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Home My WebLink About93-0368AS OF s~+~,6~ ~ , a°°~ ~9 HAS BEEN SCANNED. ALL EARLIER FILINGS TO THIS CASE HAVE BEEN MICROFILMED. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN BEAR, Petitioner v PAMELA BEAR, Respondent No. 1993 - 0368 CIVIL ACTION -LAW CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW, this J day of September, 200?,.comes Petitioner, Stephen Bear, by and through his attorney, Suzanne Spencer Abel, Esq. of Neuharth Law Offices, and who avers as follows: 1. The petition of Stephen Bear respectfully represents that on August 14, 2000, an Order of Court was entered adopting the parties' Stipulation Agreement, a true and correct copy of which are attached. 2. The subject minor child, Michael Bear, now 17 years old, is an 11~' grade student at Big Springs High School. 3. For the last three years, Respondent has enjoyed primary physical custody of the child during the school year. Petitioner has enjoyed primary physical custody of the child during the summers, visitation on alternating weekends during the school year. 4. This Order should be modified because: a. On Friday, August 31, 2007, Respondent called Petitioner in an emotionally distraught state and advised Petitioner that she was being evicted, and that she had to vacate her residence by Sunday, September 2, 2007. Respondent asked Petitioner to pick up the minor child, which he did. The child is to remain at Petitioner's residence until Respondent can establish a new residence. b. 'The minor child repeatedly expresses his fear for his safety while at Respondent's home where both Respondent and her boyfriend, William Scott Smith, have had ongoing interactions with state and local police to resolve ongoing domestic violence complaints. See Exhibit A attached. c. Respondent refuses to cooperate in good faith with Petitioner's ongoing requests to be timely advised of the child's school, social, and religious activities. d. Respondent believes that the child receives adaptive services through his school, which would necessitate an Individual Educational Plan (IEP). The child believes he has attended IEP meetings with Respondent present. Respondent refuses to advise Petitioner of the dates and times of any IEP meetings, effectively excluding Petitioner from participating in their child's educational plans. WHEREFORE, Petitioner, Stephen Bear, respectfully requests this Honorable Court to enter an Order granting him primary physical custody of the child, with alternating weekends with Respondent. Respectfully submitted, Neuharth Law Offices S Spence Abel, Esquire Id. 02443 Neuharth Law Offices P.O. Box 359 Chambersburg, PA 17201 Phone: (717) 264-2939 Fax: (717)263-2928 Page 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEVEN BEAR, Petitioner v PAMELA BEAR, Respondent VERIFICATION No. 1993 - 0368 CIVIL ACTION -LAW CUSTODY I VERIFY that I have personal knowledge of all facts not of record set forth in the foregoing pleading, and that such statements are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: ~''3~~01 Steven Bear r TH~C i~TlLJ-'t`! D At~R~lti~' err~et+e~t into thr~~ dad of +~~ryiiT~dVt "~"Ijifi R,7 #~l~~ii~~~jy~~"`~~~r lyf~'¢~s ~.`1~ ~ A~l~~l~j ~#{i7t ~~i ~~1i~+1 ~~i~ M~~~1G1~ ~ii~ ~1~1~~ ~ ~~ ~S~I Si iii #iF~~T~ ~~ 111ii~l~~s NQiiV { ~ ~V~.~~r~ 1i~~'.~i~ ~~'~« get y~ iT~7G~jr/y~iMFi {~~F~7~ +~ 11~ i1#G ~i~Giti~ ii. ~ ii it Mrivf W1~* 7FP~~~1~t ~1WI~~ 1~A~ .. W~EE~ti pe?