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Home My WebLink About07-4835a Jonathan Baker, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vi. CIVIL ACTION -LAW Tanesha Corum, No. 6 7 ~ y~3~ CIVIL Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Jonathan Baker, residing at 1 Park Street, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2. The defendant is Tanesha Corum, residing at 129 South Pitt Street, Apt. 2, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the following child: Name Present Residence DOB Age Keyonah M. Corum-Baker 129 South Pitt Street, Apt. 2 12-06-04 2 years Carlisle, Pa 17013 The child was born out of wedlock The child is presently in the custody of Tanesha Corum, residing at 129 South Pitt Street, Apt. 2, Carlisle, Cumberland County, Pennsylvania 17013. During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Jonathan Baker & 1 Park Street Birth to 12/27/06 Tanesha Corum Mt. Holly Springs Pa Tanesha Corum & Maternal Grandparents Hamilton Street Carlisle, Pa 12/27/06 to June 2007 r Tanesha Corum & 129 South Pitt Street June 2007 to present Keith Krauss Carlisle, Pa 17013 The mother of the child is Tanesha Corum, residing at 129 South Pitt Street, Apt. 2, 4 Carlisle, Cumberland County, Pennsylvania 17013. She is unmarried. The father of the child is 1 Park Street, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. He is unmarried. The relationship of plaintiff to the child is that of Father. 5. The plaintiff currently resides with the following persons. Name Melissa Keeseman Alexis Keeseman Justin Adams Relationship Girlfriend Girlfriend's daughter Brother The relationship of defendant to the child is that of Mother. 6. The defendant currently resides with the following persons. Name Keith Krauss Relationship Boyfriend Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 7. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child will be served by granting the relief request because: 8. A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the child. A Court Ordered determination of custody is required to avoid continuing conflict between the parties regarding responsibility for custody and support. WHEREFORE, Plaintiff requests this Court grant shared legal and physical custody to Plaintiff and Defendant. Respectfully submitted, ROMINGER & ASSOCIATES Date: ' I~~' Michael O. Palermo, Jr., Esq e 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. #93334 Attorney for Plaintiff Jonathan Baker, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Tanesha Corum, No. CIVIL Defendant IN CUSTODY VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. vJonathan Baker, Plaintiff -ly-e7 Jonathan Baker, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Tanesha Corum, No. CIVIL Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Michael O. Palermo, Jr., Esquire, attorney for Plaintiff do hereby certify that I this day mailed a copy of the within Complaint for Custody upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Tanesha Corum 129 South Pitt Street, Apt. 2 Carlisle, Pa 17013 Date off. is'~`~?- r.--. Michael O. Palermo, Jr., Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court LD. # 93334 Attorney for Plaintiff ~ ~ C'J ^~ ~, ~~ _ -rr ~ ,., ~~ .-+ cry ' ~ F n ~- ~ ~' r c.:~ ~' ' -:, fit ~ ~ .:..~ ~ r~ ^ ~ C 4r: °G ~~ ,~ JONATHAN BAKER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. TANESHA CORUM DF,FENDANT • 07-4835 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, August 17, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator, at~_4th Floor, Cumberland County Courthouse,_Carlisle on _____ Thursday, September 13, 2007 ~_ at _„2:00 PM for aPre-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/ ohn .Man an r. Es . 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 ~ ~~ ~ -~- ~~ ~ . ~, y ice' ~ ~~~-~ ~ ~: ;~.. '~ ,i `.~ ~~ °E:' Q~'~;ilt~~~:~Z -,. ca. ~~~~ ~~ ~ ~ <Q~ ~~ Jonathan Baker, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Tanesha Corum, No. 07-4835 CIVIL Defendant IN CUSTODY STIPULATION AGREEMENT AS TO CUSTODY The plaintiff, Jonathan Baker hereinafter referenced as "Father," and Defendant, Tanesha Corum, hereinafter referenced as "Mother," hereby agree to the entry of the following terms in a Court Order defining custody and partial custody rights and responsibilities in relation to the parties' minor child Keyonah Marie Corum-Baker, hereinafter referenced as "Child": The parties hereto agree that the best interest and continuing welfare of the Children would be best served with the custody arrangement as follows: (a). Mother and Father will share legal custody of Children as defined in 23 Pa. C.S.A. §5302. All decisions affecting the Children's growth and development, including but not limited to medical treatment, education, and religious training, are major decisions which Mother and Father shall make jointly after discussion and consultation with each other. (b). As provided 23 Pa. C.S.A. §5309(a), each parent shall have full and complete access to the Children's mental, dental, religious and school records. This includes the names, addresses and telephone numbers of all medical and other providers. (c). Mother shall have primary physical custody with partial custody in Father as apportioned below. (d). Father shall have periods of custody Monday and Friday during the day with Mother picking the child up at 4:00 p.m. on Friday. Father shall commence these periods by picking the child up at Mother's residence. (e). Father shall have every other weekend with Mother dropping off the child on Friday morning before she starts work and Mother will pick up on Monday at 4:00 p.m. unless it (f) The parties shall share the Christmas holiday with Mother having the odd numbered years starting in 2007, with Father receiving the child on December 23, 2007 and dropping the child off with Mother on December 24, 2007, at 3:00 p.m. and Mother is to return the child to Father on his next scheduled custody day. Father will receive the child on even numbered years with Mother dropping the child off at 3:00 p.m. on December 24~', and Father will return the child to Mother on December 2$`". (g) Father shall have the child on Thanksgiving Day and Easter from 9:00 a.m. unti13:00 p.m. with Father dropping the child off at 3:00 p.m. with Mother. (h) Visitation may be at such other times as the parties mutually agree. 2. Each parry shall have reasonable telephone and a-mail access to the Children while the Children are in the custody control of the parent. 3. The parties shall keep each other advised immediately relative to any emergencies concerning the Children and shall further take any necessary steps to ensure that the health, welfare and well being of the Children are protected. The parties shall do nothing that may estrange the Children from the other party or hinder the natural development of the Children's love or affection for the other party. 4. Each party shall not make any disparaging remarks or allow others to make any disparaging remarks concerning the Children's parents in front of the Children. 5. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. 6. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 7. Both parties agree that the terms of this agreement have been fully explained to them by their respective counsel or that both parties have had the opportunity to have legal counsel review and respective counsel or that both parties have had the opportunity to have legal counsel review and fully explain the terms of this agreement. Mother is represented by Harry Baturin, Esquire and Father being represented by Michael O. Palermo, Jr., Esquire. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. 9. Consented to: /o ~~ Date !a- l ~ a~" Date ~,~ I i,, i a ~° i Date jo I1~(~g~7 Date ,~~~%~ onathan B Michael O. Palermo, Esquire Tanesha Corum 1 s~,'~y,'y ~1'~ ~',^~- Harry Batunn, Esquire O -~ "' r~' ~ ~ ~.. _..a -tx9~ ~ ..+ ~~ 4 ". i,~ 'i1 = ("T't 5 OCT 17 20D~ry,`/ Jonathan Baker, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Tanesha Corum, No. 07-4835 CIVIL Defendant IN CUSTODY ORDER OF COURT AND NOW, this / ~ `day of ~~ la..~r , 2007, based on the Stipulation of the parties, the Court hereby Orders as follows: 1. The parties hereto agree that the best interest and continuing welfare of the Children would be best served with the custody arrangement as follows: (a) Mother and Father will share legal custody of Children as defined in 23 Pa. C.S.A. §5302. All decisions affecting the Children's growth and development, including but not limited to medical treatment, education, and religious training, aze major decisions which Mother and Father shall make jointly after discussion and consultation with each other. (b) As provided 23 Pa. C.S.A. §5309(x), each pazent shall have full and complete access to the Children's mental, dental, religious and school records. This includes the names, addresses and telephone numbers of all medical and other providers. (c) Mother shall have primary physical custody with partial custody in Father as apportioned below. (d) Father shall have periods of custody Monday and Friday during the day with Mother picking the child up at 4:00 p.m. on Friday. Father shall commence these periods by picking the child up at Mother's residence. (e) Father shall have every other weekend with Mother dropping off the child on Friday morning before she starts work and Mother will pick up on Monday at 4:00 p.m. unless it is a Holiday weekend then Father will keep the child on Monday and drop her off at daycaze on Tuesday morning. i i ~~t~~.r~ f` '"~ th ~..L2 ~~ s ..