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HomeMy WebLinkAbout03-5877ALICIA RENE BROWN, Plaintiff Vs. STEVE RAY BROWN Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- 5& 7 7 cc+j T e' CIVIL ACTION - LAW CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff, Alicia Rene Brown, currently resides at 12 Airport Road, Shippensburg, Cumberland County, Pennsylvania. 2. The Defendant, Steve Ray Brown, currently resides at 1985 Philadelphia Ave., Chambersburg, PA. 17201 3. The plaintiff seeks custody of the following child: Name Present Residence Date of Birth Kyler Brown 12 Airport Road December 8, 2000 Shippensburg, PA 17257 The child was not born out of wedlock. The child is presently in the custody of the plaintiff at the above address. During the past five years, Kyler has resided with the following persons and at the following addresses: Name Address Date Alicia Brown 12 Airport Road Mother Shippensburg, PA 17257 Leanna Conner 12 Airport Road Step-sister Shippensburg, PA 17257 The mother of the child is Alicia Brown, currently residing at 14 Airport Road, Shippensburg, Cumberland County, Pennsylvania. 2 She is single. The father of the children is Steve Ray Brown, currently residing at 1985 Philadelphia Ave., Chambersburg, PA. 17201 He is single. 4. The relationship of plaintiff to Kyler Brown is that of mother. The plaintiff currently resides with Kyler Brown. 5. The relationship of defendant to the child is that of father. The defendant currently resides with the following persons: Name Relationship Unknown to plaintiff 6. The 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. The plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. Plaintiff does not know of a person not a party to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 9. The best interest and permanent welfare of the child will be served by granting the relief requested for reasons including, but not limited, to the following: a) The mother has provided for Kyler, and has been his sole caretaker since birth, when the father left the residence where the parties had resided. The mother is the person who can best provide for the emotional, physical and education needs of all the children, including a stable environment. 8. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. WHEREFORE, the plaintiff requests this Court to grant her primary physical and legal custody of the child. Plaintiff further requests any other relief that is just and proper. Respectfully mitt J 4i6aDiamondstone Attorney for Plaintiff Mid Penn Legal Services 8 Irvine Row Carlisle, PA 17013 4 ?? -,,:> ==; r,+-??;` 1 (G.' rC ?. ....I ?, ? ..l 1i? .. (ti _?_. -\ ALICIA RENE BROWN, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 03- STEVE RAY BROWN : CIVIL ACTION -LAW Defendant : CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow ALICIA RENE BROWN,, Petitioner, to proceed in forma pauperis. I, Jessica Diamondstone, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. MIDPENN LEGAL SERVICES BY: Attorney for Plaintiff 8 Irvine R 'pW Carlisle, A 17013 VERIFICATION I, Jessica Diamondstone, Attorney, MidPenn Legal Services, verify that the statements contained in the above Complaint are true and correct to the best of my knowledge. The information is based on telephone conversations with Alicia Brown, Plaintiff. This verification is made pursuant to Rule 1024 (c)(2) of the Pennsylvania Rules of Court since Plaintiff is unavailable and her verification cannot be obtained in a timely manner. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: ) I a a '03 Jess' i onds ney M PENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 i rl r, \ (J7 G NOY 0 6 zW ALICIA RENE BROWN, Plaintiff IN THE COURT OF COMMON PLEAS OF vs. STEVE RAY BROWN CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-,: 16 ;' 7 : CIVIL ACTION -LAW Defendant : CUSTODY CUSTODY ORDER AND NOW, this 7A day of November, 2003, upon consideration of the agreement of the parties, it is hereby Ordered that custody of the minor child, Kyler Steven Brown, born December 8, 2000, shall be as follows: Plaintiff, Alicia Rene Brown, hereinafter referred to as the mother, and Defendant, Steve Ray Brown, hereinafter referred to as the father, shall share legal custody of the child. 2. The mother shall have primary physical custody of the child. 3. The father shall have partial custody of the child according to the following schedule: a. Alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m., starting November 7, 2003, and b. Every Wednesday at 6:00 p.m. until Thursday at 6:00 p.m. 4. The mother and father shall share custody around the following holidays: Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day at mutually agreed upon times. 5. The mother and father shall share custody around the child's birthday at mutually agreed upon times. 6. The mother and father shall alternate custody during the Christmas holiday with one parent having the child on Christmas Eve from noon until Christmas Day at noon, and the other parent having the child on Christmas Day from noon until December 26th at noon. The mother shall commence the schedule having the child beginning Christmas Eve in 2003, and in odd numbered years thereafter. 7. Unless otherwise agreed, the mother and father shall share transportation of the child for the exchanges of custody, and the exchanges shall take place at Italian Village in Chambersburg, PA. 8. The mother and father shall each be entitled to one week vacation with the child each summer. The mother and father shall each give the other parent 30 days notice of their choice of vacation week. 9. The mother and father shall be entitled to reasonable telephone contact with the child when the child is in the custody of the other parent. If either parent has the child away from their residence overnight, that parent shall inform the other parent of the phone number where the child can be reached. 10 Both parents agree that the child will not have any contact with the Oasis of Love Church or Church functions. 11. Neither party shall do anything which 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 respect for the other parent. BY31fE COURT, ?` JUDGE d N" Ai ),S'NN3d This Order is entered pursuant to the consent of Plaintiff and Defendant: (ZLe.cti CP51 o L'on Alicia Rene Brown, Plaintiff rianp arey, A enn Legal Services 8 Irvine Row, Carlisle, PA 17013 Steve Ray Brown, Defendant Pro Se ULP . - ' l lwal; j? I/ . 0 7 - 03 (::?- c-? ?, c_ ?? i ??'; ??' 'T? ,:.. :_ ;? ,? r? ALICIA RENE BROWN, Plaintiff V. STEVEN RAY BROWN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO: 03-5877 CIVIL ACTION - LAW IN CUSTODY PETITION FOR FINDING OF CONTEMPT 1. Petitioner is Steven R. Brown, who resides at 2690 Crottlestown Road, Chambersburg, Franklin County, Pennsylvania 17201. 2. Respondent is Alicia R. Brown, last know address is 159 SME, Shippensburg, Cumberland County, Pennsylvania 17257. 3. On November 7, 2003, January 11, 1999, the Honorable Edward Guido. entered a Stipulation order attached as Exhibit "A" 4. Since the entry of said Order, there has been a significant change in circumstances in that: a) Mother continuously violates the current provisions in the Order. b) Mother refuses to facilitate Father's relationship with the child. C) Mother is not acting in the best interests of the child. The best interest of the children will be served by the Court modifying said Order. WHEREFORE, Petitioner prays this Court to find Respondent in contempt of the November 7, 2004 Order of Court, to award attorney fees and costs of the within Petition and any other amount the Court deems just; additionally, Petitioner prays this Court to make necessary changes to the current Order to avoid continuing problems Date: \ 0 J Respectfully submitted, ROMINGER, BAYLEY & WHARE <7 i> Mark F. Bayley, Esquire 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 87663 Attorney for Defendant/Petitioner ALICIA RENE BROWN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO: 03-5877 STEVEN RAY BROWN, : CIVIL ACTION - LAW 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. Cons. Stat. § 4904 relating to unworn falsification to authorities. Steven R. Brown Defendant/Petitioner 0 NOY 0 62003 G ALICIA RENE BROWN, Plaintiff VS. STEVE RAY BROWN Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.03-,5 5 r 7 CIVIL ACTION - LAW CUSTODY CUSTODY ORDER AND NOW, this day of November, 2003, upon consideration of the agreement of the parties, it is hereby Ordered that custody of the minor child, Kyler Steven Brown, born December 8, 2000, shall be as follows: 1. Plaintiff, Alicia Rene Brown, hereinafter referred to as the mother, and Defendant, Steve Ray Brown, hereinafter referred to as the father, shall share legal custody of the child. 2. The mother shall have primary physical custody of the child. I. The father shall have partial custody of the child according to the following schedule: a. Alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m., starting November 7, 2003, and b. Every Wednesday at 6:00 P.M. until Thursday at 6:00 p.m. 4. The mother and father shall share custody around the following holidays: Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day at mutually agreed upon times. 5. The mother and father shall share custody around the child's birthday at mutually agreed upon times. LKH1/31T "A H 6. The mother and father shall alternate custody during the Christmas holiday with one parent having the child on Christmas Eve from noon until Christmas Day at noon, and the other parent having the child on Christmas Day from noon until December 26th at noon. The mother shall commence the schedule having the child beginning Christmas Eve in 2003, and in odd numbered years thereafter. 7. Unless otherwise agreed, the mother and father shall share transportation of the child for the exchanges of custody, and the exchanges shall take place at Italian Village in Chambersburg, PA. g. The mother and father shall each be entitled to one week vacation with the child each summer. The mother and father shall each give the other parent 30 days notice of their choice of vacation week. 9. The mother and father shall be entitled to reasonable telephone contact with the child when the child is in the custody of the other parent. If either parent has the child away from their residence overnight, that parent shall inform the other parent of the phone number where the child can be reached. 10 Both parents agree that the child will not have any contact with the Oasis of Love Church or Church functions. 11. Neither party shall do anything which 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 respect for the other parent. BY T 41E COURT, TRUE COY FROM RECORD ?--° In Tesfrmc, v;hzrecf, I h?rc orto sat niy hand / and the seal cl sa'a Cast at Ca lisla, Pa. JUDGE dar--75 This ... '- r ---- . Prothonotary This Order is entered pursuant to the consent of plaintiff and Defendant: Alicia Rene Brown, Plaintiff Steve Ra}? Brown, Defendant Pro Se an Carey, Attorney for inh 7- &Y MidPenn Legal Services 8 Irvine Row, Carlisle, PA 17013 t, ,L i 1,0 7- 0:3 (::?- v C ca Q?L ALICIA RENE BROWN IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. STEVEN RAY BROWN 03-5877 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday October 26, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse Carlisle on Tuesday„ November 23, 2004 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ac ueline M. Verney, Esp, mnc 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 4^Iv k ,..,,.. /,ve 4v ha'p'(21 Ir -*f 145,121 X '-'7 ALICIA RENE BROWN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 03-5877 STEVEN RAY BROWN, CIVIL ACTION -LAW Defendant IN CUSTODY PRAECIPE TO THE PROTHONOTARY: WITHDRAWAL OF APPEARANCE Please withdraw my appearance on behalf of the Plaintiff in the above-captioned matter. Respectfully submitted, Date: ?l - y anx??.DnmlLn _? C?9? Hannah Herman-Snyder, Esquire Griffie & Associates 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 ENTRY OF APPEARANCE Please enter my appearance on behalf of the Plaintiff in the above-captioned matter. Date: I i ?- - Ouf Respectfully submitted, Jessica ondstone, Esquire Mid-Penn Legal Services 8 Irvine Row Carlisle, PA 17013 ? N CC Y) P CO ,.., Lao DEC 0 6 20W ?, ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-5877 CIVIL TERM STEVEN RAY BROWN, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this ?4k day of 2004, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated November 7, 2003 shall remain in full force and effect except for the following modifications. 2. Paragraph 3a shall be modified as follows: alternating weekends from Friday at 5:00 p.m. until Sunday at 6:30 p.m. 3. Paragraph 3b shall be modified as follows: every Wednesday from 5:00 p.m. to 6:30 p.m. 4. Paragraph 4 shall be modified as follows: the listed holidays shall be shared such that Father shall always have physical custody :from 9:00 a.m. to 3:00 p.m. and Mother shall always have physical custody from 3:00 p.m. to 9:00 p.m. In addition, Father shall have custody of the child on trick or treat night from 6:00 p.m. to 8:00 p.m. 5. Paragraph 8 shall be modified as follows: parents shall be entitled to two (2) non-consecutive weeks during the year, provided they give 14 days notice. 6. Paragraph 9 shall be modified as follows: Father shall be entitled to call the child on his non-custodial Sunday and the following Tuesday at 8:00 p.m. Mother shall be entitled to call the child on her non-custodial Saturday at 8:00 p.m. 7. This Order is entered pursuant to an agreement of the parties at 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. Another Conciliation Conference is scheduled for January 18, 2005 at 9:30 p.m. ccXark F. Bayley, Esquire, Counsel for Father 4Xssica Diamondstone, Esquire, Mid Penn Legal Services, Counsel for Mother Y . ??-os-off Edward E. Guido, J. 0 ?a L- 3-30 331 :3 VD DEC 0 6 20041( ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. STEVEN RAY BROWN, Defendant :2003-5877 CIVIL PERM : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyler Steven Brown December 8, 2000 Mother 2. A Conciliation Conference was held in this matter on December 6, 2004, with the following individuals in attendance: The Father, Steven Ray Brown, with his counsel, Mark F. Bayley, Esquire and the Mother, Alicia Rene (Brown) Rininger, with her counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services. 3. The Honorable Edward E. Guido entered an Order of Court dated November 7, 2003 by stipulation of the parties. The Order provided for shared legal and primary physical custody in Mother, with Father having alternating weekends and one overnight per week. 4. Father filed a Petition for Contempt. Father is willing to hold the contempt in abeyance, but reserves the right to proceed in the future against Mother's alleged contempt. 5. The parties agreed to the entry of an Order in the form as attached. Date cqu ine M. Verney, Esquire 64 Custody Conciliator JAN 1 9 2005 ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 2003-5877 CIVIL TERM STEVEN RAY BROWN, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this W JIV\ day of ? 2005, upon consideration of the attached Custody Conc ation ep rt, it is ordered and directed as follows: 1. The prior Orders of Court dated November 7, 2003 and December 7, 2004 are hereby vacated. 2. The Father, Steven Ray Brown, and the Mother, Alicia Rene (Brown) Rininger, shall have shared legal custody of Kyler Steven Brown, born December 8, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 3. The Mother shall have primary physical custody of the child. 4. The Father shall have periods of partial physical custody of the child according to the following schedule: A. Alternating weekends from Wednesday at 5:00 p.m. until Sunday at 6:30 p.m. B. On the off week, every Wednesday overnight from Wednesday at 5:00 p.m. to Thursday at 6:30 p.m. C. Such other times as the parties agree. 5. Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day shall be shared such that Father shall always have physical custody from 9:00 a.m. to 3:00 p.m. and Mother shall always have physical custody from 3:00 p.m. to 9:00 p.m. In addition, Father shall have custody of the child on trick or treat night from 6:00 p.m. to 8:00 p.m. 6. Mother and Father shall share custody around the child's birthday at mutually agreed upon times. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. 8. Unless otherwise agreed, the parties shall share transportation such that custody exchanges shall occur at the Shippensburg police station. 9. Parents shall be entitled to two (2) non-consecutive weeks during the year, provided they give 14 days notice. 10. Father shall be entitled to call the child on his non-custodial Sunday and the following Tuesday at 8:00 p.m. Mother shall be entitled. to call the child on her non- custodial Saturday at 8:00 p.m. 11. Neither parry may smoke in their homes or in their cars. 12. This Order is entered pursuant to an agreement of the parties at 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. Another Conciliation Conference is scheduled for April 12, 2005 at 9:30 p.m. Edward E. Guido, J. r? cc: "aik F. Bayley, Esquire, Counsel for Father essica Diamondstone, Esquire, Mid Penn Legal Services, Counsel for Mother J 0 v 0 C IC .E Nd hz Or SUZ SAN 19 7I?(15? ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. STEVEN RAY BROWN, Defendant :2003-5877 CIVIL TERM : CIVIL ACTION- LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyler Steven Brown December 8, 2000 Mother 2. A Conciliation Conference was held in this matter on January 18, 2005, with the following individuals in attendance: The Father, Steven Ray Brown, with his counsel, Mark F. Bayley, Esquire and the Mother, Alicia Rene (Brown) Rininger, with her counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services. 3. The Honorable Edward E. Guido entered Orders of Court dated November 7, 2003 and December 7, 2004. The Orders provided for shared legal and primary physical custody in Mother, with Father having alternating weekends and one overnight per week. 4, The parties agreed to the entry of an Order in the form as attached. Date ac eline M. Verney, Esquire Custody Conciliator RECEIVED APR 13 2005 ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF 91 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. STEVEN RAY BROWN, Defendant : NO. 2003-5877 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this a01 day of 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated January 20, 2005 shall remain in full force and effect with the following modification. 2. The parties shall cooperate with co-parenting counseling, to begin separately by a counselor selected by the parties' attorneys. 3. This Order is entered pursuant to an agreement of the parties at 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. Another Conciliation Conference is scheduled for July 11, 2005 at 9:00 p.m. cc?Nlar Bayley, Esquire, Counsel for Father ssica Diamondstone, Esquire, Mid Penn Legal Services, Counsel for Mother Q ,Ot4 . A) Edward E. Guido, J. ,.O vjAj M RECEIVED APR 13 M ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. STEVEN RAY BROWN, Defendant :2003-5877 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyler Steven Brown December 8, 2000 Mother 1 A Conciliation Conference was held in this matter on April 12, 2005, with the following individuals in attendance: The Father, Steven Ray Brown, with his counsel, Mark F. Bayley, Esquire and the Mother, Alicia Rene (Brown) Rininger, with her counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services. 3. The Honorable Edward E. Guido entered an Order of Court dated January 20, 2005. The Order provided for shared legal and primary physical custody in Mother, with Father having alternating weekends and one overnight per week. 4. The parties agreed to the entry of an Order in the form as attached. 44 - Date acq line M. Verney, Esquire Custody Conciliator \?ECEIVED AUG 0 ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-5877 CIVIL TERM STEVEN RAY BROWN, : CIVIL ACTION- LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this 7 ` day of , 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated January 20, 2005 and April 20, 2005 shall remain in full force and effect with the following modification: 2. Neither parent shall permit contact between the child and the Oasis of Love Church or attend church functions. 3. This Order is entered pursuant to an agreement of the parties at 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. Another Conciliation Conference is scheduled for September 21, at 2:30 p.m. Y THE CO RT, Edward E. Guido, L cc?:)dark F. Bayley, Esquire, Counsel for Father ?.(essica Diamondstone, Esquire, Mid Penn Legal Services, Counsel for Mother l? %,( lJ E; ?? 1J1, ,? ]?l? ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. STEVEN RAY BROWN, Defendant :2003-5877 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyler Steven Brown December 8, 2000 Mother 2. A Conciliation Conference was held in this matter on August 3, 2005, with the following individuals in attendance: The Father, Steven Flay Brown, with his counsel, Mark F. Bayley, Esquire and the Mother, Alicia Rene (Brown) Rininger, with her counsel, Jessica Diamondstone, Esquire, Mid Penn Legal Services. 3. The Honorable Edward E. Guido entered Orders of Court dated January 20, 2005 and April 20, 2005. The Orders provided for shared legal and primary physical custody in Mother, with Father having alternating weekends and one overnight per week. 4. The parties agreed to the entry of an Order in the form as attached. -'? - 3 -1) ?- L?? A - V'("'? Date ac eline M. Verney, Esquire Custody Conciliator RECEIVED r7 1 "r' ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW STEVEN RAY BROWN, : NO. 2003-5877 CIVIL TERM Defendant/Petitioner IN CUSTODY ORDER OF COURT AND NOW, this 1 today of ' 49y? , 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: f 1. A Hearing is scheduled in Court Roo No. J , oft e Cumbgrlland County C Rurt House, on the *"'Or-day of , 200J_, at o'clock, A . M., at which time testimony will be taken. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. The prior Orders of Court dated January 20, 2005, April 20, 2005 and August 5, 2005 are hereby vacated. Pending further Order of Court or agreement of the parties, the following shall remain in effect: 3. The Father, Steven Ray Brown, and the Mother, Alicia Rene (Brown) Rininger shall have shared legal custody of Kyler Steven Brown, born December 8, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 4. Beginning Tuesday, October 18, 2005 the parties shall have shared physical custody of the child on a week on/week off basis. The exchange day and time shall be Sundays at 6:30 p.m. Father shall have the first week beginning October 18, 2005. 5. During each parent's period of custody they shall have the sole determination as to who provides day care or who baby sits for the child. 6. Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day shall be shared such that Father shall always have physical custody from 9:00 a.m. to 3:00 p.m. and Mother shall always have physical custody from 3:00 p.m. to 9:00 p.m. In addition, Father shall have custody of the child on trick or treat night from 6:00 p.m. to 8:00 p.m. 7. Mother and Father shall share custody around the child's birthday at mutually agreed upon times. 8. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. 9. Unless otherwise agreed, the parties shall share transportation such that custody exchanges shall occur at the Shippensburg police station. 10. The custodial parent shall arrange for the child to call the non-custodial parent on Wednesdays at 6:30 p.m. 11. Neither party may smoke in their homes or in their cars. 12. Neither parent shall permit contact between the child and the Oasis of Love Church or attend church functions. 13. Neither parent shall do or say or permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 14. The parties shall read the book "Mom's House, Dad's House: Making Two Homes for your Child." 15. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. Edward E. Guido, J. ccXIichael Finucane, Esquire, counsel for Father Zssica Holst, Esquire, counsel for Mother q? k: i .+ . , ., !J? i?^?. ALICIA RENE (BROWN) RININGER: IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. STEVEN RAY BROWN, Defendant/Petitioner : CIVIL ACTION - LAW : NO. 2003-5877 CIVIL TERM : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyler Steven Brown December 8, 2000 Mother 2. A Conciliation Conference was held October 17, 2005 with the following individuals in attendance: The Father, Steven Ray Brown, with his counsel, Michael Finucane, Esquire, and the Mother, Alicia Rene (Brown) Rininger, with her counsel, Jessica Holst, Esquire, Mid Penn Legal Services. 3. The Court previously entered Orders on January 20, 2005, April 20, 2005 and August 5, 2005 providing for shared legal custody, Mother having primary physical custody and Father having 5 overnights out of 14. 4. Father's position on custody is as follows: Father seeks shared legal and primary physical custody with Mother having alternating weekends. Father maintains that the child is more stable and happier when in his care. Father will assure the child attends Head Start and will enroll him in other positive activities. Father claims he is more likely to be generous in encouraging custodial time with Mother. 