~ Slnd the Child 8r+~ sutt t0 ern {3rder Oi' COUrt dated September . '~9~e end YYF3ERi~, Father hss a p~~Dtion ~ nxxiify the +~rrent arrangement set t~rth in that Clyder and, in fact, by C~rdet of Court dated Jane 21, ~Ot~Ui this Court did rtx~dify a~astc~3y pending a Wiring to tae hek! an the Fat~er"s petitiz~n; end WHEREAS,, the parties haws now meet in the offices crf ttte Cum~riend County Children ~ Ysautt- Servi~es't~a discuss an srniCat~e resoitrtion of this matter end now wish to enter into a new reertlent retati+re to the axstody and partial C~,stody of the Child. f. i NQW, TH~REFC3R1~, in consrderation of the mutual covenants,. promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. Ail previc~u5 orders concerning the custody of this child shall be vacated.. 2. The porkies shall have joint legal custody of the child, which shall include, but not be limited to the mutual- sharing of inforrrtatian and decis~ns with regard to medical care, education, reiigic~us instruction of the child. ~. The Mother shall .Maus primary physical custody of the child, subject to periods of temporary physical custody with the Father as follows: A, During the schoai year, an aitemating weekends from Friday at 6:t}~ p,m. until Sunday at fi:t}0 p.m. i3. During the child`s Summer vacation Pram school nn one week per month, with the Father agreeing to give the Mother 30 days notice of the weeks he wishes to exercise. this temporary custody time. In addition, during the Summer the Father shalt also have one week per month in which he exercises temporary physical custody from Wednesday at 6.Ut3 p,m, through Sunday at 6.t~t3 p.m, in place of the alternating weekend time he v++ould otherwise have the child. 9 ,} For example, for the Summer of 2t~t?0, the Father shall have the child from ,July ~- 9, July 16 ~ ~~, August ~ - 6, and August 13 ~ 20. Afl such periods shall begin and end at 6:#7fl p,m, 2.} In future Summer's the porkies shall schedule Fa#her's time with the child in a similar manner. i ~r:aw C. The i=other shall always ,have the chitd on father"s Darr Pram 9;t~0 a.m. anti! 6.t?0 p.m. and the Mother shall always have the child on Mother's Day from 9:At? a.m, until 6:00 p,m. D. At such other times as the parties may mutually agree. 4. The parties shall share custody on Easter, Thanksgiving and Christmas in order #a insure each party with reasonably equal periods of time with the child on these holidays. 5, The parties shall share holidays on New Year's day, Memorial Day, l=ourth of Juiy, Labor day and Columbus day. If the parties are unable #o work out an arrangement tha# provides for equal access with the minor child an these holidays, the parties shall alternate these major holidays. 6. The parties shah share transportation far the exchange of eustod}+. Absen# agreement of the parties, the non-custodial parent will pick up the child at the other party's home at the conclusion of the custodial parent's time. with the child. 7'. Bath parties agree that each party shall have reasonable telephone contact with the child while the child is in the ether party's custody and that the child will be permitted to call the nancustadial parent as desired while they are in the custody of the other parent, 8. The parties will keep each other advised immediately relative to any emergencies. concerning the child and shall. further take any necessary steps to ensure that the health. welfare and well being of the child is protected. 