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HomeMy WebLinkAbout03-3677eo TAWNYA L. ALLEMAN, Plaintiff V. ROGER M. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE, CUSTODY 03- 367- No. CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other right important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE. RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) - 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. TAWNYA L. ALLEMAN, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE, CUSTODY ROGER M. ALLEMAN, Defendant NO. ORDER OF COURT CIVIL TERM AND NOW, this day of , 2003, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before, , the conciliator, at , , on the day of 2003, at in., 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. FOR THE COURT: By: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. TAWNYA L. ALLEMAN, Plaintiff V. ROGER M. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE, CUSTODY NO. CIVIL TERM COMPLAINT FOR DIVORCE AND CUSTODY The Plaintiff, Tawnya L. Alleman, by her attorneys, the Family Law Clinic, sets forth the following cause of action: COUNT I. COMPLAINT UNDER 23 Pa.C.S. §§ 3301(c) and 3301(d) OF THE DIVORCE CODE The plaintiff, Tawnya L.Alleman, by her attorneys, the Family Law Clinic, sets forth the following cause of action: 1. Plaintiff is Tawnya L.Alleman, who currently resides at 7 Regency South, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Roger M. Alleman, who currently resides at 2117 Princeton Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on July 31, 2001 at Cumberland County Prison, Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff and defendant have lived separate and apart since February 25, 2002. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. COUNT II. CUSTODY 9. Plaintiff repeats and realleges paragraphs one through seven. 10. Plaintiff seeks custody of the following child: Name Present Address Age Zachary Ryan Alleman 7 Regency South, Carlisle, PA 17013 d.o.b. = 11/13/01 11. The child is presently in the custody of the Plaintiff, Tawnya Alleman, who resides at 7 Regency South, Carlisle, PA 17013. 12. During the life of the child, he has resided with the Plaintiff, Tawnya Alleman, at the following addresses: Addresses Dates YWCA of Coatesville, Samara House, 423 E. Lincoln Highway, 11/13/01 to 2/25/02 Coatesville, PA 19320 7 Regency South, Carlisle, PA 17013 2/25/02 to current 13. The mother of the child is Tawnya Alleman, currently residing at 7 Regency South, Carlisle, PA 17013. 14. She is currently married to the Defendant. 15. The father of the child is Roger M. Alleman, currently residing at 2117 Princeton Avenue, Camp Hill, PA 17011. 16. He is currently married to the Plaintiff. 17. The relationship of the Plaintiff to the child is that of mother. The plaintiff currently resides with the following persons: Name Relationship Paula Brenneman Mother Zachary Ryan Alleman Son 18. The relationship of the defendant to the child is that of father. The defendant currently resides with the following persons: Name Relationship unknown 19. Plaintiff has not participated as a parry or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 20. 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. 21. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Plaintiff has been the primary caretaker of the child since birth; b) Plaintiff provides the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; c) Plaintiff is willing to accept custody of the child; d) Plaintiff continues to exercise parental duties and enjoys the love and affection of the child; e) Defendant has not indicated to plaintiff an interest in accepting custody of the child. 22. Each parent whose parental rights to the child have not been terminated and the person who has parental custody of the child have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant her shared legal custody and primary physical custody of the child. //?? IA? A? Nicholas Aloia Certified Legal Intern A 6P4-A THOS PLACE ROBERT E. RAINS LUCY JOHNSTON WALSH Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa. C.S. §4904, the undersigned verifies that the statements made in the foregoing Complaint are true and correct, to the best of my knowledge, information and belief. Dated: 7o?J?D3 ??irca /u Tawny AlI em c-> ?-> ? :., -, _ `?` ? :.? `J ;?; ? ??- C - : ) i. _ _?? ., . -?? ?- Iil _? .. ? TAWNYA L. ALLEMAN, Plaintiff V. ROGER M. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE, CUSTODY 0.3-3677 NO. CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Tawyna L. Alleman, Plaintiff to proceed in forma pauperis. I Nicholas Aloia, a Certified Legal Intern at the Family Law Clinic, representing the party proceeding in forma pauperis, certify that the party is unable to pay the costs and that I am providing free legal service to the party. Date: S"IY 50 2.003 Nicholas Aloia Certified Legal Intern THO?AS?PLACE RO RT E. RAINS LUCY JOHNSTON WALSH Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 f= o (J 'L) ?l r ? ;: {r G,/ ..., G f= A J i'tq TAWNYA L. ALLEMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V' 03-3677 CIVIL ACTION LAW ROGER M. ALLEMAN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, August 05, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, August 29, 2003 at 10:30 AM 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, By: /s/ Hubert X. Gilroy, Esq. 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 ?,.,N?? y,?:?,tswn-?? .?.< -?,,,?? _.;a,?. :n,. TAWNYA L. ALLEMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE, CUSTODY ROGER M. ALLEMAN, Defendant NO. 03-3677 CIVIL TERM AFFIDAVIT OF SERVICE, I, Nicholas Aloia, a Certified Legal Intern of the Family Law Clinic, hereby certify that I am a competent adult and that I personally served a true and correct copy of Complaint for Divorce and Custody on the Defendant, Roger M. Alleman, at the Family Law Clinic. Service was complete upon reciept by Roger M. Alleman, on the 12" day of August, 2003. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unsworn falsification to authorities. Date: A?.yv 5r I?_ a?d3 Nicholas Aloia ? 4„ !.'I .. 7t ?f ? ?' ; _ L. l .q'! ?: ? ._ ?? n• ? { <? _? ti? CJ -{ 00003 TAWNYA L. ALLEMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW ROGER M. ALLEMAN, : NO. 2003 - 3677 CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this -C day of October, 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Tawnya L. Alleman, shall enjoy legal and physical custody of Zachary Ryan Alleman, born November 13, 2001. 2. The Father, Roger M. Alleman, shall enjoy visitation with the minor child at such time and under such circumstances as agreed to by Mother. 3. In the event Father desires to modify this order, the Father may petition the court to have the case again referred to the conciliator for a custody conciliation conference. cc: vMichael Parker Dickinson School of Law Family Law Clinic Roger M. Alleman 2117 Princeton Avenue Camp Hill, PA 17011 RKs 16 -09'43 0 RV TtM VnI TRT a tirNdm,?stir•!aa .,u U -s :l TAWNYA L. ALLEMAN, Plaintiff v ROGER M. ALLEMAN, Defendant Prior Judge: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003 - 3677 CIVIL IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Zachary Ryan Alleman, born November 13, 2001. 2. A Conciliation Conference was held on September 26, 2003, with the following individuals in attendance: The Mother, Tawyna L. Alleman, with her representative, Michael Parker with the Dickinson School of Law Family Law Clinic. The Father, Roger M. Alleman, did not appear. 3. The Father was unable to be served despite many efforts by the Family Law Clinic. The Mother indicates the Father has not seen the child for at least nine months and that she has had primary and sole custody of the child during that time. Based upon that information, the conciliator recommends the entry of an order in the form as attached. U3O DATE' Hubert X. Gilroy, Esquire Custody Conciliator / TAWYNA J. ALLEMAN, Plaintiff V. ROGER M. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 2003-3677 CIVIL TERM NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE The parties to this action separated on February 25, 2002 and have continued to live separate and apart for a period of at least two years. The marriage is irretrievably broken. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. yat f y awn i l?, awnya J. Allem ,Plaintiff a G K .: c n --n C 4? -tea r?`i C N `T3 TAWNYA L. ALLEMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. ROGER M. ALLEMAN, IN CUSTODY Defendant NO. 2003-3677 CIVIL TERM IN RE: MOTION FOR EMERGENCY RELIEF ORDER OF COURT AND NOW, this 28th day of April, 2004, the mother, Tawnya L. Alleman, being currently in prison, the motion of the father, Roger M. Alleman, for emergency relief is granted in that: 1. Roger M. Alleman shall have temporary physical and legal custody of Zachary Ryan Alleman, born November 13, 2001. 2. This period of temporary physical custody shall continue until the mother is released from prison, at which time her legal and physical custody of Zachary shall be reinstated pursuant to the custody order of October 8, 2003. By the Court, Edgar ey J Family Law Clinic For the Plaintiff Roger M. Alleman 2117 Princeton Avenue Camp Hill, PA 17011 :lfh z r ? U IZT'1 "o co O ?C2 -C W CID TAWNYA L. ALLEMAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 2003-3677 CIVIL TERM ROGER M. ALLEMAN CIVIL ACTION - LAW Defendant IN CUSTODY WITHDRAWAL OF APPEARANCE Please withdraw the appearance of the undersigned as counsel for Plaintiff, Tawnya L. Alleman, in the above-captioned matter. Respectfully submitted, Dickinson Law School Family Law Clinic Dated: Attome I. No: ?Oaq (o ENTRY OF APPEARANCE Please enter the appearance of the undersigned as counsel for Plaintiff, Tawnya L. Alleman, in the above-captioned matter. Respectfully submitted, ABOM & KUniLAKIS, L.L.P. Date: Kara W. Haggerty, e I.D. #86914 36 ?outh Hanover Street Carlisle, PA 17013 (717) 249-0900 ? ? o _.. ? ? ,?-_ -r, ?_ C _ ? 1 ?" m - ; ? R ; ? ? s'? Z? ? y ' L O -i ? N TAWNYA L. ALLEMAN, Plaintiff V. ROGER M. ALLEMAN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2003-3677 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY PETITION FOR SPECIAL RELIEF IN CUSTODY CASE PURSUANT TO 42 Pa.C..A. 01915.13 AND NOW, this day of May, 2004, comes the Petitioner, Tawnya L. Alleman, by and through her attorney, Kara W. Haggerty, Esquire, of ABOM &: KUTULAKis, LLP, and files this Petition for Special Relief, and in support thereof avers as follows: 1. Petitioner, Tawnya L. Alleman, with a permanent residence of 400 Mountain Road, Newville, Cumberland County, Pennsylvania, is the natural Mother of the subject minor child. Petitioner resides with the subject minor child and Scott Morrison. 2. Petitioner is currently incarcerated in the Cumberland County Prison. 3. Respondent, Roger M. Alleman, whose address is believed to be 308 Adelia Street, Middleton, Pennsylvania, is the natural Father of the subject minor child. 4. The subject minor child is Zachary Ryan Alleman, date of birth November 13, 2001. 5. Petitioner filed for custody of the subject minor child in July, 2003. 6. Mother/Petitioner was granted legal and physical custody of the subject minor child on October 8, 2003, following a custody conciliation conference. A copy of the Court Order is attached hereto as Exhibit A. 7. On April 28, 2004, This Honorable Court issued an Order granting respondent temporary physical and legal custody of the subject minor child until Mother is released from prison. A copy of the Order is attached hereto as Exhibit B. 8. It is Mother/Petitioner's desire for maternal grandmother, Paula Breneman, to be granted temporary physical and legal custody of the subject minor child until such as a time that she is released from prison. See letters drafted by Mother attached hereto as Exhibit C. 9. The subject minor child has always lived with his Mother since birth. 10. The subject minor child has never resided with his natural Father. Since birth, subject minor child has seen his natural Father for a total of less than 8 hours, as follows: a. When Zach was 4 months old- a four hour visit with Father. b. May 2, 2004, a one-hour visit at the park with Scott Morrison present. c. May 4, 2004, a one-hour visit with Scott Morrison present. 11. Maternal grandmother has assisted in the care and regularly visited with the subject minor child since his birth. 12. Maternal grandmother, Paula Breneman, with a permanent address of 5520 Locust Street, Harrisburg, Dauphin County, Pennsylvania, is willing and able to care for the subject minor child until such a time as custody can be returned to Mother. 13. It is believed, and therefore averred, that Respondent received an Order granting him custody of the subject minor child pursuant to a Motion for Emergency Relief, however, the Prothonotary does not have the Motion on file and undersigned counsel has never seen the Motion. 14. The Petitioner's prior counsel, The Dickinson School of Law Family Law Clinic, has not received a copy of the Motion for Emergency Relief. 15. It is believed, and therefore averred, it would be in the best interests of the subject minor child to be in the custody of his maternal grandmother rather than his natural Father, whom he does not know. WHEREFORE, Petitioner respectfully requests this Honorable Court to grant her Petition for Special Relief and grant temporary physical and legal custody of the subject minor child to his maternal grandmother, Paula Breneman. Respectfully submitted, ABOM& KUTULAKIS, L.L.P. Date: ) . Kara W. Haggerty, Esq I.D. #86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Petitioner VERIFICATION Kara W. Haggerty, Esquire, states that she is the attorney for the party filing the foregoing document; that she makes this affidavit as an attorney for the Petitioner, because the parry she represents for whom she makes this affidavit is outside the jutisdicl ion of the court, and verification of the Petitioner can not be obtained within the time allowed for the filing of the document; and that she has sufficient knowledge or information and belief, based upon het investigation of the matters averred in the foregoing document; and that this statement is made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unswotn falsification of authorities. Respectfully submitted, DATE D 5 lo ABom & Kummras, L.L.P Kara W. Haggerty, s e 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Petitioner ID #86914 00 003 TAWNYA L. ALLEMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW ROGER M. ALLEMAN, NO. 2003 - 3677 CIVIL Defendant IN CUSTODY COURT ORDER AND NOW, this - day of October, 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Tawnya L. Alleman, shall enjoy legal and physical custody of Zachary Ryan Alleman, born November 13, 2001. 