5. Mother's position on custody is as follows: Mother seeks shared legal custody and primary physical custody with Father maintaining the status quo of 5 overnights every 14 days. Mother alleges Father has a history of physical abuse against her. She also alleges that Father has been investigated by Children & Youth for child abuse. She also maintains that the child does not spend his custodial time with Father, but with the paternal grandmother or Father's girlfriend. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and granting the parents shared legal custody and shared physical custody on a week on/week off basis. It is expected that the Hearing will require one day. /r C -S- Date acq line M. Verney, Esquire Custody Conciliator ALICIA RENE (BROWN) RININGER, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2003-5877 CIVIL TERM STEVEN RAY BROWN, Defendant/Petitioner IN CUSTODY ORDER OF COURT AND NOW, this 21st day of November, 2005, after hearing, we enter the following order, which shall replace all prior Orders: 1. The Father, Steven Ray Brown, and the Mother, Alicia Rene (Brown) Rininger, shall have shared legal custody of Kyler Steven Brown, born December 8, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the chid's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. The parties shall continue the shared physical custody of the child on a week on/week off basis, with the exchange date and time being Sundays at 6:30 p.m. Unless otherwise ordered by this Court or agreed upon in writing by the parties, Mother's address shall be the primary residence of the child for purposes of enrolling him in school. Father shall see that the child gets to and from school during his week of physical custody. 3. During each parent's period of custody they shall have the sole determination as to who provides day care or who baby-sits for the child. 9. Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day shall be shared such that Father shall always have physical custody from 9:00 a.m. to 3:00 p.m. and Mother shall always have physical custody from 3:00 p.m. to 9:00 p.m. 7 In addition, Father shall have custody of the child on trick or treat night from 6:00 p.m. to 8:30 p.m. 5. Mother and Father shall share custody around the child's birthday at mutually agreed upon times. 6. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. 7. Unless otherwise agreed, the parties shall share transportation such that custody exchanges shall occur at the Shippensburg police station. 8. Mother shall provide Father with a phone number, including her cell phone, where she can be reached in times of emergency. No calls shall be made by Father to that phone number except in an emergency situation or as provided below. 9. The custodial parent shall arrange for the child to call the non-custodial parent on Mondays and Wednesdays at 8:30 p.m. Further, the custodial parent shall write the non-custodial parent at least one letter per week sharing something that occurred in the life of the child during his or her week of custody. These letters shall be not less than one page in length and shall be saved to be presented as exhibits in any future custody hearing. 10. Neither party may smoke in their homes or in their cars when the child is present. 11. Neither parent shall permit contact between the child and the Oasis of Love Church or attend church functions. 12. Neither parent shall do or say or permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 13. Mother shall cooperate with the Head Start program so as to assure the child's participation during her weeks of custody. 14. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. Edward E. Guido, J. Michael Finucane, Esquire Attorney for Defendant/Petitioner Jessica Holst, Esquire Attorney for Plaintiff/Respondent srs ?S `il?:j ?:V 71rq 1?.??? ?.'t?. -??f i ALICIA (BROWN) RININGER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2003-5877 STEVEN RAY BROWN, Defendant : Civil Action - Custody DEFENDANT STEVEN RAY BROWN'S PETITION TO MODIFY CUSTODY 1. Petitioner Steven Ray Brown who resides at 7001 Old Scotland Road, Shippensburg, Franklin County, Pennsylvania. 2. Respondent is Alicia Brown Rininger, whose last known address is 154 SME, Shippensburg, Cumberland County, Pennsylvania. 3. On November 21, 2005 the Honorable Judge Edward E. Guido entered a custody Order, attached hereto as "Exhibit A" and incorporated herein by reference thereto. 4. Since the entry of the Order there has been significant changes in circumstances in that: (a) mother voluntarily delivered the child into the father's full-time custody one week after the entry of that Order, (b) since November 28, 2005, the child has been continuously living with the father, (c) mother is prohibited from having the child at her home or while her husband is there because of his parole conditions. (d) Steven Brown took steps to adjust this child's support order based on this change of circumstances. (e) The Honorable Judge Carol L. Van Hom, a Franklin County Judge, in response to that request to change the support order by Steven Brown, has stated the child is to remain with the father until it can be heard by the Cumberland County Court on a formal basis, which this Petition brings to the Court. (f) Father's home is the one stable home to raise the child on a primary physical custody basis. 5. The best interest of the child will be served by the Court modifying said Order to be shared legal custody and primary physical custody in the father. WHEREFORE, Petitioner Steven Ray Brown respectfully prays the Honorable Court find it in the best interest of the child to make the necessary change to the current custody Order to render primary physical custody to the father and partial physical custody to the mother, with the same not to be exercised overnight in the presence of mother's husband. Respectfully Submitted, Date: 5` 3 v 6 ?--??_? MICHAEL B. FINUCA ESQUIRE Attorney for Defendant/Petitioner 14 N. Main Street, Suite 500 Chambersburg, PA 17201 717-264-1400 Attorney No. 23543 VERIFICATION I verify that the statements set forth in this Petition to Modify Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, which relates to unsworn falsifications to authorities. Date: 3 c, / / `Steven R. Brown, Defendant/Petitioner ALICIA RENE (BROWN) RININGER, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2003-5877 CIVIL TERM STEVEN RAY BROWN, Defendant/Petitioner IN CUSTODY ORDER OF COURT AND NOW, this 21st day of November, 2005, after hearing, we enter the following Order, which shall replace all prior Orders: 1. The Father, Steven Ray Brown, and the Mother, Alicia Rene (Brown) Rininger, shall have shared legal custody of Kyler Steven Brown, born December 8, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the chid's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. The parties shall continue the shared physical custody of the child on a week on/week off basis, with the exchange date and time being Sundays at 6:30 p.m. Unless otherwise ordered by this Court or agreed upon in writing by the parties, Mother's address shall be the primary residence of the child for purposes of enrolling him in school. Father shall see that the child gets to and from school during his week of physical custody. 3. During each parent's period of custody they shall have the sole determination as to who provides day care or who baby-sits for the child. 4. Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day shall be shared such that Father shall always have physical custody from 9:00 a.m. to 3:00 p.m. and Mother shall always have physical custody from 3:00 p.m. to 9:00 p.m. In addition, Father shall have custody of the child on trick or treat night from 6:00 p.m. to 8:30 p.m. 5. Mother and Father shall share custody around the child's birthday at mutually agreed upon times. 6. Christmas shall be divided into two Blocks. Block A shall be from Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. 7. Unless otherwise agreed, the parties shall share transportation such that custody exchanges shall occur at the Shippensburg police station. 8. Mother shall provide Father with a phone number, including her cell phone, where she can be reached in times of emergency. No calls shall be made by Father to that phone number except in an emergency situation or as provided below. 9. The custodial parent shall arrange for the child to call the non-custodial parent on Mondays and Wednesdays at 8:30 p.m. Further, the custodial parent shall write the non-custodial parent at least one letter per week sharing something that occurred in the life of the child during his or her week of custody. These letters shall be not less than one page in length and shall be saved to be presented as exhibits in any future custody hearing. 10. Neither party may smoke in their homes or in their cars when the child is present. 11. Neither parent shall permit contact between the child and the Oasis of Love Church or attend church functions. 12. Neither parent shall do or say or permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 13. Mother shall cooperate with the Head Start program so as to assure the child's participation during her weeks of custody. 14. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. Edward E. Guido, J. tt ehaei Finucane, Esquire orney for Defendant/Petitioner Jessica Holst, Esquire Attorney for Plaintiff/Respondent srs ??a y a cad!z a,P& 12 L LILC h? C ?? ? ?f T^ (. . - ? , a s ? --? ? ?-_ ALICIA (BROWN) RININGER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-5877 CIVIL ACTION LAW STEVEN RAY BROWN DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, April 07, 2006 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland Coup Courthouse, Carlisle on Thursday, May 04,_2006 - at 8:30 Aryt for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ /acqueGne M. Verney, 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 schedules 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 ???`:_' F ??? ?> ??_? ?? (? ' l C. ?' MAY 0 6 2006 i ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMO ALA Mr= Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW STEVEN RAY BROWN, : NO. 2003-5877 CIVIL TERM Defendant/Petitioner IN CUSTODY ORDER OF COURT AND NOW, this 14 day of /" , 2006, upon consideration of the attached Custody Conciliation A port, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. .3 , of the Cumberland County Court House, on the day of , 2006, at ,"de A -*i o'clock, _. M., at which time testimony will b en. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party or a pro se litigant shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. The prior Order of Court dated November 21, 2005 shall remain in full force and effect with the following modifications. 3. Mother shall have physical custody of the child from Friday, May 5, 2006 at 6:30 p.m. to Sunday, May 7, 2006 at 6:30 p.m. Thereafter the parties will revert to the week on/week off schedule with Father's week beginning at 6:30 p.m. Sunday, May 7, 2006. 4. During Mother's week of physical custody, she shall insure that the child attend baseball practices every Tuesday and Thursday from 6:15 p.m. to 8:00 p.m. Further, once baseball games are scheduled, she shall insure that the child attends his baseball games. Mother shall deliver him to the field slightly earlier than scheduled so he may change into his uniform. In the event that Mother violates this portion of the Order, primary physical custody shall revert to Father and Mother will have physical custody of the child on alternating weekends, Friday at 6:30 p.m. to Sunday at 6:30 p.m. 5. The child is to have no contact with stepfather. In the event that step- father is released from rehab, Mother shall exercise her week of physical custody either at her home, excluding step-father from the residence or at a friend's residence. In the event that it is at a friend's residence, Mother shall provide Father with the name, telephone number and address where the child is staying. 6. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. ccV chael Finucane, Esquire, counsel for Father (Alicia Rene (Brown) Rininger, pro se 154 SME Shippensburg, PA 17257 A )?D Edward E. Guido, J. D ? W VIN'S -USN"Ad kNrlt SC _C Wd 6- AN 900Z AtfVIMH .Ou dQ 3301 .' ALICIA RENE (BROWN) RININGER, Now ALICIA RENE GUYER, Plaintiff vs. STEVEN RAY BROWN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2003-5877 Civil Action - Custody STIPULATION AND AGREEMENT ON CUSTODY This Stipulation and Agreement on Custody is made this /8 day of m a , 2006 by and between Steven Ray Brown, father, and Alicia Rene Guyer, formerly Alicia Rene (Brown) Rininger, the mother. 1. Steven R. Brown and Alicia Rininger Guyer are the natural parents of Kyler Steven Brown, born December 8, 2000. 2. The parties are subject to a November 21, 2005 Order of Court by the Honorable Judge Edward E. Guido, as modified by a May 9, 2006 Order of Court, and by this Agreement, as allowed by the Judge's Order, wish to modify the Order by mutual agreement, and request an entry of the below-described Order of Court. 3. The parties specifically state their intention not to seek child support from the other. Steven Ray Brown specifically agrees not to seek child support while he has primary physical custody of their child, Kyler. 4. The parties have reached an agreement with regard to the custody of Kyler and desire to reduce their agreement to an Order of Court. 5. Alicia Rene Guyer acknowledges that Steven Ray Brown is represented by attorney Michael B. Finucane, and that attorney Michael B. Finucane does not represent her, and she is advised to seek independent counsel before signing this Agreement before an independent Notary Public. NOW THEREFORE, the parties intending to be legally bound hereby waive their right to be present when Michael B. Finucane, Esquire, attorney for Steven Ray Brown, presents this Agreement and Order to the Judge for signing. The parties hereby stipulate and agree that the Court may enter the following Order of Court in the above-captioned case: "ORDER OF COURT NOW this day of , 2006, after consideration of the within Stipulation and Agreement on Custody by the parties the Court enters the following Order, which shall replace all prior Orders: 1. The father, Steven Ray Brown, and the mother, Alicia Rene Guyer, formerly Alicia Rene (Brown) Rininger, shall have shared legal custody of their child, Kyler Steven Brown, born December 8, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being, including but not limited to, all decisions regarding his health, education, and religion. 2. Father shall have primary physical custody of Kyler Steven Brown at all times, except when Kyler is in the partial physical custody of his mother according to the following schedule: a. Alternate weekends from Thursday at 6:30 p.m. until Sunday at 6:30 p.m., commencing with Thursday, May 18, 2006, and alternate Thursdays thereafter. b. Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day shall be shared such that father shall always have physical custody from 9 a.m. until 3 p.m., and mother shall always have physical custody from 3 p.m. to 9 p.m. In addition, father shall have custody of the child on trick or treat night from 6 p.m. to 8:30 p.m. c. Mother and father shall share custody around the child's birthday at mutually agreed upon times. d. Christmas shall be divided into two blocks: Block A shall be from Christmas Eve at 12 noon until Christmas D% at 12 noon, and Block B shall be from Christmas Day at 12 noon until December 26 at 12 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. e. Both father and Mother shall each have up to two weeks of vacation with Kyler each summer. The first parent to notify the other parent in writing of a chosen week shall have priority for that week. 3. During mother's time of physical custody she shall insure that the child attends his baseball practices and games. Mother shall deliver him to the field slightly earlier than scheduled so he may change into his uniform. 4. The child is to have no contact with his stepfather, David Guyer. In the event that stepfather is released from rehab, mother shall exercise her time of physical custody either at her home, excluding step-father from the residence, or at a friend's residence. In the event that it is at a friend's residence, mother shall provide father with the name, telephone number and address where the child is staying. 5. Unless otherwise agreed, the parties shall share transportation such that custody exchanges shall occur at the Shippensburg police station. 6. Mother shall provide father with a phone number, including her cell phone, where she can be reached in times of emergency. 7. Neither party may smoke in their homes or in their cars when the child is present. 8. Neither parent shall permit contact between the child and the Oasis of Love Church or attend that church's functions. 9. Neither parent shall do or say or permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 10. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. 11. The costs in this proceeding have been paid by the defendant. BY THE COURT: J." IN WITNESS WHEREOF, the parties, intending to be bound by the terms and conditions of this Agreement, execute this Agreement by signing below. WITNESS: 11(19 A(1 _ " 1 ?i_ Gb STEVEN RAY BROWN (date) • _ 3 ?42(/0P ALICIA RENE GU R (date) STATE OF PENNSYLVANIA ) ( SS: COUNTY OF FRANKLIN ) On this day of 2006, before me, a Notary Public, the undersigned officer, personal y appeared the above named Steven Ray Brown, known to me or satisfactorily proven to be the person whose name is in this Agreement, and acknowledged the foregoing Stipulation and Agreement on Custody to be his act and deed and desired the same to-be recorded as such. Witness my hand seal the and year aforesaid. ARY PUBLIC COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL PAMELA A. SWITALSKI, Notary Pubic Shippensburg Twp., CumbWand County My Commission Fxdres Feb. 9, 2008 STATE OF PENNSYLVANIA ) ( SS: COUNTY OF FRANKLIN ) On this day of Ma- , 2006, before me, a Notary Public, the undersigned officer, personal) appeared the above named Alicia Rene Guyer, formerly Alicia Rene (Brown) Rininger, known to me or satisfactorily proven to be the person whose name is in this Agreement, and acknowledged the foregoing Stipulation and Agreement on Custody to be her act and deed and desired the same to be recorded as such. / - .. -'N Witness my hand seal the d#y/and year aforesaid. NOTARY PUBLI COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL EShippensburg SWITALSKI, Notary Pubic Twp., CLIMberiand County ssion Emires Feb. 9, 2008 cj - TI ^r' r= ? s l- F r r ? ALICIA RENE (BROWN) RININGER, : IN THE COURT OF COMMON Now ALICIA RENE GUYER, : PLEAS CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA vs. : No. 2003-5877 STEVEN RAY BROWN, Defendant : Civil Action - Custody ORDER OF COURT NOW this OXA day Anr , 2006, after consideration of the within Stipulation and Agreement on Custody by the parties the Court enters the following Order, which shall replace all prior Orders: 1. The father, Steven Ray Brown, and the mother, Alicia Rene Guyer, formerly Alicia Rene (Brown) Rininger, shall have shared legal custody of their child, Kyler Steven Brown, born December 8, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being, including but not limited to, all decisions regarding his health, education, and religion. 2. Father shall have primary physical custody of Kyler Steven Brown at all times, except when Kyler is in the partial physical custody of his mother according to the following schedule: a. Alternate weekends from Thursday at 6:30 p.m. until Sunday at 6:30 p.m., commencing with Thursday, May 18, 2006, and alternate Thursdays thereafter. b. Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day shall be shared such that father shall always have physical custody from 9 a.m. until 3 p.m., and mother shall always have physical custody from 3 p.m. to 9 p.m. In addition, father shall have custody of the child on trick or treat night from 6 p.m. to 8:30 p.m. c. Mother and father shall share custody around the child's birthday at mutually agreed upon times. d. Christmas shall be divided into two blocks: Block A shall be from Christmas Eve at 12 noon until Christmas Dar at 12 noon, and Block B shall be from Christmas Day at 12 noon until December 26 at 12 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. A. Guyer vs. S. Brown Custody; 2003-5877 Page Two e. Both father and Mother shall each have up to two weeks of vacation with Kyler each summer. The first parent to notify the other parent in writing of a chosen week shall have priority for that week. 3. During mother's time of physical custody she shall insure that the child attends his baseball practices and games. Mother shall deliver him to the field slightly earlier than scheduled so he may change into his uniform. 4. The child is to have no contact with his stepfather, David Guyer. In the event that stepfather is released from rehab, mother shall exercise her time of physical custody either at her home, excluding step-father from the residence, or at a friend's residence. In the event that it is at a friend's residence, mother shall provide father with the name, telephone number and address where the child is staying. 5. Unless otherwise agreed, the parties shall share transportation such that custody exchanges shall occur at the Shippensburg police station. 6. Mother shall provide father with a phone number, including her cell phone, where she can be reached in times of emergency. 7. Neither party may smoke in their homes or in their cars when the child is present. 8. Neither parent shall permit contact between the child and the Oasis of Love Church or attend that church's functions. 9. Neither parent shall do or say or permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 10. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. oh The costs in this proceeofg have been paid by the defendant. BY J. Al r r 1? ) i ` i + 9Z ?vq NU 5Z :ol 3 41 Aa ?JF? - Alicia Rene (Brown) Rininger, : IN THE COURT OF COMMON PLEAS OF Now Alicia Rene Guyer : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION-LAW IN CONTEMPT Steven Ray Brown, Defendant : NO. 2003-5877 CIVIL TERM PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF PARTIAL CUSTODY ORDER The Petitioner, Alicia Rene Guyer, by counsel, hereby brings this Petition for Civil Contempt, and respectfully requests that this Court find Defendant/Respondent, Steven R. Brown, in contempt of the May 26, 2006 Court Order. In support thereof, Petitioner states as follows: 1. The petitioner is Alicia Rene Guyer ("Mother"), an adult individual who resides at 43 %2 West King Street, Apartment #2, Shippensburg, Pennsylvania 17257. 2. The respondent is Steven Ray Brown ("Father"), an adult individual whose last known address is 7001 Old Scotland Road, Shippensburg, Pennsylvania 17257. 3. The parties are the natural parents of Kyler Brown, born December 8, 2000, age 6 years. 4. The parties are subject to a Custody Order entered by Judge Guido on May 26, 2006, a copy of which is attached to this Petition. 5. Since May 2006, Father has refused to deliver the child to Mother at the required times in accordance with paragraph 2(a) of the Order. 6. Father refused to share the Easter holiday, Fourth of July and Labor Day with Mother, in accordance with paragraph 2(b) of the Order. 7. Father refused to share custody around the child's birthday with Mother, in accordance with paragraph 2(c) of the Order. 8. Father refused to share the Christmas holiday with Mother in accordance with paragraph 2(d) of the Order. 9. Father refused to allow Mother to have any vacation time with her child during the summer of 2006, in accordance to paragraph 2(e) of the Order. 10. Mother has a strong desire to maintain a relationship with her child and Father's refusal to comply with the Custody Order has interfered with mother's ability to maintain this relationship. 11. Mother seeks enforcement of her custody rights to her child in strict compliance with the existing Custody Order. 12. Mother's counsel has made repeated efforts to contact Michael Finucane, Father's counsel, seeking concurrence in the relief requested in this petition. Mother's counsel received no response from Mr. Finucane. WHEREFORE, Petitioner requests that: a. Father be held in contempt of the Court's Order of Custody; b. Father be ordered to comply with the May, 26, 2006 Order; C. Mother be awarded additional custody time to compensate for the wrongful deprivation of custodial time; d. Mother be awarded such other relief as the Court deems appropriate. Respectfully submitted, Date: SCOTT WEBER Certified Legal Intern THO . PLACE ROBERT . RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 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. C?.. -? (C Alicia Rene Guyer Petitioner Alicia Rene (Brown) Rininger, Now Alicia Rene Guyer Plaintiff V. Steven Ray Brown, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CONTEMPT : NO. 2003-5877 CIVIL TERM CERTIFICATE OF SERVICE I, Scott Weber , hereby certify that I am serving a true and correct copy of the petition for Civil Contempt for Disobedience of Partial Custody Order and sanctions under 23 Pa.C.S. § 4346 on Michael Finucane, Esquire, 14 N. Main Street, Suite 500, Chambersburg, PA 17201, by first class US mail, postage paid. Date: SCOTT WEBER Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ALICIA RENE (BROWN) RININGER, : IN THE COURT OF COMMON Now ALICIA RENE GUYER, : PLEAS CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA vs. : No. 2003-5877 STEVEN RAY BROWN, Defendant : Civil Action - Custody ORDER OF COURT NOW this rX day o , 2006, after consideration of the within Stipulation and Agreement on Custody by the parties the Court enters the following Order, which shall replace all prior Orders: 1. The father, Steven Ray Brown, and the mother, Alicia Rene Guyer, formerly Alicia Rene (Brown) Rininger, shall have shared legal custody of their child, Kyler Steven Brown, born December 8, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being, including but not limited to, all decisions regarding his health, education, and religion. 