9, The parties shall do nothing that may estrange the child from the other parent or Injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love or affection for the o#her parent. i ~. Any modifica#ion or waiver of any of the provisions of this agreement shall be effective only if made in writing and only if executed with the same formality of this agreemento 'l t . 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. 12. The parties desire that this agreement be made an order of Court through the Court of Commcm Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas. of Cumberland Chun#y has jurisdiction over the issue of custody of the parties' minor child and shall retain such jurisdiction should circumstances change and either party desire further or require further modif~ca#ion of said C7rder. iN 1NiTNESS 1NNEREQF, the parties hereto., intending to be legally bound by the terms hereof; se# forth #heir hands and seals the day and year herein set forth. 'WITNESSETH: .. ,. , ~~~~+`' 1~y tc.a :~ C?ate: ' ~.~r~;~r. ~',~.-~,.... {SEAL] S7Ei~H A. BEAR _ ~~' ~~ Date. ~w ~. t: ~' ....~ ,~~°~.~~~ '~~ ~ :~~.~~- {SEAL) I~AMELA A BEAR v r ~•~j~.1~.. ~'~i'~ GC?MMCIENWEALTH Off' PENNSYLI/ANIA ASS: GCIUNTY OF GUNIE3ERtANC~ ~n this, the ~:~,.~~ay of , 200, before me, the undersigned ofil~cer, per~nally appeared Stephen A Ne ,known to me {or satisfactorily proven.) to be the person whose name is subscribed to the within instrument and acknowledgdd that he executed same for the purposes therein contained. IN WITNESS YVIEREflF, !hereunto set my hand and official seal. {SEAL) N~ ' Pu '~ ~, ~„ P3ai~arial Seri Ji9En'+3k~' fi Lirxi~rt~ ttio;;;ri~ ~rrJ'i Carlo Coro, Gv~n ,~na~~c~C~u~ty 11~~ CsCiif'St11iSS~Ott Expirt~;a \..^.,V. 7 Jtt'„ ~~d`t~ f~Qi1~r9S°iVk~nt~3 ~i x .X : :'. ~ , _ _ _ _ GOMNit?NWEALTH t~F PENNSYLVANIA :SS: Ct}UNTY O~ +CUMBERLANC3 fln this, the day of " ~''~~' 24U0, before me, the undersigned officer, f personally appealed Pamela A. Bear,'known to me (or satisfactorily proven} to be the person whose name is subscribed to the within instrument and acknowledged that she executed same for the purposes therein contained, IN WITNESS WHEREOF, I hereon s my hand and official seal. ~,,,~'``~',~~~ ~' . {SEAL) .~ ~ , ~, ,:;,. Notary Public ~. ~ . t ~ _.__ ~ _r u~ ~y i EXHIBIT A CRIMINAL DOCKET Magisterial District Judge 09-3-02 ROCKET 11 Judge Assigned OTN: H 296333-2 Arresting Agency: CARLISLE PSP Arresting Officer: Complaint/Incident # County: CUMBERLAND Township: PENN TWP Docket Number: CR-0000019-02 Criminal Docket COMMONWEALTH OF PENNSYLVANIA SMITH, WILLIAM SCOTT Page 1 of 1 CASE INi`ORMAT[ON Issue Date: File Date: Case Disp: Disp Date: Requested: Judgment: 02/04/2002 02/04/2002 Waived for Court 03!19/2002 $0.00 DEFEWDANT lWFORMATION Name: SMITH, WILLIAM SCOTT Address: NEWVILLE, PA 17241 Date Of Birth: 02/06/1970 Sex: Male Race: ..BAIL Bail Type: ROR Status Date: 03/19/2002 Bail Status: Set Posting Date: Bail Amount: $0.00 O/S Amount: $0.00 CHARGES # Charge Description Disposition 1 18 § 3503 §§ A1 11 CRIM TRES-BREAK INTO STRUCTURE Waived for Court (Lower Court) 2 18 § 3304 §§ Al CRIM MISCH/DMG PR OP INTENT, RECKLESS, OR NEGLIG Waived for Court (Lower Court) 3 18 § 3304 §§ Al CRIM MISCH/DMG PR OP INTENT, RECKLESS, OR NEGLIG Waived for Court (Lower Court) CALENDAR Schedule Date Event Type Status 