitored by Dr. Thuma. Therapy was held on an every other weak basis and focused on poor interactions, honesty, and comp!ating her rosoonsibilities. Around spring break, Cass :a began to talk about possibly withdrawing from Milton Hershey School at her mothers request. This seemed to cause Casete some anxiety and her behavior began to sl p in that she became somewhat aggressive with peers, tearful, falling to completo her work, and had trouble controlling her tamper according to her teacher. Student home issues were not a prevalent. The therapist talked with the mother about the possibility of withdrawal causing Cassle some a'lxiety and !ho mother agreed to talk to Cristo about it. Towards the end of the semester, Cassie stated that she might remain at Milton Hershey School and seemed to be more comfortabla wish this decision, however, a declslor, has not yet been made forma!ly. Summer plans: Soend some limo in Summer of Opportunities, discontinue Rltaun, spend time with mother in local area and rather out•of-state. Fall plan: Resume Ritatin as pot Or. Thurra, continue supportive therapy on an as needed basis. CASE WAS CLOSED BECAUSE: WA. STUDENT SEEN FOR: _ PROBLEM RESOLVED _ GROUP COUNSELING _ WITHDRAWAL FROM MHS INDIVIDUAL COUNSELING OTHER iEXPL A, N) 411 SI OF PS CAL UNSELOR GNAT RE Me .?::?' C'S) :fit: :): ..??._. .,__...i:^.'i$ '!L•. }? ?Ci. i)?.44?.. Catherine-Hill INTEMMUTIONTEAN172 LtiTTIAL pLANMECOUMNDATIONS for: Other: I aaLs Student of Concern: a MO_A._A,?,2 Date of Plan: ?- Reeatntneodotlons: Per•op Responsible: ADA Plan: _?GdlcaMental - Medical Eval -Dental Eval SpeedvHear(ng Eval Other: ?cademlc: _ LAT Referral Remedial Reaeling/Lang Arts Remedial Math Classroom Observation Other: _l,ZPsycbol1oo0?cal: __VIudhMdual Coumeling/ASSess for -Group Counseling jZEduc2donal Test'stg Persotuelity Testing V Psychiatric Evol _ Other. _ ,%?eighborhood & Family Life: -Student Obaervatlan Student Ilame Plan _Dlseoss Stud. Home Ieter"BUaas w/HP's -Other. m SIGNIFI A.\TM.-DEN'GS: ` - SPECIFICS OF PLANK: Intervention Team Members Present: C snille. (Acad) :i Welke- I* Delub (Lean Asst) htichelleAllen (Ps)eh) n Qvted) - (11", REVIEW DATE; 31ite 4Q -MTG. COMPLETED: es 110 ADA Plan attached *Individual in charge ojeaordinaling the case %Y W Student f Co SH: Catherine Hall 'TRIAGE TEAM' Referral (assessment & disposition team) icern- C12AAiQ M`611 Team: 17 Residential Administrator: - C.;!4, :L. 6 Are ,41s of Concern: Academic Behavioral Check all appropriate descriptors: ACADEMIC BEHAVIOR + )/FRY SLAW PACE OVERLY AGGRESSIVE lpn. FOLLOWING DIRECTION CL'LTY CONCENMtATING _ R SCHOOL WORK SCONSTANTDIRECTION OESN T COMPLEM WORK - CARET t?SS MLSIAKES 1FF. ORGANa1NG TASYS/SELF ?OSES IO:CESSARY MATFBIAIS ? OFF TASK ?/ DAYDREAMS OMN JJLSTRACTIDtF ?[?O0 R RE1t0. LIGN y/OORSTUOY HABILS II _CON SISTRIT PERFORwLINCE _ WORKS SIG' II7CAhTLY BELOW GRADE LEVEL. MATH :: WxwG SPELLING :RZADLNG other. gTTFIDRAWS rWON'TTAL.K ERlMOTOR ACTIVE DERACT[VEn QtED AY DREAMS EXCESSIVELY IVE STLBBORNMEFUSES TO DO V DISRUPTIVE CK OF PARTICIPATION JLACKS INIMTIVB EMS ACCIDENT PRONE ASSIVE RIFF. ACCEPTING RULES _DESTRIX:TIVE STEALING CLASS CLOWN' --TALKSEXCESSIVELY ANOM-A\TAGONMS OTIMLS -INAPPROPRIATE SEXUAL SERAV _other- Dmotional EMOTIONAL. DEPRESS SAD ° _t Mvousrw ?CRLEs TEASED.MMM -POOR PEEP, REL EEARFUL PSYCHOSOMIATTC (N OF COMPLALNYS) _.f00 SWINGs _ sm OR"ATMUDE" -UPSETS EASILY R,OuTBURSrS OF ANGER -'SUSPECTED' DRUG USE TALKS OF SUICIDE' DEATH oUICMAL THREAT-' GESTURE _suica AL ATTEMPT other: What kind of interveutiou/s have you already tried' ia!rt ,? t her, *J King, piacln? her on Ci;u.?Zyc?rl, . ,? 