2. Father shall have primary physical custody of Kyler Steven Brown at all times, except when Kyler is in the partial physical custody of his mother according to the following schedule: a. Alternate weekends from Thursday at 6:30 p.m. until Sunday at 6:30 p.m., commencing with Thursday, May 18, 2006, and alternate Thursdays thereafter. b. Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day shall be shared such that father shall always have physical custody from 9 a.m. until 3 p.m., and mother shall always have physical custody from 3 p.m. to 9 p.m. In addition, father shall have custody of the child on trick or treat night from 6 p.m. to 8:30 p.m. c. Mother and father shall share custody around the child's birthday at mutually agreed upon times. d. Christmas shall be divided into two blocks: Block A shall be from Christmas Eve at 12 noon until Christmas Dar at 12 noon, and Block B shall be from Christmas Day at 12 noon until December 26 at 12 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. A. Guyer vs. S. Brown Custody; 2003-5877 Page Two e. Both father and Mother shall each have up to two weeks of vacation with Kyler each summer. The first parent to notify the other parent in writing of a chosen week shall have priority for that week. 3. During mother's time of physical custody she shall insure that the child attends his baseball practices and games. Mother shall deliver him to the field slightly earlier than scheduled so he may change into his uniform. 4. The child is to have no contact with his stepfather, David Guyer. In the event that stepfather is released from rehab, mother shall exercise her time of physical custody either at her home, excluding step-father from the residence, or at a friend's residence. In the event that it is at a friend's residence, mother shall provide father with the name, telephone number and address where the child is staying. 5. Unless otherwise agreed, the parties shall share transportation such that custody exchanges shall occur at the Shippensburg police station. 6. Mother shall provide father with a phone number, including her cell phone, where she can be reached in times of emergency. 7. Neither party may smoke in their homes or in their cars when the child is present. 8. Neither parent shall permit contact between the child and the Oasis of Love Church or attend that church's functions. 9. Neither parent shall do or say or permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 10. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. The costs in this procee Kg have been ppid by the defendant. BY DIP J. 1AQR 0 p 200 Alicia Rene (Brown) Rininger, : IN THE COURT OF COMMON PLEAS OF Now Alicia Rene Guyer : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION - LAW IN CUSTODY Steve Ray Brown Defendant NO. 2003-5877 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Ms. Alicia Rene Guyer, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date d Respectfully submitted, _ i"'r'A Wj'-U Scott Weber Certified Legal Intern ROBER S THOMAS . PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ?-. ? r-? ?- rv , ?? a'- 1 r _',i° ^. °,, .? ? ? ?' ALICIA RENE (BROWN) RININGER, NOW IN THE COURT OF COMMON PLEAS OF ALICIA RENE GUYER PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. STEVEN RAY BROWN DEFENDANT 03-5877 CIVIL ACTION LAW IN CUSTODY . ORDER OF COURT AND NOW, _ Wednesday, April 11, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, May 03, 2007 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children ague 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ac ueline M. Verne 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 141k? 44? 81 :u ?'I,] z I C;'V LOOZ Alicia Rene (Brown) Rininger, : IN THE COURT OF COMMON PLEAS OF Now Alicia Rene Guyer : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION-LAW IN CONTEMPT Steven Ray Brown, Defendant : NO. 2003-5877 CIVIL TERM CERTIFICATE OF SERVICE I, Scott Weber, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Civil Contempt for Disobedience of Partial Custody Order on Michael Finucane, Esq., attorney for Steven R. Brown, whose office is at 14 North Main Street, Suite 500, Chambersburg, PA, 17201, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Michael Finucane, on the the 6'h day of April, 2007 as evidenced by the attached green card. Scott Weber Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 'et ? ? -- T r }yam J ^ - - ^? T_II r ? -? - ? rn CID j ¦ 039006 % wo 1.2, amts:`mw Run 4 It Fl- h A I I d D*-WY b dttn' ` ¦ yauR nrno wW addr?M on Ow mown wra can rrotum go owd to ye a. ¦ Aft* this ow d to #w bwk of to MdOGM or an 1M *OM M opme p¦enha. a. **ft Ad*ommod to: 0 Ao" 0. Isddlwiy eddM dtlM?IR * m ftm t4 p lAn k Yja wdw d *my NW*o blow: O No G?,t?, Sod o Pip C'140?mhZ?? 0 ior mwdwAxfte 4. PAWCtsd Ds6veryt (E%" Fes, ?Ilu Yes 2• Ardcq 7005 0390 0003 2632 5515 PS Form 3811, Fabnirr 2004 DonwMlo Mo.t1? _? 102595-02-M-1540 ALICIA RENE (BROWN) RININGER, Now ALICIA RENE GUYER, Plaintiff vs. STEVEN RAY BROWN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2003-5877 Civil Action - Custody STEVEN RAY BROWN'S ANSWER TO PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF PARTIAL CUSTODY ORDER NOW COMES Steven Ray Brown, defendant in the above-captioned custody matter, and respectfully answers the Petition for Civil Contempt as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Denied. Father has not refused to deliver the child, but Mother has usually not appeared or has not called. She rarely has attempted to see or call her child. 6. Denied. Father has not refused to share these holidays, but has rather found that mother has a routine of not appearing for her partial custody periods. WHEREFORE, defendant/respondent Steven Ray Brown respectfully requests this Honorable Court dismiss petitioner's Petition for Civil Contempt for the reason that Respondent has complied with the Order of Court. Respectfully Submitted: Date: `?• i -2 - 01 MICHAEL B. FINUCAN SQUIRE Attorney for Defendant/Respondent 14 N. Main Street, Suite 500 Chambersburg, PA 17201 717-264-1400 Attorney No. 23543 VERIFICATION I verify that the statements set forth in this Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, which relates to unsworn falsifications to authorities. q-1-7- 0-7 ?e- Date: STEVEN RAY BROWN Defendant/Respondent ?-.> t } r_?.. ? {.?. ? `rl ` T __ ?: ? ^ f 7 ? ?? ? Y -- - 1 ?''? -... ?+? ; 1 1 i ?# 4 `t ..nY? __ n-n..v '?"l?t ?? ' __ ? ?a 7 . ? "`` MAY 0 4 2007 IX V N ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Now ALICIA RENE GUYER, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO. 2003-5877 CIVIL TERM STEVEN RAY BROWN, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 1) A- day of f9 , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated May 26, 2006 shall remain in full force and effect and strictly adhered to with the following additions: 2. Neither party may consume alcohol to the point of intoxication or illegal or non-prescribed drugs prior to or during their periods of custody. 3. The parties shall enjoy reasonable telephone contact with the child between 6:00 p.m. and 7:00 p.m. 4. This Order is entered pursuant to an agreement of the parties at 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. Another Conciliation Conference is scheduled for June 7, 2007 at 8:30 a.m. cc: ott Weber, certified legal intern, Thomas Place, Esquire, Family Law Clinic, Counsel for Mother ael Finucane, Esquire, Counsel for Father , Edward E. Guido, k ?Vj no LS 0 W,4 9- LODZ A 'G'E t .. :.°w 71HI dO ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Now ALICIA RENE GUYER, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. :2003-5877 CIVIL TERM STEVEN RAY BROWN, : CIVIL ACTION - LAW Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyler Steven Brown December 8, 2000 Mother 2. A Conciliation Conference was held in this matter on May 3, 2007, with the following individuals in attendance: The Mother, Alicia Rene (Brown) Rininger, Now Alicia Rne Guyer, with her counsel, Scott Weber, certified legal intern and Thomas Place, Esquire, Family Law Clinic and the Father, Steven Ray Brown, with his counsel, Michael Finucane, Esquire. 3. The Honorable Edward E. Guido entered an Order of Court dated May 26, 2006, providing for shared legal custody, with Father having primary physical custody and Mother having alternating weekends Thursday to Sunday. 4. The parties agreed to the entry of an Order in the form as attached. s -0 7 /fit Date ac line M. Verney, Esquire Custody Conciliator JUNE 12007p'` kLIC RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Now AOCIA RENE GUYER : CUMBERLAND COUNTY, PENNSYLVANIA 1 Plaintiff V. : NO. 2003-5877 CIVIL ACTION - LAW STEVEN RAY BROWN, Defendant : IN CUSTODY ORDER OF COURT ND NOW, this day of , 2007, upon consider tion of the attached Custody Con liation Report, it is ordered and directed as follows. The prior Orders of Court dated May 26, 2006 and May 17, 2007 are hereby 2. ? Mother hereby withdraws her Petition for Contempt. 3. The Mother, Alicia Rene Guyer and the Father, Steven Ray Brown, shall have shay d legal custody of Kyler Steven Brown, born December 8, 2000. Each parent shall hav an equal right, to be exercised jointly with the other parent, to make all major non-emer ency decisions affecting the Child's general well-being including, but not limited to all decisions regarding his health, education and religion. Pursuant to the terms of 2 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, a residence address of the child and the other parent. To the extent one parent has posses ion of any such records or information, that parent shall be required to share the same, r copies thereof, with the other parent within such reasonable time as to make the record and information of reasonable use to the other parent. Both parents shall be entitled to 11 participation in all educational and medical/treatment planning meetings and evalua ions with regard to the minor child. Each parent shall be entitled to full and complete i formation from any physician, dentist, teacher or authority and copies of any reports giv n to them as parents including, but not limited to: medical records, birth certificates school or educational attendance records or report cards. Additionally, each parent shal be entitled to receive copies of any notices which come from school with regard to s hool pictures, extracurricular activities, sports, children's parties, musical presentatio s, back-to-school nights, and the like. The parties shall cooperate with the child's counselor. 4. Father shall have primary physical custody of Kyler Steven Brown at all times, exce t when Kyler is in the partial physical custody of his mother according to the following s hedule: 1. a. During the summer, alternate weekends from Thursday at 6:30 p.m. until Sunday at 6:30 p.m. b. During the school year, alternate weekends from Friday at 4:00 p.m. to Sunday at 6:30 p.m. c. During the school year, one evening per week from 4:00 p.m. to 7:00 p.m., provided Mother gives Father notice of which evening by the preceding Sunday. d. Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day shall be shared such that Father shall always have physical custody from 9:00 a.m. to 3:00 p.m., and Mother shall always have physical custody from 3:00 p.m. to 9:00 p.m. In addition, Father shall have custody of the child on trick or treat night from 6:00 p.m. to 8:30 p.m. e. Mother and Father shall share custody around the child's birthday at mutually agreed upon times. f. Christmas shall be divided into two blocks: Block A shall be from Christmas Eve at 12 noon until Christmas Day at 12 noon, and Block B shall be from Christmas Day at 12 noon to December 26 at 12 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. g. Both Father and Mother shall each have up to two weeks of vacation with Kyler each summer. The first parent to notify the other parent in writing of a chosen week shall have priority for that week. attends earlier 5. During Mother's time of physical custody she shall insure that the child baseball practices and games. Mother shall deliver him to the field slightly scheduled so he may change into his uniform. 6. The child is to have no contact with his stepfather, David Guyer. In the event that tepfather is released from rehab, Mother shall exercise her time of physical custody at er home, excluding stepfather from the residence, or at a friend's residence. In the eve t that it is at a friend's residence, Mother shall provide Father with the name, telephone umber and address where the child is staying. 7. Unless otherwise agreed, the parties shall share transportation such that custody ex hanges shall occur at the Shippensburg police station. 8. ? Mother shall provide Father with a phone number, including her cell phone, wh e she can be reached in times of emergency. 9. I Neither party may smoke in their homes or in their cars when the child is present. 10. Neither party shall permit contact between the child and the Oasis of Love Church or attend that church's functions. a 11. Neither parent shall do or say or permit a third party to do or say anything that ma estrange the child from the other parent, injure the opinion of the child as to the other p ent, or hamper the free and natural development of the child's love and respect for the other parent. or non-pre 1 between consent. Neither party may consume alcohol to the point of intoxication or illegal 1. c ConciliaIi )ed drugs prior to or during their periods of custody. The parties shall enjoy reasonable telephone contact with the child p.m. and 7:00 p.m. This Order is entered pursuant to an agreement of the parties at a Custody i Conference. The parties may modify the provisions of this Order by mutual the absence of mutual consent, the terms of this Order shall control. B Edward E. Guido, J. cc olly aughn, certified legal intern, Anne MacDonald-Fox, Esquire, Family Law sic, Counsel for Mother Finucane, Esquire, C J --VT ii 1 1 :6 WV 9Z NOC LGGZ AkM QNO iOW 3Hi 30 30H X3113 . ALIC RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Now A ICIA RENE GUYER : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . V. :2003-5877 CIVIL ACTION - LAW RAY BROWN, Defendant : IN CUSTODY PRIOR I,jUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL URE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. P The pertinent information concerning the Child who is the subject of this litigation i as follows: Kyler Steven Brown DATE OF BIRTH CURRENTLY IN CUSTODY OF December 8, 2000 Father 2. A Conciliation Conference was held in this matter on June 21, 2007, with the followi g individuals in attendance: The Mother, Alicia Rene Guyer, with her counsel, H lly Vaughn, certified legal intern, Anne MacDonald-Fox, Esquire, Family Law Clinic and the Father, Steven Ray Brown, with his counsel, Michael Finucane, Esquire. 3. The Honorable Edward E. Guido previously entered Orders of Court dated May 26, 20 6 and May 17, 2007, providing for shared legal custody, Father having primary ph sical custody, with Mother having alternating weekends. 4. Mother filed a Petition for Contempt. 5. The parties agreed to the entry of an Order in the form as attached. Date ac eline M. Verney, Esquire Custody Conciliator Alicia Rene (Brown) Rininger, : IN THE COURT OF COMMON PLEAS OF Now Alicia Rene Guyer : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION-LAW IN CONTEMPT Steven Ray Brown, Defendant : NO, 2003-5877 CIVIL TERM PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY ORDER The Petitioner, Alicia Rene Rininger, by counsel, hereby brings this Petition for Civil Contempt, and respectfully requests that this Court find Defendant/Respondent, Steven R. Brown, in contempt of the June 25, 2007 Court Order. In support thereof, Petitioner states as follows: 1. The petitioner is Alicia Rene Rininger ("Mother"), an adult individual who resides at 43 %2 West King Street, Apartment #2, Shippensburg, Pennsylvania 17257. 2. The respondent is Steven Ray Brown ("Father"), an adult individual whose last known address is 7001 Old Scotland Road, Shippensburg, Pennsylvania 17257. 3. The parties are the natural parents of Kyler Brown, born December 8, 2000, age 6 years. 4. On June 25, 2007, the Honorable Edward Guido entered an Order awarding Mother partial physical custody of the minor child Kyler. That Order was the negotiated result of Mother's prior Contempt Petition against Father. A true and correct copy of the order is attached to this petition. 5. Father has willfully failed to abide by the Order in that he has engaged in a course of conduct that interferes with Mother's periods of partial custody. This includes not bringing Kyler to the exchange location without explanation, setting up fun activities with Kyler on Mother's weekends and speaking ill of Mother in front of the child. 6. On July 7, 2007, Father denied Mother her weekend with her son in violation. of paragraph 4a of the Order. Father gave no explanation why he denied her this weekend. 7. On August 3, 2007, Father denied Mother her weekend with her son in violation of paragraph 4a of the Order. Father did not answer any phone calls Mother made during that weekend. 8. On August 12, 2007, Kyler telephoned Mother asking her if he could go camping with his Father instead of spending the weekend with her as he was scheduled to do. Father refused to speak to Mother about working out any compromises for that weekend. During the weekend of August 18, 2007, Mother saw Kyler and Father with their camper at Father's house. 9. On September 9, 2007, while talking on the phone with Kyler, Mother heard Father telling Kyler that Mother was a "bitch" in violation of with paragraph 11 of the Order. 10. Kyler's counselor notified Mother that Father stopped sending Kyler to counseling without consulting Mother in violation of paragraph 3 of the Order 11. Father has consistently denied telephone contact between Mother and son during agreed upon times in violation of paragraph 13 of the Order, and Father has not given Kyler messages that his Mother leaves for him. 12. Mother has a strong desire to maintain a relationship with the child and Father's continued refusal to comply with any Custody Orders has interfered with Mother's ability to maintain this relationship. 13. Mother seeks enforcement of her custody rights to her child in strict compliance with the existing order. 14. As required by C.C.R.P. 208.2(d), concurrence of counsel was sought on September 24, 2007. The undersigned left a message for opposing counsel, Michael Finucane, Esquire seeking concurrence and requesting a response by September 26, 2007. At the time of filing, opposing counsel has not responded. WHEREFORE, Petitioner requests that: a. Father be held in contempt of the Court's Order of Custody of June 25, 2007 and be subject to all available punishments prescribed by 23 Pa C.S. Section 4346 which includes: (1) Imprisonment for a period not to exceed. six months, (2) a fine not to exceed $500, (3) probation for a period not to exceed six months and (4) an order for nonrenewal, suspension or denial of operating privileges; b. Mother be awarded additional custodal time to compensate for the wrongful deprivation of custodial time; C. Mother be awarded such other relief as the Court deems appropriate. Date: t' Respectfully s omitted, b SCOTT WEBER Certified Legal Intern THOMAS M. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 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 unworn falsification to authorities. Alicia Rene Rininger Petitioner Alicia Rene (Brown) Rininger, Now Alicia Rene Guyer Plaintiff V. Steven Ray Brown, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CONTEMPT NO. 2003-5877 CIVIL TERM CERTIFICATE OF SERVICE I, Scott Weber, hereby certify that I served a true and correct copy of the Petition for Civil Contempt for Disobedience of Custody Order on Michael Finucane, Esquire, 14 N. Main Street, Suite 500, Chambersburg, PA 17201, by first class US mail, postage paid. Date: , a- 4 SCOTT WEBER Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 JUN i! 1 LUU/ ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Now ALICIA RENE GUYER : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO. 2003-5877 CIVIL ACTION - LAW STEVEN RAY BROWN, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this XJ day of , 2007, upon consideration of the attached Custody Con liation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated May 26, 2006 and May 17, 2007 are hereby vacated. 2. Mother hereby withdraws her Petition for Contempt. 3. The Mother, Alicia Rene Guyer and the Father, Steven Ray Brown, shall have shared legal custody of Kyler Steven Brown, born December 8, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 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 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, sports, children's parties, musical presentations, back-to-school nights, and the like. The parties shall cooperate with the child's counselor. 4. Father shall have primary physical custody of Kyler Steven Brown at all times, except when Kyler is in the partial physical custody of his mother according to the following schedule: a. During the summer, alternate weekends from Thursday at 6:30 p.m. until Sunday at 6:30 p.m. b. During the school year, alternate weekends from Friday at 4:00 p.m. to Sunday at 6:30 p.m. c. During the school year, one evening per week from 4:00 p.m. to 7:00 p.m., provided Mother gives Father notice of which evening by the preceding Sunday. d. Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day shall be shared such that Father shall always have physical custody from 9:00 a.m. to 3:00 p.m., and Mother shall always have physical custody from 3:00 p.m. to 9:00 p.m. In addition, Father shall have custody of the child on trick or treat night from 6:00 p.m. to 8:30 p.m. e. Mother and Father shall share custody around the child's birthday at mutually agreed upon times. f. Christmas shall be divided into two blocks: Block A shall be from Christmas Eve at 12 noon until Christmas Day at 12 noon, and Block B shall be from Christmas Day at 12 noon to December 26 at 12 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. g. Both Father and Mother shall each have up to two weeks of vacation with Kyler each summer. The first parent to notify the other parent in writing of a chosen week shall have priority for that week. 5. During Mother's time of physical custody she shall insure that the child attends his baseball practices and games. Mother shall deliver him to the field slightly earlier than scheduled so he may change into his uniform. 6. The child is to have no contact with his stepfather, David Guyer. In the event that stepfather is released from rehab, Mother shall exercise her time of physical custody at her home, excluding stepfather from the residence, or at a friend's residence. In the event that it is at a friend's residence, Mother shall provide Father with the name, telephone number and address where the child is staying. 7. Unless otherwise agreed, the parties shall share transportation such that custody exchanges shall occur at the Shippensburg police station. 8. Mother shall provide Father with a phone number, including her cell phone, where she can be reached in times of emergency. 9. Neither parry may smoke in their homes or in their cars when the child is present. 10. Neither party shall permit contact between the child and the Oasis of Love Church or attend that church's functions. 11. Neither parent shall do or say or permit a third parry to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 12. Neither party may consume alcohol to the point of intoxication or illegal or non-prescribed drugs prior to or during their periods of custody. 13. The parties shall enjoy reasonable telephone contact with the child between 6:00 p.m. and 7:00 p.m. 14. This Order is entered pursuant to an agreement of the parties at 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. B Edward E. Guido, J. cc: Holly Vaughn, certified legal intern, Anne MacDonald-Fox, Esquire, Family Law Clinic, Counsel for Mother Michael Finucane, Esquire, Counsel for Father t'? ?`' r - r 7 "f'1 -..J ?` ri." ? ?.._ ? } ??r ?.. _ {'! h? ' ' .