2. The Father, Roger M. Alleman, shall enjoy visitation with the minor child at such time and under such circumstances as agreed to by Mother. 3. In the event Father desires to modify this order, the Father may petition the court to have the case again referred to the conciliator for a custody conciliation conference. cc: v2Glichael Parker Dickinson School of Law Family Law Clinic L/Roger M. Alleman 2117 Princeton Avenue Camp Hill, PA 17011 rCa.?]a.;vr RKs /0 -o9-Q3 J. U EXHIBIT A Rv mwV ! nrmm GO0 p71 F TAWNYA L. ALLEMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. ROGER M. ALLEMAN, IN CUSTODY Defendant NO. 2003--3677 CIVIL TERM IN RE: MOTION FOR EMERGENCY RELIEF ORDER OF COURT AND NOW, this 28th day of April, 2004, the mother, Tawnya L. Alleman, being currently in prison, the motion of the father, Roger M. Alleman, for emergency relief is granted in that: 1. Roger M. Alleman shall have temporary physical and legal custody of Zachary Ryan Alleman, born November 13, 2001. 2. This period of temporary physical custody shall continue until the mother is released from prison, at which time her legal and physical custody of Zachary shall be reinstated pursuant to the custody order of October 8, 2003. By the Court, mily Law Clinic F the Plaintiff Roger M. Alleman 2117 Princeton Avenue Camp Hill, PA 17011 EXHIBIT B Edgar kley J : 1 f h e a g; ; /a/-- -_ _ ,3 o _ h Par t ncQ ? ?rc cSd?? / Q 7Z GC?t <- C - 7 e ?c y - zr EXHIBIT C 'y /yGd T/?u. CUMBERLAND COUNTY PRISON REQUEST FORM FR DATE: UNIT: L SECURITY STAFF TREATMENT STAFF ? WARDEN ? DEPUTY WARDEN-TREATMENT ? DEPUTY WARDEN-SECURITY ? DEPUTY WARDEN-OPERATIONS ? TRAINING SPECIALIST ? ACCOUNTS OFFICER ? RECORDS DEPARTMENT ? MAINTENANCE DEPARTMENT Shiftleader: ? WORK RELEASE MANAGERS ? MEDICAL DEPARTMENT ? EARNED TIME CASE MANAGER ? DRUG/ALCOHOL CASE MANAGER ? CORRECTIONAL COUNSELOR ? MENTAL HEALTH CASE MANAGER ? CHAPLAIN ? INSTITUTIONAL PAROLE OFFICER BE SPECIFIC IN EXPLAINING REQUEST ANSWERED BY: DATE: GEN-5 REVISED: 11-00 TAWNYA L. ALLEMAN, Plaintiff V. ROGER M. ALLEMAN Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA : NO. 2003-3677 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE AND NOW, this' day of May, 2004, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, LLP, hereby certify that I did serve a true and correct copy of the foregoing PETITION FOR SPECIAL RELIEF upon Respondent by depositing, or causing to be deposited, same in the U.S. mail, First-Class, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Roger M. Alleman 308 Adelia Street Middleton, PA 17057-2712 ABom,& KUTULAKiS, LLP Kara W. Haggerty, Es6di I.D. #86914 U1 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Petitioner 0 c 0 ? w r -s Vnn y. ? ? n TAWNYA L. ALLEMAN, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ROGER M. ALLEMAN, DEFENDANT 03-3677 CIVIL TERM ORDER OF COURT AND NOW, this 7m day of May, 2004, a hearing on the within petition for special relief shall commenced at 11:30 a.m., Monday, May 10, 2004, in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania., By the CV B. Bayley, :sal J V lo? ,.? A?v ?fi :I l WV L- AVM hOOZ X 'JjONONload IHL ?o gni-14 311-1 7)o-", -s TAWNYA L. ALLEMAN, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ROGER M. ALLEMAN, DEFENDANT 03-3677 CIVIL TERM ORDER OF COURT AND NOW, this 7t' day of May, 2004, it appearing that Tawnya L. Alleman is currently incarcerated in the Cumberland County Prison, the Cumberland County Sheriff is ordered to have Tawnya L. Alleman present for this civil hearing scheduled for 11:30 a.m., Monday, May 10, 2004, in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. By t ?? j / //.1/j Edgar B Kara Haggerty, Esquire For Plaintiff Sheriff -? :sal J. iW VI " "!i'Yl hl 09 *z Ild c- ),VW WZ A iO; t i 41OW :]Hi J0 ?.;1?10-0311? F Curtis R. Long Prothonotary Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor (Office of the Protbonotarp Cumberlaub Countp Mr. Roger M. Alleman 2117 Princeton Avenue Carlisle, PA 17013 April 29, 2004 Dear Mr. Alleman; This letter is in reference to the Motion for Emergency Relief you filed on 04-28-04. When you came down to our office directly from the Judges office you handed me an Order of Court. I certified this for you and gave you 2 copies of this. The original Motion for emergency relief is to be kept in our office. I think you have this Motion for Emergency Relief with your paperwork, in your possession. You will notice it is the original because it has your original signature, and has a clock in date on the back. It is very important that you return the Motion for Emergency Relief to our office immediately! Sincerely, dM?? RE E SIMPSON 1st Deputy ZWMt'If?jAW(PFFICE CU COUNTY COURTHOUSE t l?tiTa l 61 §ht f s?SQ 3387 Carlisle, PA 17013 "T04'04 -U. J. POST Roger M. Alleman (2117 Princeton Avenue ADDRESS ? ATTEMPTED NOT KNOWN ? OTHER ? NO SUCH NUMBER/ STREET S 10 NOT DELIVERABLE AS ADDRESSED RE Z: - UNABLE TO FORWARD `7 wL `a J1{.11),, fill,tun{l,.l'It11'Ii 111tI111 x111111111111111111.11 ... s1.-. . TAWNYA L. ALLEMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ROGER M. ALLEMAN, Defendant NO. 03-3677 CIVIL TERM ORDER OF COURT AND NOW, this 10th day of May, 2004, the order of April 28, 2004, is amended to add the following paragraph three: The father shall either himself or through the mother's boyfriend be sure that Zachary visits his mother at the Cumberland County Prison on both Saturdays and Sundays between the hours of 9:00 a.m. and 10:00 a.m. By oust, (A) G Edgar B. Bayley, J. ,Kara W. Haggerty, Esquire For Plaintiff /Roger M. Alleman, pro se 308 Adelia Street Middletown, PA 17057 Sheriff QS-II-0L/ prs Os: - t O o U N TAWNYA L. ALLEMAN, Plaintiff VS. ROGER M. ALLEMAN, Defendant IN THE COURT OF COMMOM PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: 2003-3677 CIVIL TERM IN CUSTODY MOTION TO MODIFY CUSTODY ORDER NOW COMES the Defendant, ROGER M. ALLEMAN, by his attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is TAWNYA L. ALLEMAN, who currently resides at Cumberland County Prison, Carlisle, County of Cumberland, Pennsylvania. 2. Defendant is ROGER M. ALLEMAN, who currently resides at 308 Adelia Street, Middletown, County of Dauphin, Pennsylvania. 3. Plaintiff and Defendant are the natural parents of a minor child, ZACHARY RYAN ALLEMAN, born November 13, 2001. 4. That on April 28, 2004, a Custody Order was entered by the Honorable Edgar B. Bayley granting temporary physical and legal custody to Defendant until such time as the Plaintiff is released from prison. Upon Plaintiff's release from prison custody would be reinstated pursuant to this court's order of October 8, 2003. Copies of said Orders are attached hereto. 5. Defendant seeks an order of primary physical custody. 6. Defendant seeks to amend the Order of May 10, 2004, requiring him to provide visitation between Plaintiff and the child every weekend. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court modify the Order as follows: a. Granting Defendant primary physical custody of the child following Plaintiffs release from prison. b. Requiring Defendant to provide visitation at the prison once per month rather than every Saturday and Sunday. Respectfully submitted, CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PP, 17111 (717) 561-1939 Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN Upon information and belief, I verify that the statements in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE CHARLES E. PETRIE b TAWNYA L. ALLEMAN, Plaintiff V. ROGER M. ALLEMAN, Defendant IN RE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN CUSTODY NO. 2003--3677 CIVIL TERM MOTION FOR EMERGENCY RELIEF ORDER OF COURT AND NOW, this 28th day of April, 2004, the mother, Tawnya L. Alleman, being currently in prison, the motion of the father, Roger M. Alleman, for emergency relief is granted in that: l]. have temporary physical . Roger M. Alleman sha 1 and legal custody of Zachary Ryan Alleman, born November 13, 2001. 2. This period of temporary physical custody shall continue until the mother is released from prison, at which time her legal and physical custody of Zachary shall . be reinstated pursuant to the custcdy order of October 8, 2003. x mily Law Clinic F the plaintiff Roger M. Alleman 2117 Princeton Avenue Camp Hill, PA 17011 By the Court, Edgar ?y J i rk e , t y ?wE?q rea ? C"rFk?Y:? I ft h ,? nao r :! L TAWNYA L. ALLEMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ROGER M. ALLEMAN, Defendant NO. 03-3677 CIVIL TERM ORDER OF COURT AND NOW, this 10th day of May, 2004, the order of April 28, 2004, is amended to add the following paragraph three: The father shall either himself or through the mother's boyfriend be sure that Zachary visits his mother at the Cumberland County Prison on both Saturdays and Sundays between the hours of 9:00 a.m. and 10:00 a.m. By e ourt, y` G Edgar B. Bayley, J. Kara W. Haggerty, Esquire For Plaintiff Roger M. Alleman, pro se 308 Adelia Street Middletown, PA 17057 Sheriff prs O O 1 w r„ 4J T, f7 L1 TAWNYA L. ALLEMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-3677 CIVIL ACTION LAW ROGER M. ALLEMAN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, _ Thursday August OS 2004 upon consideration of the attached Complaint, it is hereby directed that parties and their respective cotmsel appear before Ilubert X Gilroy Esg the conciliator, at 4th Floor, Cumberland County Courthouse Carlisle on Friday, S',eptember 03, 2004 for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in at 9:30 AM dispute; 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, By: ls/ Hubert_ X Gilroy- E* mhc 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) 249-3166 v s )OP V, 4* h4 S j 20 h 4 d S- 0RV hflflZ I???1C3????311Ja1 aC TAWNYA J. ALLEMAN, Plaintiff V. ROGER M. ALLEMAN, Defendant 1. Check either (a) or (b) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 2003-3677 CIVIL TERM O (a) I do not oppose the entry of a divorce decree. O (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): () (i) The parties to this action have not lived separate and apart for a period of at least two years. () (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): () (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. () (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date Roger M. Alleman NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. ?- ??_ -, - : ,_ T? aJ i ? tl (J TAWNYA J. ALLEMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE ROGER M. ALLEMAN, Defendant NO. 2003-3677 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: ROGER M. ALLEMAN, DEFENDANT: You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after April 28, 2004, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ?> ,,, ?.-? ?? <; -? r -n ? ?___ f ?? r. h? J ?_l l :i '?? C.') C:? i.1 TAWNYA J. ALLEMAN, Plaintiff V. ROGER M. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 2003-3677 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(d)(1) of the Divorce Code. 2. Date and manner of service of the complaint: August 12, 2003, by hand delivery to defendant by a competent adult. 3. Date of execution of the Plaintiffs Affidavit required by § 3301(d) of the Divorce Code: March 25, 2004; Date of service of the Plaintiffs Affidavit upon the Defendant: May 10, 2004. 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to Request Entry of a Divorce Decree, a copy of which is attached: United States mail, first class, postage prepaid on May 10, 2004. Date 7-2(o-04 Amy L Knuzel 4"- Certified Legal Intern ANNE GDO LUCY JOHNSTON-WALSH ROBERT E. RAINS THOMAS M. PLACE Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 C; N U _ c-o '"Tl .T? _ C,_ _? ?' "rI : .z r _ -.-? . T"i r. ?, G? _:,r-t ""r. -t _ C r'i =j i'rt t'.} ?? ! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Tawntia A Alleman No. oi -Ati77 r; v;1 VERSUS Defendant DECREE IN DIVORCE AND NOW, to -1V?? IT IS ORDERED AND DECREED THAT - nma n nl1 d - PLAINTIFF, AND Rngor M allaman DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; r`7'? ? '°?' l,? moo- 11-? ld?? TAWNYA L. ALLEMAN, Plaintiff V. ROGER M. ALLEMAN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2003-3677 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY MOTION TO CONTINUE CUSTODY CONCILIATION CONFERENCE AND NOW, comes the Plaintiff, Tawnya L. Alleman, by and through her attorney, Kara W. Haggerty, Esquire, of ABOM & KUTULAKiS, LLP, and files this Motion to Continue Custody Conciliation Conference, and in support thereof avers as follows: 1. On October 8, 2003, This Honorable Court granted Plaintiff, Tawnya Alleman, legal and physical custody of Zachary Ryan Alleman, born November 13, 2001. 2. Defendant, Roger M. Alleman, is the natural Father of the subject minor child. 3. Plaintiff is currently incarcerated in the Cumberland County Prison. 4. On April 28, 2004, This Honorable Court issued an Order granting the defendant temporary physical and legal custody of the subject minor child until Mother is released from prison. 5. The defendant recently retained counsel and filed a Motion to Modify Custody Order on July 27, 2004. 6. The undersigned counsel received service of said Motion to Modify on August 11, 2004, at which time counsel learned that Defendant retained counsel. 