~~= d~ ~~ _~~ ~~ ~ ~ ~~a tooz 3~i :~~=-fl~ll3 is a Holiday weekend then Father will keep the child on Monday and drop her off at daycare on Tuesday morning. (f). The parties shall share the Christmas holiday with Mother having the odd numbered years starting in 2007, with Father receiving the child on December 23, 2007 and dropping the child off with Mother on December 24, 2007, at 3:00 p.m. and Mother is to return the child to Father on his next scheduled custody day. Father will receive the child on even numbered years with Mother dropping the child off at 3:00 p.m. on December 24`", and Father will return the child to Mother on December 2~~'_ -rLC (g). Father shall have the child on Thanksgiving Day and Easter from 9:00 a.m. until 3 :00 p.m. with Father dropping the child off at 3:00 with Mother. (h). Visitation may be at such other times as the parties mutually agree. 2. Each party shall have reasonable telephone and a-mail access to the Children while the Children are in the custody control of the parent. 3. The parties shall keep each other advised immediately relative to any emergencies concerning the Children and shall further take any necessary steps to ensure that the health, welfare and well being of the Children are protected. The parties shall do nothing that may estrange the Children from the other party or hinder the natural development of the Children's love or affection for the other party. 4. Each party shall not make any disparaging remarks or allow others to make any disparaging remarks concerning the Children's parents in front of the Children. 5. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. 6. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 7. Both parties agree that the terms of this agreement have been fully explained to them by their fully explain the terms of this agreement. Mother is represented by Harry Baturin, Esquire of and Father being represented by Michael O. Palermo, Jr., Esquire. 8. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. Jonathan Baker, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Tanesha Corum, No. 07-4835 CIVIL. Defendant IN CUSTODY PETITION TO MODIFY CUSTODY 1. Petitioner is Jonathan Baker, who resides at 1 Pazk Street, Mt. Holly Springs, Pennsylvania 17065. 2. Respondent is Tanesha Corum, who resides at 129 South Pitt Street, Cazlisle, Pennsylvania 17013. 3. On October 19, 2007, the Honorable Kevin A. Hess, signed a stipulated Custody Order attached hereto as Exhibit "A". 4. Since the entry of said Order, there has been a significant change in circumstances in that: a) The minor child, Keyonah Marie Corum-Baker has spent almost every weekday from 7 a.m. until approximately 6 p.m with Petitioner or his grandmother. b) Respondent is not willing to allow Petitioner to have more overnight visitations with the minor child and is now requesting the child be placed in daycaze to eliminate father from the child's life. c) Your Petitioner does not wish to have his custodial periods reduced by daycaze. 5. The best interest of the child will be served by the Court modifying said Order and Petitioner requests this matter be referred to John Mangan, Esquire for Conciliation. 6. In accordance with Cumberland County Local Rule 208.3(a)(9), it is assumed due to the relief sought herein that the adverse party is opposed to this Petition. WHEREFORE, Petitioner prays this Court to grant the modification of the Custody Order as follows: Shared physical custody in the parties with agreed upon visitation by the parties. Date: Respectfully submitted, ROMINGER & ASSOCIATES • 6 ~,~- M} 1 O. Palermo, Jr., Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Petitioner VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition aze true and correct. I understand that false statements herein aze made subject to the penalties of 18 Pa. C. S. § 4904, relating to unsworn falsification to authorities. Date: ~ 9 Jonathan Baker Jonathan Baker, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Tanesha Corum, No. 07-4835 CIVIL Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Michael O. Palermo, Jr., Esquire, attorney for Jonathan Baker, do hereby certify that I this day served a copy of the Petition to Modify Custody upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Dated: ~ Respectfully submitted, ROMINGER & ASSOCIATES w • Mic el O. Palermo, Jr., Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff f,~ ".,~ 1 ~ ~ti ~1 ~~~ ~ oc~ ~ fi 200 ~~ ~~~ Jonathan Baker, ITi THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVAI~IIA v. CIVIL ACTION -LAW Tanesha Corum, No. 07-4835 CIVIL Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~~day of , 2007, based on the Stipulation of the parties, the Court hereby Orders as follows: The parties hereto agree that the best interest and continuing welfare of the Children would be best served with the custody arrangement as follows: (a) Mother and Father will share legal custody of Children as defined in 23 Pa. C.S.A. §5302. Ail decisions affecting the Children's growth and development, including but not limited to medical treatment, education, and religious training, are major decisions which Mother and Father shall make jointly after discussion and consultation with each other. (b) As provided 23 Pa. C.S.A. §5309(a), each parent shall have full and complete access to the Children's mental, dental, religious and school records. This includes the names, addresses and telephone numbers of alI medical and other providers. (c) Mother shall have primary physical custody with partial custody in Father as apportioned below. (d) Father shall have periods of custody Monday and Friday during the day with Mother picking the child up at 4:00 p.m. on Friday. Father shall commence these periods by picking the child up at Mother's residence. (e) Father shall have every other weekend with Mother dropping off the child on Friday morning before she starts work and Mother will pick up on Monday at 4:00 p.m. unless it is a Holiday weekend then Father will keep the child on Monday and drop her off at daycare on Tuesday morning. ~--- ~- ._ is a Holiday weekend then Father will keep the child on Monday and drop her off at daycare on Tuesday morning. (f). The parties shall shaze the Christmas holiday with Mother having the odd numbered years starting in 2007, with Father receiving the child on December 23, 2007 and dropping the child off with Mother on December 24, 2007, at 3:00 p.m. and Mother is to return the child to Father on his next scheduled custody day. Father will receive the child on even numbered years with Mother dropping the child off at 3:00 p.m. on December 24~', and Father will return the child to Mother on December 2S`~_ ;-~L (g). Father shall have the child on Thanksgiving Day and Easter from 9:00 a.m. unti13:00 p.m. with Father dropping the child off at 3:00 with Mother. (h). Visitation may be at such other times as the parties mutually agree. Each party shall have reasonable telephone and a-mail access to the Children while the Children are in the custody control of the parent. The parties shall keep each other advised immediately relative to any emergencies concerning the Children and shall further take any necessary steps to ensure that the health, welfare and well being of the Children are protected. The parties shall do nothing that may estrange the Children from the other party or hinder the natural development of the Children's love or affection for the other party. 4. Each party shall not make any disparaging remarks or allow others to make any disparaging remarks concerning the Children's parents in front of the Children. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. 6. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 7. Both parties agree that the terms of this agreement have been fully explained to them by their fully explain the terms of this agreement. Mother is represented by Harry Baturin, Esquire of and Father being represented by Michael O. Palermo, Jr., Esquire. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. ~i~ TRUE CO~PY~ fR~pM R~ECQRD In T moray whereof, I here unto set my hens s searrl p~ said Co rt rti e, ~a.// ~~~~// T .....,<..... ay f. .. ...