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HomeMy WebLinkAbout03-3556STEPHEN R. ST. ONGE, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION - LAW JN DIVORCE AMANDA J. WINGARD, Defendant :NO. 0.3 jSs-6 COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Stephen R. St. Onge, who, by and through his attorneys, Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Complaint for Custody, in which he avers that: 1. Plaintiff, Stephen R. St. Onge, is an adult individual residing at 630 Cedar Ridge Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant, Amanda J. Wingard, is an adult individual residing at 35 Stoney Run Road, Apt #17, Dillsburg, York County, Pennsylvania 17019. 3. Plaintiff seeks primary physical custody of the following Child: Name Present Residence Age- Nicholas O. St. Onge 630 Cedar Ridge Lane 3 Mechanicsburg, PA 17055 4. The Child is presently in the custody of Plaintiff who resides at 630 Cedar Ridge Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 5. During the past five years, the Child has resided with the following persons and at the following addresses: Persons Address Dates Plaintiff and Defendant 630 Cedar Ridge Lane Mechanicsburg, PA 17055 Birth until 2/2003 Plaintiff 630 Cedar Ridge Lane Mechanicsburg, PA 17055 2/2003 until present 6. The Mother of the Child is Amanda J. Wingard, currently residing at 35 Stoney Run Road, Apt # 17, Dillsburg, Pennsylvania 17019. 7. The Father of the Child is Stephen R. St. Onge, currently residing at 630 Cedar Ridge Lane, Mechanicsburg, Pennsylvania 17055. 8. The relationship of Plaintiff to the Child is that of Father. Plaintiff currently resides with the following persons: The parties minor Child. 9. The relationship of Defendant to the Child is that of Mother. Defendant currently resides with the following persons: Greg Stockenous, her boyfriend. 10. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the Child in this or another court. 11. Plaintiff has no information of a custody proceeding concerning the Child pending in a court of this Commonwealth. 2 12. 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. 13. The best interest and permanent welfare of the Child will be served by granting the relief requested because Plaintiff has been the primary caretaker of the Child since birth. 14. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the Child will be given notice of the pendency of this action and the right to intervene. WHEREFORE, Plaintiff respectfully requests the Court to grant him primary physical and joint legal custody of the parties' minor Child. DATED: of Counsel cc 40 BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717) 233-7691 liz?eth S. ec 3 VERIFICATION I, Stephen R. St. Onge, hereby verify that the statements made in the foregoing document 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 18 Pa. C. S. Section 4904, relating to unworn falsification to authorities. DATED: W;-) U3 C C 02A Stephe?f R. St. Onge 0 0 W STEPHEN R. ST. ONGE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-3556 CIVIL ACTION LAW AMANDA J. WINGARD IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Fridav August 01, 2003 upon consideration of the attached Complaint, the conciliator, Ma?icca P. Greevy, Esq. , it is hereby directed that parties and their respective counsel appear` a ao?esday, September 10, 2003 at 10:30 AM at 301 Market Street, Lemoyne, PA 17043 on for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, /s/ Melissa P Gh&-%ro Fsa By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-31.66 ? ? ? 4?J MNVAIASNN3d 91 :1 Wj I - Jtlb co Co-/ --5 fa/.,I ':!