7. The Defendant was and is aware that Plaintiff is represented by counsel as the undersigned counsel has corresponded at length with the Defendant regarding custody and had entered her appearance on behalf of Plaintiff on May 7, 2004. 8. A hearing is scheduled for Friday, September 3, 2004 at 9:30 a.m. before Hubert X. Gilroy, Esquire. 9. The undersigned counsel has a previously scheduled commitment before the Divorce Master on the above date and time. WHEREFORE, Petitioner respectfully requests this Honorable Court to grant the within Motion to Continue Conciliation Conference and reschedule for a time to be determined by the parties. Respectfully submitted, ABOM & KUTUL.AKIS, L.L.P. Date: D _L 60v?- Kara W. Ha yge: quire I.D. #86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-090CI Attorney for Plaintiff CERTIFICATE OF SERVICE: AND NOW, this L4 day of August, 2004, I, Kara VV. Haggerty, Esquire, of Abom & Kutulakis, LLP, hereby certify that I did serve a true and correct copy of the foregoing MOTION TO CONTINUE by first class mail as follows: Charles E. Petrie, Esquire 3528 Brisban Street Harrisburg, PA 17111 ABom & KUTULAKIS, LLP Kara W. Haggerliyy, uire I.D. #86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff ? n,o C. <?:, ,,-- -?-?? - :"Yl ( - ?f-; C 1 -:: C n, y. TAWNYA L. ALLEMAN, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ROGER M. ALLEMAN, DEFENDANT 03-3677 CIVIL TERM ORDER OF COURT AND NOW, this 18th day of August, 2004, the motion of plaintiff for a continuance of a custody conciliation conference, IS GRANTED. The conciliator shall reschedule the conference. ByffSe Cou Kara Haggerty, Esquire For Plaintiff &< harles E. Petrie, Esquire For Defendant Hubert X. Gilroy, Esquire- Custody Conciliator Edgar 13. Bayley, J. 08-19?0? :sal f, - ??. `'; ?.? ,?.: ,,_ TAWNYA L. ALLEMAN, Plaintiff v ROGER M. ALLEMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 03 - 3677 : IN CUSTODY COURT ORDER AND NOW, this I I day of 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The mother, Tawnya L. Alleman, shall continue to enjoy legal and physical custody of Zachary Ryan Alleman, born November 13, 2001 consistent with the prior orders of Court in this case. 2. The father, Roger M. Alleman, shall enjoy periods of temporary custody/visitation with the minor child as follows: a. Initially, father shall have supervised visitation arranged through the Carlisle YWCA or another facility as agreed upon by legal counsel for the parties. b. Father shall also undergo a drug/alcohol evaluation with the results of that evaluation to be provided to the attorney for the mother. c. Once the mentioned evaluation is complete and once father has fulfilled a fair amount of supervised visitations, legal counsel for the father may contact the Custody Conciliator directly to schedule a telephone conference between the attorneys and the Conciliator at addressed with respect to expansion of father-i BY TIEE CO? Judge cc: wIfa'ra Haggerty, Esquire Qp t9harles E. Petrie, Esquire 1 ???? the issue will be with the minor child. to-?a -o y? ()F T?7 Iftrl' 2004 OCT I I pt; 1: 01 TAWNYA L. ALL,MAN , Plaintiff v ROGER M. ALLEMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 03 - 3677 : IN CUSTODY IN ACCO - -... •` ?,uiVII?LdIR-RT RDANCE PROCEDURE THE 1915.3-8(bITH the andersig MB RL ned The COUNTY C report: IWL RULE OF y Conciliator submits the following 1• pertinent information is as follows: PertaiWug to the child who is the subject of this litigation Zachary Ryan Alleman, born November 13, 2001. 2. A Conciliation Conference was held on October 1 individuals in attendance: ' 2004, with the following The mother, Tawnya L. Alleman, with her father, Roger M. Alleman, with his counsel, counsel, Kara . 3 Charles E, Petrie. Haggerty, and the The parties agree to the entry of an order in the form as attached. DATE C/! Hubert X, G 0 Custod ' Esq e y Con ' atn. ' OCT 2 6 2005 -? TAWNYA L. JUMPER (formerly : IN THE COURT OF COMMON PLEAS OF TAWNYA L. ALLEMAN) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v NO. 03-3677 CIVIL ACTION - LAW ROGER M. ALLEMAN, IN CUSTODY Defendant ORDER OF COURT AND NOW, this Z-1 day of October, 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. This Court's prior Order of October 11, 2004 is modified such that Father shall enjoy periods of temporary custody with the minor child on every Tuesday from 10:00 a.m. until 4:15 p.m. Father shall pick the minor child up at the child's day care and return custody to the Mother at WalMart off PA Route 114 in Silver Spring Township. The parties shall exchange contact information with respect to phone numbers, etc., in order to be able to contact each other. The parties may modify these points of exchange or times of exchange in the event they reach an agreement. 2. The above custody shall remain in place until the parties meet with the Custody Conciliator again at 8:30 a.m. on Thursday, December 15, 2005. BY THE CQ T: ... Edgar B. Bayley, Cc: kefiarles E. Petrie, Esquire ?"As. Tawnya L. Jumper fib" 1, . r TAWNYA L. JUMPER (formerly TAWNYA L. ALLEMAN) Plaintiff v ROGER M. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3677 CIVIL ACTION - LAW IN CUSTODY Prior Judge: The Honorable Edgar B. Bayley CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Zachary Ryan Alleman, born November 13, 2001 2. A Conciliation Conference was held on October 20, 2005 with the following individuals in attendance: The Mother, Tawnya L. Jumper, who appeared without counsel The Father, Roger M. Alleman, with Charles E. Petrie, Esquire 3. The parties agree to an entry of an Order in the form as attached. Date: l0 - a q b,S' /zl? \k ubert. Gilroy, Esquire Custody Conciliator TAWNYA L. JUMPER (formerly : IN THE COURT OF COMMON PLEAS OF TAWNYA L. ALLEMAN) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V NO. 03-3677 CIVIL ACTION - LAW ROGER M. ALLEMAN, IN CUSTODY Defendant ORDER AND NOW, this day of February, 2006, the Conciliator having not received any additional request from the parties to reschedule a conference in this matter, the Conciliator relinquishes jurisdiction. 4ubert . Gilroy, Esquire Custo y Conciliator ..i_,? '!,_,1 ,, ? :_ . TAWNYA L. ALLEMAN, Plaintiff VS. ROGER M. ALLEMAN, Defendant IN THE COURT OF COMMOM PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: 2003-3677 CIVIL TERM IN CUSTODY MOTION TO MODIFY CUSTODY ORDER NOW COMES the Defendant, ROGER M. ALLEMAN, by his attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is TAWNYA L. ALLEMAN, who currently resides at 400 Mountain Road, Newville, County of Cumberland, Pennsylvania. 2. Defendant is ROGER M. ALLEMAN, who currently resides at 5641 Lancaster Street, Harrisburg, County of Dauphin, Pennsylvania. 3. Plaintiff and Defendant are the natural parents of a minor child, ZACHARY RYAN ALLEMAN, born November 13, 2001. 4. That on October 11, 2004, a Custody Order was entered by the Honorable Edgar B. Bayley granting supervised visitation to Defendant until such time as the Defendant had undergone a drug/ alcohol evaluation. 5. Defendant has successfully completed an outpatient substance abuse treatment program and seeks an Order of temporary physical and shared legal custody. A copy his completion letter from Gaudenzia, Inc., is attached hereto. 6. Defendant seeks to amend the Order of October 11, 2004, to permit Defendant to have overnight, unsupervised visitation with his son. 7. During the last week of April the parties agreed to switch Defendant's visitation days from Fridays to Tuesdays because of Defendant's work schedule. Plaintiff has not presented the child for a Friday visit since the date of the agreement. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court modify the Order granting Defendant rights of temporary physical and shared legal custody of the child. Said rights of temporary physical custody shall included overnight visits with said minor child. Respectfully submitted, CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing Motion are true and correct. 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. DATE ROG R M. ALLEMAN Robert P. Kelly Chairman of the Board HARRISBURG OUTPATIENT SERVICES CA U D E N Z I A , Inc. 2039 North Second Street, Harrisburg, PA 17102 (717) 233-3424 FAX: (717) 233-6399 Michael Harle, M.H.S. Presidenaxecutive Director A United Way Donor Option Agency Date: 3/2/06 To Whom It May Concern: This letter is in regards to Roger Alleman. Roger was admitted to Gaudenzia Harrisburg Outpatient on 4/14/05 to deal with issues of substance abuse and dependence. Gaudenzia Harrisburg Outpatient is a drug-free substance abuse treatment program. Roger has made positive progress on all treatment goals and has developed a stable support system. Roger successfully completed the outpatient treatment program on 2/16/06. Thank you, Andrea Yamarik Counselor II Helping people3ielp tl emse)vea since 1968 . . . . . . . . . . . . . . . . . na C ' [O c s- ILO -f; t, 1 vV ^ c TAWNYA L. ALLEMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ROGER M. ALLEMAN DEFENDANT 03-3677 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 11, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, June 16, 2006 at 10:30 AM 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, By: /s/ Hubert X. Gilroy, Esq. , im Custody Conciliator ,.P 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) 249-3166 °lO.s/S H N "l SNH3d QE .E Wd S 1 IN 900Z &VICIN H!O3d 3H! JO 3OLL40-0310 R-1'E!VE0 JUI: 28 0-Q19 y TAWNYA JUMPER (formerlyAlleman), : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v ROGER M. ALLEMAN, Defendant CIVIL ACTION - LAW NO. 03-3677 IN CUSTODY COURT ORDER AND NOW, this 5 0- day of June, 2006, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No. 2 of the Cumberland County Courthouse on the ?t day of , 2006 atq;00 cL m. At this hearing, the father shall be the moving party and ll proceed initially with testimony. Counsel for the parties, or the parties themselves if they do not retain legal counsel, shall file with the Court and opposing counsel/party a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least rive days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's Order of October 11, 2004 shall remain in effect subject to the understanding that father shall continue with the status quo on temporary custody which is on Tuesdays from 10:000 a.m. until 4:15 p.m. BY THE Judge cc: Charles E. Petrie, Esquire 30 _?? ?D ?. 1 z? WL& (44 ) Tawnya L. Jumper " r jh? <'v CJ tW TAWNYA JUMPER (formerlyAlleman), Plaintiff v ROGER M. ALLEMAN, Defendant Prior Judge: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 03-3677 : IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Zachary Ryan Alleman, born November 13, 2001. 2. A Conciliation Conference was held on June 16, 2006, with the following individuals in attendance: The mother, Tawnya Jumper (formerly Alleman), who appeared without counsel, and the father, Roger M. Alleman, with his counsel, Charles E. Petrie, Esquire. 3. The parties are working under a Custody Order from October 2004 at which it was agreed that father would have some supervised visitation. Since that time, the parties agreed to expand the visitation for father and father has generally been seeing the child one day a week for approximately six hours. Father now desires to expand that period of temporary custody to incorporate some overnights, and he suggests that this should be on weekends for the weekends he is off work or during the week when is off work. Father works for Purina and has somewhat of an irregular work schedule. Mother is unwilling to agree to expand temporary custody for the father at this point. 4. Mother suggests father has not been regular in his visits and she suggests the father should still not have overnight custody. The parties are unable to agree and a hearing is required. The Conciliator 5. recommends an Order in the form as attached. &-A-?-D? DATE Z?o Hubert X. G' y, Esquire Custody Co iliator '. .-'+1 TWANYA L. JUMPER, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. ROGER M. ALLEMAN, DEFENDANT 03-3677 CIVIL TERM ORDER OF COURT AND NOW, this 18 day of August, 2006, following a hearing on the merits, IT IS ORDERED: (1) All prior custody orders are vacated and replaced with this order. (2) Twanya L. Jumper and Roger M. Alleman shall have shared legal custody of their son, Zachary Ryan Alleman, born November 13, 2001. (3) The mother shall have primary physical custody of Zachary. (4) Starting on Saturday, August 26, 2006, the father, for as long as he works weekends, shall have Zachary in alternate weeks from 10:00 a.m., Saturday to 7:00 p.m. Sunday. After this break-in period, and starting on the fourth weekend in September, this alternate weekend schedule shall start at 6:00 p.m., Friday to 7:00 p.m. Sunday. (5) If the father's work schedule changes and his days off are mid-week, this same alternate week schedule shall be followed with the break-in period lasting through Sunday, September 10. The father shall provide the mother notice not later than two days in advance, and earlier if possible, of the weekdays he will exercise his periods of temporary physical custody. Any weekday periods shall take precedent over preschool. (6) Starting in the summer of 2007, the father, as long as he is on vacation, may have Zachary for up to two full weeks separated by at least a two week period. The f father shall provide the mother at least two weeks advance notice of his exercise of such periods of temporary physical custody. (7) Christmas shall alternate in two segments. Segment A shall be from December 24th at 9:00 a.m. until December 25th at 2:00 p.m. Segment B is from December 25th at 2:00 p.m. until December 26th at 7:00 p.m. The mother shall have Segment A in 2006. (8) The parents shall alternate Labor Day, Thanksgiving, New Year's Day, Memorial Day and July 4th, with the father's first alternate holiday being Labor Day. On the father's alternate holidays he shall have Zachary from 9:00 a.m. until 7:00 p.m. (9) All exchanges shall be at the Wal-Mart on the Carlisle Pike in Cumberland County. By the Co , WA-1 Edgar B. Bayley, J. .wnya Jumper, Pro se 400 Mountain Road Newville, PA 17241 arles E. Petrie, Esquire For Defendant J :sal ?? FN za M a TAWNYA L. JUMPER, : IN THE COURT OF COMMOM PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NUMBER: 03-3677 CIVIL ACTION LAW ROGER M. ALLEMAN, Defendant IN CUSTODY PETITION FOR FINDING OF CONTEMPT OF ORDER OF COURT AND FOR MODIFICATION OF ORDER OF COURT CONTEMPT OF ORDER OF COURT TO THE HONORABLE EDGAR B. BAYLEY, JUDGE: NOW COMES Defendant, ROGER M. ALLEMAN, by and through his attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is TAWNYA L. JUMPER, who currently resides at 400 Mountain Road, Newville, County of Cumberland, Pennsylvania. 