~ L~~X.r _ ~~ Jonathan Baker, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Tanesha Corum, No. 07-4835 CIVIL Defendant IN CUSTODY STIPULATION AGREEMENT AS TO CUSTODY The plaintiff, Jonathan Baker hereinafter referenced as ``Father," and Defendant, Tanesha Corum, hereinafter referenced as "Mother," hereby agree to the entry of the following terms in a Court Order defining custody and partial custody rights and responsibilities in relation to the parties' minor child Keyonah Marie Corum-Baker, hereinafter referenced as "Child": The parties hereto agree that the best interest and continuing welfare of the Children would be best served with the custody arrangement as follows: (a). Mother and Father will shaze legal custody of Children as defined in 23 Pa. C.S.A. §5302. All decisions affecting the Children's growth and development, including but not limited to medical treatment, education, and religious training, are major decisions which Mother and Father shall make jointly after discussion and consultation with each other. (b). As provided 23 Pa. C.S.A. §5309(a), each parent shall have full and complete access to the Children's mental, dental, religious and school records. This includes the names, addresses and telephone numbers of aIi medical and other providers. (c). Mother shall have primary physical custody with partial custody in Father as apportioned below. (d). Father shall have periods of custody Monday and Friday during the day with Mother picking the child up at 4:00 p.m. on Friday. Father shall commence these periods by picking the child up at Mother's residence. (e). Father shall have every other weekend with Mother dropping off the child on Friday morning before she starts work and Mother will pick up on Monday at 4:00 p.m. unless it (f) The parties shall share the Christmas holiday with Mother having the odd numbered years starting in 2007, with Father receiving the child on December 23, 2007 and dropping the child off with Mother on December 24, 2007, at 3:00 p.m. and Mother is to return the child to Father on his next scheduled custody day. Father will receive the child on even numbered years with Mother dropping the child off at 3:00 p.m. on December 24~', and Father will return the child to Mother on December 28~'. (g) Father shall have the child on Thanksgiving Day and Easter from 9:00 a.m. unti13:00 p.m. with Father dropping the child off at 3:00 p.m. with Mother. (h} Visitation may be at such other times as the parties mutually agree. 2. Each parry shall have reasonable telephone and a-mail access to the Children while the Children aze in the custody control of the parent. The parties shall keep each other advised immediately relative to any emergencies concerning the Children and shall further take any necessary steps to ensure that the health, welfare and well being of the Children are protected. The parties shall do nothing that may estrange the Children from the other party or hinder the natural development of the Children's love or affection for the other party. 4. Each party shall not make any disparaging remarks or allow others to make any disparaging remarks concerning the Children's parents in front of the Children. 5. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. 6. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 7. Both parties agree that the terms of this agreement have been fully explained to them by their respective counsel or that both parties have had the opportunity to have legal counsel review and respective counsel or that both parties have had the opportunity to have legal counsel review and fully explain the terms of this agreement. Mother is represented by Harry Baturin, Esquire and Father being represented by Michael O. Palermo, Jr., Esquire. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. 9. Consented to: !o fiG Date !~-lam a~.. Date e~ ~~.~ 1i.9 ~`~ / Date ~oliol~~-7 Date Jonathan B Michael O. Palermo, Esquire Tanesha Corum Harry Baturin, Esquire 0 .~ s r e ` ~-``r te ,. Ca e` ~~ ~= -~ .~~ ~`~~ _ ~~, k_,i 7 ~ ~ rn' ~~ . crr .-fir JONATHAN BAKER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. TANESHA CORUM DF,FEN DANT • 2007-4835 CLVIL ACTLON LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, May 19, 2008 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, June 24, 2008 at 11:00 AM ~ for aPre-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. FOR THE COURT, By: /s/ ohn .Man an r. Es . 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 ~~L s ~ ~~~-, v ~~a~ ~-. 4. ~~= ~Q ~(I ~ b 1 ~~~~ ~Q~Z Aa`~~,~1v~:~~~~~~~~:1 3N.~ ~~ ~~i~~~~w~~~~ r Jonathan Baker, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW Tanesha Corum, No. 07-4835 CIVIL Defendant IN CUSTODY PETITION TO MODIFY CUSTODY 1. Petitioner is Jonathan Baker, who resides at 1 Park Street, Mt. Holly Springs, Pennsylvania 17065. 2. Respondent is Tanesha Corum, whose last known mailing address was believed to be 704 Hamilton Street, Carlisle, Pennsylvania 17013. 3. On October 19, 2007, the Honorable Kevin A. Hess, signed a stipulated Custody Order attached hereto as Exhibit "A". 4. Since the entry of said Order, there has been a significant change in circumstances in that: a) The minor child, Keyonah Marie Corum-Baker has spent almost every weekday with either Petitioner or his grandmother for the past four (4) months. b) Respondent is not willing to allow Petitioner to formalize these more frequent overnight periods of custody with the minor child. c) Your Petitioner does not wish to have his custodial periods reduced by Mother and instead would like to reduce the amount of time the child spends in daycare, leaving Father with more quality time with the child. 5. The best interest of the child will be served by the Court modifying said Order and Petitioner requests this matter be referred to John Mangan, Esquire for Conciliation. 6. In accordance with Cumberland County Local Rule 208.3(a)(9), it is assumed due to the relief sought herein that the adverse party is opposed to this Petition. WIiEREFORE, Petitioner prays this Court to grant the modification of the Custody Order as follows: Primary. physical custody with Petitioner/Father with partial physical custody in Mother/Respondent herein. Date: ~~ 3~~ ~~'~' 1 Respectfully submitted, ROMINGER & ASSOCIATES Michael O. Palermo, Jr., Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Petitioner Jonathan Baker, Plaintiff v. Tanesha Corum, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 07-4835 CIVIL. IN CUSTODY CERTIFICATE OF SERVICE I, Michael O. Palermo, Jr., Esquire, attorney for Jonathan Baker, do hereby certify that I this day served a copy of the Petition to Modify Custody upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Tanesha Corum Harry Baturin, Esquire BATURIN & BATURIN 2604 N. Second St. Harrisburg, PA 17110 Dated: ~• 3y~ ~~' l Respectfiilly submitted, ROMINGER & ASSOCIATES ~~~~^~~ Michael O. Palermo, Jr., Esquire 155 South Hanover Street Carlisle, PA 17013 (717)241-6070 Supreme Court ID # 93334 Attorney for Plaintiff Jonathan Baker, Plaintiff v. Tanesha Corum, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. CIVIL IN CUSTODY VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. +~ on~~aker, Petitioner/Father . v; ~~ .lonathan Baker, Iti THE COURT OF COM~IOti PLEAS OF Plaintiff CU:~TBERLAND COL~TY, PEwSYLVANIA v. CIVIL ACTION - LAVE' Tanesha Corum, No. 07-4835 CIVIL Defendant IN CUSTODY' ORDER OF COURT AND NOW, this ~~day of ~~ , 2007, based on the Stipulation of the parties, the Court hereby Orders as follows: The parties hereto agree that the best interest and continuing welfaze of the Children would be best served with the custody arrangement as follows: (a) Mother and Father will shaze legal custody of Children as defined in 23 Pa. C.S.A. §5302. All decisions affecting the Children's growth and development, including but not limited to medical treatment, education, and religious training, aze major decisions which Mother and Father shall make jointly after discussion and consultation with each other. (b} As provided 23 Pa. C.S.A. §5309(x), each pazent shall have full and complete access to the Children's mental, dental, religious and school records. This includes the names, addresses and telephone numbers of all medical and other providers. (c) Mother shall have primary physical custady with partial custody in Father as apportioned below. (d) Father shall have periods of custody Monday and Friday during the day with Mother picking the child up at 4:00 p.m. on Friday. Father shall commence these periods by picking the child up at Mother's residence. (e) Father shall have every other weekend with Mother dropping off the child on Friday morning before she starts work and Mother will pick up on Monday at 4:00 p.m. unless it is a Holiday weekend then Father wilt keep the child on Monday and drop her off at daycare on Tuesday morning. t- is a Holiday weekend then father will keep the child on Monday and drop her off at daycare on Tuesday morning. (f~. The parties shall share the Christmas holiday with Mother having the odd numbered years starting in 2007, with Father receiving the child on December 23, 2007 and dropping the child off with Mother on December 24, 2007, at 3:00 p.m. and 1~lother is to return the child to Father on his next scheduled custody day. Father will receive the child on even numbered years with Mother dropping the child off at 3:00 p.m. on December 24~', and Father will return the child to i~fother on December ~`~.... --~L (g). Father shall have the child on Thanksgiving Day and Easter from 9:00 a.m. until 3:00 p.m. with Father dropping the child off at 3:00 with Mother. (h). Visitation may 6e at such other times as the parties mutually agree. Each party shall have reasonable telephone and a-mail access to the Children while the Children are in the custody control of the parent. The parties shall keep each other advised immediately relative to any emergencies concerning the Children and shall further take any necessary steps to ensure that the health, welfare and well being of the Children are protected. The parties shall do nothing that may estrange the Children from the other party or hinder the natural development of the Children's love or affection for the other parry. 