-? , C,.l ' •-G -- r ` Alicia Rene (Brown) Rininger, Now Alicia Rene Guyer Plaintiff V. Steve Ray Brown Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY : NO. 2003-5877 CIVIL, TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Ms. Alicia Rene Guyer, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date Scott Weber Certified Legal Intern ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 r-N ? v ~rt cn ! r y ,`7 r ALICIA RENE (BROWN) RININGER, NOW ALICIA RENE GUYER PLAINTIFF V. STEVEN RAY BROWN DEFENDANT IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA 2003-5877 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Friday, October 05, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, November 01, 2007 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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/ ac ueline M. Verne 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 infonnation 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 .a? o J 6 ? f r 1 Alicia Rene (Brown) Rininger, Now Alicia Rene Guyer Plaintiff V. Steven Ray Brown, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CONTEMPT NO. 2003-5877 CIVIL TERM CERTIFICATE OF SERVICE I, Scott Weber, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Petition for Civil Contempt for Disobedience of Custody Order on the attorney for Steven R. Brown, Michael Finucane, Esq., whose office is at 14 North Main Street, Suite 500, Chambersburg, PA, 17201, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Michael Finucane, Esq., on the 28th day of September, 2007 as evidenced by the attached green card. ??' j YV AW.rV Scott Weber Certified Legal Intern ¦ Complete items 1, 2, and 3. Also complete Item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so-that we can return the card to you. t Attach this card to the back of the mallpiece, or on the front If space permits. Article Addressed to: A i n u&&,u, Ej. 1 L/ Ma'`''y -6& loa;"j °a FA c hw???5' A. ? Agent B. Received by (Printed Name) C.,pate of Delivery D. Is delivery address different from Rem 11 V Yes If YES, enter delivery address below: )&No 3. Service Type JSCartlffed Mail 0 Express Mail ? Registered ,?7 Retum Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) ryes 2• Arta 7005 0390 0003 2632 5690 (rr,; Ps Form 3811, February 2004 Dorrmtlc Retum Receipt 102595-o2-M-1540 r. ? .- ? ? a : i _ ...a { ` ,,1 ?'; ?,3 t'w. -?, f,` ALICIA RENE (BROWN) RININGER, Now ALICIA RENE GUYER, Plaintiff/Petitioner vs. STEVEN RAY BROWN, Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2003-5877 Civil Action - Custody STEVEN RAY BROWN'S ANSWER TO PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF PARTIAL CUSTODY ORDER NOW COMES Steven Ray Brown, Respondent in the above-captioned custody matter, and respectfully answers the Petition for Civil Contempt as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Denied. Father has not engaged in a course of conduct interfering with Mother's periods of partial custody but rather has been frustrated by the frequency of her not exercising her scheduled weekends. There have been regular times that the child has not been brought to the exchanged location but that is because the mother has advised she is not having custody of the child for that weekend. Father does not specifically set up fun activities for Kyler when he knows he will be with his mother however Steven's family for example goes camping many weekends just a normal course of family conduct. Steven does 13. Admitted. Mother is apparently seeking enforcement. 14. Admitted. WHEREFORE, Respondent Steven Ray Brown respectfully requests this Honorable Court dismiss mother's Contempt Petition and find that he has properly complied with the existing custody order. Respectfully Submitted: Date: 1d12-410 ^? MICHAEL B. FI UCA , ESQUIRE Attorney for Defendant/Respondent 14 N. Main Street, Suite 500 Chambersburg, PA 17201 717-264-1400 Attorney No. 23543 ('1 Q c;:;) .; T,f r 21 - - .7 NOV 0 2 2007 O ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Now ALICIA RENE GUYER, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . V. : NO. 2003-5877 CIVIL TERM STEVEN RAY BROWN, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this 5 day of 0 relv?? , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated June 25, 2007 shall remain in full force and effect and strictly adhered to with the following additions: 2. The parties shall cooperate with a psychological evaluation for the child and follow any recommendations resulting therefrom. 3. Father shall provide the child's medical insurance card to opposing counsel for transmittal to Mother. 4. This Order is entered pursuant to an agreement of the parties at 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. Another Conciliation Conference is scheduled for January 3, 2008 at 10:30 a.m. cc::cott Weber, certified legal intern, Thomas Place, Esquire, Family Law Clinic, Coum )4ichael Finucane, Esquire, Counsel for Father k Edward E. Guido, J. `F ?-. ? ?L4t 1V} `? ' ft ! ? :8 W ??c'Z ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Now ALICIA RENE GUYER, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. STEVEN RAY BROWN, Defendant :2003-5877 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyler Steven Brown December 8, 2000 Father 2. A Conciliation Conference was held in this matter on November 1, 2007, with the following individuals in attendance: The Mother, Alicia Rene (Brown) Rininger, Now Alicia Rene Guyer, with her counsel, Scott Weber, certified legal intern and Thomas Place, Esquire, Family Law Clinic and the Father, Steven Ray Brown, with his counsel, Michael Finucane, Esquire. 3. The Honorable Edward E. Guido entered an Order of Court dated June 25, 2007, providing for shared legal custody, with Father having primary physical custody and Mother having alternating weekends. 4. Mother's Contempt allegations shall be held in abeyance. 5. The parties agreed to the entry of an Order in the form as attached. Date cq ine M. Verney, Esquire Custody Conciliator JAN 0 4 2008,4 ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Now ALICIA RENE GUYER, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. :2003-5877 CIVIL TERM STEVEN RAY BROWN, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of, yNN" , 2008, upon consideration of the attached Custody CoMiliation Report, it is ordered and directed as follows: 1. A Hearing is sched ed in Co%1 Room No. , of the Cumberland County Court House, on the 1 day of , 2008, at A :04 o'clock, M., at which time testimony will be taken. For purposes of this Hearing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Orders of Court dated June 25, 2007 and November 5, 2007 shall remain in full force and effect, with the following modifications. 3. Paragraph 4 b of the Order of Court of June 25, 2007 shall be amended to read: "During the school year, alternate weekends from Friday at 5:00 p.m. to Sunday at 7:00 p.m." 4. Paragraph 2 of the Order of Court dated November 5, 2007 is hereby deleted. 5. The parties shall cooperate in obtaining individual counseling for the child. 6. The parties shall explore the option of family counseling. 7. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. BY THE Edward E. cc: Scott Weber, certified legal intern, counsel for Mother Anne MacDonald-Fox, Esquire, Family Law Clinic Michael Finucane, Esquire, counsel for Father J. CoPI .-C-S mat LicL Nno Z 1 •6 WV 6- Or BON 1?t s a vv 3s 3Hi ?O ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Now ALICIA RENE GUYER, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. STEVEN RAY BROWN, Defendant :2003-5877 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the foilowing report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyler Steven Brown December 8, 2000 Father 2. A Conciliation Conference was held January 3, 2008 with the following individuals in attendance: Mother's counsel, Scott Weber, certified legal intern, Anne MacDonald-Fox, Esquire, Family Law Clinic and the Father, Steven Ray Brown, with his counsel, Michael Finucane, Esquire. 3. The Honorable Edward E. Guido previously entered Orders of Court dated June 25, 2007 and November 5, 2007 providing for shared legal custody, Father having primary physical custody and Mother having alternating weekends. 4. Mother's position on custody is as follows: Mother seeks a finding of contempt alleging Father has failed to transfer custody to mother in accord with the Order of Court. She seeks makeup time with the child. 5. Father's position on custody is as follows: Father denies the contempt allegations and asserts that he had an agreement with mother to deviate from the Order. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the status quo, with minor changes agreed to by the parties. It is expected that the Hearing will require one-half day. 1-3-08- Date 6Jae-iTn_e M. Verney, Esquire Custody Conciliator Alicia Rene (Brown) Rininger, : IN THE COURT OF COMMON PLEAS OF Now Alicia Rene Guyer, CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW CUSTODY Steve Ray Brown, Defendant NO. 03-5877 CIVIL TERM CERTIFICATE OF SERVICE I, Holly O. Vaughn, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the January 8, 2008 Order of Court by depositing a copy of the same in the United States mail, postage prepaid to the following: Michael Finucane, Esquire Counsel for Defendant 14 North Main Street, Suite 500 Chambersburg, PA 17201 Date: Ide Holly O. aughn Certified Legal Inte FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ? ?? '''i ,,T..- ? ? ? ,, .? `' ?`. ._ ?.?. ? _° ? , ATOM cSZ' KUTLiLAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 ALICIA RENE (BROWN) RININGER, Now ALICIA RENE GUYER, Plaintiff V. STEVEN RAY BROWN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-5877 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY PRAECIPE TO WITHDRAW APPEARANCE Please withdraw my appearance on behalf of the Defendant, Steven Ray Brown, in the above- captioned matter. Date: / 3 d'' Respectfully submitted, Michael B. Finucane, Esquire ` 14 North Main Street, Suite 500 Chambersburg, PA 17201 (717) 264-1400 Attorney ID #23543 PRAECIPE FOR ENTRY OF APPEARANCE c" Please enter my appearance on behalf of the Defendant, Steven Ray Brown, in the above- captioned matter. Respectfully submitted, ABOM & KUTULAKIS, LLP Date: ZS Kara W. Haggerty, Esq e 36 South Hanover Stre Carlisle, PA 17013 (717) 249-0900 ID #86914 C-D Alicia Rene (Brown) Rininger, Now Alicia Rene Guyer Plaintiff V. Steve Ray Brown Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW IN CONTEMPT : NO. 2003-5877 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Alicia Rene Rininger, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date D- (-{8 ?q Xu4n&+t Nicole Berman Certified Legal Intern ROB INS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 sv r Ji; C= N 4 Alicia Rene (Brown) Rininger, : IN THE COURT OF COMMON PLEAS OF Now Alicia Rene Guyer : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION-LAW IN CONTEMPT Steven Ray Brown, Defendant : NO. 2003-5877 CIVIL TERM NOTICE AND ORDER TO APPEAR Legal proceedings have been brought against you alleging you have willfully disobeyed an order of court for Custody. If you wish to defend against the claim set forth in the following pages, you may, but are not required to file in writing with the court your defenses or objections. Whether or not you file in writing with the court your defenses or objections, you iIAD at : oo P.M. in must appear in person in court on Cb a11' Courtroom -, in the Cumberland Coun Courthouse, Carlisle, Pennsylvania, 17013. IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST If the court finds that you have willfully failed to comply with its order for partial custody, you may be found to be in contempt of court and committed to jail, fined or both. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 3 l BY THE COURT: J. AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Y Alicia Rene (Brown) Rininger, : IN THE COURT OF COMMON PLEAS OF Now Alicia Rene Guyer : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION-LAW IN CONTEMPT Steven Ray Brown, Defendant : NO. 2003-5877 CIVIL TERM AMENDED PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY ORDER The petitioner, Alicia Rene Rininger, by and through her counsel, the Family Law Clinic, hereby brings this Amended Petition for Civil Contempt and respectfully requests that this Court find Defendant/Respondent, Steven R. Brown, in contempt of the June 25, 2007 Court Order. In support thereof, Petitioner states as follows: 1. The petitioner is Alicia Rene Rininger ("Mother"), an adult individual who resides at 28 East Orange Street, Shippensburg, Pennsylvania 17257. 2. The respondent is Steven Ray Brown ("Father"), an adult individual whose last known address is 7001 Old Scotland Road, Shippensburg, Pennsylvania 17257. 3. The parties are the natural parents of Kyler Brown, born December 8, 2000, age 7 years ("the child"). 4. On June 25, 2007, the Honorable Edward Guido entered an Order awarding Mother partial physical custody of the minor child Kyler. That Order was the negotiated result of Mother's prior Contempt Petition against Father. A true and correct copy of the order is attached to this petition as "Exhibit A." 5. Father has willfully failed to abide by the Order in that he has engaged in a course of conduct that interferes with Mother's periods of partial custody by failing to make Kyler available to Mother during her scheduled custody periods. 6. Father has also failed to abide by the Order by making disparaging remarks about Mother in the child's presence and by refusing to permit Mother to have reasonable telephone contact with the child. J 7. On July 7, 2007, Father denied Mother her weekend custody of Kyler in violation of paragraph 4a of the Order. Father gave no explanation why he denied her this weekend. 8. On August 3, 2007, Father denied Mother her weekend custody of Kyler in violation of paragraph 4a of the Order. Father did not respond to any phone calls Mother made to him during that weekend. 9. On August 12, 2007, Kyler spoke with Mother on the telephone and asked her if he could go camping with Father instead of spending the upcoming four-day weekend with her as he was scheduled to do. 10. Although Mother did not agree to forgo her time with Kyler for the weekend of August 18, 2007, she left several phone messages for Father in an attempt to reach a compromise for a portion of the weekend. 11. Father did not respond to Mother's messages. Although he did not speak to Mother about a possible compromise, Father denied Mother custody of Kyler for the entire four-day weekend of August 18, 2007, in violation of the Order. 12. On September 9, 2007, while talking on the phone with Kyler, Mother heard Father telling Kyler that Mother was a "bitch" in violation of paragraph 11 of the Order. 13. Mother filed a second Petition for Civil Contempt for Disobedience of a Custody Order on September 27, 2007, and another conciliation conference took place before Jacqueline Verney, Esq. on November 1, 2007. 14. On November 5, 2007, the Honorable Judge Edward. E. Guido entered an Order stating that the June 25, 2007 Order shall remain in full force and effect and be strictly adhered to. A true and correct copy of that Order is attached as "Exhibit B." 15. Father has continued to violate the Court's Order. 16. On November 22, 2007, Thanksgiving, Father failed to deliver the child to Mother in violation of paragraph 4e of the order, which states that Mother, was to have custody from 3:00 p.m. until 9:00 p.m. on Thanksgiving Day. Father prevented Mother from having any time with Kyler on the holiday. 17. On Friday, November 23, 2007, Father did not deliver the child to Mother for her weekend custody period. When Mother contacted Father, he informed her that he was out of town and that Kyler was in the care of Father's girlfriend. 18. Father did not deliver Kyler to Mother on Friday, December 7, 2007, in violation of the Order. Per the Order, that weekend was Mother's custodial period, except that the parties were to share custody of the child on the child's birthday, Saturday, December 8, 2007. 19. Father permitted Mother to spend 10:15 A.M. until 2:30 P.M. with Kyler on his birthday, but did not permit Mother to exercise custody of the child for any other portion her scheduled custodial weekend. 20. Just prior to the Christmas holiday, Father told Mother that if she would let him have custody of Kyler on Friday, December 21, 2007, he would deliver the child to her on the following day and that she could keep him until Thursday, December 27, 2007. 21. Mother did not agree to Father's proposed change to the Christmas schedule. 22. Despite the lack of agreement, Father did not deliver Kyler to Mother on Friday, December 21, 2007, in violation of the Order. Therefore, pursuant to Father's proposal, Mother kept Kyler until Wednesday, December 26, 2007. 23. Father has consistently denied telephone contact between Mother and Kyler and continues to do so in violation of paragraph 13 of the Order. 24. Mother has a strong desire to maintain her relationship with the child and Father's continued refusal to comply with the Custody Order has interfered with Mother's ability to maintain and develop this relationship. 25. As required by C.C.R.P. 208.2(d), concurrence of counsel was sought and was not obtained. WHEREFORE, Petitioner requests that: a. Father be held in contempt of the Court's Order of Custody of June 25, 2007 and be subject to all available punishments prescribed by 23 Pa C.S. Section 4346 which includes: (1) Imprisonment for a period not to exceed six months, (2) a fine not to exceed $500, (3) probation for a period not to exceed six months and (4) an order for nonrenewal, suspension or denial of operating privileges; b. Mother be awarded additional custodial time to compensate for the wrongful deprivation of her custodial time; C. Mother be awarded such other relief as the Court deems appropriate. Date: Respectfully submitted, AMY RACHER Certified Legal Intern THO . PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ?y. 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 unworn falsification to authorities. " Date: tho?on ? 1 A -l ' Alicia Rene Rininger Petitioner Alicia Rene (Brown) Rimnger, Now Alicia Rene Guyer Plaintiff V. Steven Ray Brown, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CONTEMPT : NO. 2003-5877 CIVIL TERM CERTIFICATE OF SERVICE I, Anne MacDonald-Fox, hereby certify that I am serving a true and correct copy of the Petition for Amended Civil Contempt for Disobedience of Custody Order on Kara W. Haggerty, Esquire, 36 South Hanover Street, Carlisle PA, 17013, by depositing it in first class U.S. mail, postage paid this 1St day of February 2008. Date: a v? Anne MacD Vnald-Fox Clinic Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 JUN 21ZUU1 7'' ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Now ALICIA RENE GUYER : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO. 2003-5877 CIVIL ACTION - LAW STEVEN RAY BROWN, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of , 2007, upon consideration of the attached Custody Con liation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated May 26, 2006 and May 17, 2007 are hereby vacated. 2. Mother hereby withdraws her Petition for Contempt. 3. The Mother, Alicia Rene Guyer and the Father, Steven Ray Brown, shall have shared legal custody of Kyler Steven Brown, born December 8, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 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 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to `them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, sports, children's parties, musical presentations, back-to-school nights, and the like. The parties shall cooperate with the child's counselor. 4. Father shall have primary physical custody of Kyler Steven Brown at all times, except when Kyler is in the partial physical custody of his mother according to the following schedule: EXHIBIT a. During the summer, alternate weekends from Thursday at 6:30 p.m. until Sunday at 6:30 p.m. b. During the school year, alternate weekends from Friday at 4:00 p.m. to Sunday at 6:30 p.m. c. During.the school year, one evening per week from 4:00 p.m. to 7:00 p.m., provided Mother gives Father notice of which evening by the preceding Sunday, d. Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day shall be shared such that Father shall always have physical custody from 9:00 am. to 3:00 p.m., and Mother shall always have physical custody from 3:00 p.m. to 9:00 p.m. In addition, Father shall have custody of the child on trick or treat night from 6:00 p.m. to 8:30 p.m. e. Mother and Father shall share custody around the child's birthday at mutually agreed upon times. f. Christmas shall be divided into two blocks: Block A shall be from Christmas Eve at 12 noon-until Christmas Day at 12 noon, and Block B shall be from Christmas Day at 12 noon to December 26 at 12 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. g. Both Father and Mother shall each have up to two weeks of vacation with Kyler each summer. The first parent to notify the other parent in writing of a chosen week shall have priority for that week. 5. During Mother's time of physical custody she shall insure that the child attends his baseball practices and games. Mother shall deliver him to the field slightly earlier than scheduled so he may change into his uniform. 6. The child is to have no contact with his stepfather, David Guyer. In the event that stepfather is released from rehab, Mother shall exercise her time of physical custody at her home, excluding stepfather from the residence, or at a friend's residence. In the event that it is at a friend's residence, Mother shall provide Father with the name, telephone number and address where the child is staying. 7. Unless otherwise agreed, the parties shall share transportation such that custody exchanges shall occur at the Shippensburg police station. 8. Mother shall provide Father with a phone number, including her cell phone, where she can be reached in times of emergency. Neither party may smoke in their homes or in their cars when the child is present. 10. Neither party shall permit contact between the child and the Oasis of Love Church or attend that church's functions. a f 11. Neither parent shall do or say or permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 12. Neither party may consume alcohol to the point of intoxication or illegal or non-prescribed drugs prior to or during their periods of custody. 13. The parties shall enjoy reasonable telephone contact with the child between 6:00 p.m. and 7:00 p.m. 14. This Order is entered pursuant to an agreement of the parties at 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. B Edward E. Guido, J. cc: Holly Vaughn, certified legal intern, Anne MacDonald-Fox, Esquire, Family Law Clinic, Counsel for Mother Michael Finucane, Esquire, Counsel for Father 5 1 : ? ALICIA RENE (BROWN) RPUNGER,: IN THE COURT OF COMMON PLEAS OF Now ALICIA RENE GUYER : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. :2003-5877 CIVIL ACTION - LAW STEVEN RAY BROWN, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyler Steven Brown December 8, 2000 Father 2. A Conciliation Conference was held in this matter on June 21, 2007, with the following individuals in attendance: The Mother, Alicia Rene Guyer, with her counsel, Holly Vaughn, certified legal intern, Anne MacDonald-Fox, Esquire, Family Law Clinic and the Father, Steven Ray Brown, with his counsel, Michael Finucane, Esquire. 3. The Honorable Edward E. Guido previously entered Orders of Court dated May 26, 2006 and May 17, 2007, providing for shared legal custody, Father having primary physical custody, with Mother having alternating weekends. 4. Mother filed a Petition for Contempt. 5. The parties agreed to the entry of an Order in the form as attached. -ar-o -U Date ac eline M. Verney, Esquire Custody Conciliator . A ?G V () 2, 2 0 0 7 ALICIA RENE (BROWN) RININGER, Now ALICIA RE NE GUYER, Plaintiff V. STEVEN RAY BROWN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 2003-5877 CIVIL TERM CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT 5- 4AN day of , 2007, upon AND NOW, this consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated June 25, 2007 shall remain in full force and effect and strictly adhered to with the following additions: 2. The parties shall cooperate with a psychological evaluation for the child and follow any recommendations resulting therefrom. 3. Father shall provide the child's medical insurance card to opposing counsel for transmittal to Mother. 4. This Order is entered pursuant to an agreement of the parties at 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. Another Conciliation Conference is scheduled for January 3, 2008 at 10:30 a.m. Michael Finucane, Esquire, Counsel for Father I Dcri?Q IBIT cc: Scott Weber, certified legal intern, Thomas Place, Esquire, Family Law Clinic, Counsel for Mother TRUE COF rmC?A hand In Testimony whereof, i hsre unto set my and the ls ihf ' P thonotary Edward E. Guido, J. ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Now ALICIA RENE GUYER, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. :2003-5877 CIVIL TERM STEVEN RAY BROWN, : CIVIL ACTION - LAW Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyler Steven Brown December 8, 2000 Father 2. A Conciliation Conference was held in this matter on November 1, 2007, with the following individuals in attendance: The Mother, Alicia Rene (Brown) Rininger, Now Alicia Rene Guyer, with her counsel, Scott Weber, certified legal intern and Thomas Place, Esquire, Family Law Clinic and the Father, Steven Ray Brown, with his counsel, Michael Finucane, Esquire. 