03/19/2002 Arraignment 03/28/2002 Preliminary Hearing CASE ACCOUNTING Total Due: $0.00 Total Adj: $0.00 Total Paid: $0.00 Balance: $0.00 SU1~1MfONS Summons Date Summons Action 02/07/2002 SUMMONS ACCEPTED 1200 Printed: 08/30/2007 11:33 am Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-3-02 Dl?CKET COMMONWEALTH OF PENNSYLVANIA { v. SMITH, WILLIAM SCOTT Docket Number: CR-0000177-02 Criminal Docket Page 1 of 1 CASE INFpRMATiON Judge Assigned: Issue Date: 10/20/2002 OTN: L 136518-4 File Date: 10/20/2002 Arresting Agency: CARLISLE PSP Case Disp: Held for Court Arresting Officer: Disp Date: 10/28/2002 Complaint/Incident # Requested: $0.00 County: CUMBERLAND Judgment: Township: UPPER FRANKFORD TWP . . [7iEFEMt}pNT 1NFpRIYtATl4N s______. _ AM SCO Address: NEWVILLE, PA 17241 Name: Date Of Birth: MITH WILLI 02/06/1970 Sex: Male Race: BAIL Bail Type: Monetary Status Date: 10/22/2002 Bail Status: Posted- Posting Date: 10/22/2002 Bail Amount: $5000.00 O/S Amount: $5000.00 CDNIMITMENT Location Commit Reason Commit Date Release Date Release Reason 10/20!2002 10/22/2002 CH~A RGES # Charge Description Disposition 1 18 § 2701 §§ Al SIMPLE ASSAULT Held for Court (Lower Court) 2 18 § 2709 §§ Al HARASSMENT/STRIKE, SHOVE, KICK, ETC. Held for Court (Lower Court) CALENDAR Schedule Date Event Type Status 10/20/2002 Arraignment 10/24/2002 Preliminary Hearing CONT 10/28/2002 Preliminary Hearing HDCT CASE ACCOUNTING Total Due: $0.00 Total Adj: $0.00 Total Paid: $0.00 Balance: $0.00 Printed: 08/30!2007 11:30 am 1200 Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only lie provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-3-02 DOCKET Judge Assigned: OTN: Arresting Agency: Arresting Officer: Complaint/Incident # County: Township: Docket Number: CR-0000192-05 Criminal Docket COMMONWEALTH OF PENNSYLVANIA v. SMITH, WILLIAM SCOTT L 255348-2 CARLISLE PSP NEMES, CHRISTOPHER A CUMBERLAND UPPER FRANKFORD TWP CASE Itd~oR~iIATWN Issue Date: 09/12/2005 File Date: 09/12/2005 Case Disp: Dismissed Disp Date: 02/22/2006 Requested: $0.00 Judgment: DEFENDANT IN~QRMATK?N Name: SMITH, WILLIAM SCOTT Address: NEWVILLE, PA 17241 Date Of Birth: 970 Sex: Male Race: White Bail Type: Bail Status: Bail Amount: # Charge 1 18 § 2705 2 18 § 5503 §§ A4 Schedule Date 10/20/2005 12/01 /2005 01 /04/2006 01 /04/2006 01 /04/2006 03/09/2006 BAIL Unsecured Status Date: 01/04/2006 Set Posting Date: $500.00 O/S Amount: $500.00 CHARGES Description RECKLESSLY ENDANGERING ANOTHER PERSON DISORDER CONDUCT HAZARDOUS/PHYSI OFF -SUMMARY CALENDAR Event Type Preliminary Hearing Preliminary Hearing Arraignment Arraignment Preliminary Hearing Preliminary Hearing CASE ACCdUN'T'ING Total Due: $0.00 Total Adj: Total Paid: $0.00 Balance: SUNMAONS' Summons Date Summons Action 09/16/2005 SUMMONS ACCEPTED Name: NEMES, CHRISTOPHER A Status CONY CONY CONY CONY DIS $0.00 $0.00 AFFtANT t~itFQRMAT1oN Address: PA STATE POLICE 1070 EBERLY WY LEMONY FURNACE, PA 15456 Page 1 of 1 Disposition Dismissed (Lower Court) Moved to Non-Traffic (Lower Court) 1200 Printed: 08130/2007 11:29 am Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not Comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9t83. Magisterial District Judge 09-3-02 C10GKET COMMONWEALTH OF PENNSYLVANIA v. SMITH, WILLIAM SCOTT Docket Number: NT-0000862-04 Non-Traffic Citation Docket Page 1 of 1 casE ~NfaRn~aTiQN Judge Assigned: Issue Date: 12/22/2004 OTN: File Date: 12/22/2004 Arresting Agency: CARLISLE PSP Case Disp: Guilty By Plea Arresting Officer: JOHNSTON, MATTHEW D Disp Date: 12/28/2004 Complaint/Incident # T0080983-0 Requested: $0.00 County: CUMBERLAND Judgment: Township: UPPER FRANKFORD TWP _.