4. Each party shall not make any disparaging remazks or allow others to make any disparaging remarks concerning the Children's parents in front of the Children. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. Both parties agree that the terms of this agreement have been fully explained to them by their fulL~ explain the teens of this agreement. Mother is represented by Harry Baturin. Esquire of and Father being represented by Michael O. Palermo, Jr., Esquire. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. / a J. TRUE CC~PY~ fROM 1tRCfJRD In T rtaony whereof. 1 hEfe unto set my hens a seat said Co rt rti ......~.~. , r~. Jonathan Baker, I~ THE COURT OF CO~Iti(O~ PLE.-~S OF Plaintiff CL;tiIBERLA~D COUNTY". PE~~SYLVANL-~ C[VIL ACTION -LAW Tanesha Corum, v'o. 07-4833 CIVIL Defendant Iti CUSTODY 5TtPULATION AGREEiVIENT AS TO CUSTODY The piaintii`£ Jonathan Baker hereinafter referenced as "Father," and Defendant, Tanesha Corum, hereinafter referenced as '`Mother," hereby agree to the entry of the following terms in a Court Order defining custody and partial custody rights and responsibilities in relation to the parties' minor child Keyonah Marie Corum-Baker, hereinafter referenced as "Child": The parties hereto agree that the best interest and continuing welfare of the Children would be best served with the custody arrangement as follows: (a). Mother and Father will share legal custody of Children as defined in 23 Pa. C.S.A. §302. All decisions affecting the Children's growth and development, including but not limited to medical treatment, education, and religious training, are major decisions which Mother and Father shall make jointly after discussion and consultation with each other. (b). As provided 23 Pa. C.S.A. §~309(a), each parent shall have full and complete access to the Children's mental, dental, religious and school records. This includes the names, addresses and telephone numbers of all medical and other providers. (c}. Mother shall have primary physical custody with partial custody in Father as apportioned below. (d). Father shat[ have periods of custody Monday and Friday during the day with Mother picking the child up at 4:00 p.m. on Friday. Father shall commence these periods by picking the child up at Mother's residence. (e). Father shall have every other weekend with Mother dropping off the child on Friday morning before she starts work and Mother will pick up on Monday at 4:00 p.m. unless it tl The parties shall share the Christmas holiday with Mother having the odd numbered years starting in 2007, with Father receiving the child on December 23, 2007 and dropping the child off with Mother on December 24, 2007, at 3:00 p.m. and 1~tother is to return the child to Father on his next scheduled custody day. Father will receive the child on even numbered years with Mother dropping the child off at 3:00 p.m. on December 24~', and Father will return the child to Mother on December 28`x. (~) Father shall have the child on Thanksgiving Day and Easter from 9:00 a.m. until 3:00 p.m. with Father dropping the child off at 3:00 p.m. with ivlother. (h) Visitation may be at such other times as the parties mutually agree. Each party shall have reasonable telephone and a-mail access to the Children while the Children are in the custody control of the parent. The parties shall keep each other advised immediately relative to any emergencies concerning the Children and shall further take any necessary steps to ensure that the health, welfare and well being of the Children are protected. The parties shall do nothing that may estrange the Children from the other party or hinder the natural development of the Children's love or affection for the other party. 4. Each party shall not make any disparaging remarks or allow others to make any disparaging remarks concerning the Children's parents in front of the Children. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. 6. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 7. Both parties agree that the terms of this agreement have been fizlly explained to them by their respective counsel or that both parties have had the opportunity to have legal counsel review and P respective counsel or that both parties have had the opportunity- to have legal counsel revie~~ and fully explain the terms of this agreement. Mother is represented b~ Harry Baturin, Esquire and Father being represented by Michael O. Palermo, Jr., Esquire. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. 9. Consented to: /o fG Date !a-~s= a Date Date j~i;nl~l~-7 Date Jonathan B -----r Michael O. Palermo, Esquire -, ;, I'anesha Corum ~~,~~,,,,~, ,~~r -rte Starry Baturin, Esquire ~'' «' ~' E ~ ~~ 1 r~ ~~~ e ~~9 ~~ ~ 1 ~.. y:~ j ~. w .:~ J Fey.}Y(~i! ~~ ~ ~ ~`7 ~~ ~ ~ ~ JONATHAN BAKER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA. V. TANESHA CORUM DF?FF~:NDANT • 2007-4835 CIVIL ACTION LAW IN CUSTODY ORllEIt OF COURT ANC) NOW, ___Thursday, Janu~07, 2010_ -, upon consideration of the attached Complaint, it is herehy directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. ,the conciliator, at 4th Floor, Cumberland Coun Courthouse, Carlisle on Thursday, February 11, 2010 at 9:00 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues rn dispute; or if this cannot he 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. FOR. THE COURT, By: /s/ ohn .Man an r. Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by laws 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 A"I'TORNEY AT ONCE. 1F 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 C ounty Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3 l66 non-~~ ~~~~ t3~ 7Hc ~',~t~Tt~'C?~?~TARY 2010 3AI~ -8 P~ 3= 15 ~1.1P~.~,~_: ~~:-Jr~ ~r , ~~ ~ / . j f S~ ` .' ' ,% ,j' AFB 1 6 2g1n JONATHAN BAKER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. No. 07-4835 CIVIL ACTION LAW TANESHA CORUM, IN CUSTODY n 4 . ; Defendant ~~ - d ~`' • n ~ Prior Judge: Kevin A. Hess, P.J. , . , ~ - cJ ~ n y ~ -a ~ - ~ _ ,: s ORDER OF COURT '-~ - -n ~~ 1S ~ -r' ~~ y. ~_ N l ' ` ~:.~ Cr; AND NOW this l day of February 2010, upon consideration of the attac ~d C~ sto l d Conciliation Report, it is Ordered and Directed as follows: a ~ 1. The prior Order dated October 19, 2007 is hereby VACATED and replaced with this Order. 2. Legal Custody: The Father, Jonathan Baker, and the Mother, Tanesha Corum, shall have shared legal custody of Keyonah Marie Corum-Baker, born 12/06/2004. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's general well- being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: Father shall have primary physical custody of the Child subject to Mother's liberal physical custody as the parties may agree. 4. The non-custodial parent shall have liberal telephone/emaiUtext contact with the Child on a reasonable basis. 5. Holidays: The parents shall arrange the holiday schedule as mutually agreed upon. In the absence of agreement, the parties may adhere to the attached holiday schedule for convenience and equality's sake. 6. In the event the custodial parent should take the Child out of state, the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. O~ 8. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 9. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 10. In the event that either party desires to relocate a significant distance from where they currently reside, that party shall be required to file an appropriate petition with this Court for determination absent express consent (in writing) to said request for relocation. 11. The instant Order shall not preclude either party from filing a Petition for Modification as necessary or appropriate. 12. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. D' tribution: 1 Rominger, Esquire Baturin, Esquire, 2604 N. Second Street, Harrisburg, PA 17110 sha Corum, 704 Hamilton Street, Carlisle, PA 17013 ohn J. Mangan, Esquire ~ies .n~il~c~.~ a/i8~iv ~r~ By the Court, TIMES EVEN ODD HOLIDAYS AND YEARS YEARS SPECIAL DAYS Easter Da 1St Half From 9 am until 3 m Father Mother Easter Day 2" Half From 3 pm until 9 m Mother Father Memorial Day From 9 am until 9 pm Mother Father Inde endence Day From 9 am until 9 m Father Mother Labor Day From 9 am until 9 m Mother Father Halloween From one hour before trick or Father Mother treating to one hour after trick or treatin Thanksgiving 1St From 8 am Thanksgiving Day to 2 Father Mother Half m on Thanksgivin Day Thanksgiving 2n From 2 pm on Thanksgiving Day to Mother Father half noon the day after Thanksgivin Day Christmas 1St Half From noon on 12/24 to noon on Father Mother 12/25 Christmas 2" Half From noon on 12/25 to noon on Mother Father 12/26 New Year's From 6 pm 12/31 until noon January Mother Father 1St (with the 12/31 year to control the even/odd determination) Mother's Day From 9 am until 9 m Mother Mother Father's Day From 9 am until 9 m Father Father JONATHAN BAKER, Plaintiff v. TANESHA CORUM, Defendant Prior Judge: Kevin A. Hess, P.J. IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA No. 07-4835 CIVIL ACTION LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH 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: Name Date of Birth Currently in the Custody of Keyonah Marie Corum-Baker 12/06/2004 Father and Mother 2. An Order of Court was issued October 19, 2007, a conference was scheduled June 24, 2008 but upon request of counsel, the conference was continued due to an agreement and a Conciliation Conference was held with regard to this matter on February 11, 2010 with the following individuals in attendance: The Mother, Tanesha Corum, nor her counsel, Harry Baturin, Esq. did not appear The Father, Jonathan Baker, with his counsel, Karl Rominger, Esq. 3. The undersigned recommends the entry of an Order in the form as attached. ~ _S ~~ Date Jo gan, Esquire Cu od -Conciliator COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TANESHA L. CORUM, ) Plaintiff ) C= M' —U:1 w ; MCO :C- v. ) No. 07-4835 Z:r— �v cam ' JONATHAN D. BAKER, ) . Defendant xc� mac , Petition for Modification 1. Petitioner is Plaintiff, TANESHA L. CORUM, who currently resides at 317 Market Street, Mechanicsburg, Cumberland County, PA 17055. 