3. The Honorable Edward E. Guido entered an Order of Court dated June 25, 2007, providing for shared legal custody, with Father having primary physical custody and Mother having alternating weekends. 4. Mother's Contempt allegations shall be held in abeyance. The parties agreed to the entry of an Order in the form as attached. t` Z -07 ?cJ'.c c /ll Date hacq eline M. Verney, Esquire Custody Conciliator It Alicia Rene (Brown) Rininger, : IN THE COURT OF COMMON PLEAS OF Now Alicia Rene Guyer : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION-LAW IN CONTEMPT Steven Ray Brown, Defendant : NO. 2003-5877 CIVIL TERM AMENDED PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY ORDER The petitioner, Alicia Rene Rininger, by and through her counsel, the Family Law Clinic, hereby brings this Amended Petition for Civil Contempt and respectfully requests that this Court find Defendant/Respondent, Steven R. Brown, in contempt of the June 25, 2007 Court Order. In support thereof, Petitioner states as follows: 1. The petitioner is Alicia Rene Rininger ("Mother"), an adult individual who resides at 28 East Orange Street, Shippensburg, Pennsylvania 17257. 2. The respondent is Steven Ray Brown ("Father"), an adult individual whose last known address is 7001 Old Scotland Road, Shippensburg, Pennsylvania 17257. 3. The parties are the natural parents of Kyler Brown, born December 8, 2000, age 7 years ("the child"). 4. On June 25, 2007, the Honorable Edward Guido entered an Order awarding Mother partial physical custody of the minor child Kyler. That Order was the negotiated result of Mother's prior Contempt Petition against Father. A true and correct copy of the order is attached to this petition as "Exhibit A." 5. Father has willfully failed to abide by the Order in that he has engaged in a course of conduct that interferes with Mother's periods of partial custody by failing to make Kyler available to Mother during her scheduled custody periods. 6. Father has also failed to abide by the Order by making disparaging remarks about Mother in the child's presence and by refusing to permit Mother to have reasonable telephone contact with the child. t 7. On July 7, 2007, Father denied Mother her weekend custody of Kyler in violation of paragraph 4a of the Order. Father gave no explanation why he denied her this weekend. 8. On August 3, 2007, Father denied Mother her weekend custody of Kyler in violation of paragraph 4a of the Order. Father did not respond to any phone calls Mother made to him during that weekend. 9. On August 12, 2007, Kyler spoke with Mother on the telephone and asked her if he could go camping with Father instead of spending the upcoming four-day weekend with her as he was scheduled to do. 10. Although Mother did not agree to forgo her time with Kyler for the weekend of August 18, 2007, she left several phone messages for Father in an attempt to reach a compromise for a portion of the weekend. 11. Father did not respond to Mother's messages. Although he did not speak to Mother about a possible compromise, Father denied Mother custody of Kyler for the entire four-day weekend of August 18, 2007, in violation of the Order. 12. On September 9, 2007, while talking on the phone with Kyler, Mother heard Father telling Kyler that Mother was a "bitch" in violation of paragraph 11 of the Order. 13. Mother filed a second Petition for Civil Contempt for Disobedience of a Custody Order on September 27, 2007, and another conciliation conference took place before Jacqueline Verney, Esq. on November 1, 2007. 14. On November 5, 2007, the Honorable Judge Edward. E. Guido entered an Order stating that the June 25, 2007 Order shall remain in full force and effect and be strictly adhered to. A true and correct copy of that Order is attached as "Exhibit B." 15. Father has continued to violate the Court's Order. 16. On November 22, 2007, Thanksgiving, Father failed to deliver the child to Mother in violation of paragraph 4e of the order, which states that Mother was to have custody from 3:00 p.m. until 9:00 p.m. on Thanksgiving Day. Father prevented Mother from having any time with Kyler on the holiday. 1 17. On Friday, November 23, 2007, Father did not deliver the child to Mother for her weekend custody period. When Mother contacted Father, he informed her that he was out of town and that Kyler was in the care of Father's girlfriend. 18. Father did not deliver Kyler to Mother on Friday, December 7, 2007, in violation of the Order. Per the Order, that weekend was Mother's custodial period, except that the parties were to share custody of the child on the child's birthday, Saturday, December 8, 2007. 19. Father permitted Mother to spend 10:15 A.M. until 2:30 P.M. with Kyler on his birthday, but did not permit Mother to exercise custody of the child for any other portion her scheduled custodial weekend. 20. Just prior to the Christmas holiday, Father told Mother that if she would let him have custody of Kyler on Friday, December 21, 2007, he would deliver the child to her on the following day and that she could keep him until Thursday, December 27, 2007. 21. Mother did not agree to Father's proposed change to the Christmas schedule. 22. Despite the lack of agreement, Father did not deliver Kyler to Mother on Friday, December 21, 2007, in violation of the Order. Therefore, pursuant to Father's proposal, Mother kept Kyler until Wednesday, December 26, 2007. 23. Father has consistently denied telephone contact between Mother and Kyler and continues to do so in violation of paragraph 13 of the Order. 24. Mother has a strong desire to maintain her relationship with the child and Father's continued refusal to comply with the Custody Order has interfered with Mother's ability to maintain and develop this relationship. 25. As required by C.C.R.P. 208.2(d), concurrence of counsel was sought and was not obtained. WHEREFORE, Petitioner requests that: a. Father be held in contempt of the Court's Order of Custody of June 25, 2007 and be subject to all available punishments prescribed by 23 Pa C.S. Section 4346 which includes: (1) Imprisonment for a period not to exceed six months, (2) a fine not to exceed $500, (3) probation for a period not to t I exceed six months and (4) an order for nonrenewal, suspension or denial of operating privileges; b. Mother be awarded additional custodial time to compensate for the wrongful deprivation of her custodial time; Mother be awarded such other relief as the Court deems appropriate. Respectfully submitted, Date: AMY BRACHER Certified Legal Intern THOMAS M. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 1 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 unworn falsification to authorities. Date: Alicia Rene Rininger Petitioner I Alicia Rene (Brown) Rininger, : IN THE COURT OF COMMON PLEAS OF Now Alicia Rene Guyer : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION-LAW IN CONTEMPT Steven Ray Brown, Defendant : NO. 2003-5877 CIVIL TERM CERTIFICATE OF SERVICE I, Anne MacDonald-Fox, hereby certify that I am serving a true and correct copy of the Petition for Amended Civil Contempt for Disobedience of Custody Order on Kara W. Haggerty, Esquire, 36 South Hanover Street, Carlisle PA, 17013, by depositing it in first class U.S. mail, postage paid this ISt day of February 2008. Date: Anne MacDonald-Fox Clinic Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 H w 0 Q Alicia Rene (Brown) Rininger, : IN THE COURT OF COMMON PLEAS OF Now Alicia Rene Guyer : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION-LAW IN CONTEMPT Steven Ray Brown, Defendant : NO. 2003-5877 CIVIL TERM NOTICE AND ORDER TO APPEAR Legal proceedings have been brought against you alleging you have willfully disobeyed an order of court for Custody. If you wish to defend against the claim set forth in the following pages, you may, but are not required to file in writing with the court your defenses or objections. Whether or not you file in writing with the court your defenses or objections, you must appear in person in court on tb dt?. 11 S at S*e _E.M. in Courtroom -, in the Cumberland Coun y Courthouse, Carlisle, Pennsylvania, 17013. IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST If the court finds that you have willfully failed to comply with its order for partial custody, you may be found to be in contempt of court and committed to jail, fined or both. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 BY THE T: J. AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. C c -r3 , r W -n 17; -C ? Sri ?. °? -rt mss,: ? ??, ? ?' ? 3? Q4. ? ? i?j b i:? ? ,..may ? ? ^? t,J"? ALICIA RENE (BROWN) GUYER : IN THE COURT OF COMMON PLEAS OF Now ALICIA RENE RININGER, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : : CIVIL ACTION - LAW IN CONTEMPT VS NO. 2003-5877 CIVIL TERM STEVEN RAY BROWN, Defendant IN RE: CONTEMPT ORDER OF COURT AND NOW, this 15th day of February, 2008, after hearing, we cannot find beyond a reasonable doubt that Father is in willful violation of our order, although we have strong suspicions thereof. We expect our order to be complied with to the letter. We further order that the Child start counseling with a counselor within 30 days of today's date and that confirmation of the counseling be filed with this Court. In the event that an appointment cannot be scheduled within that time, both parties must file an explanation as to why not. By tlye Court, Edward E. Guido, J. X'my Bracher, Certified Legal Intern For the Plaintiff Kara W. Haggerty, Esquire For the Defendant :mlc 00 tE5 rn.-7[Lsr,` a?az?o8 ? r f l '?? i`v11? 1 !,d ZZ 933 8001 3A 20 Alicia Rene (Brown) Rininger, Now Alicia Rene Guyer Plaintiff VS. Steven Ray Brown, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5877 CIVIL ACTION - LAW Custody Confirmation of Counseling Appointment The Plaintiff is Alicia Rene Rininger (Mother), who resides at 28 East Orange Street, Shippensburg, Pennsylvania 17257. 2. The Defendant is Steven Ray Brown (Father), who resides at 2004 Philadelphia Avenue, Lot # 54, Chambersburg, Pennsylvania 17201. 3. Mother and Father are the natural parents of Kyler Brown (the child), born December 8, 2000. 4. On February 15, 2008, the Honorable Judge Edward E. Guido ordered that the child start counseling with a counselor within 30 days of the date of the Order. See attached exhibit "A". 5. Using what she believed to be the correct insurance information for the child, Plaintiff attempted to arrange counseling with the counselor of her preference, Dr. Stephen Overcash. 6. Plaintiff did not possess the accurate insurance information for the child on the date that she made the appointment with Dr. Stephen Overcash. 7. Plaintiff requested that the Defendant provide her with the new insurance information on February 27, 2008. 8. Defendant provided Plaintiff with the correct insurance information on March 3, 2008. 9. The insurance procedures required by the new insurance company would have delayed the scheduling of the child's appointment with Dr. Stephen Overcash. 10. Recognizing the Child's need for immediate counseling, Plaintiff agreed to Father's selected counselor, Dr. Paul Scalia, who both accepted the current insurance and could schedule an appointment sooner than Dr. Stephen Overcash. 11. The Child has a scheduled appointment with Dr. Paul Scalia of Manito Counseling on March 29, 2008. See attached exhibit "B" which confirms this appointment. Respectfully Submitted, Amy E. Bracher Certified Legal Intern ?Lz??- Anne Donald-Fox U Clinic Supervising Attorney. Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ALICIA RENE (BROWN) GUYER IN THE COURT OF COMMON PLEAS OF NOW ALICIA RENE RININGER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW IN CONTEMPT VS NO. 2003-5877 CIVIL TERM STEVEN RAY BROWN, Defendant IN RE: CONTEMPT ORDER OF COURT AND NOW, this 15th day of February, 2008, after hearing, we cannot find beyond a reasonable doubt that Father is in willful violation of our order, although we have strong suspicions thereof. We expect our order to be complied with to the letter. We further order that the Child start counseling with a counselor within 30 days of today's date and that confirmation of the counseling be filed with this Court. In the event that an appointment cannot be scheduled within that time, both parties must file an explanation as to why not. By Edward E. Guido, J. Amy Bracher, Certified Legal Intern For the Plaintiff Kara W. Haggerty, Esquire For the Defendant :mlc EXHIBIT I A-] I Alicia Rene (Brawn) Rininger, Now Alicia Rene Guyer Pl:tinti ff vs. Steve Ray Boon, Defendant IN TI It; COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5877 : CIVIr. ACTION -- LAW Gustudy Cg mat r-of Counseling I hereby confirm that Kyler Brown, child of Alics Rininger and Steven Brown, has an appointment for counseling with J:Z;tl?t an this day of /- , , C. - . ? P,,- k g=?= Counselor Signature Date -. +It1 phaeMs ONw CMNM Address _ Y -- ??3 Pho EXHIBIT U' d V00'nN Zb: £t 8012T lbw : aI r a C=D C3 4 <= Mo -rt V; Cf... rYi K-. c:.; i 400 OM & jI TULAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 ALICIA RENE (BROWN) RININGER, Now ALICIA RENE GUYER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. STEVEN RAY BROWN, Defendant NO. 2003-5877 CIVIL TERM : CIVIL ACTION -LAW IN CUSTODY TO THE HONORABLE EDWARD E. GUIDO, JUDGE OF SAID COURT. DEFENDANT'S CONFIRMATION OF COUNSELING AND NOW, comes the Defendant, Steven R. Brown, by and through his counsel, Kara W. Haggerty, Esquire, of ABOM & KUTULAKIS, L.L.P., and files the within Confirmation of Counseling, and in support thereof, avers as follows: 1. The Plaintiff is Alicia Rene Rininger, an adult individual residing at 28 East Orange Street, Shipensburg, Pennsylvania. 2. The Defendant is Steven R. Brown, an adult individual residing at 7001 Old Scotland Road, Shippensburg, Pennnsylvania. 3. Plaintiff and Defendant are the natural parents of Kyler Brown, born December 8, 2000. 4. On February 15, 2008, following a hearing on the Contempt Petition filed by Mother, This Honorable Court ordered that the child begin counseling within thirty (30) days of the Court's order. r, 5. Father had previously contacted Dr. Paul Scalia with Manito, Inc. to enroll Kyler in counseling; however, Mother refused to consent to counseling until following the hearing on her Petition for Contempt. 6. Pursuant to This Court's Order dated February 15, 2008, Father once again requested that Kyler begin counseling with Dr. Paul Scalia with Manito, Inc. 7. Mother ultimately consented to the counseling, and an appointment is presently scheduled for March 29, 2008. 8. Undersigned counsel has received a copy of the Confirmation of Counseling Appointment that was to be filed by Plaintiff's counsel, with attached exhibits, and does concur with the counseling appointment scheduled with Dr. Paul Scalia. 9. The within confirmation is being filed pursuant to This Court's Order of February 15, 2008. Respectfully submitted, ABOM & Sy LLP. Kara W. Haggerty, E 36 South Hanover S Carlisle, PA 17013 (717) 249-0900 Attorney ID #86914 Attorney for Defendant r CERTIFICATE OF SERVICE AND NOW, this 14th day of March, 2008, I, Kara W. Haggerty, of Abom & Kutulakis, LLP, hereby certify that I did serve a true and correct copy of the foregoing Defendant's Confirmation of Counseling upon all parties of record by depositing, or causing to be deposited, same in the U.S. mail, First-Class, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Array Bracher, Ce * ied L e Inkrn Family Law Clinic 45 North Pit Suet Carl* PA 17013 Respectfully submitted, ABOM & Kvs, LLP ' 1 V DATE O's 14- rTI CO "}t 't '=Z; ° c. < Alicia Rene (Brown) Rininger, IN THE COURT OF COMMON PLEAS Now Alicia Rene Guyer Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 03-5877 Steven Ray Brown, CIVIL ACTION - LAW Defendant Custody CERTIFICATE OF SERVICE I, Megan M. Michael, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Confirmation of Counseling Appointment on Kara W. Haggerty, counsel for Defendant, at 36 South Hanover Street, Carlisle, Pennsylvania, 17013, by depositing a copy of the same in the United States mail on March 14, 2008. Mean M. Mic ael Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 -M rl Fri CO N n ?1 Alicia Rene Rininger, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Steve R. Brown, Defendant : NO.OJ - 5877 CIVIL TERM PETITION TO MODIFY CUSTODY ORDER 1. The petition of Alicia Rene Rininger by her attorneys, the Family Law Clinic, respectfully represents that on January 8, 2008, an Order of Court was entered for custody of Kyler Brown, born December 8, 2000, a true and correct copy of which is attached. True and correct copies of Orders dated June 25, 2007 and November 5, 2007 are also attached, since provisions of those Orders were affirmed by the January 8, 2008 Order. Under the existing Order, the parties share legal custody of the child. Father has primary physical custody of the child. Mother has partial custody of the child on alternate weekends during the school year from Friday at 5:00 p.m. until Sunday at 7:00 p.m., and one evening per week from 4:00 pm to 7:00 pm, provided Mother gives Father notice of which evening by the proceeding Sunday. During the summer, Mother has alternating weekends from Thursday at 6:30 p.m. until Sunday 6:30 pm. The parties share custody of the child on major holidays and the child's birthday. Each parent has up to two weeks of vacation with the child each summer. The parties are to cooperate in obtaining individual counseling for the child and are to explore the option of family counseling. 2. This Order should be modified because: a. The child, who is eight years old, has expressed a desire to spend more time with Mother. b. The child wishes to spend more time with his eleven-year-old sister, who resides with Mother. c. On Mother's scheduled weekends she does not get to spend much time with child because of child's involvement in sports and other weekend activities. d. The child would not have to switch schools if he were to spend weekdays with Mother as Mother recently moved to live in the school district where the child attends school. e. Mother had primary physical custody of the child from 2003 until 2005 when the parties began alternating weeks with the child; she was the child's primary caretaker during that period and would like to resume a larger role in the child's daily life. f. Issues which caused Mother to agree to Father having primary custody of the child in 2006 no longer exist. f. During her periods of custody, Mother will transport the child to all games, matches, and practices related to his extracurricular activities. WHEREFORE, Petitioner asks that the Court modify the existing Order for Custody and grant Mother shared physical custody of the child on an alternating week schedule because such an arrangement will be in the best interest of the child. Date: 411P '7LO9 ictor a ' n II Certified Legal Intern ,-? ylse?- A - - NNE DONALD-FO 'IT Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Date: PA, AIM Alicia Rene Rininger ,1A N 0 .LL le V V a ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Now ALICIA RENE GUYER, CUMBERLAND COUNTY, PENNSYL)(ANI„A Plaintiff , V. :2003-5877 CIVIL TERM STEVEN RAY BROWN, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of 2008 u on consideration of the attached Custody Co filiation Report, it is ordered and directed as follows: 1. A Hearing is sched ed in CoW Room. No. of the Cumberland County Co House, on the trday of o , 2008, at ; Gd o'clock, M., at which time testimony will be taken. For purposes of this Hearng the Mother shall be deemed to be the moving party and shall proceed initially with ? testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Orders of Court dated June 25, 2007 and November 5, 2007 shall remain in full force and effect, with the following modifications. 3. Paragraph 4 b of the Order of Court of June 25, 2007 shall be amended to read: "During the school year, alternate weekends from Friday at 5:00 p.m. to Sunday at 7:00 p.m." 4. Paragraph 2 of the Order of Court dated November 5, 2007 is hereby deleted. 5. The parties shall cooperate in obtaining individual counseling for the child. 6. The parties shall explore the option of family counseling. 7. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. cc: Scott Weber, certified legal intern, counsel for Mother Anne MacDonald-Fox, Esquire, Family Law Clinic Michael Finucane, Esquire, counsel for Father TRUE Py FROM R ORU to T"Onm wherw, i hem unto ray Mnd CarttsMe. P& $ &9d the seo ut aid Colt n "N aen6 rb rawara h. Guido, J. JUN L 1 ZUU/p" ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Now ALICIA RENE GUYER : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO. 2003-5877 CIVIL ACTION - LAW STEVEN RAY BROWN, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of 2007 u on consideration of the attached Custody Con liation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated May 26, 2006 and May 17, 2007 are hereby vacated. 2. Mother hereby withdraws her Petition for Contempt. 3. The Mother, Alicia Rene Guyer and the Father, Steven Ray Brown, shall have shared legal custody of Kyler Steven Brown, born December 8, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 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 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to `them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, sports, children's parties, musical presentations, back-to-school nights, and the like. The parties shall cooperate with the child's counselor. 4. Father shall have primary physical custody of Kyler Steven Brown at all times, except when Kyler is in the partial physical custody of his mother according to the following schedule: a. During the summer, alternate weekends from Thursday at 6:30 p.m. until Sunday at 6:30 p.m. b. During the school year, alternate weekends from Friday at 4:00 p.m. to Sunday at 6:30 p.m. c. During the school year, one evening per week from 4:00 p.m. to 7:00 p.m., provided Mother gives Father notice of which evening by the preceding Sunday. d. Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day shall be shared such that Father shall always have physical custody from 9:00 a.m. to 3:00 p.m., and Mother shall always have physical custody from 3:00 p.m. to 9:00 p.m. In addition, Father shall have custody of the child on trick or treat night from 6:00 p.m. to 8:30 p.m. e. Mother and Father shall share custody around the child's birthday at mutually agreed upon times. f. Christmas shall be divided into two blocks: Block A shall be from Christmas Eve at 12 noon until Christmas Day at 12 noon, and Block B shall be from Christmas Day at 12 noon to December 26 at 12 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. g. Both Father and Mother shall each have up to two weeks of vacation with Kyler each summer. The first parent to notify the other parent in writing of a chosen week shall have priority for that week. 5. During Mother's time of physical custody she shall insure that the child attends his baseball practices and games. Mother shall deliver him to the field slightly earlier than scheduled so he may change into his uniform. 6. The child is to have no contact with his stepfather, David Guyer. In the event that stepfather is released from rehab, Mother shall exercise her time of physical custody at her home, excluding stepfather from the residence, or at a friend's residence. In the event that it is at a friend's residence, Mother shall provide Father with the name, telephone number and address where the child is staying. 7. Unless otherwise agreed, the parties shall share transportation such that custody exchanges shall occur at the Shippensburg police station. 8. Mother shall provide Father with a phone number, including her cell phone, where she can be reached in times of emergency. 9. Neither party may smoke in their homes or in their cars when the child is present. 10. Neither party shall permit contact between the child and the Oasis of Love Church or attend that church's functions. 11. Neither parent shall do or say or permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 12. Neither party may consume alcohol to the point of intoxication or illegal or non-prescribed drugs prior to or during their periods of custody. 13. The parties shall enjoy reasonable telephone contact with the child between 6:00 p.m. and 7:00 p.m. 14. This Order is entered pursuant to an agreement of the parties at 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. B Edward E. Guido, J. cc: Holly Vaughn, certified legal intern, Anne MacDonald-Fox, Esquire, Family Law Clinic, Counsel for Mother Michael Finucane, Esquire, Counsel for Father '?' ` „ /1 a It ALICIA RENE (BROWN) RININGER,: IN THE COURT OF COMMON PLEAS OF Now ALICIA RE NE GUYER, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO. 2003-5877 CIVIL TERM STEVEN RAY BROWN, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 6 day of 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated June 25, 2007 shall remain in full force and effect and strictly adhered to with the following additions: 2. The parties shall cooperate with a psychological evaluation for the child and follow any recommendations resulting therefrom. 