_:? h'''I Do SHERIFF'S RETURN - OUT OF COUNTY SE NO: 2003-03556 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ST ONGE STEPHEN R VS WINGARD AMANDA J R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: WINGARD AMANDA J but was unable to locate Her deputized the sheriff of YORK in his bailiwick. He therefore serve the within COMPLAINT - CUSTODY County, Pennsylvania, to On August 27th , 2003 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep York County 37.28 .00 74.28 08/27/2003 BECKLEY & MADDEN So answers R. homas Kline Sheriff of Cumberland County Sworn and subscribed to before me this 3 day of ?2Utz3 A.D. l- ^ /tom 0 / Pr thonotary ' COUNTY OF YORK OFFICE OF THE SHERIFF s 71;I; ; CALL 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE INSTRUCTIONS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LINE 1 THRU 12 DO NOT DETACH ANY COPIES 1. PLAINTIFF/S/ 2. COURT NUMBER Stephen R. St. Onge 03-3556 civil (03-3556) 3. DEFENDANT/S/ 4. TYPE OF WRIT OR COMPLAINT Amanda J. Wingard Complaint for Custody SERVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. Amanda J. Wingard 6. ADDRESS (STREET OR RFD WITH BOX NUMBER, APT. NO., CITY, BORO, TWP., STATE AND ZIP CODE) AT 35 Stoney Run Road Apt 17 Dillsburg, PA 17019 7. INDICATE SERVICE: J PERSONAL O PERSON IN CHARGE XXDEPUTIZE CRT. IL ? 1ST CLASS MAIL ? POSTED ? OTHER NOW July 29 20 03 I, SHERIFF J??MNTY, PA, do ereby deputi sheriff of York COUNTY to execute this t e return ccording to law. This deputization being made at the request and risk of the plaintiff. r SHERIFF OF11 COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Cumberland OUT OF COUNTY CUMBERLAND ADVANCED FEE PAID BY CUMBERLAND CO SWRIFF NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. ,,,jjj OE LYPENAME aad ADDRESS oLATTORNEY2 fGINATTR,anrLSIGNATUR BO}{ 11998 H$C, PA 17102]10. TELERHODIE NWMBEH 11. DATE FILED l,?L.?Y 6r C?1-11JIJi',1V L1L1V 3 (1 J 06 I L3,S !b`?l 7-25-03 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). Cumberland CO SHERIFF SPACE BELOW FOR USE OF THE SHERIFF - DO NOT WRITE BELOW THIS LINE 13. 1 acknowledge receipt of the writ R AHREN S R 14. }DATE EC I f203 TL'1 15. Expo' tiop/Heant' ate t5 _ L 4 - . or complaint as indicated above. "" RESIDENCE ( ) POSTED( J POE( 16. HOW SERVED: PERSONAL (/1, ) SHERIFFS OFFICE OTHER ( ) SEE REMARKS BELOW ' 17. ? her certify, and return a astern ble to locate the individual, company, etc. name above. (See remarks below. ) ES 8 NA ME N T O DI UHERE IF NOT SHOWN ABOVE (Relatlonship to Defendant) 19. Date of Service 20. Time of Service W nr A A 2TTEMPTSte 1 1 ` Int. I Date ?T me Miles Int. Date Time Miles Int. Date Time I Miles Int. Date Time Miles Int. A `~ 22. REMARKS c?- g)403 23. Advance Costs 24. Service Costs 25. N/F 26. Mileage 27. Posta a 28. Sub Total 29. Pound 30. Notary 31. Surch . 32. Tot. Costs 93. Casts Due w F11Gd Check No. 75.00 18.00 17.28 g 35.28 12.00 1 8137.2 8137.72 '- VOfa 34. Foreign County Costs 135. Advance Costs 136. Service Costs 137. Notary Cert. 138. Mileage/Posted/Not Found 139. Total Casts 140. Costs Due or Refund 71 41. AFFIRMED and subscribed to before me thi. 44. Signature of az.dayof AUGUST ,2043 ?f e"--eep.sbedff I N RY 46. Signature of York NCtariR: Seal County Sheriff damesV Vengrai.n Notary Public WILLIAM M. City of York, "o-k County, PA My Cornrhlssion Mar. 21, 2005 48. Signature of Foreign County Sheriff 50. 1 ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE OF AUTHORIZED ISSUING AUTHORITY AND TITLE SO ANSWERS DATE 47. DATE HOSE 8-21-03 49. DATE 51. DATE RECEIVED 1. WHITE- Issuing Authority 2. PINK - Attomey 3. CANARY - Sheriffs Office 4. BLUE - Sheriffs Office SEP 6 2003 STEPHEN R. ST. ONGE, Plaintiff V. AMANDA J. W INGARD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3556 CIVIL TERM CIVIL ACTION - LAW ORDER OF COURT IN CUSTODY AND NOW, this day of September, 2003, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Stephen R. St. Onge and Amanda J. Wingard, shall have shared legal custody of the minor child, Nicholas O. St. Onge, born August 10, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Father shall have primary physical custody subject to Mother's rights of partial custody which shall be arranged as follows: A. Effective September 22, 2003, each Monday and Friday from 10:00 a.m. to 3:00 p.m. B. At such other times as the parties agree. 