2. Respondent is Defendant, JONATHAN D. BAKER, who currently resides at 37 Pine Street, Carlisle, Cumberland County, PA 17013. 3. Petitioner and Respondent are the natural parents of the following child: Name Age KEYONAH M. CORUM-BAKER 8 years 4. A custody order was entered on 02/18/2010, in the Cumberland County Court of Common Pleas. A copy of the custody order is attached. Petitioner seeks to modify the custody order because: 1. While in primary care of Father there has been a significant decline in child, Keyonah Corum's (8 years old) Health. Health Related Incidents- severe eczema break outs (back of neck, Popliteal Fossa, antecubital space), multiple staph infections (legs, arms, groin area, and waist), weight(4ft 6in, 1001bs), type 1 diabetes (Hershey Medical Facility currently diagnosed child "at risk"), dental hygiene (several fillings and teeth pulled due to cavities) 493-oo /l-3CC Petition for Modification Page 3 of 6 Child is biracial (African American/Caucasian)with many attributes which require different up-keeping however the child Keyonah has no perception of this and the child Keyonah has had some difficulty figuring out how to deal with comments made by prejudice individuals. The child exhibits struggles with self-esteem and comfort with herself. The Mother feels child should be subject to both race and ethnicity of her and the Father. Mother wishes to teach the child about her heritage with the focus primarily on the child to teach the child to accept herself so that she can truly find her identity. 2. Father is withholding physical custody from the Mother due to current custody agreement however Mother supports the encouragement of shared parenting and cooperative in order that the child maintain an equal and loving relationship with both parents, where the child is guaranteed frequent, consistent, and continuous contact with both parents, and the inalienable rights of each parent are preserved, as granted to each, and outlined by the 14th Amendment of the US Constitution 3. On numerous occasions the minor child, Keyonah Corum has spent equal days and nights with both Father and Mother; due to Mother taking the necessary steps to reclaim responsibilities for the Child and resume "normal parenting" 4. Overnights child could spend with Mother are being spent with Fathers Grandmother 5. Validity of Current Custody Order (dated 2/18/2010) Absence at previous Conciliation Conference held 2/11/10 was because: Plaintiff- Tanesha Corum and her counsel Harry Baturin. Esq were not served (by mail or in person) by Defendant Jonathan Baker and/or his counsel Karl Rominger. However a Petition to Modify Custody was not filed timely by mother due to unfamiliarity of Custody proceedings. There is no documented proof of signed "Certificate of Mailing" nor receipts from the postal clerk provided by the Father or his counsel Petitioner believes the custody order should be changed as follows: Legal Custody: Mother, Tanesha Corum and Father, Jonathan Baker equal shared legal custody of Keyonah Marie Physical Custody: Mother, Tanesha Corum and Father, Jonathan Baker equal shared Physical custody of Keyonah Marie Petition for Modification Page 4 of 6 Joint Custody Arrangements: Mother, Tanesha Corum and Father, Jonathan Baker will work out a schedule according to their work requirements and housing arrangements and the childs' needs by splitting weeks between each patents house/apartment. These weeks will alternate with the child being with the mother one week and with the father next. (Mon-Sun, Wed-Wed, etc...) Child Tax Credit: Mother, Tanesha Corum will claim the exemption for the child on even years and Father, Jonathan Baker will claim the exemption for the child on odd years. Holidays: Mother, Tanesha Corum will have the child day of holiday(Memorial Day, Labor Day, Thanksgiving,New Year's) on even years and Mother's Day every year and Father, Jonathan Baker will have the child.day of holiday (Easter, Independence Day, Halloween, Christmas) on odd years and Father's Day every year. WHEREFORE, Petitioner respectfully requests that this Court modify the Order as requested. l� C Date: t_N�1IA L. CORUM, Plaintiff Verification I, TANESHA L. CORUM, Plaintiff, verify that the facts stated in the foregoing Petition are true and correct to the best of my knowledge, information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. '4904 relating to unsworn falsification to authorities. Date: �"HA L. CORUM Plaintiff Petition for Modification Page 5 of 6 TANESHA L.CORUM IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2007-4835 CIVIL ACTION LAW JONATHAN D. BAKER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday,.September 05,2013 —, upon consideration of the attached Complaint, it is hereby directed that pat-ties and their respective counsel appear before John J.Mangan,Jr.,Esq. the conciliator, at 4th Floor,Cumberland County Courthouse,Carlisle - on Friday,October 11,2013 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 ternporat-y 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. FOR THE COURT, By: /s/ LO—An-1.Alan,-Rnz-If-, Es!9-I z AAZ/ Custody Conciliator V, 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 ) C-� FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association X-M M 32 South Bedford Street —0 CE4 t14 V11 Carlisle, Pennsylvania .17013 ::(,�CD CM C-- , -46 Telephone (717)249-3166 "C�.tD , =7,-! )> CD J. -J. ��ft3 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION TANESHA L. CORUM, ) (-) Plaintiff ) v. ) No. 07-4835 r co JONATHAN D. BAKER, -- Defendant ) < c c3 Certificate Of Service r , I, TANESHA L. CORUM, Plaintiff in the above matter,hereby certify that on i 9ci , I mailed a true and correct copy of the Petition for Modification, by certified mail, return receipt requested,restricted delivery, and another copy of the same document by first class mail, postage prepaid, to: JONATHAN D. BAKER 37 Pine Street Carlisle, PA 17013 I certify that (check ALL of the following which are true): Certified mail: [X] The green and white sender's receipt is attached. (ATTACH receipt.) [ ] The green recipient's receipt is attached; JONATHAN D. BAKER signed the certified mail receipt on (ATTACH receipt.) The certified mail was returned to me unsigned, with the notation that the certified mail was: [ ] refused ( .. laimed [ ] other notation: [ ] Neither the certified mail envelope nor the certified mail receipt was returned to me. Regular mail: The regular mail has not been returned to me. [ ] The regular mail was returned to me, with the notation: Certificate of Service Page 1 of 2 I verify that the information in the Certificate of Service is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unsworn falsification to authorities. Date: 11) Y3 )► (Signature) TANESHA L. CORUM STAPLE OR TAPE THE CERTIFIED MAIL RECEIPTS BELOW: U.S. Postal Service,. CERTIFIED MAILTM RECEIPT f1.t (Domestic Mail Only;No Insurance Cover-je 9rovided) ErFor delivery information visit our website at wv 73s parr r -, Postage $ $0.66 11/1‘.1.. Certified Fee $3.10 444 Return Receipt Fee I o F1oslmark D. O (Endorsement Required) t' Here r Cl) Restricted Delivery Fee (Endorsement Required) $0.O0 k) 8 ' ra Total Postage&Fees $6.31 , : X y 1-1 nt o =xyi r-1 C:1 street,stet)vo.; or PO Box No. City,State,ZIP+4 PS Form 3600,August 2006 See Reverse for Instructions GREEN RECEIPT WITH JONATHAN D. BAKER'S SIGNATURE Certificate of Service Page 2 of 2 6 JONATHAN BAKER, • IN THE COURT OF COMMON PLEAS OF l Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA _I v. No. 07-4835 CIVIL ACTION LAVA: F Aw _ _ rn cp TANESHA CORUM, • IN CUSTODY �r= ' _ Defendant x> ' _ Prior Judge: Kevin A. Hess, P.J. ORDER OF COURT AND NOW this 11' day of October 2013,upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Father, Jonathan Baker, and the Mother, Tanesha Corum, shall have shared legal custody of Keyonah Marie Corum-Baker,born 12/06/2004. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's general well- being including,but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including,but not limited to,medical, dental,religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information,that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody: Father and Mother shall arrange physical custody of the Child as follows: a. In week one, Mother shall have physical custody from Wednesday 6:00 pm until Thursday morning bringing the Child to the bus stop (or to paternal grandmother's residence at 7:00 am if no school) and then from Friday 6:00 pm until Monday morning bringing the Child to the bus stop (or to paternal grandmother's residence at 7:00 am if no school). b. In week two, Mother shall have physical custody from Wednesday 6:00 pm until Friday morning bringing the Child to the bus stop (or to paternal grandmother's residence if no school). c. The parents are free to alter the above schedule by written mutual agreement. Regular Physical Custody Schedule(M=mom D=dad) Monday Tuesday Wednesday Thursday Friday Saturday Sunday D D D M M D D M M M M ID D D M M M D D D 3. The non-custodial parent shall have liberal telephone/email/text contact with the Child on a reasonable basis. 4. Holidays: The parents shall arrange the holiday schedule as mutually agreed upon. In the absence of agreement, the parties shall adhere to the attached holiday schedule. 5. In the event the custodial parent should take the Child out of state,the custodial parent shall notify the non-custodial parent within twenty-four hours of departure of the intended destination and a telephone number at which they can be reached. 6. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible,both parties shall not allow third parties to disparage the other parent in the presence of the Child. 7. In the event of a medical emergency,the custodial party shall notify the other party as soon as possible after the emergency is handled. 8. During any periods of custody or visitation,the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure,to the extent possible,that other household members and/or house guests comply with this provision. 9. Vacation: Each parent shall be entitled to up to ten(10) consecutive days of vacation with the Child per year. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation time shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure,the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. The Court notes that Father has already requested vacation from 12/13/13 until 12/23/13. 10. Relocation. The parties are advised that neither party shall hereafter relocate the child or children if such relocation will significantly impair the ability of a non-relocating party to exercise his or her custodial rights unless (a) every person who has custodial rights to the child/children consents to the proposed relocation or(b) the court approves the proposed relocation. The party seeking relocation must follow the procedures required by 23 Pa.C.S. §5337. 11. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent,the terms of this Order shall control. By the Court, P. J. Dom' tribution: ,/Karl Rominger, Esquire ./i sha Corum, 317 Market St., Mechanicsburg, PA 17055 ohn J. Mangan, Es uir Q.S Mat . / /C.!/? - TIMES EVEN ODD HOLIDAYS AND YEARS YEARS SPECIAL DAYS Easter Day 1st Half From 9 am until 3 pm Father Mother Easter Day 2nd Half From 3 pm until 9 pm Mother Father Memorial Day From 9 am until 9 pm Mother Father Independence Day From 9 am until 9 pm Father Mother Labor Day From 9 am until 9 pm Mother Father Halloween From one hour before trick or Father Mother treating to one hour after trick or treating Thanksgiving 1st From 8 am Thanksgiving Day to 2 Father Mother Half pm on Thanksgiving Day Thanksgiving 2nd From 2 pm on Thanksgiving Day to Mother Father half noon the day after Thanksgiving Day Christmas 1st Half From noon on 12/24 to noon on Father Mother 12/25 Christmas 2nd Half From noon on 12/25 to noon on Mother Father 12/26 New Year's From 6 pm 12/31 until noon January Mother Father 1st (with the 12/31 year to control the even/odd determination) Mother's Day From 9 am until 9 pm Mother Mother Father's Day From 9 am until 9 pm Father Father JONATHAN BAKER, • IN THE COURT OF COMMON PLEAS OF Plaintiff • CUMBERLAND COUNTY, PENNSYLVANIA • v. • No. 07-4835 CIVIL ACTION LAW • TANESHA CORUM, IN CUSTODY • Defendant Prior Judge: Kevin A. Hess, P.J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH 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: Name Date of Birth Currently in the Custody of Keyonah Marie Corum-Baker 12/06/2004 Father and Mother 2. An Order of Court was issued October 19, 2007, a conference was scheduled June 24, 2008 but upon request of counsel, the conference was continued due to an agreement, a Conciliation Conference was held with regard to this matter on February 11, 2010, an Order issued February 18, 2010 and a conference was held October 11, 2013 with the following individuals in attendance: The Mother, Tanesha Corum, self-represented party The Father,Jonathan Baker, with his counsel, Karl Rominger, Esq. 3. The undersigned recommends, and the parties agreed to,the entry of an Order in the form as attached. / Cl// Date John J M. ,gan, Esquire Cust••y •onciliator COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TANESHA L. CORUM, Plaintiff v. JONATHAN D. BAKER, Defendant No. 07 -4835 Petition for Modification and Contempt of Custody 1. Petitioner is Plaintiff, TANESHA L. CORUM, who currently resides at 704 Hamilton Street, Carlisle, Cumberland County, PA 17013. 2. Respondent is Defendant, JONATHAN D. BAKER, who currently resides at 130 Channel Drive, Carlisle, Cumberland County, PA 17013. 3. Petitioner and Respondent are the natural parents of the following child: Name KEYONAH M. CORUM -BAKER Age 9 years 4. A custody order was entered on 07 -4835, in the Cumberland County Court of Common Pleas. A copy of the custody order is attached. 5. Petitioner seeks to modify the custody order because: Due to past events concerning Child and Youth Services it would be in the child's best interest to no longer spend mornings or evenings (no alone time whatsoever) with Bridget Shupp without the presence of father Jonathan Baker. Currently the child is dropped off with Jonathan Bakers mother Tammy Gardener in the mornings to be taken to school. However recently (March 2014) there was a death in her home caused by the over dosage of Heroin AND currently there is a continuing investigation of members in the household and safety of the child (Jillian) residing within the household. It would be in the Keyonah's best interest to no longer be subjected to this lifestyle. This is the second death within 3 months of persons involved in Jonathan Bakers life where death was caused by an overdose of drugs. %a Cory", G Current Physical Custody states Fattier and Mother shall arrange physical custody of the Child as follows: a. In week one, Mother shall have physical custody from Wednesday 6: 00 pm until Thursday morning bringing the Child to the bus stop (or to paternal grandmother's residence at 7: 00 am if no school) and then from Friday 6: 00 pm until Monday morning bringing the Child to the bus stop (or to paternal grandmother's residence at 7: 00 am if no school). b. In week two, Mother shall have physical custody from Wednesday 6: 00 pm until Friday morning bringing the Child to the bus stop (or to paternal grandmother's residence if no school). I request to Change the Physical Custody as follows: a. In week one, Mother shall have physical custody from Monday after school or 6: 00 pm until the following Monday morning bringing the Child to the school (or before and after school care) or father if no school b. In week one, Father shall have physical custody from Monday after school or 6: 00 pm until the following Monday morning bringing the Child to the school (or before and after school care) or Mothers residence Child Keyonah has electronics (Ipod) which may be used to contact (text/email) each parent at her digression; Jonathan will not allow Child to contact mother without him overseeing the conversation and with ONLY using his cellular device which inhibits the child to freely express herself. Jonathan Bakers rule of "nothing of your mothers is allowed at your fathers" was placed to keep child from seeking assistance from her mother during troubling times. Current Custody Order states the non- custodial parent shall have liberal telephone/ email/ text contact with the Child on reasonable basis. I request to Change the Current Custody Order as follows: The non- custodial parent shall have liberal telephone/ email/text contact with the Keyonah at the child's discretion including the use of her Ipod within Jonathan Bakers household. CONTEMPT OF CUSTODY Section 1: Legal Custody States all decisions regarding Health, Education, Religion to the extent one parent has possession of any such records or information, and it's required this information be shared with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Violation of Section 1: Child and Youth Services report has been filed again Jonathan Bakers fiance; Bridget Schupp for abuse against Keyonah Corum. Child and Youth Services performed a home visit at Jonathan Bakers residence. Jonathan did not report any information or records regarding this incident. Staff at Crestview Elementary have continuously contact Jonathan Baker with concerns of the child's behavior at school which stem from issues within the Baker Household and recommended additional Youth Counseling/Therapy outside of school. Additionally the child has missed an exceeding amount of Physical Education (Gym) at school due to not wearing the proper footwear