3. Father shall provide the child's medical insurance card to opposing counsel for transmittal to Mother. 4. This Order is entered pursuant to an agreement of the parties at 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. Another Conciliation Conference is scheduled for January 3, 2008 at 10:30 a.m. cc Scott Weber, certified legal intern, Thomas Place, Esquire, Family Law Clinic, Counsel for Mother .. thonotaryEdward E. Guido, J. Michael Finucane, Esquire, Counsel for Father TRUE COPY FROM RECORD In Testimony .,.hereof, 1 here into set my hand and the s//e??at of said ours it .isle, Ra. Thi ..l..l7.. day of.... aY•:••: OF THE 2M APR 27 PH 59 I-Folop Alicia Rene Rininger/Guyer, Plaintiff V. Mr. Steve R. Brown Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY • G3? S?f 77 NO-09- CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Alicia Rene Rininger, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date 0-71-0 Respe su tted, ictor Dav I Certified Legal Intern ONALD- Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 A LED OF T -EE ; R0T -;,- h.'r T ?`! 2009 APR 27 PH : 59 S.It.?`i?'' a } to ? ? t ,w ALICIA RENE RININGER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. STEVE R. BROWN DEFENDANT 2003-5877 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Thursday, April 30, 2009 - , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, May 28, 2009 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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/ ac ueEne M. Verne 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 2H9 APR 30 Ffl 3: 3 Ili'- MAY 2 9 20090 ALICIA RENE RININGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2003-5877 CIVIL ACTION - LAW STEVE R. BROWN, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this a? day of 00014- , 2009, upon consideration of the attached Custody Conci ation Report, it is ordered and directed as follows: R?_i 1. A Hearing is scheded in Co. , of the Cumberland County Court House, on the J? Vr' day ofourt R om N , 2009, at PD O o'clock, _. M., at which time testimony wff be en. For purposes of this Hearing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Orders of Court dated June 25, 2007, November 5, 2007 and January 8, 2008 shall remain in full force and effect. 3. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. 2 BY TH , Edward E. Guido, J. ccrKrystal MacIntyre , certified legal intern, counsel for Mother Winne MacDonald-Fox, Esquire, Family Law Clinic . - kara W. Haggerty, Esquire, counsel for Father ?YSrrtaasiL J i ?i?'r''A WAd yr+ 31"Y ?1, ALICIA RENE RININGER, Plaintiff V. STEVE R. BROWN, Defendant PRIOR JUDGE: Edward E. Guido, J. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :2003-5877 CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyler Steven Brown December 8, 2000 Father 2. A Conciliation Conference was held May 28, 2009 with the following individuals in attendance: Mother, Alicia Rene Rininger, with her counsel, Krystal MacIntyre, certified legal intern, Anne MacDonald-Fox, Esquire, Family Law Clinic and the Father, Steve R. Brown, with his counsel, Kara W. Haggerty, Esquire. 3. The Honorable Edward E. Guido previously entered Orders of Court dated June 25, 2007, November 5, 2007 and January 8, 2008 providing for shared legal custody, Father having primary physical custody and Mother having alternating weekends. 4. Mother's position on custody is as follows: Mother seeks shared legal custody and shared physical custody of the child. Mother asserts that she has moved in to the same school district as Father and the reasons that necessitated Father having primary physical custody no longer exist. 5. Father's position on custody is as follows: Father seeks the status quo continue. He refutes all of Mother's allegations as to why she should have shared physical custody of the child. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the status quo. It is expected that the Hearing will require one-half day. l ' Date jqu4e M. Verney, Esquire Custody Conciliator ALICIA R. RININGER, :-IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS NO. 2003-5877 CIVIL TERM STEVEN R. BROWN, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 28th day of July, 2009, after hearing, all prior custody orders are vacated and replaced with the following: 1. The Mother, Alicia Rene Rininger and the Father, Steven Ray Brown, shall have shared legal custody of Kyler Steven Brown, born December 8, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 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 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: Medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, sports, children's parties, musical presentations, back-to-school nights, and the like. The parties shall cooperate with the child's counselor. 2. Father shall have primary physical custody of Kyler Steven Brown at all times, except when Kyler is in the partial physical custody of his mother according to the following schedule: a. During the summer on alternating weeks from Thursday at 5:00 p.m. until Tuesday at 5:00 p.m. The transfer to be at the Shippensburg Police Station and to be accomplished without the participation of either parent. No videotaping is permitted. b. During the school year on alternating weekends from Thursday after school until Monday at the beginning of school. Mother is to pick the child up from school on Thursday and deliver the child to school on Monday. C. Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day shall be shared such that Father shall always have physical custody from 9:00 a.m. to 3:00 p.m. and Mother shall always have physical custody from 3:00 p.m. to 9:00 p.m. In addition, Father shall have custody of the child on trick or treat night from 6:00 p.m. to 8:30 p.m. d. Christmas shall be divided into two blocks: Block A shall be from Christmas Eve at 12 noon until Christmas Day at 12 noon, and Block B Shall be from Christmas Day at 12 noon to December 26 at 12 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. e. Both Father and Mother shall each have up to two weeks of vacation with Kyler each summer. The first parent to notify the other parent in writing of a chosen week shall have priority for that week. All vacation weeks must be chosen by May 1 of each year. 3. During Mother's time of physical custody, she shall ensure that the child attends all sport practices, games, meets, etc. If Mother is unable to see that the child attends said functions, she shall notify Father at least 24 hours in advance so that he may transport the child to said functions. 4. The custodial parent shall ensure that the child makes telephone contact with the noncustodial parent every Wednesday and Sunday evening between 8:00 and 9:00 p.m. The calls are to be made from the custodial parent's cell phone so that the records may be produced in court. 5. The parties shall e-mail each other on a daily basis to discuss matters concerning their son. The e-mail shall be initiated by the custodial parent and responded to by the noncustodial parent. Copies of all e-mails shall be preserved to be presented as an exhibit in any future proceedings. 6. Neither party may smoke in their homes or in their cars when the child is present. 7. Neither party shall permit contact between the child and the Oasis of Love Church or attend that church's functions 8. Neither party shall do or say or permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 9. Neither party may consume alcohol to the point of intoxication or illegal or non-prescribed drugs prior to or during their periods of custody. By t Court Edward Gdi , J. /ystal J. MacIntyre, Certified Legal Intern Anne MacDonald-Fox, Esquire Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 For the Plaintiff ./Kara W. Haggerty, Esquire Abom & Kutulakis 2 West High Street Carlisle, PA 17013 For the Defendant mlc t .E;_? ! r a O THE 2009 SJIL '13 d k 8: 0 Li ALICIA R. RININGER Plaintiff VS. STEVEN R. BROWN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA : CIVIL ACTION-LAW IN CONTEMPT NO. 2003-5877 CIVIL TERM PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY ORDER The Petitioner, Steven Ray Brown, Pro Se, hereby brings this Petition for Civil Contempt, and respectfully requests that this Court find Plaintiff/Respondent, Alicia R. Rininger, in contempt of the July 28, 2009 Court Order. In support thereof, Petitioner states as follows: 1. The petitioner is Steven R. Brown ("Father"), an adult individual who resides at 7001 Olde Scotland Road, Shippensburg, Pennsylvania 17257. 2. The respondent is Alicia R. Rininger ("Mother"), an adult individual whose last known address is 2825 Orrstown Road, Shippensburg, Pennsylvania 17257. 3. The parties are the natural parents of Kyler Steven Brown, born December 8, 2000, age 8 years. 4. On July 28, 2009, the Honorable Edward Guido entered an Order awarding Father primary physical custody of the minor child, Kyler. A true and correct copy of the order is attached to this petition. 5. Mother has willfully failed to abide by the Order in that she does not engage in a course of conduct that is in the best interest of the minor child, Kyler. 6. On July 30, 2009, Mother was present at the custody exchange in violation of Paragraph 2(a) of the Order. 7. Mother had child call his Father on Sunday, August 2, 2009 from a blocked phone number this is in violation of Paragraph (4) of the Order. 8. During Mother's custodial time of August 13 and August 14, 2009, she did not exercise her custodial time with her son in violation of Paragraph 2(a) of the Order. Mother scheduled a vacation to be out of time during her custodial time. Mother did exercise her visitation from Sunday, August 16, 2009 at 2:00 pm through Tuesday, August 18, 2009 at 5:00 pm. 9. Mother did not have child call his father on Sunday, August 16, 2009 between 8:00 and 9:00 pm in violation of Paragraph (4) of the Order. 10. Mother did not take child to his football practice on Monday, August 17, 2009 in violation of Paragraph (3) of the Order. 11. Father has a strong desire to work amicably with Mother since this is in the best interest of the child. Mother's continued refusal to comply with any Custody Orders has interfered with the ability to do so. WHEREFORE, Petitioner requests that: a. Mother be held in contempt of the Court's Order of Custody of July 28, 2009 and be subject to all available punishments prescribed by 23 Pa C.S. Section 4346 which includes: (1) Imprisonment for a period not to exceed six months, (2) a fine not to exceed $500, (3) probation for a period not to exceed six months and (4) an order for nonrenewal, suspension or denial of operating privileges; b. Mother be ordered to take parental counseling to learn how to put the child's best interest and needs before her own. Mother should have supervised visitation until Mother completes parental counseling. c. Father be awarded such other relief as the Court deems appropriate. Respectfully submitted, S - VA - aq DATE /? ?, Steven R. Brown, Pro Se 7001 Olde Scotland Road Shippensburg, PA 17257 (717) 977-1690 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. ?teve-nR. Brown Petitioner ALICIA R. RININGER IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PA VS. : CIVIL ACTION-LAW IN CONTEMPT STEVEN R. BROWN, Defendant NO. 2003-5877 CIVIL TERM CERTIFICATE OF SERVICE I, Steven R. Brown, Pro Se, hereby certify that I did, the 19 day of August, 2009, cause a copy of Petition for Civil Contempt for Disobedience of Custody Order to be served upon Plaintiff/Respondent, through her attorney, by serving her by first-class mail, postage prepaid at the following address: Krystal MacIntyre, Certified Legal Intern The Dickinson School of Law Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Anne MacDonald-Fox, Esquire The Dickinson School of Law Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Date: August 1q , 2009 ?l?_ Steven R. Brown, Pro Se 7001 Olde Scotland Road Shippensburg, PA 17257 (717) 977-1690 ALICIA R. RININGER, Plaintiff VS STEVEN R. BROWN, Defendant IN THE COURT OF 'COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003-5877 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 28th day of July, 2009, after hearing, all prior custody orders are vacated and replaced with the following: 1. The Mother, Alicia. Rene Rininger and the Father, Steven Ray Brown, shall have shared legal custody of Kyler Steven Brown, born December 8, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 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 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: Medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, sports, children's parties, musical presentations, back-to-school nights, and the like. The parties shall cooperate with the child's counselor. 2. Father shall have primary physical custody of Kyler Steven Brown at all times, except when Kyler is in the partial physical custody of his mother according to the following schedule: a. During the summer on alternating weeks from Thursday at 5:00 p.m. until Tuesday at 5:00 p.m. The transfer to be at the Shippensburg Police Station and to be accomplished without the participation of either parent. No videotaping is permitted. b. Durln?g the scho)c)l year u n ai L'Iic t iil _ ;' nr;11 I Cf SCho, i l";)r !" ,: 7. i$' fi.:7 C'r ie' ,'1il l_'"1 up fr'.D;n schoc 1 orI TYl l_I' S'd..ty •_i I i, (a ? L d-I' e ci t. lJ school on Monday. C. Thanksgiving, Easter, Memorial Day, Fourth of July and Tabor Day shall be shared such that Father shall always have physical custody from 9:00 a.m. to 3:00 p.m. and Mother shall always have physical custody from 3:00 p.m. to 9:00 p.m. In addition, Father shall have custody of the child on trick or treat night from 6:00 p.m. to 8:30 p.m. d. Christmas shall be divided into two blocks: Block A shall be from Christmas Eve at 12 noon until Christmas Day at 12 noon, and Block B Shall be from Christmas Day at 12 noon to December 26 at 12 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. e. Both Father and Mother shall each have up to two weeks of vacation with Kyler each summer. The first parent to notify the other parent in writing of a chosen week shall have priority for that week. All vacation weeks must be chosen by May 1 of each year. 3. During Mother's time of physical custody, she shall ensure that the child attends all sport practices, games, meets, etc. If Mother is unable to see that the child attends said functions, she shall notify Father at least 24 hours in advance so that he may transport the child to said functions. 4. The custodial parent shall ensure that the child makes telephone contact with the noncustodial parent every Wednesday and Sunday evening between 8:00 and 9:00 p.m. The calls are to be made from the custodial parent's cell phone so that the records may be produced in court. 5. The parties shall e-mail each other on a daily basis to discuss matters concerning their son. The e-mail shall be initiated by the custodial parent and responded to by the noncustodial parent. Copies of all e-mails shall be preserved to be presented as an exhibit in any future proceedings. 6. Neither party may smoke in their homes or in their cars when the child is present. 7. Neither party shall permit contact between the child and the Oasis of Love Church or attend that church's functions 8. Neither party shall do or say or permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development cf the child's lore and respect for the other parent. ti. NeiLhe.r party lllay c'OT"?St.1P,lE d1co`.lol to Cl pr tit Of 1r.C .. ::L <%: -Jr 1 I e''-(ci t o? 3 _.1x17 ?_)E,L )dE? oD CUS t.od;'. By t e Court Edward Guid J. Krystal J. MacIntyre, Certified Legal Intern Anne MacDonald-Fox, Esquire Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 For the Plaintiff Kara W. Haggerty, Esquire Abom & Kutulakis 2 West High Street Carlisle, PA 17013 For the Defendant ml c z ALE }- ;i---_l?_ '}' ?(? V' THE I-?i/) TI Ji- !, Y Il"1S 2003 ,BUG' 19 P? 1 2: '317 OJO 10, o l l? ?us?- ALICIA R. RININGER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2003-5877 CIVIL ACTION LAW STEVEN R. BROWN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, August-26,2009 _ , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, September 22, 2009 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to 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/ Jacqueline M. Verney, 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 CF THE .t,)TARY 2009 AUG 28 PFD 2: 42 CUM ? 1 a SEP 2 3 2009 ALICIA R. RININGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2003-5877 CIVIL ACTION - LAW STEVEN R. BROWN, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of <?_ , 2009, upon consideration of the attached Custody Concilia ion Report, it is ordered and directed as follows: 1. A Hearing is sche}led in Cou Q? No. , of the Cumberland County Co rt House, on the b day of O&Gr , 2009, at ,30 • 00 o'clock,. M., at which time testimony will be taken. For purposes of this Heari g, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Order of Court dated July 28, 2009 shall remain in full force and effect. 3. 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, Edward E. Guido, J. cc:?$teven R. Brown, pro se 7001 Olde Scotland Road Shippensburg, PA 17257 J Xrysal MacIntyre, certified legal intern, Counsel for Mother Anne MacDonald-Fox, Esquire, Family Law Clinic ALICIA R. RININGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY; PENNSYLVANIA V. :2003-5877 CIVIL ACTION - LAW STEVEN R. BROWN, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyler Steven Brown December 8, 2000 Father 2. A Conciliation Conference was held September 22, 2009 with the following individuals in attendance: Father, Steven R. Brown, pro se and Mother, Alicia R. Rininger, with her counsel, Krystal MacIntyre, certified legal intern, Anne MacDonald-Fox, Esquire, Family Law Clinic. 3. The Honorable Edward E. Guido previously entered an Order of Court dated July 28, 2009 providing for shared legal custody, Father having primary physical custody and Mother having alternating weekends. 4. Father filed a Petition for Civil Contempt. His position is as follows: Father cites five alleged violations of the Court Order by Mother: 1. Mother was present at a custody exchange in violation of Paragraph 2(a); 2. Mother called the child on August 2, 2009 from a telephone that blocked the telephone number in violation of Paragraph 4 of the Order; 3. Mother failed to exercise her custodial time on August 13 and 14, 2009 in violation of Paragraph 2(a) of the Order; 4. Mother failed to have the child call Father on August 16, 2009 in violation of Paragraph 4 of the Order; and 5. Mother failed to take the child to football practice on August 17, 2009 in violation of Paragraph 3 of the Order. There was a question regarding who should have physical custody of the child on Monday school holidays. Father suggested that Mother keep the child until 12:00 noon if it coincides with her custodial weekends. 5. Mother's response to Father's allegations of contempt are as follows: 1. She did not participate in the exchange of custody, although she was nearby the exchange location; 2. Calling from a blocked phone is not a violation of the Court Order; 3. It is not a violation of the Court Order if she does not exercise her custodial time; 4. She admits failing to having the child call Father on August 16, 2009; and 5. She admits failing to take the child to football practice. Mother believed that whoever had physical custody on the weekend that coincides with the school holiday should keep the child until the evening. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the status quo. It is expected that the Hearing will require one-half day. Date Jac line M. Verney, Esquire Custody Conciliator u ?atwt? M OCT -1 AM IO: 0 1 "MADVAW ALICIA R. RININGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CLINlB?t COUNTY, PENNSYLVANIA n1?1 ?- ??T??y VS 6FJHr PFR'3"x'8A CIVIL TERM STEVEN R. BROWN, ZQQ I2$AFd&''M- LAW Defendant : IN CUSTODY AND NOW, this 26th day of October, 2009, after hearing, the Petition for Contempt is dismissed. In order to clarify our prior order, paragraph 2(b) is amended to add the additional language: In the event that the child does not have school on the Monday following Mother's custody, the partial custody shall extend to the beginnninag of school on Tuesday. By Court, Edward E. Guido, J. Steven R. Brown 7001 Olde Scotland Road Shippensburg, PA 17257 Krystal MacIntyre, Certified Legal Intern Anne MacDonald-Fox, Esquire Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 :mlc e6p1E s /7,9aIL BLED- ,,?RCE (-)P THE PP TPONOTARY 2009 OCT 28 PM 4: 0 ! CUf??.- d ur??`i ABOM cSZ' KUTLILAKIS Kara W. Haggerty, Esquire Attorney I.D. No.: 86914 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 ALICIA RENE (BROWN) RININGER, Now ALICIA RENE GUYER, Plaintiff V. STEVEN RAY BROWN, Defendant 2010 AIF 14 F 2': j IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003-5877 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY TO THE HONORABLE EDWARD E. GUIDO, JUDGE OF SAID COURT: AND NOW, this 14th day of April, 2010, comes the Petitioner, Steven Ray Brown, by and through his counsel, Kara W. Haggerty, Esquire, of ABOM & KUTULAKIS, L.L.P., and files this Petition for Contempt and in support thereof avers the following: 1. Petitioner is Steven Ray Brown, who was the Defendant in the above captioned action between the parties. 2. Respondent is Alicia Rene Guyer, who was the Plaintiff in that action and is represented by Dickinson Family Law Clinic. 3. Petitioner and Respondent are the parents of Kyler Steven Brown, born December 8, 2000. 47b, oo PO A 77-/ co 668(0 6* 4. On July 28, 2009, This Honorable Court entered an Order of Court following a hearing. (A true and correct copy of the Order of Court is attached hereto as Exhibit A.) a. The Order of Court states that Mother and Father will have shared Legal Custody of the child. b. Regarding physical custody the Order provides Father primary physical custody and Mother partial physical custody on alternating weekends from Thursday through Monday during the school year. 5. On April 14, 2010, simultaneously with the within Petition, the Petitioner filed a Petition for Special Relief. 6. Respondent is in contempt of the Order of Court regarding custody of the minor child in that she has failed to follow through with this Honorable Court's Orders. a. Mother picked the child up from school on Monday, April 12, 2010, at a time when it was not her court-ordered custodial period of time. 1. Mother's most recent period of custody, which she exercised, was from Thursday, April 8, 2010 after school through Monday, April 12, 2010 at school. b. Mother failed to notify Father that she was picking the child up from school. 1. Father learned that the child was not coming home when the child did not get off the school bus Monday afternoon. 2. Father was forced to utilize the Pennsylvania State Police to learn that the child was with his Mother and that he was safe. 3. Father has been unable to learn any other information as to why Mother has unilaterally and willfully retained custody of the child other than learning that the child was interviewed by Franklin County Children and Youth Services, who advised Father that there was no wrongdoing found on Father's part. c. Mother has failed to email Father to advise what is happening with the child as required by the Court Order. 1. Mother responded to one of Father's emails on Tuesday evening, but only indicated that she had the child and she intended to keep him. d. Mother did not take the child to school on Friday, April 9, 2010, Tuesday, April 13, 2010 or Wednesday, April 14, 2010. It is believed that at least two (2) of these absences will be considered unexcused. e. Mother has not been cooperating with the child's counselor, Paul Scalia. 1. Mother has not attended or participated in counseling with the child. 2. Mother contacted the child's counselor on Sunday, April 11, 2010 and advised him that he was not doing his job and that he would no longer be seeing Kyler. 7. It is believed and therefore averred Mother's retaining the child this week are a direct violation of the Court Order and that Mother is in Contempt of Court. 8. It is believed and therefore averred that Mother is engaging in behavior in an attempt to alienate the child from his Father. 9. It is believed and therefore averred that Mother is making an effort to estrange the child from his Father, injure the opinion of the child as to his Father, and to hamper the free and natural development of the child's love and respect for his Father. 10. Mother's breach of the terms of the Court is the sole reason Petitioner had to file this Petition for Contempt and Enforcement. 11. Petitioner has incurred attorney's fees and costs in connection with the preparation and pursuit of this Petition and Respondent should be held responsible for said costs. EREFORE, Petitioner respectfully requests that this Honorable Court enter an Order finding Respondent in Contempt of Court and directing Respondent to immediately comply with This Honorable Court's Order. It is further requested that Mother's periods of custody be supervised and that she pay Petitioner's counsel fees and costs. Respectfully submitted, ABom & KuTULA"s, L.L.P. i Kara W. Haggerty, q Attorney I.D No.