~ aES~E~~T ~nrFOa~AT~oN Name,:. MITH, WILLIAM SCOT Address: NEWVILLE, PA 17241 Date Of Birth: 02/06/1970 Sex: Male Race: GH/1RC~ES # Charge Description Disposition 1 18 § 2709 §§ Al HARASSMENT -SUBJECT OTHER TO PHYSICAL CONTACT Guilty Plea (Lower Court) CASE ACCOUNTING Total Due: $174.50 Total Adj: $0.00 Total Paid: $174.50 Balance: $0.00 SUlillIIIIONS Summons Date Summons Action 12/28/2004 SUMMONS ACCEPTED AFFIANT INFQRt~IATK}N Name: JOHNSTON, MATTHEW D Address: PA STATE POLICE 1538 COMMERCE AVENUE CARLISLE, PA 17013 1200 Printed: 08!30/2007 11:26 am Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers .who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-3-02 DOCKET COMMONWEALTH OF PENNSYLVANIA v. SMITH, WILLIAM SCOTT CASE 1NFORAAATtON Judge Assigned: COHICK, VIVIAN Issue Date: 09/12/2005 OTN: File Date: 09/12/2005 Arresting Agency: CARLISLE PSP Case Disp: Guilty By Plea Arresting Officer: NEMES, CHRISTOPHER A Disp Date: 02/22/2006 Complaint/Incident # CR-192-05 Requested: $0.00 County: CUMBERLAND Judgment: Township: UPPER FRANKFORD TWP DEFENflANT <~NFQRMATifJN Name: _ MITH WILLIAM SCOTT Address: NEWVILLE, PA 17241 Date Of Birth: _ 02/06/1970 Sex: Male Race: White CHARGES # Charge 1 18 § 5503 §§ A4 Total Due: $423.50 Total Paid: $423.50 Description Disposition DISORDER CONDUCT HAZARDOUS/PHYSI OFF -SUMMARY Guilty Plea (Lower Court) Name: NEMES, CHRISTOPHER A CASE ACCOUNTING Total Adj: $0.00 Balance: $0.00 AFFlANT iNFORMATIt3N Address: PA STATE POLICE 1070 EBERLY WY LEMONY FURNACE, PA 15456 Page 1 of 1 1200 Printed: 08!30/2007 11:23 am Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only Lie provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Docket Number: NT-0000126-06 Non-Traffic Citation Docket Magisterial District Judge 12-2-04 DOCKET Docket Number: NT-0000378-06 Non-Traffic Citation Docket COMMONWEALTH OF PENNSYLVANIA v. SMITH,WILLIAM S Page 1 of 1 CASE' INFOR~lIATK}N Judge Assigned: JENNINGS III, ROBERT Issue Date: 04/16/2006 OTN: File Date: 05/22/2006 Arresting Agency: HARRISBURG, POLICE DEPT Case Disp: Guilty By Plea Arresting Officer: HEFFNER, DONALD E Disp Date: 06/09/2006 Complaint/Incident # P5029624-5 Requested: $0.00 County: DAUPHIN Judgment: Township: HARRISBURG CITY ~, DEFENt~ANT tNfORIYlATl4N Name: MITH, WILLIAM S Address: NEWVILLE, PA 17241 Date Of Birth: 02/06/1970 Sex: Male Race: White CHARGES # Charge Description 1 3-3371A LOITER/PROWL IN PUBLIC W INTENT; CONTROLLED SUBST GASE ACGOUNTlNG Total Due: $382.78 Total Adj: $0.00 Total Paid: $382.78 Balance: $0.00 SLi14~IMONS Summons Date Summons Action 05/23/2006 SUMMONS ISSUED Name: HEFFNER, DONALD E AFFlANT lNFORMATtoN Address: HARRISBURG PD 123 WALNUT ST HARRISBURG, PA 17101 Disposition Guilty Plea (Lower Court) 1200 Printed: 08/30/2007 11:25 am Recent entries made in the ceurt filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-2-01 DOCKET COMMONWEALTH OF PENNSYLVANIA v. SMITH, WILLIAM SCOTT Docket Number: NT-0001075-05 Non-Traffic Citation Docket Page 1 of 1 casE iNFOR~raTEaN Judge Assigned: CORREAL, PAULA P Issue Date: 07/08/2005 OTN: File Date: 07/11!2005 Arresting Agency : NORTH MIDDLETON, POL ICE DEPT Case Disp: Guilty By Plea Arresting Officer: STUM, DENNIS R Disp Date: 07/20/2005 Complaint/incident # P4534523-0 Requested: $0.00 County: CUMBERLAND Judgment: Township: NORTH MIDDLETON TWP DEFENDANT INF4RMATtON Name: MITH, WILLIAM SCOTT Address: NEWVILLE, PA 17241 Date Of Birth: 02/06/1970 Sex: Male Race: White CNARGE~ # Charge Description Disposition 1 18.