3. Transportation. Mother shall assist with transportation by picking up the child at the beginning of her custodial time and returning him to the child care provider at the end of her custodial time. I![ NO. 03-3556 CIVIL TERM 4. Holidays. The parties will share time mutually agree. '0000 BY on holidays as they J. Dist: ?Imanda J. Wingard, 35s StoneyRunn Road, Apt 17, Dillsbu gAPA 1117019 7 ?4? R)?5 09-30-m VWAJAS?n 8 .g 6aa t?t' d..JJ SEP ?Z00 STEPHEN R. ST. ONGE, Plaintiff V. AMANDA J. WINGARD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3556 CIVIL TERM CIVIL ACTION - LAW IN 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 THE CUSTODY OF Nicholas O. St. Onge August 10, 2000 Father 2. A Custody Conciliation Conference was held on September 22, 2003 with the following individuals in attendance: the Father, Stephen R. St. Onge, and his counsel, Elizabeth S. Beckley, Esquire; the Mother, Amanda J. Wingard, attended pro se. The Mother reported that she had received a phone call late last evening indicating that her counsel was unable to attend. 3. The parties reached an agreement in the ford n Order as attached. Date el ssa Peel Greevy, Esquire Custody Conciliator :218663 STEPHEN R. ST. ONGE, Plaintiff/Respondent AMANDA J. WINGARD, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA : NO. 03-3556 CIVIL TERM : CIVIL ACTION -LAW : IN CUSTODY EMERGENCY PETITION FOR TEMPORARY CUSTODY AND MODIFICATION OF CUSTODY ORDER AND NOW, this J if day of July, 2009, comes the Defendant/Petitioner, Amanda J. Wingard, by and through her undersigned attorney, Joseph L. Hitchings, Esquire and avers in support of her Emergency Petition for Temporary Custody as follows: 1. Defendant/Petitioner, Amanda J. Wingard, is an adult individual residing at 6 Village Court, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Plaintiff/Respondent, Stephen R. St. Onge, is an adult individual with a last known address of 630 Cedar Ridge Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17055 3. Plaintiff/Respondent is currently in the Intensive Care Unit of Holy Spirit Hospital for treatment of acute pancreatitis and related ailments. 4. Plaintiff and Defendant are the natural parents of a minor son, Nicholas O. St. Onge, born August 10, 2000, age 8. 5. The child was born out of wedlock. 6. Pursuant to an Order of Court dated September 29, 2003, and based on an agreement of the parties, the parties shared legal custody of Nicholas, with Plaintiff having primary physical custody and Defendant having periods of partial physical custody. A true and correct copy of the Court Order is attached hereto as Exhibit "A". 7. Plaintiff is currently under investigation for a hit and run accident that occurred on June 27, 2009 on Route 15 in Cumberland County. The minor child was present in the vehicle with the Plaintiff as he drove at a high rate of speed, and hit 3 vehicles injuring 4 people, and then attempted to hide the vehicle. 8. The minor child repeatedly asked the Plaintiff to slow down and at one point asked the Plaintiff if they were going to die, to which the Plaintiff responded he was going to "kill them both". 9. After attempting to hide the vehicle, Plaintiff had the minor child walk to his girlfriend's residence over a mile away. 10. The minor child was instructed to lie on the floor of Plaintiff's girlfriend's residence to hide from the police and not tell anyone what had happened. 11. It is believed and therefore averred that the Plaintiff was driving while intoxicated with the minor in his vehicle. 12. The minor child has been interviewed by the Upper Allen Township Police Department and a Children and Youth Investigation is underway. 13. The minor child was released by Children and Youth Services to the Defendant, and a Protection From Abuse Petition against the Plaintiff was filed on the minor's behalf. 14. Plaintiff has a history of alcohol abuse, and it is believed and therefore averred that Plaintiff is in Holy Spirit ICU treating for acute pancreatitis as a result of his alcohol abuse. 15. It is believed and therefore averred that the minor child is at risk due to Plaintiff's conduct. 16. Plaintiff is not able to care for the minor child. 17. Plaintiff has failed to comply with the legal custody requirements of the existing Order in that he has failed to inform the Defendant that the minor child sees a therapist, has been diagnosed with bipolar disorder, is on medication and requires regular blood testing. 18. Plaintiff is in contempt of the existing Custody Order. 