8ct her ? "Catt;h up o??.. us4 nmv?i55 Any Reeon?eendatious: (what do you feel may be iudicated/ceeded to be done for this . student) the she, needs " h? se¢ rt b?- a_ ecl.Lrt lGr. CQS?aE rrl Lx r, -1?dowr ;she leefs oI?erwhelmeel wren Referred by: *** Arrach aF Date: 6- /a - ?s flr edtrpossible**• ?(U k. on C.a_ru-vr bye hpr ?,?CiPnC2 t?'?C?7Pl ?`. She, dcc,+ -'emu.,, u)h? she GIu1?n/ G h,cm??c _I - - . chi'. nnain0- v4& lDr .7 71"1" REAyVNS 1'1IR wiTI:i7li UAL ?ci<f,?ca?drA l}?Li1'-{-1 ice. _ ?l 1 X18 STUDENP 9 NAME L-2: DATE I. PAR,IENT` INIT aT D . 1 • Remarriage 2. Flnanclal situation improved 3. AnAnclal situation requires child at home; e.g., to babysit 4. Moved out of state S. Parent's emotional needs; e.g., misses child Family/Community Disstisfaction with educational setting Dis8atisfaction with residential setting Dissatisfaction with special services; e.g., medical 10. Cornfliet with nonsponsoring parent it. BTURMIX MMMTED L Dislike of School's rules and regulations 2. Poor academic grades 3. Poor academic behavior 4. Poor behavior In residential setting 6. Desire to be inability to in home community 7. Desire to end schooling and enter the fob market 8. Feelings of stress and anxiety 9. Age 18 - sign self out I[I. l?OOL INITIATED 1. Disrespect 2. Stealing 3. Drug use 4. Inappropriate sexual behavior 5. Disregard of academic standards 6. Disregard of residential standards 7. Bullying 8. Emotional instability 9. Chronic runaway 30. Refusal to paltielpate In program Student'a adjustment at BM - ft Satisfactory ? Unsatisfactory Sent home - than". to sign ? Sent home - no chance to sign 2 Reeidcutial/I%d naI & afore Y1`^yy. TRENT K. MARTIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V 99-7355 CIVIL TERM CIVIL ACTION - LAW JULIANNE WINTERS, Defendant IN CUSTODY IN RE: DISCOVERY ORDER OF COURT AND NOW, this 1st day of. June, 2000, following argument thereon, the discovery motion of Trent K. Martin seeking the name and address of the child's therapist is deemed moot as this information has already been provided. That portion of his discovery motion seeking copies of subject e-mail messages in the possession of the defendant, Julianne Winters, is granted, and she is ordered and directed to provide copies of same to counsel for the plaintiff forthwith. Disposition on the remaining motion, namely that of the defendant for copies of other e-mail messages, is deferred. Carol J. Lindsay, Esquire For the Plaintiff Keith 0. Brenneman, Esquire For the Defendant By the Court, Ke in A. Hess, J. G -60 ';i K S :mae ?hki;{q 4: r, 1, )vi\ I Y A I cI w `E TRENT K. MARTIN, Plaintiff V. JULIANNE WINTERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-7355 CIVIL TERM ORDER OF COURT AND NOW, this 7th day of June, 1999, after hearing it is ordered and directed that the parties shall