§ 2709 §§ A4 HARASSMENT -COMM. LEWD, THREATENING, ETC. LANG. Guilty Plea (Lower Court) CASE ACCO-tJNTtNt3 Total Due: $222.50 Total Adj: $0.00 Total Paid: $222.50 Balance: $0.00 3U~iiIQNS Summons Date Summons Action 07/14!2005 SUMMONS ISSUED AFFIANT fNFOR~ifATlt?N Name: STUM, DENNIS R Address: NORTH MIDDLETON TWP PD 2051 SPRING RD CARLISLE, PA 17013 1200 Printed: 08/30/2007 11:26 am Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the • Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Judge Assigned: OTN: Arresting Agency: Arresting Officer: Complaint/Incider County: Township: CARLISLE PSP BARBOUR, MEGHAN F it # T0139788-5 CUMBERLAND UPPER FRANKFORD TWP Name: BEAR,IP MELAA Date Of Birth: /04/1968 # Charge 1 18§2709§§A1 Total Due: $173.50 Total Paid: $173.50 Summons Date Summons Action 11/30/2005 SUMMONS ACCEPTED Name: BARBOUR, MEGHAN F AFFIANT INF~R#AATIt?N Address: PA STATE POLICE 1538 COMMERCE AVE CARLISLE, PA 17013 Disposition Guilty Plea (Lower Court) Page 1 of 1 1200 Printed: 08/30/2007 11:15 am Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) may be subject to civil liability gs set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-3-02 DOCKET COMMONWEALTH OF PENNSYLVANIA v. BEAR, PAMELA A. CASE' INFORMATIQN Issue Date: 11/28/2005 File Date: 11/28/2005 Case Disp: Guilty By Plea Disp Date: 11/30/2005 Requested: $0.00 Judgment: DEFENDANT: lNFORMATfON Address: NEWVILLE, PA 17241 Sex: Female Race: CHARGES Description HARASSMENT -SUBJECT OTHER TO PHYSICAL CONTACT CASE ACCOUNTING Total Adj: $0.00 Balance: $0.00 SUINMONS Docket Number: NT-0000704-05 Non-Traffic Citation Docket ,' Judge Assigned: CORREAL, PAULA P OTN: Arresting Agency: Arresting Officer: Complaint/lncident # P1316130-4 County: CUMBERLAND Township: NORTH MIDDLETON TWP Name: BEAR PA_~t a a~ Date Of Birth: 12/04/1968 # Charge 1 18 § 2709 §§ Al Total Due: $178.50 Total Paid: $178.50 Magisterial District Judge 09-2-01 DOCKET Docket Number: NT-0000877-00 Non-Traffic Citation Docket COMMONWEALTH OF PENNSYLVANIA v. BEAR, PAMELA A CASE #NFORMATFON Issue Date: File Date: Case Disp: Disp Date: Requested: Judgment: Page 1 of 1 06/07/2000 06/07/2000 Guilty By Plea 06/22/2000 $0.00 DEFENDANT. INFORII~ATION Address: Sex: Race: ct~-ROEs Description HARASSMENT/STRIKE, SHOVE, KICK; ETC. CASE ACCOUNTING Total Adj: Balance: sul~woNs Summons Date Summons Action 06/20/2000 SUMMONS ISSUED NEWVILLE, PA 17241 Female White $0.00 $0.00 Disposition Guilty Plea (Lower Court) 1200 Printed: 08/30!2007 11:16 am Recent entries made in the court filing offices may not Lie immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEPHEN BEAR, Petitioner No. 1993 - 0368 v CIVIL ACTION -LAW PAMELA BEAR, : Respondent _ CUSTODY CERTIFICATE OF SERVICE I certify that, concurrent with filing the foregoing Complaint for Custody, I am this day serving a copy of same via certified, return receipt requested, First Class U.S. Mail, to the prior counsel of record, and to the following Defendant: Michael Scherer, Esq., prior counsel of record O'Brien, Baric & Sherer 19 West South Street Carlisle, PA 17013 Pamela Bear 162 East Louther Street Carlisle, PA 17013 Date: ~~s~~~ S e Spe cer Abel uharth Law Offices 232 Lincoln Way East Chambersburg, PA 17201 Phone (717) 264-2939 ('.