19. Plaintiff's relatives came to the Defendant's residence at midnight and demanded that the minor child be turned over to them. As a result, this temporary Order is needed to govern custody of the minor child and to ensure that he is safe and his medical and emotional needs are being met. 20. Petitioner is requesting the Court grant her temporary, sole physical and legal custody of her minor son pending a Custody Conciliation and the result of the Children and Youth Investigation and the PFA outcome in this matter. 21. Petitioner requests that the Court ultimately award her primary physical custody of her minor son. 22. It is believed and therefore averred that it is in the minor child's best interest and permanent welfare to have the Petitioner granted temporary, sole physical and legal custody of him pending a Custody Conciliation and the result of the Children and Youth Investigation and the PFA outcome in this matter. 23. Defendant/Petitioner is ready, willing and able to provide her minor son with a safe and loving environment, and see that his emotional and medical needs are met. WHEREFORE, Defendant/Petitioner, Amanda I Wingard, respectfully requests that this Honorable Court enter a temporary Order granting her sole physical and legal custody of the parties' minor son, Nicholas O. St. Onge, pending further Order of Court. Respectfully Submitted, Law Office of Joseph L. Hitchings SUUU Futter Koad, Juite Ld?, Mechanicsburg, PA 17055 Telephone: (717) 458-8123 Fax (717) 790-6019 Attorney for Defendant/Petitioner VERIFICATION I, Amanda J. Wingard, verify that the statements made in this Emergency Petition for Temporary Custody are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. tfilo i'VNIq Date i Amanda J. Wingard EXHIBIT "A" SEP2003 V STEPHEN R. ST. ONCE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintrif : NO. 03-3556 CIVIL TERM V. CIVIL ACTION - LAW AMANDA J. WINGARD, Defendant • IN CUSTODY ORDER OF COURT AND NOW, this day of September, 2003, upon consideration of the attached Custody Conciliation Summary" Report, it is hereby ordered and directed as follows: 1. Le-gal Custody. The parties, Stephen R. St. Onge and Amanda J. Wingard, shall have shared legal custody of the minor child, Nicholas O. St. Onge, born August 10, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of Pa. C. Sr. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Father shall have primary physical custody subject to Mother's rights of partial custody which shall be arranged as follows: A. Effective September 22, 2003, each Monday and Friday from 10:00 a.m. to 3:00 p.m. B. At such other times as the parties agree. 3. Transportation. Mother shall assist with transportation by picking up the child at the beginning of her custodial time and returning him to the child care provider at the end of her custodial time. NO. 03-3556 CIVIL TERM 4. Holida s. mutually agree. The parties will share time on holidays as they BY Dist: Elizabeth S. Beckley, Esquire, PO Box 11998, Harrisburg, PA 17108 ,oAmanda J. Wingard, 35 Stoney Run Road, Apt. 17, Dillsburg, PA 17019 ? qatl RA5 o4-3o-m STEPHEN R. ST. ONGE, Plaintiff V. AMANDA J. WINGARD, Defendant SEP2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3556 CIVIL TERM CIVIL ACTION - LAW IN 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 THE CUSTODY OF Nicholas O. St. Onge August 10, 2000 Father 2. A Custody Conciliation Conference was held on September 22, 2003 with the following individuals in attendance: the Father, Stephen R. St. Onge, and his counsel, Elizabeth S. Beckley, Esquire; the Mother, Amanda J. Wingard, attended pro se. The Mother reported that she had received a phone call late last evening indicating that her counsel was unable to attend. 3. The parties reached an agreement in the fo n Order as attached. Date -Melissa Peel Greevy, Esq ire Custody Conciliator :218663 STEPHEN R. ST. ONGE, : IN THE COURT OF COMMON PLEAS Plaintiff/Respondent : CUMBERLAND COUNTY PENNSYLVANIA NO. 03-3556 CIVIL TERM AMANDA J. WINGARD, : CIVIL ACTION -LAW Defendant/Petitioner : IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that I am this day serving the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service via First Class US Postal Services Stephen R. St. Onge 630 Cedar Ridge Lane Mechanicsburg, PA 17055 Dated: July -if-, 2009 Joseph L. itchings squire Attorney ID No.: 6 1 5000 Ritter Road, Suite 02 Mechanicsburg, PA 17055 Telephone: (717) 458-8123 Fax (717) 790-6019 Attorney for Defendant/Petitioner r OF TP 41 . 