- 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Petitioner VERIFICATION I, Steven Brown, verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. L4 2 Date STEVEN BROWN ALICIA R. RININGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS : NO. 2003-5877 CIVIL TERM STEVEN R. BROWN, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 28th day of July, 2009, after hearing, all prior custody orders are vacated and replaced with the following: 1. The Mother, Alicia Rene Rininger and the Father, Steven Ray Brown, shall have shared legal custody of Kyler Steven Brown, born December 8, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 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 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. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: Medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, sports, children's parties, musical presentations, back-to-school nights, and the like. The parties shall cooperate with the child's counselor. 2. Father shall have primary physical custody of Kyler Steven Brown at all times, except when Kyler is in the partial physical custody of his mother according to the following schedule: a. During the summer on alternating weeks from Thursday at 5:00 p.m. until Tuesday at 5:00 p.m. The transfer to be at the Shippensburg Police Station and to be accomplished without the participation of either parent. No videotaping is permitted. b. During the school year on alternating weekends from Thursday after school until Monday at the beginning of school. Mother is to pick the child up from school on Thursday and deliver the child to school on Monday. C. Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day shall be shared such that Father shall always have physical custody from 9:00 a.m. to 3:00 p.m. and Mother shall always have physical custody from 3:00 p.m. to 9:00 p.m. In addition, Father shall have custody of the child on trick or treat night from 6:00 p.m. to 8:30 p.m. d. Christmas shall be divided into two blocks: Block A shall be from Christmas Eve at 12 noon until Christmas Day at 12 noon, and Block B Shall be from Christmas Day at 12 noon to December 26 at 12 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. e. Both Father and Mother shall each have up to two weeks of vacation with Kyler each summer. The first parent to notify the other parent in writing of a chosen week shall have priority for that week. All vacation weeks must be chosen by May 1 of each year. 3. During Mother's time of physical custody, she shall ensure that the child attends all sport practices, games, meets, etc. If Mother is unable to see that the child attends said functions, she shall notify Father at least 24 hours in advance so that he may transport the child to said functions. 4. The custodial parent shall ensure that the child makes telephone contact with the noncustodial parent every Wednesday and Sunday evening between 8:00 and 9:00 p.m. The calls are to be made from the custodial parent's cell phone so that the records may be produced in court. 5. The parties shall e-mail each other on a daily basis to discuss matters concerning their son. The e-mail shall be initiated by the custodial parent and responded to by the noncustodial parent. Copies of all e-mails shall be preserved to be presented as an exhibit in any future proceedings. 6. Neither party may smoke in their homes or in their cars when the child is present. 7. Neither party shall permit contact between the child and the Oasis of Love Church or attend that church's functions 8. Neither party shall do or say or permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. 9. Neither party may consume alcohol to the point of intoxication or illegal or non-prescribed drugs prior to or during their periods of custody. By t Court Edward Guid J. Krystal J. MacIntyre, Certified Legal Intern Anne MacDonald-Fox, Esquire Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 . For the Plaintiff Kara W. Haggerty, Esquire Abom & Kutulakis 2 West High Street Carlisle, PA 17013 For the Defendant :mlc U.- cc .a5 f 6& [O'n t ATI'7 hef w . I twe up.t set MY tiara ALICIA RENE (BROWN) RININGER, Now ALICIA RENE GUYER, Plaintiff V. STEVEN RAY BROWN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003-5877 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY AND NOW, this 14?h day of April, 2010, I, Kara W. Haggerty, Esquire, hereby certify that I did serve a true and correct copy of the foregoing PETITION FOR CIVIL CONTEMPT upon counsel of record, by US Mail, addressed as follows: Ann MacDonald-Fox Family Law Clinic Penn State Dickinson School of Law 45 North Pitt Street Carlisle, PA 17013 ABOM & KUTULA)US, L.L.P. Kara W. Haggerty, Es /4 Attorney I.D No.: 6 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Petitioner ABOM ?' Ki.ITLILAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 2 West High Street Carlisle, PA 17013 (717)249-0900 FILFi, ., ;._ ,` ,r ? f 'rT` ?,? 20IL1 A R 14 Pil 2: 48 ac ALICIA RENE (BROWN) RININGER, IN THE COURT OF COMMON PLEAS Now ALICIA RENE GUYER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. STEVEN RAY BROWN, Defendant NO. 2003-5877 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY TO THE HONORABLE EDWARD E. GUIDO, JUDGE OF SAID COURT: Petitioner, Steven Ray Brown, by and through his counsel, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P., files this Petition for Special Relief as follows: 1. On July 28, 2009, this Honorable Court entered an Order of Court providing Father with primary physical custody and Mother partial physical custody on alternating weekends during the school year of Kyler Steven Brown, born December 8, 2000. 2. Mother's last custodial weekend was exercised on Thursday, April 8, 2010 through Monday, April 12, 2010. 3. On Monday, April 12, 2010, without notifying Father, Mother picked the child up from school and has retained custody of the child ever since, in direct violation of This Court's Order. a. Father learned that the child was picked up from school only after the child did not get off the school bus at the end of the day. `470.00 PA ATTY X64 al &5' P1* 1 b. As of the filing of this Petition, the only contact Father has had with Mother is a response to one email that Father received on the evening of April 13, 2010. c. Father had to contact the Pennsylvania State Police to ensure the child's safety as he was completely unable to contact the child at all. 4. Upon learning that Mother picked the child up from school in violation of the Court Order, Father contacted the Pennsylvania State Police who advised Father that Mother had contacted them and stated that she had taken the child on advice from Franklin County Children and Youth Services. 5. Father contacted Tammy Lay, supervisor at Franklin County Children and Youth Services, who advised that a caseworker did speak with the child over the weekend, but determined that there is no abuse being perpetrated by Father. Ms. Lay also advised Father that, from her perspective, Mother is in violation of the court order as they did not advise Mother to retain custody of the child. 6. Mother has not sent the child to school since she has unlawfully retained custody of him, resulting in at least two (2) unexcused absences. 7. Father has been working with Franklin County Children and Youth Services to ensure that the child does go to school as the child is currently in the middle of his PSSA testing. On Friday, April 9, 2010, Mother kept the child home from school alleging that he was sick. 9. On Monday, April 12, 2010, Mother picked up the child from school early, removing him early from his PSSA testing, in order to prevent the child from coming home to his Father on the school bus. 10. On Tuesday, April 13, 2010, Mother kept the child home from school for unknown reasons, and it is believed that this will result in an unexcused absence. 11. On Wednesday, April 14, 2010, Mother kept the child home from school for unknown reasons, and it is believed that this will result in an unexcused absence. 12. Father has been unable to ensure the child's safety since Monday, April 12, 2010, without the assistance of law enforcement or child services. 13. With the exception of one email from Mother stating that she has the child and intends to keep him, Father has been unable to communicate with Mother or the child since Monday, April 12, 2010. 14. It is believed and therefore averred that Mother is engaging in behavior in an effort to alienate the child from Father. 15. It is believed and therefore averred that Mother has lied to multiple authority figures, to include the Pennsylvania State Police, the child's school and Franklin County Children and Youth Services, in an effort to unlawfully and willfully withhold the child from the custody of Father. 16. It is believed and therefore averred that it is in the child's best interests for him to be immediately returned to the custody of his Father. 17. It is believed and therefore averred that it is in the best interest of the child to limit his contact with his Mother to supervised visitation until both she and the child are evaluated by mental health professionals. a. The July 28, 2009 Order of Court requires the parties to cooperate with the child's counselor. b. Simultaneously with the filing of this petition, Father is filing a Petition for Contempt where part of the allegations are Mother's failure to cooperate with the child's counseling. c. It is believed and therefore averred that the child should immediately return to his counselor, Paul Scalia, to determine the effect that Mother's false allegations against Father have had on the child. 18. It is believed and therefore averred that Mother's actions have been malicious and willful in nature solely to interfere and thwart Father's relationship with the child and have not been in the child's best interests. WHEREFORE, Petitioner respectfully requests that this Honorable Court grant the request for Special Relief and immediately direct Mother to return the child to Father. It is further requested that Mother's periods of custody be suspended until a hearing may be held on this petition. Respectfully submitted, ABOM & %UTULAKIS, LLP Date: ate• Kara W. Haggerty, Esq e 2 West High Street Carlisle, PA 17013 (717) 249-0900 ID #86914 VERIFICATION I, Steven Brown, verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date y- 0 _. /?t STEVEN BROWN AND NOW, this 14th day of April, 2010, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Petition for Special Relief, upon the counsel for Plaintiff/Respondent by depositing, or causing to be deposited, same in the United States Mail, postage prepaid addressed to the following: Ann MacDonald-Fox Family Law Clinic Penn State Dickinson School of Law 45 North Pitt Street Carlisle, PA 17013 Respectfully submitted, Abom & Kutulakis, L.L.P. Kara W. Haggerty, Attorney ID No. 86, 2 West High Street Carlisle, PA 17013 (717) 249-0900 t? « APR 1 4 2010 ALICIA RENE (BROWN) RININGER, IN THE COURT OF COMMON PLEAS Now ALICIA RENE GUYER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO. 2003-5877 CIVIL TERM STEVEN RAY BROWN, CIVIL ACTION -LAW Defendant IN CUSTODY AND NOW, this day of 2010, upon consideration of the Petition for Special Relief, said Petition is hereby GRANTED. Plaintiff is directed to immediately return the child to the custody of his Father, Steven Brown. Plain+;fP° H°wods of ee6+edy-a;P, An emergency hearing is scheduled for the ?I ay of April, 2010, at '.3o m. in Courtroom No. 3 of the Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, >stribution: K W. Haggerty, Esquire MacDonald-Fox, Esquire J-6 CV-S, f'ytC'&t LC 2?7A Jude ri r--a - ?J ? T1s-- ,Cl :D3. J Alicia Rininger, IN THE COURT OF COMMON PLEAS Plaintiff/ Respondent OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW IN CUSTODY Steven R. Brown, Defendant/ Petitioner No. 03-5877 CIVIL TERM RESPONDENT'S ANSWER TO PETITION FOR SPECIAL RELIEF SEEKING EMERGENCY CUSTODY PURSUANT TO PA R.C.P. 1915.13 AND NOW, comes Respondent, Alicia Rininger ("Mother"), by and through her counsel, the Family Law Clinic, and files this Answer to Petition for Special Relief ? N Seeking Emergency Custody Pursuant to PA R.C.P. 1915.13, respectfully stating irw,1 b ^' rim support thereof as follows: - Admitted. 1 Z Z . 1 2. Admitted. 3. Admitted in part; denied in part. It is admitted that, without notifying Father at the time, Mother picked the child up from school on Monday, April 12, 2010. It is denied that Mother retained custody of the child since that date, having returned him to Father the afternoon of Wednesday, April 14, 2010. a. Mother lacks sufficient knowledge to admit or deny when Father learned that Mother had picked the child up at school. b. Admitted. By way of further answer, Mother e-mailed Father on Tuesday, April 13, 2010 to advise him that the child was doing great and that his PSSA testing had been taken care of. C. Denied. Since the school principal and counselor were aware that the child was in Mother's custody en route to an appointment at Franklin County Children and Youth Services, Father was not forced to contact the Pennsylvania State Police to ensure the child's safety. 4. Admitted. 5. Admitted in part; denied in part. It is admitted that Franklin County Children and Youth Services did not advise Mother to retain custody of the child but did tell Mother that it was her duty to protect the child. It is denied that a caseworker spoke with the child over the weekend. By way of further answer, because no caseworker spoke with the child over the weekend, Mother contacted Franklin County Children and Youth Services again due to her concern for the child's well being. A casework told Mother to bring the child to Franklin County Children and Youth Services on the afternoon of Monday, April 12, 2010. 6. Denied. By way of further answer, Mother was in contact with the child's school, particularly the principal, receptionist, and counselor, about the child's safety and none of the child's absences during the pertinent period were considered unexcused. 7. Mother lacks sufficient information to admit or deny whether Father has been working with Franklin County Children and Youth Services. By way of further answer, the child participated in his PS SA testing on Monday, April 12, 2010 and again on the afternoon of Wednesday, April 14, 2010. 8. Admitted. By way of further answer, the child was vomiting and feeling ill on Friday, April 9, 2010, so Mother did not send him to school. 9. Admitted in part; denied in part. It is admitted that Mother picked up the child before school adjourned on Monday, April 12, 2010. It is denied that Mother removed the child early from his PSSA testing. By way of further answer, Mother contacted the school to find out when the PSSA testing would be completed. She picked the child up after he had finished his tests in order to take the child to Franklin County Children and Youth Services for an evaluation. 10. Admitted in part; denied in part. It is admitted that Mother kept the child home from school on Tuesday, April 13, 2010. It is denied that Mother's action resulted in an unexcused absence for the child. By way of further answer, Mother was concerned with the child's safety and believed she was abiding by the instructions of Franklin County Children and Youth Services to "keep the child safe" when she kept the child from school. 11. Denied. Per her arrangement with the school principal and counselor, Mother took the child to school at 1:30 p.m. to complete his PSSA testing. By way of further answer, Mother did not take the child to school earlier on Wednesday, April 14, 2010 because a caseworker from Franklin County Children and Youth Services had arranged to visit the child at her home to ensure that the child had appropriate living accommodations and food. 12. Denied. Mother e-mailed Father on the night of Tuesday, April 13, 2010 stating that the child was safe with her. 13. Admitted in part; denied in part. It is admitted that Mother e-mailed Father on Tuesday, April 13, 2010. It is denied that Mother stated that she "ha[d] " the child and intend[ed] to keep him." By way of further answer, the e-mail from Mother informed Father of the child's safety, that his PSSA testing had been taken care of, and that the child was afraid to go back to Father. Mother also e-mailed Father on Wednesday, April 14, 2010. 14. Denied. By way of further answer, Mother had become aware of Father's recent behaviors in disciplining the child and was concerned for the child's safety. 15. Denied. By way of further answer, Mother's communications with the Pennsylvania State Police, the child's school, and Franklin County Children and Youth Services were truthful and based on her concern for the child's safety. 16. Denied. By way of further answer, the child was returned to the custody of Father on the afternoon of Wednesday, April 14, 2010. 17. Denied. a. Admitted. b. Admitted. C. Denied. By way of further answer, Mother believes it would be in the best interests of the child to obtain counseling services from a different professional, due to child's discomfort with his current counselor, Paul Scalia. Mother does not object to an evaluation of the child by a licensed psychologist trained to perform such evaluations, unlike Paul Scalia who is simply a licensed counselor. 18. Denied. WHEREFORE, as the exigency has been resolved, Mother respectfully requests that this Honorable Court dismiss Father's Petition for Special Relief. Respectfully submitted, -+1?i Date -, Ashley FergusonU Certified Legal Intern )6x 41 LU JOHNSTON-WA ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013-2899 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing Custody Complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. `h Dater J Alicia Rininger, Petitioner Alicia Rininger, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Steven R. Brown, Defendant/Petitioner NO. 03-5877 CIVIL TERM CERTIFICATE OF SERVICE I, Ashley Ferguson, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Answer to Petition for Special Relief on Kara Haggerty, Counsel for the defendant/petitioner, on April 21, 2010, by facsimile and by depositing a copy of the same in the United States mail, postage prepaid addressed to the following: Kara Haggerty, Esq. Abom & Kutulakis, LLP 2 West High Street Carlise, PA 17013 I verify that the statements made in this Affidavit of Service are true and correct to the best of my personal knowledge and 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 Ashley Ferguso Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ALICIA RININGER, NOW ALICIA GUYER IN THE COURT OF COMMON PLEAS OF PLAINTIFF V. STEVEN RAY BROWN DEFENDANT . CUMBERLAND COUNTY, PENNSYLVANIA 2003-5877 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW. _ Monday, April 19, 2010 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at- 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, May 18, 2010 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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/ Jacqueline M. Verney, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. JJ n A' ??t_ `Cumberland County Bar Association "1 °20 Vim` etl 32 South Bedford Street n Carlisle, Pennsylvania 17013 -,., s• =?o? o "Uc r Telephone (717) 249-3166 ?Z?r7 L.? . ?p • (b Nor?i Ce-? ??o "?O t f = o wtae?Jona?C? - Fo>c _ -? 1'2o'!0 co 0 N ALICIA RENE (BROWN) IN THE COURT OF COMMON PLEAS OF RININGER, CUMBERLAND COUNTY, PENNSYLVANIA Now ALICIA RENE GUYER, ; Plaintiff V. STEVEN RAY BROWN, : NO. 2003 - 5877 CIVIL TERM Defendant CIVIL ACTION -CUSTODY ORDER OF COURT AND NOW, this 21St day of APRIL, 2010, after conference with counsel and it appearing that the child has been returned to Father and it having been related that there is no evidence that the child is in immediate danger, the issues raised in Father's Petition for Special Relief shall be addressed at the upcoming conciliation. the Court t/ Kara W. Haggerty, Esquire MacDonald - Fox, Esquire Court Administrator :sld Edward E. Guido, J. N p ?11 t.. : O _j G: N Alicia Rininger, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW CUSTODY A, O • ?O Steven R. Brown, Defendant/Petitioner : NO. 03-5877 CIVIL TERM 0 CERTIFICATE OF SERVICE I, Ashley Ferguson, Certified Legal Intern, Family Law Clinic, hereby certify that Ik served a true and correct copy of the Pre-Hearing Memorandum of Respondent Alicia Rininger on Kara Haggerty, Counsel for the Defendant/Petitioner, on August 20, 2010, by facsimile and by depositing a copy of the same in the United States mail, postage prepaid addressed to the following: Kara Haggerty, Esq. Abom & Kutulakis, LLP 2 West High Street Carlise, PA 17013 I verify that the statements made in this Affidavit of Service are true and correct to the best of my personal knowledge and 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 Date Ashley Ferguson Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ABOM ?Z' j?LITLILAKIS Nara W. f Ia?ticrte. I;,yuirc ltromcc I.D. #: 86914 3 \Vcst I Jigh Strcct Carlislc, 1) \ 17013 71 319-0900 ALICIA RENE (BROWN) RININGER, Now ALICIA RENE GUYER, Plaintiff v. STEVEN RAY BROWN, Defendant " f;' - i'J 25 PM 3: 06 ,.._ CUMBEh?_N 1u 03UN Y PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-5877 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY PRAECIPE TO WITHDRAW AND DISCONTINUE TO THE PROTHONOTARY: Please withdraw and discontinue Defendant's Petition for Civil Contempt in the above-referenced custody action. The Hearing scheduled for Friday, August 27, 2010 at 9:30 a.m. is cancelled. Respectfully submitted, ABOM & KUTULAIM, L.L.P, t Date: r I l t' ,_ I t ff /C C4 .._ Kara W. Haggerty,,,Ets--.re 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Defendant F CERTIFICATE OF SERVICE AND NOW, this day of August, 2010, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing document, upon the Plaintiff by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Ashley P. Freguson Certified Legal Intern Anne MacDonald-Fox, Esquire Supervising Attorney Family Law Clinic 45 N. Pitt Street Carlisle, PA 17013 Respectfully submitted, AABOM & KUTUI.AKIS, L.L.P. DATE Kara W. Haggerty, Es e OM & ?TLILAKIS Kara W. Haggerty, Esquire Attorney I. D. #: 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 ALICIA RENE (BROWN) RININGER, Now ALICIA RENE GUYER, Plaintiff V. STEVEN RAY BROWN, Defendant FILED-OFFICE ',E Pti?0 t #ititt,k'is fr`%In, w: X011 APR 29 AN 10: 14 CUMBERLAND COUN PENNSYLVf HOA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-5877 CIVIL TERM CIVIL ACTION - LAW : IN CUSTODY TO THE HONORABLE EDWARD E. GUIDO, JUDGE OF SAID COURT: Petitioner, Steven Ray Brown, by and through his counsel, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P., files this Petition for Special Relief as follows: 1. On July 28, 2009, this Honorable Court entered an Order of Court providing Father with primary physical custody and Mother partial physical custody on alternating weekends during the school year of Kyler Steven Brown, born December 8, 2000. 2. Mother's last custodial weekend was exercised on Easter weekend, April 21, 2011 through April 25, 2011. Father was allowed time to spend time with Kyler on Easter Sunday. 3. On Monday, April 25, 2011, Kyler and two (2) other children were taken to Shippensburg, Pennsylvania with their bicycles by paternal uncle's girlfriend and dropped off to make their own way home. a. The distance between downtown Shippensburg and Kyler's uncle's home is in excess of four (4) miles. 7r - 00 fvl - 4 b. One child, the son of paternal uncle's neighbor, returned home and indicated he did not know where Kyler was. c. The neighbor, an acquaintance of Father, telephoned Father and advised him that Kyler's whereabouts were unknown, and advised him of the situation. d. Father contacted maternal uncle to determine Kyler's whereabouts and safety. When not provided with a satisfactory response, Father did go to maternal uncle's home. The police were contacted and appeared; however, no charges were filed against Father. e. Mother never contacted Father to advise of Kyler's whereabouts or safety. f. Father's concerns were compounded by the fact that Kyler was flown by helicopter to Hershey Medical Center two (2) years ago due to a severe bicycle accident. 3. On Tuesday, April 26, 2011, Mother did not send child to school. The Mother's reasoning was that the child was sick. Mother did not return the child to Father. a. Mother sent a text message to Father, called her attorney and contacted the police stating that she would not be taking the child to school on Tuesday. Mother never telephoned Father to advise him that Kyler was ill or would not be going to school. 4. On Wednesday, April 27, 2011, Mother once again did not send child to school and once again the child was not returned to Father. a. Father learned from the school that Kyler would likely not be in for the remainder of the week as Mother had requested his assignments for the week. b. Mother sent Father text messages stating that Kyler would not be going to school or being returned to Father. Mother never provided Father a reason for said action. c. Father had to contact the Pennsylvania State Police to ensure the child's safety as he was completely unable to contact the child at all. 5. It is believed and therefore averred that Mother is alienating the child from Father and poisoning the child's mind against Father. 