~ _ N c~ _-s C~ -- "~ ..,~ -z'1 f L ~ 7'{ _ ' 7t ~ ~ ' f T 0 r - Ca"1 t='? ~ O " ' 1 - ~., s ~ _ ~-' c ' `~ ~ . ~~ `'a ~ ~ ,: ~, STEFHEN BEAR IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. PAMELA BEAR DEFENDANT • 1993-0368 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, September 13, 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 Friday, October OS, 2007 at 1:00 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 . M an r. Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabiiites 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. 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 County Bar Association 32 South Bedford Street ~,.',. Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 yam' ,~ ca ei b 7,z"'~~ S ~~ wd ~ I d~S tO~Z k~dlCl~iv~.l.{~~e{ 3H.1 ~0 ~~lw.-~~--Q~l~ r•1 OCT 0 52DOl,,~r STEPHEN BEAR Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. PAMELA BEAR Defendant Prior Judge: 3. Wesley Oler, Jr., J. No. 93-0368 Civil Term ACTION IN CUSTODY COURT ORDER AND NOW, this ~ b day of October, 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. All prior Orders in this matter are hereby VACATED. 2. Legal Custody: The Father, Stephen Bear and the Mother, Pamela Bear, shall enjoy shared legal custody of the minor child, Michael Bear, born 3/27/90. The parties shall have an equal right, to be exercised jointly with the other pazent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regazding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each pazent 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 pazent 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: The Father shall have primary physical custody of Michael Beaz subject to Mother's partial physical custody as follows. Mother shall have physical custody two weekends per month from Friday 6:00 pm until Sunday 6:00 pm. The parties shall mutually agree to which weekends Mother shall have. The pick up/drop off locations for the custody exchanges shall be mutually agreed to. 4. The non-custodial parent shall be entitled to have reasonable liberal telephone contact with the Child. 5. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 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. >.- ~~ cr ~.. ~ ~~ _ ~ -~ ~ ~ ~ .~ ~ i'Ja +.1 f..+w wW. ~~ ~. .r M .~ \~.r/ ' . tj 3A ~ Q r^s r.7 ~ l 1 ~,~ V w •. 7. 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. 8. Holidays shall be alternated and arranged as mutually agreed upon. 9. 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 T C UR , J. Cc: ~san Spencer Abel, Esq. ~amela Bear, 3 James Court, Carlisle, PA 17015 ~iehn J. Mangan, Esquire 1 .~ - . STEPHEN BEAR IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. No. 93-0368 Civil Term PAMELA BEAR Defendant :ACTION 1N CUSTODY Prior Judge: J. Wesley Oler, Jr., J. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Michael Bear, born 3/27/90, currently in the primary physical custody of Father. 2. A Conciliation Conference was held on October 5, 2007 with the following individuals in attendance: The Father, Stephen Bear, with his counsel, Susan Spencer Abel, Esquire The Mother, Pamela Bear, pro se 3. The parties agreed to the entry of an Order in the form as attached. Date: f Q /a~ ^----- Jo J. angan, Esquire Custod Conciliator