share legal and physical custody of the child, Cassandra Jean Martin, born March 21st, 1985. Pending further order, temporary custody of the child is awarded to her mother subject to a period of partial custody in the father during the summer of 2000 from June 19th, 2000 until August 14th, 2000. Further hearing herein is set for Thursday, August 17, 2000. Between now and said hearing each party shall allow the other liberal and frequent telephone and/or e-mail contact with the child. Incoming calls to Cassandra may be without limitation, though a party may insist that outgoing calls be made collect. It is further directed that the defendant make available to the plaintiff report cards and other school records reflecting the performance of the child during the spring semester of 2000. By the Court, Carol J. Lindsay, Esquire For the Plaintiff Keith Brenneman, Esquire For the Defendant it is, J. G. ?q.do __.__ ,.t _i 1 ?,._ '/ ._ _} + :.? i'. .1 :.-: ;. ;..I " _ ?_"? ' li ij c .:L C-? _? '" C7 C? martin slip for custody tjb October 30, 2000 6. In the event that the child determines that she wishes to reside in Pennsylvania with her mother, she shall be permitted to do so provided that the exchange of residence does not interrupt a school year. 7. The parties intend that the terms of this Stipulation be entered as an Order of Court. Trent K. Martin, Father Date: - 5 ao 0 11 1 SAIDIS SHUFF FLOWER uw Hleh aUeel CAdWe. PA Jut anne Winters, Mother Date: ZO/ t 7 br r /3 Ir '. i? martin slip for custody ljb Oclober30,2000 TRENT K. MARTIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 99 gr,5CIVIL TERM JULIANNE WINTERS, Defendant IN CUSTODY ORDER OF COURT SAHMS S & EFJ? - e? 26 W. elan street Grible, PA AND now this 30 ? day of Noel-- r- , 2000, upon consideration of the within Stipulation of the Parties, the terms thereof are hereby made a temporary Order of Court. cc: Carol J. Lindsay, Esquire Keith O. Brenneman, Esquire m? l?•ul.cro By the Court, :,_i rpr-f CE c0 NO'S 30 PM 3: 2e cumpF?n%'Nw martin slip for custody tjb October 30, 2000 TRENT K. MARTIN, Plaintiff V. JULIANNE WINTERS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99- CIVIL TERM IN CUSTODY STIPULATION OF THE PARTIES FOR CUSTODY 1. The parties hereto are TRENT K. MARTIN, who resides at 5002 Chase Mountain Drive, Bacliff, Texas 77518, since 1997, hereinafter FATHER, and JULIANNE WINTERS, who resides at 123 Limestone Drive, Camp Hill, Cumberland County, Pennsylvania 17011, hereinafter MOTHER. 2. The parties hereto were married on February 14, 1984, and divorced by the Court of Common Pleas of Bucks County, Pennsylvania, on December 13, 1989. 3. The parties are parents of a child, Cassandra Jeanne Martin, born March 21, 1985. 4. Commencing the same date as the date of the Order entered hereon, the parties shall share legal custody of the child. FATHER shall have primary SAIDFS SHUFF?? R physical custody of the child, and MOTHER shall have partial custody at times as 26 W. Mg, street desired by Cassandra. aHWe, PA I 5. FATHER will keep MOTHER advised of the child's special education progress. Cassandra must remain in an IEP Program at all times. i. ., i. r r. i ,. 77., T 4 [ y ?+ ? ^. .' m NW '. V ?.nin r ~ l ' t C?