which is partially the result of Jonathan Bakers rule of "nothing of your mothers is allowed at your fathers ". Recently there was a Growth Screening Program performed recently on Keyonah at school; documents provided by the school state Keyonahs measurements were: Height: 58.25 Weight: 113.8 and Body Mass Index for Age Percentile: 97+ %. None of the communications from Crestview Elementary were forwarded to the mother from the father excluding the Growth Screening Program results. During a meeting in February 2014 with Keyonahs' teacher, guidance counselor, and principal these concerns and additional concerns were expressed about Keyonahs inappropriate behavior including Keyonah stating she wanted to run away from the Baker Household and had a bag packed and ready to do so. Keyonah expressed sexual curiosity with her pets within the Baker residence including telling other children she performed sexual acts on these pets. Keyonah has also expressed the intent of suicidal tendencies stating the reason was due to "stress at Home" (Baker Residence). Section 6: Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the child Violation of Section 6: There have been numerous issues including verbal and physical abuse within Jonathan's household between Keyonah, Jonathan Baker, and fiance Bridget Schupp in which the child was told NOT to discuss with her mother. Mother has photos of marks and scratches on Keyonah. At the time of the incidents Keyonah advised her mother they were from Horse Play with Bridget Shupp. Child has voiced concerns to her Guidance Counselor at Crestview Elementary regarding her home life at the Baker residence. Which she has been scolded for and has been told she is NOT allowed to discuss events within the Baker residence, she has ruined "things" for Jonathan Baker, she has "blew it ", she WILL NOT be the cause of ruining Jonathan Bakers marriage to Bridget Shupp, and if Tanesha Corum seeks primary custody of Keyonah, Jonathan Baker will not be "wasting money on a lawyer" to fight for custody (your mother can have you). Section 3: The non - custodial parent shall have liberal telephone /email/text contact with the Child on reasonable bases. Violation of Section 3: Child Keyonah has electronics (Ipod) which may be used to contact (text/email) each parent at her digression; Jonathan will not allow Child to contact mother without him overseeing the conversation and with ONLY using his cellular device which inhibits the child to freely express herself. Jonathan Bakers rule of "nothing of your mothers is allowed at your fathers" was placed to keep child from seeking assistance from her mother during troubling times. 5. Respondent began violating the custody order on or around the following date: January 2014 to Current. 6. Petitioner has taken the following actions to enforce the custody order: Child and Youth Services report has been filed again Jonathan Bakers fiance; Bridget Schupp for abuse against Keyonah Comm by Crestview Elementary. This case is being handled by MSW Intake Caseworker, Corinne Bennett, with a tentative completion date of March 2014 and a copy of the file will be provided. WHEREFORE, Petitioner respectfully requests that this Court modify the Order as requested. . CORUM, Plaintiff Verification I, TANESHA L. CORUM, Plaintiff, verify that the facts stated in the foregoing Petition are true and correct to the best of my knowledge, information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. ' 4904 relating to unsworn falsification to authorities. Date: iLifo 14 ESHA L. CORUM, Plaintiff COPY JONATHAN BAKER, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07 -4835 CIVIL ACTION LklYst r- TANESHA CORUM, IN CUSTODY Defendant Prior Judge: Kevin A. Hess, P.J. ORDER OF COURT <c -0 r7, f•J AND NOW this `v day of October 2013, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. Legal Custody: The Father, Jonathan Baker, and the Mother, Tanesha Corum, shall have shared legal custody of Keyonah Marie Corum - Baker, born 12/06/2004. The parties shall have an equal right to make all major non - emergency decisions affecting the Child's general well- being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody: Father and Mother shall arrange physical custody of the Child as follows: a. In week one, Mother shall have physical custody from Wednesday 6:00 pm until Thursday morning bringing the Child to the bus stop (or to paternal grandmother's residence at 7:00 am if no school) and then from Friday 6:00 pm until Monday morning bringing the Child to the bus stop (or to paternal grandmother's residence at 7:00 am if no school). b. In week two, Mother shall have physical custody from Wednesday 6:00 pm until Friday morning bringing the Child to the bus stop (or to paternal grandmother's residence if no school). c. The parents are free to alter the above schedule by written mutual agreement. Regular Physical Custody Schedule (M=mom D =dad Monday Tuesday Wednesday Thursday Friday Saturday Sunday D D D M M I D D M M M M ID ' D D M M M D D D 3. The non - custodial parent shall have liberal telephone /email/text contact with the Child on a reasonable basis. 4. Holidays: The parents shall arrange the holiday schedule as mutually agreed upon. In the absence of agreement, the parties shall adhere to the attached holiday schedule. COPY 5. In the event the custodial parent should take the Child out of state, the custodial parent shall notify the non - custodial parent within twenty -four hours of departure of the intended destination and a telephone number at which they can be reached. 6. Neither party may say or do anything nor permit 'a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 7. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 8. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 9. Vacation: Each parent shall be entitled to up to ten (10) consecutive days of vacation with the Child per year. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation time shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. The Court notes that Father has already requested vacation from 12/13/13 until 12/23/13. 10. Relocation. The parties are advised that neither party shall hereafter relocate the child or children if such relocation will significantly impair the ability of a non - relocating party to exercise his or her custodial rights unless (a) every person who has custodial rights to the child/children consents to the proposed relocation or (b) the court approves the proposed relocation. The party seeking relocation must follow the procedures required by 23 Pa.C.S. §5337. 11. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. stribution: Karl Rominger, Esquire Corum, 317 Market St., Mechanicsburg, PA 17055 ohn J. Mangan, Es /•//2 — JONATHAN BAKER, Plaintiff v. copy. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07 -4835 CIVIL ACTION LAW TANESHA CORUM, IN CUSTODY Defendant Prior Judge: Kevin A. Hess, P.J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH 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: Name Date of Birth Currently in the Custody of Keyonah Marie Corum -Baker 12/06/2004 Father and Mother 2. An Order of Court was issued October 19, 2007, a conference was scheduled June 24, 2008 but upon request of counsel, the conference was continued due to an agreement, a Conciliation Conference was held with regard to this matter on February 11, 2010, an Order issued February 18, 2010 and a conference was held October 11, 2013 with the following individuals in attendance: The Mother, Tanesha Corum, self - represented party The Father, Jonathan Baker, with his counsel, Karl Rominger, Esq. 3. The undersigned recommends, and the parties agreed to, the entry of an Order in the form as attached. C77/ c(10 Date John Cust gan, Esquire onciliator Plaintiff Vs 10u_ COc\)(n Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 14(2?3.5 CIVIL ACTION - LAW IN CUSTODY CIVIL TERM TERM N) ■L-7 CRIMINAL RECORD / ABUSE HISTORY VERIFICATION CY\ , hereby swear or affirm, subject to pe law including 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities that: ."< r\.) es of • Unless indicated by my checking the box next to a 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 household member Ei 18 Pa.C.S. Ch. 25 fl (relating to criminal homicide) fl 18 Pa.C.S. §2702 fl E1 (relating to aggravated assault) 18 Pa.C.S. §2706 (relating to terroristic threats1 fl 18 Pa.C.S. §2709.1 (relating to stalking) 18 Pa.C.S. §2901 fl (relating to kidnapping) fl Date of Sentence conviction, guilty plea, no contest plea or pending charges fl 11.§29112 fl {!Lating to unlawful restrault 18 Pa.C.S. §2903 if:elatirgi to false im frJating to a child into a motor vehicle or struc} 18 friating to ra e 18iLas,L§3122.1 relating r!ating to statuqy senIgAgALid 17 fl 18 Pa.C.S. §3123 fl relatirLivoluntary deviate sexual inter_zccimrse imasAL§312/u n fr latirig to sexual _21c5. §3125 gelatine el atng to aggravated assault) indecent 0 7, d a frting to indecent assault} 18 §3127 Lrelatingto expaa_n frelating to sexual jIercourse with Irelating to Conduct relating to sex offer■cifers fl 12§3311 17.7 relating to arson and rted offense} 18 Pa.C.S. §4302 iLelating tQjflces 18 Pa.C.S. §4303 ET] Lrelating to cjeghofchkcill 1/3.121C304 frLating to endangefrg eifare of 1.41.1i1cfren .F7 18 _IazAm3p5 frjating to iJnfant children) relating to rostjtutjon a n related 0 ffentsi .71 f_c_1(.11 reLi to obscene and other sexual materials and Performancesj fl __ 1a,Ls.