2. Defendant is ROGER M. ALLEMAN, who currently resides at 5641 Lancaster Street, Harrisburg, County of Dauphin, Pennsylvania. 3. Plaintiff and Defendant are the natural parents of a minor child, ZACHARY RYAN ALLEMAN, born November 13, 2001. 4. That on August 18, 2006, the Honorable Edgar B. Bayley entered an Order granting primary physical custody of the minor child to the Plaintiff and rights of temporary physical custody of said minor child to the Defendant. A copy of the Order is attached hereto. 5. Said Order directs that the parties will alternate the holidays beginning with Father having Labor Day, 2006. Plaintiff has denied Defendant his rights of temporary physical custody with the minor child on Labor Day, 2006, and New Year's Day, 2007. ? r 6. That Plaintiff failed to pick up said minor child on Sunday, February 25, 2007, as directed by this Court's Order. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court enter an Order finding Defendant to be in contempt of an Order of Court and providing such relief as Your Honorable Court may deem just and proper. MODIFICATION OF COURT ORDER 7. Plaintiff hereby incorporates paragraphs 1 through 6 above as if fully set forth herein. 8. That Defendant called the home of the Plaintiff to inquire into her whereabouts and Defendant was told to keep said minor child because the Plaintiff was out using drugs and had been all weekend. 9. That Plaintiff told Defendant that her boyfriend abuses her and that he had recently held a gun to her head. 10. That Plaintiff's boyfriend told Defendant that Plaintiff is very abusive to him. 11. That the minor child has told Defendant during his visits that both Plaintiff and Plaintiffs boyfriend are abusive. 12. The minor child is not permitted to refer to his natural father as "Dad" while in Plaintiff's home. He must refer to his father as "Roger." 13. That the best interest and permanent welfare of the minor child will be served by confirming primary physical custody in Defendant. WHEREFORE, Defendant respectfully requests that Your Honorable Court amend the Order of August 18, 2006, to grant primary physical custody of the subject minor child to Defendant. Respectfully submitted, CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff TAWNYA L. JUMPER, Plaintiff VS. ROGER M. ALLEMAN, Defendant : IN THE COURT OF COMMOM PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NUMBER: 2003-3677 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE I, KELLY P. ROBERTS, Paralegal, for Attorney Charles E. Petrie, hereby certify that on March 1, 2007, a true and correct copy of the attached Petition for Contempt and Modification of Order was served by First class mail, postage prepaid on the following: ROGER M. ALLEMAN 5641 Lancaster STREET HARRISBURG, PA 17111 HUBERT X. GILROY, ESQUIRE 4 NORTH HANOVER STREET CARLISLE, PA 17013 TAWNYA JUMPER 400 MOUNTAIN ROAD NEWVILLE, PA 17241 DATED: 3/0112007 CHARLES E. PETRIE, ESQUIRE BY: rly P /Roberts 528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 TWANYA L. JUMPER, PLAINTIFF V. ROGER M. ALLEMAN, DEFENDANT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 03-3677 CIVIL TERM QRDER OF COURT AND NOW, this 8 - day of August, 2006, following a hearing on the merits, IT IS ORDERED: (1) All prior custody orders are vacated and replaced with this order. (2) Twanya L. Jumper and Roger M. Alleman shall have shared legal custody of their son, Zachary Ryan Alleman, born November 13, 2001. (3) The mother shall have primary physical custody of Zachary. (4) Starting on Saturday, August 26, 2006, the father, for as long as he works weekends, shall have Zachary in alternate weeks from 10:00 a.m., Saturday to 7:00 p.m. Sunday. After this break-in period, and starting on the fourth weekend in September, this alternate weekend schedule shall start at 6:00 p.m., Friday to 7:00 p.m. Sunday. (5) If the father's work schedule changes and his days off are mid-week, this same alternate week schedule shall be followed with the break-in period lasting through Sunday, September 10. The father shall provide the mother notice not later than two days in advance, and earlier if possible, of the weekdays he will exercise his periods of temporary physical custody. Any weekday periods shall take precedent over preschool. (6) Starting in the summer of 2007, the father, as long as he is on vacation, may have Zachary for up to two full weeks separated by at least a two week period. The father shall provide the mother at least two weeks advance notice of his exercise of such periods of temporary physical custody. (7) Christmas shall altemate in two segments. Segment A shall be from December 24th at 9:00 a.m. until December 251h at 2:00 p.m. Segment B is from December 25th at 2:00 p.m. until December 2e at 7:00 p.m. The mother shall have Segment A in 2006. (8) The parents shall alternate Labor Day, Thanksgiving, New Year's Day, Memorial Day and July 4th, with the father's first alternate holiday being Labor Day. On the father's alternate holidays he shall have Zachary from 9:00 a.m. until 7:00 p.m. (9) All exchanges shall be at the Wal-Mart on the Carlisle Pike in Cumberland County. Tawnya Jumper, Pro se 400 Mountain Road NewAlle, PA 17241 Charles E. Petrie, Esquire For Defendant By tom cor Edgar B. Bayley, J. .sal /c.> ?' ?\. ?? ?, r ? a, ?-,s - r--? : -? ?e? -;t i-? .. ?`a.? :- --?? ? ??=-? ?-- ?; ?.. .._.. TAWNYA L. JUMPER, Plaintiff/ Petitioner V. ROGER M. ALLEMAN, Defendant/ Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN CUSTODY No. 03-3677 CIVIL TERM PETITION FOR SPECIAL RELIEF SEEKING EMERGENCY CUSTODY PURSUANT TO PA R.C.P. 1915.13 AND NOW, this 2"d day of March, 2007, pursuant to Rule 1915.13 of the Pennsylvania Rules of Civil Procedure, comes the Petitioner, Tawyna L. Jumper, by her attorneys, the Family Law Clinic, seeking emergency custody of the minor child, Zachary Ryan Alleman, born November 13, 2001. In support of her Petition for Emergency Relief, Petitioner avers the following: 1. The Petitioner is Tawnya L. Jumper, an adult individual who resides at 400 Mountain Road, Newville, PA 17241. 2. The Respondent is Roger M. Alleman, an adult individual who resides at 5641 Lancaster Avenue, Harrisburg, PA 17111. 3. The Petitioner is the biological mother (hereinafter "Mother") of the five-year-old minor child, Zachary Ryan Alleman, born November 13, 2001 (hereinafter "Child") 4. The Respondent is the biological father (hereinafter "Father") of the child. 5. The child was born in wedlock. 6. Mother has been the primary caretaker of the child since his birth. 7. On August 18, 2006, the Court ordered that Mother and Father enjoy shared legal custody of minor Child. Mother was granted primary physical custody and Father was granted alternate weekends with the Child. 8. Under the Court Order of August 18, 2006, Father had custody of minor Child on alternating weekends beginning on Saturday, August 26, 2006, from 10:00 a.m., Saturday to 7:00 p.m., Sunday. 9. Under the Court Order dated August 18, 2006, beginning the fourth weekend of September, the alternate weekend schedule enjoyed by Father began at 6:00 p.m., Friday to 7:00 p.m. Sunday. 10. A copy of,the August 18, 2006, Court Order is attached to this Petition as Exhibit A. 11. On Sunday, February 25, 2007, Father attempted to return Child to Mother. Mother was unable to make the exchange at the designated time and place due to car trouble and a miscommunication with her fiancd. 12. On Monday, February 26, 2007, Father telephoned Mother and informed her that he would not return the Child until ordered by a court. 13. Father has refused to allow Mother to see or speak with the Child since Monday, February 26, 2007. 14. Mother is concerned about the Child's safety since learning that Father's eighteen-year old son, Matt Alleman, has been supervising the minor Child. 15. Mother believes and therefore avers that Matt Alleman was recently involved in an incident where he threatened to stab someone. The Swatera Township Police were involved. 16. Mother believes and therefore avers that it is in the best interests of the minor child that Mother be granted shared legal and temporary primary physical custody of the child, pending further Order of Court. 17. Prior proceedings regarding this matter have been overseen by the Honorable Judge Bayley. 18. Pursuant to Cumberland County Local Rule 208.3(a), Mother's counsel attempted to contact Father's counsel, Charles E. Petrie, Esquire, to seek his concurrence to this petition, but was unable to reach him. 19. Mother believes and therefore avers that Father will only release the child to her if she is accompanied by law enforcement. WHEREFORE, the Petitioner, Tawnya L. Jumper, respectfully requests that this Honorable Court restore the status quo by entering an Order granting Petitioner temporary legal and primary physical custody of the Child, Zachary Ryan Apeman, by ordering Respondent to return the Child immediately to Petitioner and by scheduling this matter for hearing or conciliation. Petitioner also respectfully requests that this Honorable Court direct the Cumberland County Sheriff to deputize the Dauphin County Sheriff to assist with the transfer of custody of the Child from Father to Mother. Respectfully submitted, YJeica Date W man-Hardy Legal Intern 1 LUCY JOHNSTON-WALS ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013-2899 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing Custody Complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: o? Ze Tawnya r, Petitioner Exhibit A TWANYA L. JUMPER. PLAfNT?PP V. ROGER M. ALLEM N, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUM13ORLAND COUNTY, PENNSYLVANIA 03.3677 OPAL TVW ORIDE CCU AND NOW, No + day of August, 2009, ibllawing It 1104(mg On the manta, IT IS ORDMD1 (1) All parlor custody 9rd¦rs ¦mvasaW and rdpleaed wlth this order. (2) Twanye L, .hrmperant! Roger M. Allornan shall have ehm* Isgal aunt dy of thelr son, Zachary Ryw Allernran, bom Nwarnber 19, 2001. (8) Ths. rmtherspan MvG p*Mly phydlaal custody Of Zachar?. (4) Starting on Saturday, August 20, 2000, the larthar, tir as long as he works wssksnds, shall hove ZaOory In 2110mats waeka from 10:00 a.m., Saturday to 7:00 p.m. Sunday. Altar this break-in perlod, and atarbng on Ihs #du* Weaftnd In Septamber, thIs Warrinks wsaksnd sabodule shall start at 8:00 p.m., Friday to 7:00 p.m. svnday. (0) If the fathers work $ChadUl• c h¦ngss end his days effara m?wm*, this two allarnatts weak aohaduis shWi be foliciwed With the break4n, period Iasting through Sunday. September 10. The father sheVl provide tho mother nation riot Inter than %= days in advanoe, and earlier If possible, df tho weekdays he wIU weretse his periods of lsmporary phybleal oustody. Arvr weekday perWs shell tslae proosd•nt over pwahool. A ftrting In the bummer of 2007, the NEW, as long ae he fa on vve =lion, may ham Zachary for up to lama full weeks separated by at toast a &* weak period. Tihe father shall prcr?Ida the mother at Wat iwo weelu pAvance nollce, of hid ox¦rolw M such pertoda of temporary phystaid custody, (7) Chrisbinee shall eftmele In two eegmenfa, 8egrnent A sh¦ll be from December 241h at 9:00 p.m. untii Oecemb¦r 281°1 et 2:00 p.m. $9prtwnt 9 le Irem C*o¦mtmr leP" at 2:00 p.m. until December 2011h at 7:00 p.m. The mother 0 0 have Sepmwt A In 2006. ($) The perents shell alternate Labor Davy, Thankagtuing, Now Yesfa Darr, Mewrlel Day and July 4a'`, with the father's ft alternate holbdayf being Labor Dag, On the fatheft alternate halldays hO hh*ll h** Z9010ry from B.'00 G.M. until 7:00 p.m. (1) All hinges Shall to at the Wel-Mart on the Carpels Pllm In Cumberland County. yy? r Cc C 0,? wnya,Jumper, Pro w 400 Mountaln Road NsWrilla, PA 17241 eriea S. Petrie, Esquire 4Far Defandsnt :eel o??A1e CHARLES DeCURTIS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW IN CUSTODY JANE DeCURTIS, Defendant NO. 05 - 4367 CIVIL TERM CERTIFICATE OF SERVICE I, Megan Riesmeyer, Esquire, Family Law Clinic, hereby certify that I served a true and correct copy of the Petition for Reconsideration and Stay of Order on Charles DeCurtis, residing at 2808 Knoll Way, Sinking Spring, PA 19608, by depositing a copy of the same in the United States mail, first class, postage prepaid. Date Meg Riesmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 r...a r? 4 4 y tt?? r - -t. (ate cl) TAWNYA L. JUMPER, PLAINTIFF V. ROGER M. ALLEMAN, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-3677 CIVIL TERM ORDER OF COURT AND NOW, this 70VA- day of March, 2007, a hearing on the within petition for special relief seeking emergency custody shall commence at 2:00 p.m., Monday, March 5, 2007, in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. By the Cou Edgar B. Bayley, J. Family Law Clinic - J??CL ?t For Plaintiff y Charles Petrie, Esquire ?. For Defendant P ?'?? L :sal rr? ?i ?+ ti T1 fem.. TAWNYA L. JUMPER, Plaintiff/ Petitioner V. ROGER M. ALLEMAN, Defendant/ Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW : IN CUSTODY : No. 03-3677 CIVIL TERM PRAECIPE TO WITHDRAW PETITION FOR SPECIAL RELIEF SEEKING EMERGENCY CUSTODY To the Prothonotary: Please withdraw without prejudice the Petition for Special Relief Seeking Emergency Custody in the above-captioned Complaint for Custody filed in the Cumberland County Courthouse on March 2, 2007. Date: -3 15 &a! rista Ann Fre, ertified Legal Lucy J stop-Walsh Anne MacDonald-Fox Thomas Place Robert Rains Megan Riesmeyer Supervising Attorneys The Family Law Clinic 45 N. Pitt Street Carlisle, PA 17013 (717)243-2968 TAWNYA L. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW CUSTODY ROGER M. ALLEMAN, Defendant NO. 03 - 3677 CIVIL TERM CERTIFICATE OF SERVICE I, Krista Ann Freego, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Praecipe to Withdraw Petition for Special Relief on Charles E. Petrie, Esquire, at 3528 Brisban Street, Harrisburg, PA 17111, by depositing a copy of the same in the United States mail, first class, postage prepaid. ?f Date k?& Lucy J ston-Walsh Anne MacDonald-Fox Thomas Place Robert Rains Megan Riesmeyer Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 C? rJ ? ? ^'r'{ _- ...- ?» _? 1"?'? C1'1 Y; {" ? .?+? .= "'t" ? ) .~ - C3 `;_a i-^' ?+„} TAWNYA L. JUMPER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-3677 CIVIL ACTION LAW ROGER M. ALLEMAN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, March 08, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, April 05, 2007 at 10:30 AM [or 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, By: /s/ Hubert X. Gilroy, Esq. Custody Conciliator --?r 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) 249-3166 y ? X6241 r .; h7 ?uf lE .,r 2 If 11"i ? I clivw LD0Z i? ?? :; ?Ni 3O TAWNYA L. JUMPER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PA V. : NO. 2003-3677 CIVIL TERM ROGER M. ALLEMAN CIVIL ACTION -LAW Defendant IN CUSTODY WITHDRAWAL OF APPEARANCE Please withdraw the appearance of the undersigned as counsel for Plaintiff, Tawnya L. Jumper, in the above-captioned matter. Respectfully submitted, ABOM & KUT ULAKIS, L.L.P. Date: 03 tdd Kara W. Haggerty, Es ire I.D. #86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 ENTRY OF APPEARANCE Please enter the appearance of the undersigned as counsel for Plaintiff, Tawnya L. Jumper, in the above-captioned matter. Respectfully submitted, Dickinson Law School Family Law Clinic Y 'f Date: j /I q p Attorne I.D. No: g'7r/4,7 C> C3'% TAWNYA L. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE ROGER M. ALLEMAN, Defendant : NO. 03-3677 CIVIL TERM ACCEPTANCE OF SERVICE I accept service of the Petition for Finding of Contempt of Order of Court and for Modification of Order of Court on behalf of Plaintiff, Tawnya L. Jumper, and certify that I am authorized to do so. Y _. Date L/`Z-O, Susan Plano Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Lucy Jo - alsh Anne Mac onald-Fox Thomas Place Robert Rains Megan Riesmeyer Supervising Attorneys i7t rte, - r=• s°s ? ? ?. ro =' + - C,3 APR 12 2007 OV TAWNYA L. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW ROGER M. ALLEMAN, : NO. 03-3677 Defendant : IN CUSTODY COURT ORDER AND NOW, this day of April, 2007, upon consideration of the attached Custody Conciliation report, it is ordered and directed that this Court's prior Order of August 18, 2006 shall remain in place and be subject to the following modifications: 1. The mother shall abide by the prior Order with respect to providing father custody on holidays. Additionally, father shall be entitled to two days of make- up custody for two prior holidays that he missed. Father shall be provided with this make-up by being afforded an extra weekend with the minor child to occur within the next sixty days on a weekend to be agreed upon by the parties. Father shall give mother at least one week notice as to designating the weekend he will be using for the make-up. 2. For exchange custody, mother shall always be present for exchange of custody. In the unique event that mother is not available for the custody exchange, she shall insure that her boyfriend is not involved in the exchange at that time and she shall secure another person to handle exchange of custody on her behalf. 3. Neither parent shall disparage the other parent to the child or allow other individuals to disparage the other parent. Additionally, both parents are directed to encourage the child to refer to the other parent as the appropriate parent, being mother or father, rather than on a first name basis. 4. Father shall insure that neither he or anyone else in his household is smoking cigarettes inside the home or in a car when father has tody of the minor child. Judge Edgar B. Bayley,Jrr. Cc: Student Attorney, Susan Plano, Dickinson School of Law Family Law Clinic Charles Petrie, Esquire F:\FQ,ES\DATAFILE\General\Curtent\1232IV umper v Alleman Conciliation Report-Ordenwpd ,r- 3 U, Fi 1 12, V9 1 M TAWNYA L. JUMPER, Plaintiff v ROGER M. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3677 IN CUSTODY Prior Judge: Edgar B. Bayley, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Zachary Ryan Alleman, born November 13, 2001. 2. A Conciliation Conference was held on April 5, 2007, with the following individuals in attendance: The mother, Tawnya L. Jumper, with her counsel, Student Attorney, Susan Plano, Dickinson School of Law Family Law Clinic, and the father, Roger M. Alleman, with his counsel, Charles Petrie, Esquire. 3. The parties agree to the entry of an Order in the form as attached. q-?1-6 OIQ DATE Hubert X. Gilroy, Es Custody Conciliator 1000, Op, Al- Old TAWNYA L. JUMPER, IN THE COURT OF COMMOM PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NUMBER: 03-3677 CIVIL ACTION LAW ROGER M. ALLEMAN, Defendant IN CUSTODY PETITION FOR EMERGENCY CUSTODY ORDER OF COURT TO THE HONORABLE EDGAR B. BAYLEY, JUDGE: NOW COMES Defendant, ROGER M. ALLEMAN, by and through his attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is TAWNYA L. JUMPER, whose last known address is 430 Fairground Avenue, Carlisle, County of Cumberland, Pennsylvania. 2. Defendant is ROGER M. ALLEMAN, who currently resides at 508 West Strawberry Alley, Mechanicsburg, County of Cumberland, Pennsylvania. 3. Plaintiff and Defendant are the natural parents of a minor child, ZACHARY RYAN ALLEMAN, born November 13, 2001. 4. That on August 18, 2006, the Honorable Edgar B. Bayley entered an Order granting primary physical custody of the minor child to the Plaintiff and rights of temporary physical custody of said minor child to the Defendant. A copy of the Order is attached hereto as Exhibit "A." On April 16, 2007, a Court Order was entered partially modifying the Order of August 18, 2006. A copy of this Order is attached hereto as Exhibit "B." 5. The Orders grant primary physical custody of the minor child to Plaintiff and rights of partial custody to Defendant. 6. That Defendant has been informed of the following information by Plaintiff's former boyfriend, SCOTT MORRISON: A. Plaintiff lost her job approximately one month ago. B. Plaintiff resumed her use of crack cocaine and has spending most of her time at a crack house on or near Pitt Street in Carlisle, Pennsylvania. C. The minor child has spent most nights during the past month with Scott Morrison at Plaintiffs former residence with Plaintiff not being present. The minor child has spent other nights in the past seven days with friends of Plaintiff who are strangers to the minor child, one of whom is a known crack addict with warrants for her arrest. D. That a friend of Scott Morrison picked up the minor child on Sunday, August 10, 2008, and returned the minor child to Scott. E. Defendant picked up the child at Scott Morrison's home (formerly Plaintiffs home as well) on Monday evening, August 11, 2008, and the child is currently in Defendant's custody. Plaintiff was not present for the exchange and had not seen the minor child for several days. 7. Plaintiff has a criminal record involving crimes of manufacturing and possessing drugs (1999), reckless endangerment (2000) unauthorized use of a motor vehicle, theft by unlawful taking, and receiving stolen property (1999). A summary of Plaintiffs criminal record is attached hereto as Exhibit "C." 8. Defendant fears that Plaintiff has reverted to her former ways and knows that the child has not been properly cared for during the past month. Plaintiff can properly care for the child. 9. Plaintiff has filed a Petition for Modification of Custody Order and a Conciliation Conference has not been scheduled. WHEREFORE, Defendant respectfully requests that Your Honorable Court enter an Order granting primary physical custody of the minor child to Defendant until further Order of Court. Respectfully submitted, CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Defendant COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. g 1? fl$ DATE a ?- D&4w--'? R 04?R M. ALLEMAN TWANYA L. JUMPER, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ROGER M. ALLEMAN, DEFENDANT 03-3677 CIVIL TERM ORDER OF COURT AND NOW, this day of August, 2006, following a hearing on the merits, IT IS ORDERED: (1) All prior custody orders are vacated and replaced with this order (2) Twanya L. Jumper and Roger M. Alleman shall have shared legal custody of their son, Zachary Ryan Alleman, bom November 13, 2001. (3) The mother shall have primary physical custody of Zachary. (4) Starting on Saturday, August 26, 2006, the father, for as long as he works weekends, shall have Zachary in alternate weeks from 10:00 a.m., Saturday to 7:00 p.m. Sunday. After this break-in period, and starting on the fourth weekend in September, this alternate weekend schedule shall start at 6:00 p.m., Friday to 7:00 p.m. Sunday_ (5) If the father's work schedule changes and his days off are mid-week, this same alternate week schedule shall be followed with the break-in period lasting through Sunday, September 10. The father shall provide the mother notice not later than two days in advance, and earlier if possible, of the weekdays he will exercise his periods of temporary physical custody. Any weekday periods shall take precedent over preschool. (6) Starting in the summer of 2007, the father, as long as he is on vacation, may have Zachary for up to two full weeks separated by at least a two week period. The EXHIBIT "A" father shall provide the mother at least two weeks advance notice of his exercise of such periods of temporary physical custody. (7) Christmas shall alternate in two segments. Segment A shall be from December 24t° at 9:00 a.m. until December 251h at 2:00 p.m. Segment B is from December 25th at 2:00 p.m. until December 28th at 7:00 p.m. The mother shall have Segment A in 2008. (8) The parents shall alternate Labor Day, Thanksgiving, New Year's Day, Memorial Day and July 4t", with the father's first alternate holiday being Labor Day. On the father's alternate holidays he shall have Zachary from 9:00 a.m. until 7:00 p.m. (9) All exchanges shall be at the Wal-Mart on the Carlisle Pike in Cumberland County. Tawnya Jumper, Pro se 400 Mountain Road Newville, PA 17241 Charles E. Petrie, Esquire For Defendant By?tiw Edgar B. Bayley, J. :sal APR 1 2 2007 I'l TAWNYA L. JUNIPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW ROGER M. ALLEMAN, NO. 03-3677 Defendant IN CUSTODY COURT ORDER AND NOW, this A day of April, 2007, upon consideration of the attached Custody Conciliation report, it is ordered and directed that this Court's prior Order of August 18, 2006 shall remain in place and be subject to the following modifications: 1. The mother shall abide by the prior Order with respect to providing father custody on holidays. Additionally, father shall be entitled to two days of make- up custody for two prior holidays that he missed. Father shall be provided with this make-up by being afforded an extra weekend with the minor child to'',occur within the next sixty days on a weekend to be agreed upon by the parties. Father shall give mother at least one week notice as to designating the weekend he will be using for the make-up. 2. For exchange custody, mother shall always be present for exchange of custody. In the unique event that mother is not available for the custody exchange, she shall insure that her boyfriend is not involved in the exchange at that time and she shall secure another person to handle exchange of custody on her behalf. 3. Neither parent shall disparage the other parent to the child or allow other individuals to disparage the other parent. Additionally, both parents are directed to encourage the child to refer to the other parent as the appropriate parent, being mother or father, rather than on a first name basis. 4. Father shall insure that neither he or anyone else in his household is smoking cigarettes inside the home or in a car when father has custody of the minor child. BY THE COURT, As/ /1"L. ?J dge dgar B. Bay ey( r. Cc: Student Attorney, Susan Plano, Dickinson School of Law Family Law Clinic Charles Petrie, Esquire 17\FILFS\DATAFILB.Gencral\CinTent\1'_32 I Uwnper v Alleman Conciliation R•po-Ordcr.wpd T%. t any whereof, 0 hare unto set my hW SO# Of Skid Court at Cads, P& EXHIBIT "B" 3 O ? J-00-7 P Ihr? rV / Cumberland County Court of Common Pleas Court Summary Jumper, Tawnya Lynn 17013 Aliases: Jumper, Tawnya DOB:01 /22/1970 Sex: Female Eyes:Hazel Hair:Brown Race:Caucasian Closed Cumberland CP-21-CR-0001160-1999 Proc Status: Sentenced/Penalty Imposed DC No: OTN:F241 f 894 Arrest Dt: 05117/1999 Disp Date: 08/24/1999 Disp Judge, Hoffer, George E. Def Atty: Barry, Ellen Knowles - (PR) Sea No Statute Grade Description Disposition Sentence Length sentence DL , ggMMC Tvce Program Period 1 35 § 780-113 F Manuf/Dei/Poss/W int Manuf Or Del Guilty Plea 10119/1999 IPP Max: 5 Year(s) Dauphin CP-22-CR-0000447-2000 Proc Status: Migrated Case DC No: OTN:E9894415 Arrest Dt: 02103/2000 Disp Date: Disp Judge: Sea No Statute grade Description Disposition 1 18 § 2705 M2 Recklessly Endangering Another Person York CP-67-CR-0000081-1999 Proc Status: Migrated Case DC No: OTN:E$027380 Arrest Dt: 09/23/1998 Disp Date: 12/29/1998 Disp Judge: Migrated, Judge Def Atty: Blocher, Bruce Piersoll - (PR) Grade r Sea No Statute Disposition Description Sentence Dt. Sentence Tvce Progra m Period sentence Length 1 18 § 3928 M2 Unauth Use Motor/Other Vehicles Guilty Plea 12/2911998 Probation Max: 2 Month(s) 30 Day(s) 2 18 § 3921 M2 Theft By Unlaw Taking-Immovable Withdrawn Prop 3 18 § 3925 M2 Receiving Stolen Property Withdrawn Archived CP-21-CR-0000966-1996 Comm. v. Jumper, Tawnya CP-22-CR-0000639-1999 CP-22-MD-2100311-1999 Comm. v. Jumper, Tawnya in Re: Jumper, Tawnya AOPC 3541 REV. 08112/2008 Page 1 of 1 Printed: 8112/2008 1:19 PM Recent entries made in the court filing offices may not be immediately reflected on the court summary report. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assume any liability for inaccurate or delayed data, errors or omissions on these reports. Court Summary Report information should not be used in place of a criminal history background check which can only be provided by the Pennsylvania State Police. Moreover an employer who does not comply with the provisions of the Criminal History Record Information Act may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. EXHIBIT "C" TAWNYA L. JUMPER, IN THE COURT OF COMMOM PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. NUMBER: 2003-3677 CIVIL TERM ROGER M. ALLEMAN, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, KELLY P. ROBERTS, Paralegal, for Attorney Charles E. Petrie, hereby certify that on August 13, 2008, a true and correct copy of the attached Petition for Emergency Custody Order was served by First class mail, postage prepaid on the following: ROGER M. ALLEMAN 508 W. STRAWBERRY ALLEY MECHANICSBURG, PA 17050 HUBERT X. GILROY, ESQUIRE 4 NORTH HANOVER STREET CARLISLE, PA 17013 TAWNYA JUMPER 430 FAIRGROUND AVENUE CARLISLE, PA 17113 DATED: 8/13/2008 CHARLES E. PETRIE, ESQUIRE BY: )KqKy P. Roberts <3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 C"? ? ?? c . ?:? .,-?, ? ? ??'' ,:a ., ?? ?i??? r? -a .,. (`^.J TAWNYA L. JUMPER, Plaintiff VS. ROGER M. ALLEMAN, Defendant IN THE COURT OF COMMOM PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NUMBER: 03-3677 CIVIL ACTION LAW : IN CUSTODY PETITION FOR MODIFICATION OF ORDER OF COURT TO THE HONORABLE EDGAR B. BAYLEY, JUDGE: NOW COMES Defendant, ROGER M. ALLEMAN, by and through his attorney, Charles E. Petrie, and respectfully represents as follows: 1. Plaintiff is TAWNYA L. JUMPER, whose last known address is 430 Fairground Avenue, Carlisle, County of Cumberland, Pennsylvania. 2. Defendant is ROGER M. ALLEMAN, who currently resides at 508 West Strawberry Alley, Mechanicsburg, County of Cumberland, Pennsylvania. 3. Plaintiff and Defendant are the natural parents of a minor child, ZACHARY RYAN ALLEMAN, born November 13, 2001. 4. That on August 18, 2006, the Honorable Edgar B. Bayley entered an Order granting primary physical custody of the minor child to the Plaintiff and rights of temporary physical custody of said minor child to the Defendant. A copy of the Order is attached hereto as Exhibit "A." On April 16, 2007, a Court Order was entered partially modifying the Order of August 18, 2006. A copy of this Order is attached hereto as Exhibit "B." 5. The Orders grant primary physical custody of the minor child to Plaintiff and rights of partial custody to Defendant. 6. That Defendant has been informed of the following information by Plaintiffs former boyfriend, SCOTT MORRISON: A. Plaintiff lost her job approximately one month ago. B. Plaintiff resumed her use of crack cocaine and has spending most of her time at a crack house on or near Pitt Street in Carlisle, Pennsylvania. C. The minor child has spent most nights during the past month with Scott Morrison at Plaintiff's former residence with Plaintiff not being present. The minor child has spent other nights in the past seven days with friends of Plaintiff who are strangers to the minor child, one of whom is a known crack addict with warrants for her arrest. D. That a friend of Scott Morrison picked up the minor child on Sunday, August 10, 2008, and returned the minor child to Scott. E. Defendant picked up the child at Scott Morrison's home (formerly Plaintiff's home as well) on Monday evening, August 11, 2008, and the child is currently in Defendant's custody. Plaintiff was not present for the exchange and had not seen the minor child for several days. 7. Plaintiff has a criminal record involving crimes of manufacturing and possessing drugs (1999), reckless endangerment (2000) unauthorized use of a motor vehicle, theft by unlawful taking, and receiving stolen property (1999). A summary of Plaintiff's criminal record is attached hereto as Exhibit "C." 8. Defendant fears that Plaintiff has reverted to her former ways and knows that the child has not been properly cared for during the past month. Plaintiff can properly care for the child. WHEREFORE, Defendant respectfully requests that Your Honorable Court enter an Order granting primary physical custody of the minor child to Defendant until further Order of Court. Respectfully submitted, ???, A CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Defendant COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ?, 10 1, 0.3 &0, wj . DATE R R M. ALLEMAN TWANYA L. JUMPER, PLAINTIFF V. ROGER M. ALLEMAN, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 03-3677 CIVIL TERM ORDER OF COURT AND NOW, this _day of August, 2006, following a hearing on the merits, IT IS ORDERED: (1) All prior custody orders are vacated and replaced with this order. (2) Twanya L. Jumper and Roger M. Alleman shall have shared legal custody of their son, Zachary Ryan Alleman, born November 13, 2001. (3) The mother shall have primary physical custody of Zachary. (4) Starting on Saturday, August 26, 2006, the father, for as long as he works weekends, shall have Zachary in alternate weeks from 10:00 a.m., Saturday to 7:00 p.m. Sunday. After this break-in period, and starting on the fourth weekend in September, this alternate weekend schedule shall start at 6:00 p.m., Friday to 7:00 p.m. Sunday_ (5) If the father's work schedule changes and his days off are mid-week, this same alternate week schedule shall be followed with the break-in period lasting through Sunday, September 10. The father shall provide the mother notice not later than two days in advance, and earlier if possible, of the weekdays he will exercise his periods of temporary physical custody. Any weekday periods shall take precedent over preschool. (6) Starting in the summer of 2007, the father, as long as he is on vacation, may have Zachary for up to two full weeks separated by at least a two week period. The EXHIBIT "A" father shall provide the mother at least two weeks advance notice of his exercise of such periods of temporary physical custody. (7) Christmas shall alternate in two segments. Segment A shall be from December 24th at 9:00 a.m. until December 25th at 2:00 p.m. Segment 8 is from December 25th at 2:00 p.m. until December 26th at 7:00 p.m. The mother shall have Segment A in 2006. (8) The parents shall alternate Labor Day, Thanksgiving, New Year's Day, Memorial Day and July 4th, with the father's first alternate holiday being Labor Day. On the father's alternate holidays he shall have Zachary from 9:00 a.m. until 7:00 p.m. (9) All exchanges shall be at the Wal-Mart on the Carlisle Pike in Cumberland County. By the' Co Edgar B. Bayley, J. Tawnya Jumper, Pro se 400 Mountain Road Newville, PA 17241 Charles E. Petrie, Esquire For Defendant :sal APR 1 2 2007 TAWNYA L. JUNIPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLN`ANIA CIVIL ACTION - LAW ROGER M. ALLEMAN, NO. 03-3677 Defendant IN CUSTODY COURT ORDER AND NOW, this %i. ?_ day of April, 2007, upon consideration of the attached Custody Conciliation report, it is ordered and directed that this Court's prior Order of August 18, 2006 shall remain in place and be subject to the following modifications: 1. The mother shall abide by the prior Order with respect to providing father custody on holidays. Additionally, father shall be entitled to two days of make- up custody for two prior holidays that he missed. Father shall be provided with this make-up by being afforded an extra weekend with the minor child to occur within the next sixty days on a weekend to be agreed upon by the parties. Father shall give mother at least one week notice as to designating the weekend he will be using for the make-up. 2. For exchange custody, mother shall always be present for exchange of custody. In the unique event that mother is not available for the custody exchange, she shall insure that her boyfriend is not involved in the exchange at that time and she shall secure another person to handle exchange of custody on her behalf. 3. Neither parent shall disparage the other parent to the child or allow other individuals to disparage the other parent. Additionally, both parents are directed to encourage the child to refer to the other parent as the appropriate parent, being mother or father, rather than on a first name basis. 4. Father shall insure that neither he or anyone else in his household is smoking cigarettes inside the home or in a car when father has custody of the minor child. BY THE COURT, Judge t dgar B. Bayley; Jr. Cc: Student Attorney, Susan Plano, Dickinson School of Law Family Law Clinic Charles Petrie, Esquire {.y P ril.r5VDAVAI-I L['l?ua raPC unm 1'_1'_IVun?x v,AIla,nn Gmcihz, io,, R,1-1-01 J11 11 Jkj ? ,tJ=ny whereat. s "Ire unte set my ham SON of said Corgi rt at Carbi k P& EXHIBIT "B" 6(LAi_'' -) t Z ._._. p?t?tk++IMit?r'o W- Jumper, Tawnya Lynn 17013 Aliases: Jumper, Tawnya Cumberland County Court of Common Pleas Court Summary DOB:01122/1970 Sex:Female Eyes:Hazei Hair: Brown Race:Caucasian Closed Cumberland CP-21-CR-0001160-1999 Proc Status: Sentenced/Penalty Imposed DC No: OTN:F2411894 Arrest Dt: 05/17/1999 Disp Date: 08/24/1999 Disp Judge: Hoffer, George E. Def Atty: Barry, Ellen Knowles - (PR) Sea No Statute Grade Description Disposition Sentence Dt. Sentence Type Program Period Sentence Length 1 35 § 780-113 F Manuf/Del/Poss/W Int Manuf Or Del Guilty Plea 10/19/1999 IPP Max: 5 Year(s) Dauphin CP-22-CR-0000447-2000 Proc Status: Migrated Case DC No: OTN:E9894415 Arrest Dt: 02/03/2000 Disp Date: Disp Judge: Sea No Statute Grade Description Disposition 1 18 § 2705 M2 Recklessly Endangering Another Person York CP-67-CR-0000081-1999 Proc Status: Migrated Case DC No: OTN:E8027390 Arrest Dt: 09/23/1998 Disp Date: 12129/1998 Disp Judge: Migrated, Judge Def Atty: Blocher, Bruce Piersoll - (PR) Sea No Statute Grade Description Disposition Sentence Dt. Sentence Type Progra m Period Sentence Length 1 18 § 3928 M2 Unauth Use Motor/Other Vehicles Guilty Plea 12/29/1998 Probation Max: 2 Month(s) 30 Day(s) 2 18 § 3921 M2 Theft By Unlaw Taking-Immovable Withdrawn Prop 3 18 § 3925 M2 Receiving Stolen Property Withdrawn Archived CP-21-CR-0000966-1996 CP-22-CR-0000639-1999 CP-22-MD-2100311-1999 Comm. v. Jumper, Tawnya Comm. v. Jumper, Tawnya In Re: Jumper, Tawnya AOPC 3541 REV. 08/1212008 Page 1 of 1 Printed: 8112/2008 1:19 PM Recent entries made in the court filing offices may not be immediately reflected on the court summary report. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assume any liability for inaccurate or delayed data, errors or omissions on these reports. Court Summary Report information should not be used in place of a criminal history background check which can only be provided by the Pennsylvania State Police. Moreover an employer who does not comply with the provisions of the Criminal History Record Information Act may be subjectto civil liability as set forth in 18 Pa.C.S. Section 9183. EXHIBIT "C" TAWNYA L. JUMPER, IN THE COURT OF COMMOM PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. NUMBER: 2003-3677 CIVIL TERM ROGER M. ALLEMAN, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, KELLY P. ROBERTS, Paralegal, for Attorney Charles E. Petrie, hereby certify that on August 13, 2008, a true and correct copy of the attached Petition for Modification of Order of Court was served by First class mail, postage prepaid on the following: ROGER M. ALLEMAN 508 W. STRAWBERRY ALLEY MECHANICSBURG, PA 17050 HUBERT X. GILROY, ESQUIRE 4 NORTH HANOVER STREET CARLISLE, PA 17013 TAWNYA JUMPER 430 FAIRGROUND AVENUE CARLISLE, PA 17113 DATED: 8L!312008 CHARLES E. PETRIE, ESQUIRE BY: Iy P. e rts 528 Brisban n Street Harrisburg, PA 17111 (717) 561-1939 w? ?_ ? ?,? S V Y? f ... ?l .E'.1 t;' .. ? ?? yae :;:. ' ?.7 i? t7Z ?? `?.? V TAWNYA L. JUMPER, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ROGER M. ALLEMAN, DEFENDANT 03-3677 CIVIL TERM ORDER OF COURT AND NOW, this P"k day of August, 2008, a hearing on the within petition for an emergency order granting temporary physical custody of Zachary Ryan Alleman, born November 13, 2001, to Roger M. Alleman, shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania at 1:30 p.m., August 20, 2008. /awnya Jumper, Pro se 430 Fairground Avenue Carlisle, PA 17013 ,f-Arles E. Petrie, Esquire or Defendant sal V'1?je-a VA 1 By the Edgar B. Bayley, J. .^ ? C?:% ` _ - LLJ LD ii =:> ; - t i iE- .erg J CL t C) cv TAWNYA L. JUMPER, Plaintiff V. ROGER M. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 03-3677 CIVIL ACTION -LAW IN CUSTODY PLAINTIFF'S ANSWER TO DEFENDANT'S PETITION FOR EMERGENCY CUSTODY ORDER OF COURT AND NEW MATTER AND NOW, comes Plaintiff, TAWNYA L. JUMPER, by and through her attorneys, The Family Law Clinic, and respectfully represents the following: 1. DENIED. By way of further answer, Plaintiff, Tawnya L. Jumper, resides at 111 Broad Street, Newville, Cumberland County, Pennsylvania 17241. 2. ADMITTED. 3. ADMITTED. 4. ADMITTED. 5. ADMITTED. 