2 ! it tj i ?v {2i«f as S?Na STEPHEN R. ST. ONCE, PLAINTIFF/RESPONDENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. AMANDA J. WINGARD, DEFENDANT/PETITIONER : 03-3556 CIVIL TERM ORDER OF COURT AND NOW, this tri day of July, 2009, a hearing shall be conducted on the within emergency petition at 2:45 p.m., Monday, July 27, 2009, in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania.' By the OAL% Edgar B. Bayley, J. ,Xt'ephen R. St. Onge, Pro se 630 Cedar Ridge Lane Mech icsburg, PA 17055 seph L. Hitchings, Esquire For Defendant/Petitioner :sal ' There is already a temporary order entered on a PFA petition at 09-4682, for which a hearing is scheduled for July 22, 2009, at 2:00 p.m., that provides that Stephen R. St. Onge shall have no partial physical custody/visitation rights with Nicholas St. Onge pending further order of court. RLE , 2099 JU 17 PN 1?: 5 G Ci ,?;' STEPHEN R. ST. ONGE, : TN THE COURT OF COMMON PLEAS Plaintiff/Respondcnt :CUMBERLAND COUNTY PENNSYLVANIA NO. 03-3556 CIVIL TERM AMANDA J. WINGARD, : CIVIL ACTION -LAW Defendant/Petitioner : IN CUSTODY ORDER OF COURT AND NOW, this -b day of August, 2009, a hearing shall be conducted on the within emergency petition at 9:30 a.m., Thursday, September 3, 2009, in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. Distribution: Office of the Prothonotary Court Administration .1-loseph L. Hitchiuags, Esquire, 5000 Ritter Road, Suite 202, Mechanicsburg, PA 1705 ,,.,4iizabeth Beckley, Esquire, 212 N. P Street, Harrisburg, PA 17101 0-0 PCeJ ,r%Z&61CL gI(, JCR ?:=M oL STEPHEN R. ST. ONGE, PLAINTIFF/RESPONDENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. AMANDA J. WINGARD, DEFENDANT/PETITIONER 03-3556 CIVIL TERM ORDER OF COURT AND NOW, this ES V- day of September, 2009, the hearing currently scheduled for September 3, 2009, is continued generally. The hearing will be rescheduled at the request of any party. By the Court, C Edgar B. ? Elizabeth Beckley, Esquire For Plaintiff/Respondent /Joseph L. Hitchings, Esquire For Defendant/Petitioner :sal ma?lCL 9???09 ??Yl OF THE P? r;; , OARY I 2009 'IEf' - ll Fli 4- 08 Cu'tJc. "?`' Johnson Duffie, Stewart and Weidner By: David W. DeLuce I.D. No. 41687 301 Market Street P.O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717)761-4540 STEPHEN R. ST. ONGE, Plaintiff V. Attorneys for Movants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3556 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY AMANDA J. WINGARD, Defendant Judge Edward E. Guido MICHAEL J. CASSIDY and DEIDRE D. CASSIDY Movants ORDER AND NOW, this day of , 2012, upon consideration of the attached Custody Stipulation executed by all parties and indicating that the parties have agreed to have this Court enter an Order to modify the existing order, it is hereby Ordered and Directed as follows: 1. The Movant's Motion to Intervene is GRANTED upon the consent of all parties. 2. This Court's prior order of September 29, 2003 is vacated and replaced with the Order which follows. Deidre D. Cassidy and Michael J . Cassidy shall have primary legal custody of the minor child, Nicholas St. Onge, born August 10, 2000. Deidre D. Cassidy and Michael J. Cassidy shall have the right and responsibility to make all major decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa. C. S. § 5336, Deidre D. Cassidy and Michael J. Cassidy shall be entitled to all records and information pertaining to the child including, but not limited to, medical dental, religious or school records. 4. Deidre D. Cassidy and Michael J. Cassidy shall have primary physical custody subject to rights of visitation with Stephen St. Onge and Amanda J. Wingard, as arranged by mutual agreement of the parties. BY THE -, J. Distribution: ? David W. DeLuce, Esquire P.O. Box 109, Lemoyne, Pennsylvania 17043-0109,. I ? Amanda J. Wingard 721 South Mountain Road, Apt # 409 Dillsburg, Pennsylvania 17019 ? Stephen R. St.Onge 942 Allenview Drive, Mechanicsburg, Pennsylvania 17055 % -? eo r eS ?1ticc. ltd It/1 ?? ,'