§11 re lati corrupt Lminp D fl D Eli 18 Pa.C.S. §6312 (relating to sexual abuse of children) FT 18 Pa.C.S. §6318 El (relating to unlawful contact with minor) El 71 18 Pa.C.S. §6320 El FT (relating to sexual exploitation of children' 23 Pa.C.S. §6114 FT FT (relating to contempt for violation of Protection order or agreement) Driving under the El influence of drugs or alcohol Manufacture, sale, El El delivery, holding, offering for sale or possession of any controlled substance or 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 all that apply Self Other household member FT A finding of abuse by a Children & Youth El Agency or similar agency in Pennsylvania or similar statute in another jurisdiction FT Abusive conduct as defined under the FT Protection from Abuse Act in Pennsylvania or similar statute in 7. Date another jurisdiction Other: Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 1.C4 69-) C) C cc (C TY), C -0`q5C13 2Lo25S -2.01 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 party's household has or have a criminal / abuse history, please explain: 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. Signature Printed Name COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION.- LAW Tanesha L. Corum, Petitioner v. Jonathan D. Baker, Respondent No. 07 -4835 CERTIFICATE OF SERVICE I certify that a true and correct copy of the Petition for Contempt of Custody was served upon Jonathan D. Baker by (check at least one): First class mail, postage prepaid, and certified mail, return receipt requested at the following address: 130 Channel Drive Carlisle, PA 17013 ❑ In person by an adult other than Tanesha L. Corum at the following address: The person who served the Petition for Contempt of Custody on Jonathan D. Baker in person was: Name: Address: Signature of person who made service: Certificate of Service (Jonathan D. Baker) Page 1 of 2 I, Tanesha L. Corum, certify that this service was made on the (Y' C LX C.h , 20 14 day of Certificate of Service (Jonathan D. Baker) Page 2 of 2 wilmmilmmor CARLISLE MPO CARLISLE, Pennsylvania 170139998 4134870013 -0093 03/14/2014 (800)275 -8777 12:33:42 PM Sales Receipt Product Sale Unit Final Description Oty Price Price Photo /Doc 1 $1.59 $1.59 Mailer 9.75x12.25 Chipboard CARLISLE PA 17013 Zone -0 $2.03 First -Class Mail Large Env 5.30 oz. Expected Delivery: Sat 03/15/14 ________ Issue PVI: $2.03 Total: $3.62 Paid by: Cash $20.00 Change Due: - $16.38 ********* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * ** ********* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * ** BRIGHTEN SOMEONE'S MAILBOX. 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BAKER DEFENDANT CUMBERLAND COUNTY, PENNSYLVANIA 2007 -4835 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, March 18, 2014 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, April 11, 2014 1:30 PM 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/ John J. Mangan, Jr., Esq p\ 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. capi.Es ()tat 14 `r. 0.6 3//ispy Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249 -3166 G.) c CD o JONATHAN BAKER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. No. 07 -4835 CIVIL ACTION LAW TANESHA CORUM, IN CUSTODY rn co D rn efendant rte.. Prior Judge: Kevin A. Hess, P.J. ORDER OF COURT AND NOW this 2 1 ' day of April 2014, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: N Xaw N CO 1. By agreement of the parties, Mother's petition for contempt is hereby DISMISSED without prejudice. 2. Legal Custody: The Father, Jonathan Baker, and the Mother, Tanesha Corum, shall have shared legal custody of Keyonah Marie Corum- Baker, born 12/06/2004. The parties shall have an equal right to make all major non - emergency decisions affecting the Child's general well- being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: Father and Mother shall arrange shared physical custody of the Child on a 2/2/5/5 basis as follows: a. Father shall have every Monday and Tuesday overnight, Mother shall have every Wednesday and Thursday overnight and the parents shall alternate weekends from Friday until Monday. b. All exchanges shall occur at school; when there is no school, the custody exchanges shall occur at 6:00 pm with the non - custodial parent picking up Keyonah from the other parent to begin their custodial period. It is understood that Keyonah may be cared for by paternal grandmother in the mornings c. The parents are free to alter the above schedule by written mutual agreement. It is also specifically understood that Father shall have custody of Keyonah for a reasonable period for his upcoming wedding. Regular Physical Custody Schedule (M=mom D =dad Monday Tuesda Wednesday Thursday Friday Saturday Sunday D D D M M M M M M D D D M M M D D D 4. The non - custodial parent shall have liberal telephone /email /text contact with the Child on a reasonable basis. 5. Counseling: The parents are strongly encouraged to engage in therapeutic family counseling (with the focus on co- parenting) with a mutually agreed upon professional. Both parents shall meaningfully participate in said counseling until successfully discharged. In counseling, the parents shall discuss the issue about phone communication (how Keyonah shall communicate with the non - custodial parent) and follow the recommendations of the counselor. The parents shall further explore individual counseling for Keyonah to see if counseling would be beneficial to her. The parents shall adhere to any recommendations. 6. Holidays: The parents shall arrange the holiday schedule as mutually agreed upon. In the absence of agreement, the parties shall adhere to the attached holiday schedule. 7. In the event the custodial parent should take the Child out of state, the custodial parent shall notify the non - custodial parent within twenty -four hours of departure of the intended destination and a telephone number at which they can be reached. 8. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 9. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 10. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and /or house guests comply with this provision. 11. Vacation: Each parent shall be entitled to up to ten (10) consecutive days of vacation with the Child per year (to include their respective weekends). The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation time shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 12. Relocation. The parties are advised that neither party shall hereafter relocate the child or children if such relocation will significantly impair the ability of a non - relocating party to exercise his or her custodial rights unless (a) every person who has custodial rights to the child/children consents to the proposed relocation or (b) the court approves the proposed relocation. The party seeking relocation must follow the procedures required by 23 Pa.C.S. §5337. 13. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Distribution: chael 0. Palermo, Esquire �I'anesha Corum, 704 Hamilton St., Carlisle, PA 17013 /John J. Mangan, Esquire By the Court, .2-es,se P. J. HOLIDAYS AND SPECIAL DAYS TIMES EVEN YEARS ODD YEARS Easter Day 1st Half From 9 am until 3 pm Father Mother Easter Day 2nd Half From 3 pm until 9 pm Mother Father Memorial Day From 9 am until 9 pm Mother Father Independence Day From 9 am until 9 pm Father Mother Labor Day From 9 am until 9 pm Mother Father Halloween From one hour before trick or treating to one hour after trick or treating Father Mother Thanksgiving 1St Half From 8 am Thanksgiving Day to 2 pm on Thanksgiving Day Father Mother Thanksgiving 2nd half From 2 pm on Thanksgiving Day to noon the day after Thanksgiving Day Mother Father Christmas 1St Half From noon on 12/24 to noon on 12/25 Father Mother Christmas 2nd Half From noon on 12/25 to noon on 12/26 Mother Father New Year's From 6 pm 12/31 until noon January 1st (with the 12/31 year to control the even/odd determination) Mother Father Mother's Day From 9 am until 9 pm Mother Mother Father's Day From 9 am until 9 pm Father Father JONATHAN BAKER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. No. 07-4835 CIVIL ACTION LAW TANESHA CORUM, IN CUSTODY Defendant Prior Judge: Kevin A. Hess, P.J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH 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: Name Date of Birth Currently in the Custody of Keyonah Marie Corum-Baker 12/06/2004 Father and Mother 2. An Order of Court was issued October 19, 2007, a conference was scheduled June 24, 2008 but upon request of counsel, the conference was continued due to an agreement, a Conciliation Conference was held with regard to this matter on February 11, 2010, an Order issued February 18, 2010, a conference was held October 11, 2013, an Order issued October 16, 2013 and a conference was held April 11, 2014 with the following individuals in attendance: The Mother, Tanesha Corum, self-represented party The Father, Jonathan Baker, with his counsel, Michael 0. Palermo, Esq. The undersigned recommends, and the parties agreed to, the entry of an Order in the form as attached. Date 7-Z-"/ Jo J. angan, Esquire C stod Conciliator