6. Plaintiff lacks sufficient knowledge to admit or deny whether Scott Morrison provided Defendant with the listed information. A. DENIED. By way of further answer, Plaintiff resigned from her job approximately one month ago. Plaintiff is awaiting confirmation of a security clearance from Letterkenny Army Depot and expects to begin employment there in the immediate future. B. ADMITTED IN PART AND DENIED IN PART. It is admitted that Plaintiff's abstention from drugs was interrupted on one (1) occasion while the minor Child was not in her care. It is denied that Plaintiff currently uses illegal drugs and that 1 she has been spending any time at a crack house on or near Pitt Street in Carlisle, Pennsylvania. C. ADMITTED IN PART AND DENIED IN PART: It is admitted that the Child spent approximately one (1) week at the home of Scott Morrison without Plaintiff being present after Mr. Morrison, Plaintiff s former paramour, kicked her out on approximately July 31, 2008 and would not permit her to return to their home. It is denied that the minor child has spent other nights in the past seven days with friends of Plaintiff who are strangers to the minor child. By way of further answer, while Plaintiff was in the process of securing new housing, the Child spent a total of two (2) nights with Plaintiff at the home of friends known to the child. Neither of those individuals has ever used drugs, nor were there any drug users in the home or around the child. D. ADMITTED. By way of further answer, the friend is a mutual friend of Plaintiff and Scott Morrison. E. ADMITTED. By way of further answer, Plaintiff has not seen the Child for several days because Defendant will not permit her to see the Child, and Defendant has restricted Plaintiff's telephone contact with the Child as well. 7. ADMITTED. However, by way of further answer, the charges of theft by unlawful taking and receiving stolen property were withdrawn. 8. ADMITTED IN PART AND DENIED IN PART. It is admitted that Plaintiff can properly care for the child. It is denied that the child has not been properly cared for during the past month. Plaintiff lacks sufficient information to address the issue of Defendant's fears. 2 9. ADMITTED IN PART AND DENIED IN PART. It is admitted that a Conciliation Conference has not been scheduled. It is denied that Plaintiff filed a Petition for Modification of Custody Order. NEW MATTER: Safety and Welfare of the child 10. Paragraphs One through Nine are hereby incorporated as if fully set out herein. 11. Plaintiff currently resides with her grandfather in his three (3) bedroom home at 111 Broad Street, Newville, PA. Plaintiff resides in the Big Spring School District. The Child attended kindergarten in this school district, where he has established friendships and a reasonable level of comfort with the faculty and his peers. 12. The Child is registered for the first grade and is expected to begin classes in the Big Springs School District on August 29, 2008. 13. Defendant does not reside in the Big Spring School District, and the Child will be forced to change school districts if primary custody is transferred to Defendant. 14. Except for a period of approximately five (5) months in 2004, Plaintiff has been the Child's primary caregiver since his birth. 15. Defendant, Roger M. Alleman has a history of drug use, public drunkenness, and possession of illegal drugs. A copy of Defendant's criminal record has been attached hereto as Exhibit "A." 16. Defendant currently resides with his twenty-year-old son, Matthew Alleman, who has a juvenile and adult criminal history involving harassment and violence. Defendant often leaves the minor Child alone with Matthew Alleman while the minor Child is in Defendant's custody. 3 17. In addition to leaving the Child in the care of Matthew Alleman, Defendant has left the young child alone and unsupervised in Defendant's apartment. WHEREFORE, Plaintiff requests that this Honorable Court deny Defendant's Petition for Emergency Custody Order of Court and direct Defendant to return the Child to Plaintiff pursuant to the August 18, 2006 Order of Court. Date: $ Zo 0% -T Reessppeectf illy Submitted, MICHAEL A. O'DONNELL Certified Legal Intern 4 zl:::4, MEGA RIESMEYER 10, ANNE MACDONALD-FOX Supervising Attorney THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 4 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. .r Date (? 9 Plaintiff "Ji Tawnya J p EXHIBIT "A": DEFENDANT'S CRIMINAL RECORD Magisterial District Judge 12-1-03 MEL Docket Number: CR-0000617-03 Criminal Docket COMMONWEALTH OF PENNSYLVAN IA V. ALLEMAN, ROGER M Page 1 of 1 Judge Assigned: SOLOMON, JOSEPH S Issue Date: OTN: H 789848-3 File Date: 09/08/2003 Arresting Agency: HARRISBURG, POLICE DEPT Case Disp: Waived for Court Arresting Officer: Disp Date: 10/27/2003 Complaint/incident # 2286677-1 Requested: $0.00 County: DAUPHIN Judgment: $0.00 Township: HARRISBURG CITY Case Status: Adjudicated Name: ALLEMAN, ROGER M Address: NEW CUMBERLAND, PA 17070 Date Of Birth: 08/27/1964 Sex: Male Race: White Bail Type: ROR Status Date: 10/27/2003 Bail Status: Set Posting Date Bail Amount: $0.00 O/S Amount: $0.00 Bail Percentage: # Charge Grade Description Disposition 1 35 § 780-113 §§ A16 INT POSS CONTR SUBST BY PER NOT REG Waived for Court (Lower Court) 2 18 § 5505 S PUBLIC DRUNKENNESS AND SIMILAR Waived for Court (Lower Court) MISCONDUCT Schedule Date Event Type Status 10/13/2003 10:00 AM Preliminary Hearing CONT 10/27/2003 01:00 PM Preliminary Hearing WAV Total Due: $0.00 Total Adj: $0.00 Total Paid: $0.00 Balance: $0.00 Summons Date Summons Action 09/12/2003 SUMMONS ACCEPTED EXHIBIT 1200 rnmea: utsntsrzuuts a:za pm Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) may be subject to civil liability asset forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 12-1-04 Docket Number: NT-0000442-04 Non-Traffic Citation Docket COMMONWEALTH OF PENNSYLVA NIA V. ALLEMAN, ROGER M Page 1 of 1 Judge Assigned: STEWART, MARSHA C Issue Date: 03/04/2004 OTN: File Date: 03/09/2004 Arresting Agency: HARRISBURG, POLICE DEPT Case Disp: Guilty By Plea Arresting Officer. Disp Date: 03/25/2004 Complaint/incident # P4791170-6 Requested: $0.00 County: DAUPHIN Judgment: $0.00 Township: HARRISBURG CITY Case Status: Adjudicated Name: ALLEMAN, ROGER M Address: MIDDLETOWN, PA 17057 Date Of Birth: 08/27/1964 Sex: Race: # Charge Grade Description Disposition 1 18 § 5505 S PUBLIC DRUNKENNESS AND SIMILAR Guilty Plea (Lower Court) MISCONDUCT Total Due: $142.50 Total Adj: $0.00 Total Paid: $142.50 Balance: $0.00 EXHIBIT -A 1200 i nmea: ua iaituua o.za pm Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 at seq.) maybe subject to civil liability asset forth in 18 Pa.C.S. Section 9183. Northampton County Court of Common Pleas Court Summary Alleman, Roger M. DOB:08/27/1964 Sex:Male Harrisburg, PA 17111 Eyes:Hazel Hair:Blond or Strawberry Race:Caucasian Closed Northampton CP-48-SA-0002269-2004 Proc Status: Migrated Case DC No: OTN: Arrest Dt: 08/13/2004 Disp Date: Disp Judge: Sea No Statute Grade Description Disposition 1 75 § 4902 S Restrictions On Use Of Highways And Bridges Dauphin CP-22-CR-0003805-2003 Proc Status: Sentenced/Penalty Imposed DC No: OTN:H7898483 Arrest Dt: Disp Date: 04114/2004 Disp Judge: Migrated, Judge Def Atty: Abeln, Gregory Barton - (PR) e No Statute Grade Description Disposition Sentence Dt. Sentence Type Program Period Sentence Lenath 1 35 § 780-113 M Use/Poss Of Drug Paraph ARD - County 2 18 § 5505 S Public Drunkenness And Similar ARD - County Misconduct EXHIBIT A AOPC 3541 REV. 08/18/2008 Page 1 of 1 Printed: 8118/2008 5:23 PM Recent entries made in the court filing offices may not be immediately reflected on the court summary report. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assume any liability for inaccurate or delayed data, errors or omissions on these reports. Court Summary Report information should not be used in place of a criminal history background check which can only be provided by the Pennsylvania State Police. Moreover an employer who does not comply with the provisions of the Criminal History Record Information Act may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Dauphin County Court of Common Pleas Court Summary Alleman, Roger M. Harrisburg, PA 17111 DOB:08/27/1964 Closed Dauphin CP-22-CR-0003805-2003 Proc Status: Sentenced/Penalty Imposed DC No: Arrest Dt: Disp Date: 04/14/2004 Disp Judge: Migrated, Judge Def Atty: Abeln, Gregory Barton - (PR) Sea No Statute Grade Description Sex:Male Eyes:Hazel Hair.Blond or Strawberry Race:Caucasian Disposition OTN:H7898483 Sentence Dt. Sentence Type Program Period Sentence Length 1 35 § 780-113 M Use/Poss Of Drug Paraph ARD - County 2 18 § 5505 S Public Drunkenness And Similar ARID - County Misconduct Northampton CP-48-SA-0002269-2004 Proc Status: Migrated Case DC No: Arrest Dt: 08/13/2004 Disp Date: Disp Judge: Sea No Statute Grade Description Disposition 1 75 § 4902 S Restrictions On Use Of Highways And Bridges OTN: EXHIBIT AOPC 3541 REV. 08!18/2008 Page 1 of 1 Printed: 8/18/2008 5:24 PM Recent entries made in the court filing offices may not be immediately reflected on the court summary report Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assume any liability for inaccurate or delayed data, errors or omissions on these reports. Court Summary Report information should not be used in place of a criminal history background check which can only be provided by the Pennsylvania State Police. Moreover an employer who does not comply with the provisions of the Criminal History Record Information Act may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 12-3-02 Docket Number: NT-0000256-05 Non-Traffic Citation Docket COMMONWEALTH OF PENNSYLVA NIA V. ALLEMAN, ROGER M Page 1 of 1 Judge Assigned: JOHNSON, GREGORY D Issue Date: 11/29/2005 OTN: File Date: 11/29/2005 Arresting Agency: LYKENS PSP Case Disp: Guilty By Trial Arresting Officer. DION, MATTHEW C Disp Date: 01/30/2006 Complaint/incident # T0118616-1 Requested: $0.00 County: DAUPHIN Judgment: $0.00 Township: HALIFAX TWP Case Status: Adjudicated Name: ALLEMAN, ROGER M Address: DAUPHIN, PA 17018 Date Of Birth: 08/27/1964 Sex: Male Race: White # Charge Grade Description Disposition 1 18 § 5505 S PUBLIC DRUNKENNESS AND SIMILAR Guilty by Trial (Lower Court) MISCONDUCT Schedule Date Event Type Status 01/30/2006 10:45 AM Summary Trial GT Total Due: $193.50 Total Adj: $0.00 Total Paid: $193.50 Balance: $0.00 Summons Date Summons Action 11/29/2005 SUMMONS ISSUED Name: DION, MATTHEW C EXHIBIT 1200 rnmeo: uoi iwzuuo 7:ci Pm Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) maybe subject to civil liability as set forth in 18 Pa.C.S. Section 9183. TAWNYA L. JUMPER, Plaintiff V. ROGER M. ALLEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 03-3677 CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I, Michael O'Donnell, Certified Legal Intern, Family Law Clinic, hereby certify that I will serve a true and correct copy of Plaintiff's Answer to Defendant's Petition for Emergency Custody Order of Court and New Matter on Charles E. Petrie, Esquire, attorney of record for Defendant, via facsimile and hand delivery on August 20, 2008. Date: 8? sc Da' MICHAEL A. O'DONNELL Certified Legal Intern A ftuqV MEGA RIESMEYER ANNE MACDONALD-FOX Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ra `TI C? TAWNYA L. JUMPER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ROGER M. ALLEMAN DEFENDANT 2003-3677 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, August 19, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, September 11, 2008 at 9:30 AM 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, By: Js/ Hubert X. Gilroy, Esq. 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) 249-3166 r lop 5c,-7- ?nq,;.,f? c^?,nn 1 e1 ?2 V9 ??l a?vl Vi?fj )anrr, 9S :C Wd 61 SnVoooz d?ib'1C alt; c3 :iii ?G 1,XJ4 `t--03j TAWNYA L. JUMPER, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ROGER M. ALLEMAN, DEFENDANT 03-3677 CIVIL TERM ORDER OF COURT AND NOW, this 21s' day of August, 2008, following a hearing on the petition of Roger M. Alleman for an emergency order of temporary physical custody of Zachary Ryan Alleman, born November 13, 2001, the petition IS DENIED. Roger M. Alleman, shall return Zachary to Tawnya L. Jumper on Monday, August 25, 2008, not later than 7:00 p.m. Anne Macdonald-Fox, Esquire Michael A. O'Donnell, Certified Legal Intern ,,Wily Law Clinic For Plaintiff By th?'Court, (r 2, a Edgar B. Bayley, .9harles E. Petrie, Esquire For Defendant sal C?. C b ?+ U SHERIFF'S RETURN - REGULAR CASE NO: 2003-03677 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ALLEMAN TAWNYA L VS ALLEMAN ROGER M MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within ORDER OF COURT was served upon ALLEMAN TAWNYA L the PLAINTIFF , at 0014:05 HOURS, on the 15th day of August , 2008 at 430 FAIRGROUND AVENUE CARLISLE, PA 17013 TAWYNA L JUMPER by handing to a true and attested copy of ORDER OF COURT EMERGENCY CUSTODY HEARING together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Postage Sworn and Subscibed to before me this So Answers: 18.00 5.00 .00 10.00 ,Thomas Kline .42 33.42 08/19/2008 CHARLES PETRIE, ESQUIRE gla1a'Iol By: day Deputy eriff of A. D. TAWNYA L. JUMPER, IN THE COURT OF COMMOM PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NUMBER: 03-3677 CIVIL ACTION LAW ROGER M. ALLEMAN, Defendant IN CUSTODY 012ATiINTO ` NOW COMES Defendant, ROGER M. ALLEMAN, by and through his attorney, Charles E. Petrie, and respectfully withdraws his Petition for Modification of Order of Court filed on August 13, 2008. Respectfully submitted, CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Defendant TAWNYA L. JUMPER, IN THE COURT OF COMMOM PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs. NUMBER: 2003-3677 CIVIL TERM ROGER M. ALLEMAN, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Charles E. Petrie, hereby certify that on September 10, 2008, a true and correct copy of the attached Petition for Emergency Custody Order was served by First class mail, postage prepaid on the following: HUBERT X. GILROY, ESQUIRE 10 EAST HIGH STREET CARLISLE, PA 17013 FAMILY LAW CLINIC 45 NORTH PITT STREET CARLISLE, PA 17013 DATED: 9/10/2008 CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 °, ,., t?,r• _.? i Sri 1 .?' A.._? - .. ?..i '4"Ka TAWNYA L. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW ROGER M. ALLEMAN, NO. 2003-3677 Defendant IN CUSTODY COURT ORDER AND NOW, this l day of September, 2008, the Conciliator being advised the Defendant withdraws the Petition for Modification, the Conciliator relinquishes jurisdiction. Bert X. Gilr , Esquire Custody Con iliator r-A ,C:::? A OM & Nu UL.AKIS Kara W Haggerty, Esquire AttorneyLD. #: 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 TAWNYA JUMPER, Plaintiff/Petitioner V. ROGER M. ALLEMAN, Defendant/Respondent t ? JU 20 P 5 ? V,jq IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3677 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY AND NOW, comes the Petitioner, TAWNYA JUMPER, by and through her attorney, Kara W. Haggerty, Esquire, of ABOM & KUTULAKis, L.L.P., and respectfully petitions for modification of custody, and in support thereof avers the following: 1. Petitioner is Tawnya Jumper, Plaintiff/Petitioner (hereinafter referred to as "Mother"), who currently resides at 910 J Hanover Street, New Oxford, Adams County, Pennsylvania and is represented by Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P. 2. Respondent is Roger M. Alleman, Defendant/Respondent (hereinafter referred to as "Father"), who currently resides at 508 Strawberry Lane, Mechanicsburg, Cumberland County, Pennsylvania. 3. On August 21, 2008, the Honorable Edgar G. Bayley issued a Court Order denying Defendant's emergency order of temporary physical custody and instructing Defendant to return the Minor Child to Mother's custody. cv Qirvt? `7().Co pd a Olt as ro R 9 CDC) $oa 4. However, Mother and Father have not been following the August 21, 2008 Order attached hereto and made a part hereof marked "Exhibit A". 5. Father has been exercising sole physical custody of the Minor Child and has not allowed Mother to see the Child for months. 6. Paragraphs one (1) through four (4) of this Complaint are incorporated herein by reference as though set forth in full. 7. This Agreement should be modified because: a. Father is restricting all access mother has with Minor Child. b. Mother is requesting a phase in schedule, which will eventually lead to shared physical custody. c. Mother wants to reestablish her relationship with the Minor child and be a constant in the Minor Child's life. WHEREFORE, the Petitioner requests that this Court modify the existing custody arraignment to allow Mother's to have regular contact with the Minor Child by a phase in schedule. Respectfully submitted, DINE Db 12,0) r AB 0M & KUTULAKIS, L.L.P. Kara W. Haggerty, Es 44 Supreme Court ID 86 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Petitioner/Plaint 4 AND NOW, this 20th day of June, 2011, I, Sally Evans, of Abom & Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Petition for Modification of Custody, upon the Defendant/Respondent by depositing, or causing to be deposited, same in the United States Mail, , postage prepaid addressed to the following: Roger M. Alleman 508 Strawberry Lane Mechanicsburg, PA 17055 Pro Se Defendant 1 Sally Evans TAWNYA JUMPER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA j ?Y V, 2003-3677 CIVIL ACTION LAW =M x ? i-- F ro rr ROGER M. ALL "-MAN IN CUSTODY r--p Cp - - DFF END.ANT 1 , S- ORDER OF COURT ? AND NOW, Friday, July 01, 2011 upon consideration of the attached Co mplaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Sunday, July 31, 2011 at 8:30 AM 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. Failure to ar)jear at the conference may provide grounds for entry of a temporary or permanent order. The court h reby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orde s, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilro?, Es Custody Conciliator The C ourt 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 dis, bled individuals having business before the court, please contact our office. All arrangements must be made a. least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or h °aring. YOC 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 ?eff eop q?l Telephone (717) 249-3166 cvv M ?','? U C/ ?io?7?or low I rr C9 I lecil 710 /?? A? S TAWNYA JUMPER, Plaintiff v ROGER M. ALLEMAN, Defendant PRIOR JUDGE: Albert H. Masland IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2003-3677 CIVIL ACTION - LAW IN CUSTODY r COURT ORDER ``•' e AND NOW, this :-161? day of October, 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's prior Order of September 26, 2011, shall remain in place subject to the following modifications: 1. The mother's periods of temporary custody are modified such that she shall have custody on October 22, October 29 and November 5 from 9:00 a.m. until 3:00 p.m. Starting November 12, the mother shall have custody from 9:00 a.m. until 8:00 p.m. on November 12, November 19, November 26 and December 3. 2. The parties shall meet again for another Custody Conciliation Conference on Thursday, December 8, 2011, at 8:30 a.m. 3. Neither party shall disparage the other parent to the child or in front of the child nor permit any other adult to disparage the other parent in front of the minor child. 4. When mother has custody, she shall insure that the minor child calls the father once during that time to be in the middle of the custodial time. 5. Neither party shall smoke when they have custody of the minor child nor shall they be in the presence of other adults who are smoking in an enclosed location such as building or an automobile. 6. Paragraph 6 of the September 26, 2011 Order is modified such that the mother has custody from 3:00 p.m. on Thanksgiving Day until 8:00 p.m. In all other respects, this Court's prior Order of September 26, 2011, shall remain in effect. 8. Legal counsel for the parties are directed to communicate with each other prior to the custody Conciliation Conference scheduled above and attempt to determine whether an agreement can be reached for an extension of the custodial arrangement between the parties. If an agreement can be reached, they can notify the Custody Conciliator in advance of the Custody Conciliation Conference scheduled above and the Conciliator can submit an appropriate Order to this Court to cancel that conference and recommend a more permanent custody arrangement. BY THE COURT, cc: ? Kara W. Haggerty, Esquire ? Charles Peterie, Esquire ?Pi", pwled Io (WQ,A 11 TAWNYA JUMPER, Plaintiff v ROGER M. ALLEMAN, Defendant PRIOR JUDGE: Albert H. Masland IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2003-3677 CIVIL ACTION - LAW IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Zachary Alleman, born September 13, 2001. 2. A Conciliation Conference was held on October 19, 2011, with the following individuals in attendance: Kara W. Haggerty, Esquire, who represents the mother, Tawnya Jumper. The mother was available via telephone if needed. Also present was the father, Roger M. Alleman, with his counsel, Charles Petrie, Esquire. 3. Based upon the recommendation of the Custody Conciliator, the parties agree to the entry of an Order in the form as attached. Date: October,20, 2011 Hube . Gilroy, Esquire Cus dv Conciliator TAWNYA L. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 03-3677 ROGER M. ALLEMAN, : CIVIL ACTION — LAW Defendant : IN CUSTODY PETITION TO MODIFY CUSTODY ORDER (2P AND NOW, comes Tawnya Jumper (Mother), by her attorneys, the Community Law Clinic, and respectfully petitions this court to modify the Order of Court entered on the 13th day of December, 2011 for custody of Zachary Allman, (the child) born September 13, 2001, a true and correct copy of which is attached. 1. Mother is an adult individual residing at 910 J Hanover Street, New Oxford, PA 17241. 2. Roger Alleman, (Father) is an adult individual residing at 308 Adelia Street, Middletown, PA 17057. 3. Under the existing Order, Father has primary physical custody of the child. Mother has partial physical custody of the child. Mother is to have physical custody of the child on alternate weekends from Friday at 3:45 p.m. until Sunday at 6:00 p.m. 4. This Order should be modified because: a. The child has expressed the desire to see Mother on holidays and birthdays, but Father does not allow for the child to be with Mother on those days if they fall outside of the days required by the court order. b. The current order does not allow Mother any extra time with the child during the summer months when child is on vacation from school. c. Father makes it difficult for Mother to see the child during holidays, birthdays and the summer months. d. The current order does not require the parties to work together to come up with alternative arrangements for when periods of custody need to be changed due to emergencies or conflicts. e. Father is speaking negatively about Mother to the child, and blaming her for any time that Mother is not able to see the child. f. The child, who is 13, expresses desire to spend more time with Mother. g. Mother has attempted to work out a holiday and summer schedule with Father, but Father will not agree, or will initially agree and change his mind on the matter. 5. Concurrence was sought from opposing attorney on November 20, 2014. To date, opposing counsel has not indicated his concurrence. 6. The Honorable Judge Masland has previously ruled in this matter. WHEREFORE, Petitioner asks that the Court modify the existing Order for Custody and grant Mother specific times defined in a summer and holiday schedule because it will be in the best interest of the child. Date: ri /o2-57/ Nicole Ridley Certified Leg. Intern MEGA& RIESMEYER Supervising Attorney COMMUNITY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are subject to the e penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: CERTIFICATE OF SERVICE I, Nicole Ridley, Certified Legal Intern, the Community Law Clinic, hereby certify that I am serving a true and correct copy of a Petition to Modify Custody Order on the following person by first class U.S. Mail, postage prepaid, this5, day of \\\perk( , 2014: Charles E Petrie, Esquire 3528.Brisban Street Harrisburg, PA 17111 ico e Ridley Certified Lega tern COMMUNITY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 TAWNYA L. JUMPER, Plaintiff v. ROGER M. ALLEMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 03-3677 -t)aw — , . co ca i.`' : CIVIL ACTION - LAW r- N.) _rn ? : IN CUSTODY -<)::- cn CO _ y (--)M C) -r- M -_ •--; CRIMINAL RECORD/ABUSE HISTORY VERIFICATION , hereby swear or affirm, subject to penalties of law including 18 Pa.C.S. §4904 relating to unsworn falsification to authorities, that: 1. Unless indicated by my checking the box next to the crime below, neither I nor any other member of my household have been convicted or pled guilty, or pled no contest, or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act, 42 Pa.C.S. §6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check all that apply Crime Self Other Date of household conviction, member guilty plea, no contest plea or pending charges 0 18 Pa.C.S. Ch. 25 0 ❑ (Relating to criminal Homicide) ❑ 18 Pa. C.S. §2702 (relating to aggravated assault) ❑ ❑ ❑ 18 Pa.C.S. §2706 0 0 (relating to terroristic Sentence threats) ❑ 18 Pa. C.S. §2709.1 ❑ ❑ (related to stalking) ❑ 18 Pa.C.S. §2901 ❑ ❑ (related to kidnapping) ❑ 18 Pa.C.S. §2902 ❑ ❑ (relating to unlawful restraint) ❑ 18 Pa.C.S. §2903 ❑ ❑ (relating to false imprisonment) ❑ 18 Pa.C.s. §2910 (relating to luring a child into a motor vehicle or structure) ❑ ❑ ❑ 18 Pa.C.S. §3121 ❑ ❑ (relating to rape) ❑ 18 Pa.C.S. §1322.1 (relating to statutory sexual assault) ❑ ❑ ❑ 18 Pa.C.S. §3123 ❑ ❑ (relating to involuntary deviate sexual intercourse) ❑ 18 Pa.C.S. §3124.1 ❑ ❑ (relating to sexual assault) ❑ 18 Pa.C.S. §3125 ❑ ❑ (relating to aggravated indecent assault) ❑ 18 Pa.C.S. §3126 (relating to indecent assault) ❑ ❑ ❑ 18 Pa.C.S. §3127 ❑ ❑ *elating to indecent exposure) ❑ 18 Pa. C.S. §3129 ❑ ❑ (relating to sexual intercourse with animal) ❑ 18 Pa.C.S. §3130 (relating to conduct relating to sex offenders) ❑ 18 Pa. C.S. §3301 (relating to arson and related offenses) . ❑ ❑ ❑ ❑ ❑ 18 Pa.C.S. §4302 ❑ ❑ (relating to incest) ❑ 18 Pa.C.S. §4303 ❑ ❑ (relating to concealing death of child) ❑ 18 Pa.C.S. §4304 (relating to endangering welfare of children) ❑ ❑ ❑ 18 Pa.C.S. §4305 ❑ ❑ (relating to dealing in infant children) ❑ 18 Pa.C.S. §5902(b) ❑ ❑ (relating to prostitution and related offenses) ❑ 18 Pa.C.S. §5903(c) or 0 ❑ (d) (relating to obscene and other sexual materials and performances) O 18 Pa.C.S. §6301 (relating to corruption of minors) ❑ ❑ ❑ 18 Pa.C.S. §6312 0 0 (relating to sexual abuse of children) O 18 Pa.C.S. §6318 0 0 (relating to unlawful contact with minor) ❑ 18 Pa.C.S. §6320 0 0 (relating to sexual exploitation of children) O 23 Pa.C.S. §6114 ❑ ❑ (relating to contempt for violation of protection order or agreement) ❑ Driving under the 0 0 influence of drugs or alcohol Manufacture, sale, delivery, holding, offering for sale or possession of any controlled substance or 0 iqqg (-14- f_ ek"-P-fcij other drug or device 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check Self Other Date all that household apply member ❑ A finding of abuse by a Children & Youth ❑ D Agency or similar agency in Pennsylvania or similar statute in another jurisdiction ❑ Abusive conduct as defined under the ❑ ❑ Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction ❑ Other: ❑ ❑ 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child. 5. If you are aware that the other party or members of the other party's household has or have a criminal/abuse history, please explain: 4-S" Cdejice),62--e I verify that the information above is true and correct to the best of my knowledge, information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ,f/r>2/>/ ate TAWNYA L. JUMPER IN THE COURT OF COMMON PLEAS OF PLAINTIFF V. ROGER M. ALLEMAN DEFENDANT . CUMBERLAND COUNTY, PENNSYLVANIA 2003-3677 CIVIL ACTION LAW IN CUSTODY -0 rn u,r r= v c, tv CD C") r r. Jrn CD CD ORDER OF COURT `' Z_ CD c.D AND NOW. Monday, December 01, 2014 , upon consideration of the attached Cl lain't, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq.,the cotor,—: at 4th Floor , Cumberland County Courthouse, Carlisle on Friday, January 02, 2015 10:30 AM 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. 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. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in-person contact with the court (including, but not limited to, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P. No. 1915.17 regarding relocation. FOR THE COURT. By: /s/ Hubert X. Gilroy, Esq. ve 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. t o �pmmc" l a' ' o !?e7� o ��lf�y, est a t/fr Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166