6. Father has had no contact with Kyler since Easter Sunday. 7. It is believed and therefore averred that Mother has informed Kyler of the incident between Father and maternal uncle, has told the child that Father was arrested and possibly in jail. a. Despite the fact that these allegations are untrue, Mother is involving Kyler in the custody matter in a completely inappropriate fashion by lying to him and alienating him against his Father. 8. Mother scheduled and attended an appointment for Kyler and herself with Kyler's counselor, Mark Keck of Manito, Inc., on Wednesday, April 27, 2011. a. Undersigned counsel spoke with Mark Keck who indicated that he does not know Kyler or the parties well enough at this point to make a statement regarding custody; however, he indicated that the communication problems between Mother and Father are having an adverse impact on Kyler. b. Kyler has been regularly attending counseling at Manito for over two (2) years, but his counselor, Paul Scalia, unexpectedly passed away approximately one month ago and Kyler was reassigned to Mr. Keck. 9. Father is willing to undertake any action in order to improve the communication between himself and Mother. a. At previous court proceedings, the court had ordered the parties to communicate daily via email, but Mother cancelled her email account in May 2010. b. When Father attempts to contact Mother via telephone, Mother reports this communication to the police as harassment. c. When Father attempts to speak to Mother regarding issues about Kyler, Mother simply hangs up the telephone. d. When Father attempts to speak to Kyler during his court-ordered times while Kyler is with his Mother, Mother listens to the conversations and ends the calls after a minute or two. 10. It is believed and therefore averred that Mother refuses to facilitate any relationship with Father for the benefit of Kyler. 11. It is believed and therefore averred that it is in the child's best interests for him to be immediately returned to the custody of his Father. 12. It should be brought to the attention of This Honorable Court that Mother withheld the child from Father exactly one (1) year ago resulting in a similar petition being filed before This Court. 13. It is believed and therefore averred that it is in the best interest of the child to limit his contact with his Mother to supervised visitation until both she and the child are evaluated by mental health professionals. 14. It is believed and therefore averred that Mother's actions have been malicious and willful in nature solely to interfere and thwart Father's relationship with the child and have not been in the child's best interests. WHEREFORE, Petitioner respectfully requests that this Honorable Court grant the request for Special Relief and immediately direct Mother to return the child to Father. It is further requested that Mother's periods of custody be suspended until a hearing may be held on this petition. Respectfully submitted, Date: 4I2q I 1 t ?t ABOM & KUTULAKIS, LLP \J1 "(k OMMU Kara W. Haggerty, squire 2 West High Street Carlisle, PA 17013 (717) 249-0900 ID #86914 VERIFICATION I, Steven Brown, verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date STEVEN BRO AND NOW, this 28 h day of April, 2011, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Petition for Special Relief, upon the counsel for Plaintiff/Respondent by depositing, or causing to be deposited, same in the United States Mail, postage prepaid addressed to the following: Megan Riesmeyer Family Law Clinic Penn State Dickinson School of Law 45 North Pitt Street Carlisle, PA 17013 Respectfully submitted, Abom & Kutulakis, L.L.P. Kara W. Haggerty, squire Attorney ID No.86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 i ALICIA RENE (BROWN) RININGER, Now ALICIA RENE GUYER, Plaintiff V. STEVEN RAY BROWN, Defendant AND NOW, this 2 1' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-5877 CIVIL TERM c ° CIVIL ACTION -LAW -;o rnr- IN CUSTODY cnr- F\) $ c- r i ORDER OF COURT day of 2011, upon consideration of the Petition for Special Relief, said Petition is hereby GRANTED. Plaintiff is directed to immediately return the child to the custody of his Father, Steven Brown. Plaintiff s periods of custody are suspended until hearing is held on the within Petition. Law enforcement authorities are directed to assist in the enforcement of this Order. An emergency hearing is scheduled for the S' day of /17-4Y , 2011, at i/.•ob Lm. in Courtroom No. 3 of the Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, Distribution: V Kara W. Haggerty, Esquire ? Megan Riesmeyer, Esquire i JAOV ti?9 Guido, J. _ ABOM ?' KUTLIL,AKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 2 West High Street Carlisle, PA 1701; (717) 249-0900 ALICIA RENE (BROWN) RININGER, Now ALICIA RENE GUYER, Plaintiff V. STEVEN RAY BROWN, Defendant PRAECIPE TO WITHDRAW AND DISCONTINUE TO THE PROTHONOTARY: Please withdraw and discontinue Defendant's Petition for Special Relief in the above-referenced custody action. The Hearing scheduled for Thursday, May 5, 2011 1= ILED-O F C Gh F THE PR0TH0?ff7 'f'", ,,, 2011 MAY -3 AH 11: 33 CUMBERLAND GOUN T'J` PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003-5877 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY at 11:00 a.m. is cancelled. Respectfully submitted, Date: 5 't3- ? /I ABOM & KUTULASIS, L.L.P. Kara W. Haggerty, F 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Defendant CERTIFICATE OF SERVICE AND NOW, this 3rd day of May, 2011, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing document, upon the Plaintiff by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Megan Riesmeyer, Esquire Family Law Clinic Penn State Dickinson School of Law 45 N. Pitt Street Carlisle, PA 17013 Respectfully submitted, ABOM & KUTULAKM, L.L.P. DATE G' Kara W. Haggerty ALICIA RENE (BROWN) RININGER, Now ALICIA RENE GUYER, Plaintiff v. STEVEN RAY BROWN, Defendant 1j IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-5877 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY cs c ro? zm r- _..^_ f=> C? N -n =r -n r ?o .P- C? -4o -C -n C.3 AND NOW, this _;_V day of , 2011, upon consideration of the Petition for Special Relief, y eno s o e 04 SUFArnemen r. ?. A An emergency hearing is scheduled for the 4 G day of , 2011, at / `,b .m. in Courtroom No. ? of the Cumberland County Courthouse, Carlisle, Pennsylvania. Distribution: ?Kara W. Haggerty, Esquire Garret Brouwer, Esquire - Family Law Clinic 00P ?? ham' ALICIA (BROWN) RININGER, : IN THE COURT OF COMMON PLEAS OF Now ALICIA RENE GUYER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. STEVEN RAY BROWN, NO. 2003 - 5877 CIVIL TERM r co Defendant : ? x -<>. C CIVIL ACTION - LAW - r] vZ >>? ORDER OF COURT t AND NOW, this 6TH day of JUNE, 2011, we will hold a follow up hearing on FRIDAY, JUNE 17, 2011, at 1:00 p.m. Pending said hearing Father's visitation with the child shall be limited to his attendance at sessions with the child's counselor. B Court, Edward E. Guido, J. Garret Brouwer, CLI Family Law Clinic ,/ Kara W. Haggerty, Esquire Mo? C?Pi it 1,1 o*b :sld r r ti ALICIA (BROWN) RININGER now ALICIA RENE GUYER, Plaintiff V. STEVEN RAY BROWN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003-5877 CIVIL TERM ORDER OF COURT AND NOW, this 17th day of June, 2011, after hearing, this matter is continued yet again to July 11, 2011, at 2:30 p.m. Pending said hearing, our Order of May 26, 2011, shall remain in full force and effect. Pending said hearing, Kyler shall attend weekly sessions with Mr. Keck, which shall also be attended by Mr. Brown. In addition, Kyler will visit with his Father on the following schedule: June 18, 2011, from 9:00 a.m. until 9:00 p.m., on June 19, 2011, from 9:00 a.m. until 5:00 p.m., on June 22, 2011, from 9:00 a.m. until 5:00 p.m., on June 25, 2011, from 9:00 a.m. until 5:00 p.m., on June 29, 2011, from 9:00 a.m. until 5:00 p.m., on July 2, 2011, from 9:00 p.m. until 5:00 p.m., on July 6, 2011, from 9:00 a.m. until 5:00 p.m., on July 9, 2011, from 9:00 a.m. until 5:00 p.m. Provided, however, that during Father's periods of visitation the child shall have in his possession at all times his cell phone. If at any time he wants to end the visitation, he may call Mother. Kyler shall not be prohibited from calling his Father at any time. o?O/I JON- c9c) 17L? By the Court, Edward E. uido, J. /Garret Brouwer, Certified Legal Intern Megan. Riesmeyer, Esquire Family Law Clinic / For the Plaintiff Kara W. Haggerty, Esquire For the Defendant Copivs MaA ted u VI,srs ALICIA (BROWN) RININGER, : IN THE COURT OF COMMON PLEAS OF now ALICIA RENE GUYER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. -ox STEVEN RAY BROWN zmw c- r CIVIL ACTION - LAW cz r` -vim Defendant NO. 2003-5877 CIVIL TEfj6 o :I-- C-3 ORDER OF COURT c -4 C17 wa: AND NOW, this 11th day of July, 2011, after -i' hearing we are satisfied that father is not a danger to the child, and based upon the testimony of Mr. Keck, that the child has overcome his anxiety about reunification. Consequently, the custody order of July 28, 2009, shall be reinstated. It is further ordered and directed as follows: 1. Kyler shall have unlimited access to call or talk to either parent while in the custody of the other parent. He is to be allowed to have his own cell phone and to keep it in his possession at all times. If I find that either party violates any portion of the order but particularly that one, I will come down hard in a contempt proceeding. 2. The child shall participate in counseling with Mr. Keck until he is successfully discharged. The custodial parent shall make sure that he makes all of those sessions. 3. The parents are directed to begin co-parent counseling with an agreed upon counselor. If the parties cannot agree, they shall counsel with Mr. Keck. By the Court,.. Edward E. Guido, J. f Garret Brouwer, CLI Megan Riesmeyer, Esquire Family Law Clinic For the Plaintiff Kara W. Haggerty, Esquire For the Defendant :lfh ALICIA (BROWN) RININGER, IN THE COURT OF COMMON PLEAS OF now ALICIA RENE GUYER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. STEVEN RAY BROWN, CIVIL ACTION - LAW C C= Defendant rncao C_ NO. 2003-5877 CIVIL TERI r- r*t ORDER OF COURT CD--- qc:) AND NOW, this 11th day of July, 2011, aftAW-Cc. 3 " c^ c3 _n n ? M cn r- several hearings in this matter, this Court has serio concerns about the emotional well-being of the parties' child, Kyler Steven Brown, as a result of the parents' total inability to agree upon anything. The child has been required to attend counseling, there have been allegations of physical and mental abuse going back and forth, and mother and dad cannot even agree upon the time of day. The child's primary residence is in Franklin County. We believe that Children and Youth involvement is necessary for the emotional well-being of this child. As a result, we are making a copy of this order available to Franklin County Children and Youth. v/ Garret Brouwer, CLI Megan Riesmeyer, Esquire [A? Family Law Clinic M For the Plaintiff Kara W. Haggerty, For the Defendant Esquire :lfh r:awara E. Guido, J. Alicia Rene (Brown) Rininger, Now Alicia Rene Rininger Plaintiff vs. Steve R. Brown, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5877 CIVIL ACTION - LAW CUSTODY C-) c rn M .Z r+1 ;C;;o Cn N c c? t? rrn -urn C-) . , PETITION FOR LEAVE TO WITHDRAW Petitioner, The Family Law Clinic, hereby petitions for leave to withdraw from further representation of Alicia Rene (Brown) Rininger, pursuant to Pa. R.P.C. 1.16(b)(4 - 5) and Pa.R.C.P. 1012(c), and in support therefore avers the following: The Family Law Clinic entered an appearance in the above captioned matter on behalf of Alicia Rene (Brown) Rininger, on May 6, 2004. 2. An Order of Court was issued on July 28, 2009, granting Alicia Rene (Brown) Rininger shared legal and periods of partial physical custody. 3. The Family Law Clinic believes that it can no longer represent Ms. Rininger in a manner consistent with the Pennsylvania Rules of Professional Conduct Rule 1.16(b) in that irreconcilable differences have arisen between the Family Law Clinic and Ms. Rininger which have made further representation of her unreasonably difficult. 4. Pursuant to Pa.R.C.P. 1012(d): the Plaintiff's address is 2825 Orrstown Road, Shippensburg, PA, 17257. The Family Law Clinic has served copies of the petition on Ms. Rininger and Attorney Haggerty via first class mail. 5. Attorney Haggerty has consented to the relief we have requested in this petition. 6. The Honorable Judge Guido has previously ruled in this matter. WHEREFORE, pursuant to Pa. R.P.C. 1.16(b), an attorney may withdraw from ;."9 representation if the aforementioned criteria are met. Because we believe we do, the Family Law Clinic respectfully requests the leave of the court to withdraw from this action. Date: . ?6 f I I (Loll Respectfully Submitted, Garret Brouwer Certified Legal Intern MEGAN RIESMEYER THOMAS M. PLACE ROBERT E. RAINS ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 VERIFICATION I verify that the statements made in the foregoing Petition for Leave to Withdraw are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date ql l u L' W OftiYA . Garret Brouwe Student Attorney .1 Alicia Rene (Brown) Rininger, Now Alicia Rene Rininger Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5877 C= C yi Steve R. Brown, CIVIL ACTION - LAW -; Defendant CUSTODY X 7Q r _ ?t Sw' cn 4? ? ORDER OF COURT AND NOW, this day of August , 2011, upon consideration of the attached Petition for Leave to Withdraw, it is hereby Ordered that the Family Law Clinic is granted leave to withdraw as counsel for Alicia Rene (Brown) Rininger. BY WRR J. Cc The Family Law Clinic, Counsel for Plaintiff ?Kara Haggerty, Esq., Counsel for Defendant M?? C'pie511411 ALICIA R. RININGER, : IN THE COURT OF COMMON PLEAS OFF , Plaintiff : CUMBERLAND COUNTY,PENNSY0A1A v. : No. 2003-5877 CIVIL TERM ' ° ; ( N cr. _te r STEVEN R. BROWN, • r; .. , r Via, Defendant : IN CUSTODY PETITION TO MODIFY CUSTODY AND NOW, comes Petitioner, Steven R. Brown, by and through his counsel, Drew F. Deyo, Esquire, and in support of his Petition to Modify Custody, respectfully avers as follows: 1. Petitioner is Steven R. Brown, who currently resides at 7001 Olde Scotland Road, Shippensburg, PA 17257. 2. Respondent is Alicia R. Rininger, who currently resides at 198 Black Gap Road, Lot 130, Fayetteville, PA 17222. 3. The Parties are the natural parents of Kyler Steven Brown, born December 8, 2000. 4. On July 11, 2011, this Honorable Court entered an Order adopting a previous Custody Order that was entered on July 28, 2009. A true and correct copy of the July 11, 2011 Order is attached hereto as Exhibit "A". A true and correct copy of said Custody Order of July 28, 2009, is attached hereto as Exhibit `B". 5. Since the entry of said Order, there has been a significant change in circumstances in that: a) Respondent has refused to communicate with Petitioner regarding the child. b) Respondent has refused Court-Ordered counseling. c) Respondent will not allow the child to have contact with Petitioner when Respondent is exercising physical custody. �3•DD Pd• 4 At a S 7.37 d) Respondent has allowed an individual with an extensive criminal history, including crimes enumerated in Rule 5329,to move into her home where she exercises physical custody of the child. e) It is believed and therefore averred that Respondent uses and allows others in her home, including minors, to use illegal drugs. 6. The best interest of the child will be served by the Court modifying said Order. WHEREFORE, Petitioner prays this Court to grant the modification of the Custody Order as follows: 1. Grant Petitioner Primary Physical Custody of the Child with agreed upon Partial Custody to Respondent. 2. Any other requirements this Honorable Court deems appropriate. Respectfully submitted, DEYO & K LLING Date: I /2(51 3 re Deyo, Es• are 50 East High Street Carlisle, PA 17013 (717) 386-5639 Supreme Court ID# 308857 Attorney for Petitioner, Steven R. Brown ALICIA R. RININGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2003-5877 CIVIL TERM • • STEVEN R. BROWN, Defendant • IN CUSTODY AVEREMENT I, Drew F. Deyo, Esquire, do hereby aver that to the best of my belief and my knowledge, the opposing party, Alicia R. Rininger, is not represented by counsel. Daterr 3 Respectfully Submitted, DEYO&KULLING 4 r,. ,- Drew F. i ey r s s ire 50 Eas High Street Carlisle, PA 17013 (717) 386-5639 Supreme Court ID # 308857 Attorney for Petitioner, Steven R. Brown VERIFICATION I certify that the facts in this Petition are true and correct to the best of my knowledge and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. 4904,relating to unsworn falsification to authorities. Date: IC - - _ - - • \ k+ • (;:•i, • C L1) fl3V5T (.; ;_,c1 t L . y --( ; ;Ph") ; y•cr..1 c ; '•••.• ); ,„i• ••••v C c• . c. c • ' S TRUE COPY FR't314.4 In Testimony whereof, here unit) and the seat of said Court at Cal J , Prt, \\ This day iii ' i3j4 , f,r(,thc,itotary (1 ALICIA (BROWN) RININGER, . IN THE COURT OF COMMON PLEAS OF now ALICIA RENE GUYER, CUMBERLAND COUNTY, PENNSYLVANIA Plain tiff V. STEVEN RAY BROWN, CIVIL ACTION - LAW Defendant NO. 2003-5877 CIVIL TERM ORDER OF COURT AND NOW, this 11th day of July, 2011, after hearing we are satisfied that father is not a danger to the child, and based upon the testimony of Mr. Keck, that the child has overcome his anxiety about reunification. Consequently, the custody order of July 28 , 2009, shall be reinstated. It is further ordered and directed as follows : 1 . Kyler shall have unlimited access to call or talk to either parent while in the custody of the other parent . He is to be allowed to have his own cell phone and to keep it in his possession at all times . If I find that either party violates any portion of the order but particularly that one, I will come down hard in a contempt proceeding. 2 . The child shall participate in counseling with Mr. Keck until he is successfully discharged. The custodial parent shall make sure that he makes all of those sessions . 3 . The parents are directed to begin co-parent counseling with an agreed upon counselor. If the parties cannot agree, they shall counsel with Mr. Keck. By the Court_, _ - „, Edward E. Guido, J . Garret Brouwer, CLI TRUE COPY FROM RECORD Megan R L Clinic i r, Esquire In Testimony whereof, I here unto set my hand Family Law aw Clinic and the ofsaidCou atCadislZO For the Plaintiff y, Thia" '� ot Prothonotary Kara W. Haggerty, Esquire For the Defendant : lfh • . / ALICIA R. RININGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS : NO . 2003-5877 CIVIL BERM STEVEN R. BROWN, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 28th day of July, 2009, after hearing, all prior custody orders are vacated and replaced with the following : 1 . The Mother, Alicia Rene Rininger and the Father, Steven Ray Brown, shall have shared legal custody of Kyler Steven Brown, born December 8 , 2000 . Each parent shall have an equal right , to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child' s general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 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 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 . Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist , teacher or authority and copies of any reports given to them as parents including, but not limited to : Medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pi ctures, extracurricular activities, sports, children' s parties, musical presentations, back-to-school nights, and the like. The parties shall cooperate with the child ' s counselor. 2 . Father shall have primary physical custody of Kyler Steven Brown at all times, except when Kyler is in the partial physical custody of his mother according to the following schedule : a. During the summer on alternating weeks from Thursday at 5 : 00 p.m. until Tuesday at 5 : 00 p.m. The transfer to be at the Shippensburg Police Station and to be accomplished without the participation of either parent . No videotaping is permitted. b. During the school year on alternating weekends from Thursday after school until Monday at the beginning of school . Mother is to pick the child up from school on Thursday and deliver the child to school on Monday. c . Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day shall be shared such that Father shall always have physical custody from 9 : 00 a .m. to 3 :00 p.m. and Mother shall always have physical custody from 3 : 00 p .m. to 9 : 00 p . m. In addition, Father shall have custody of the child on trick or treat night from 6 : 00 p.m. to 8 : 30 p .m. d. Christmas shall be divided into two blocks : Block A shall be from Christmas Eve at 12 noon until Christmas Day at 12 noon, and Block B Shall be from Christmas Day at 12 noon to December 26 at 12 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years . Father shall have Block A in even numbered years and Block B in odd numbered years . e . Both Father and Mother shall each have up to two weeks of vacation with Kyler each summer. The first parent to notify the other parent in writing of a chosen week shall have priority for that week. All vacation weeks must be chosen by May 1 of each year. 3 . During Mother ' s time of physical custody, she shall ensure that the child attends all sport practices , games, meets, etc . If Mother is unable to see that the child attends said functions, she shall notify Father at least 24 hours in advance so that he may transport the child to said functions . 4 . The custodial parent shall ensure that the child makes telephone contact with the noncustodial parent every Wednesday and Sunday evening between 8 : 00 and 9 : 00 p .m. The calls are to be made from the custodial parent ' s cell phone so that the records may be produced in court . 5 . The parties shall e-mail each other on a daily basis to discuss matters concerning their son. The e-mail shall be initiated by the custodial parent and responded to by the noncustodial parent . Conies of all e-mails shall be preserved to be presented as an exhibit in any future proceedings . 6 . Neither party may smoke in their homes or in their cars when the child is present . 7 . Neither party shall permit contact between the child and the Oasis of Love Church or attend that church ' s functions 8 . Neither party shall do or say or permit a third party to do or say anything that may estrange the child from the other parent , injure the opinion of the child as to the other parent, or hamper the free and natural development of the child ' s love and respect for the other parent . 9 . Neither party may consume alcohol to the point of intoxication or illegal or non-prescribed drugs prior to or during their periods of custody . • Py t :, Court Edw!rd:ild:e, J. Krystal J. Maclntyre, Certified Legal Intern Anne MacDonald-Fox, Esquire Family Law Clinic 45 North Pit: Street Carlisle, PA 17013 For the Plaintiff Kara W. Haggerty, Esquire Abom & Kutulakis 2 West High Street Carlisle, PA 17013 For the Defendant :mlc Li • F, =- `r,•,` • tWVE E:it cry teat:-,. ii • pa. , • , 4„. cr::v • - A(//4.041'...-.400,41,,- PM.970C41+a ALICIA R. RININGER, • IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA • v. • No. 2003-5877 CIVIL TERM • STEVEN R. BROWN, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Drew F. Deyo, Esquire, do hereby certify that I served copies of the Petition to Modify upon the following by U.S. Mail, First Class, Return Receipt Requested, addressed as follows: Alicia R. Rininger 198 Black Gap Road, Lot 130 Fayetteville, PA 17222 Respectfully submitted, DEYO & KULLING Date: j( qt 3 Pre . De •, E •uire 50 East High Street Carlisle, PA 17013 (717) 386-5639 Supreme Court ID # 308857 Attorney for Petitioner, Steven R. Brown / " ( I' C(, a R- , g_. - t\,/�ln z, IN THE COURT OF COMMON PLEAS Plaintiff �J CUMBERLAND COUNTY, PA Vs No. GO — -1 -7 CIVIL TERM ��' e- =� il , �j(�MJ/1 CIVIL ACTION - LAW Defendant IN CUSTODY rn rTl E'er 11.1 / CRIMINAL RECORD/ABUSE HISTORY VERIFICATION c-.D fit I, 4 A1C. 1 �,., PR )-t4. ( , hereby swear or affirm, subject to pe fiites 6# law including 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities that: 1. 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 Crime Self Other Date of Sentence all that household conviction, apply member guilty plea, no contest plea or pending charges 18 Pa.C.S. Ch. 25 (relating to criminal, homicide) 18 Pa.C.S. §2702 (relating to aggravated assault) 18 Pa.C.S. §2706 (relating to terroristic threats) 18 Pa.C.S. §2709.1 E -' (relating to stalkingl F 18 Pa.C.S. §2901 (relating to kidnapping) 18 Pa.C.S. §2902 I (relating to unlawful restraint) 18 Pa.C.S. §2903 fT Ir (relating to false imprisonment) 18 Pa.C.S. §2910 CT IT (relating to luring a child into a motor vehicle or structure) 18 Pa.C.S. §3121 IT (relating to rape) 18 Pa.C.S. §3122.1 IT CT relating to statutory sexual assault) 18 Pa.C.S. §3123 IT (relating to involuntary deviate sexual intercourse) C 18 Pa.C.S. §3124.1 IT (relating to sexual assault) r 18 Pa.C.S. §3125 CT fT (relating to aggravated indecent assault) 18 Pa.C.S. §3126 FT (relating to indecent assault) 18 Pa.C.S. §3127 IT IT (relating to indecent exposure) 18 Pa.C.S. §3129 7 CT (relating to sexual intercourse with animals) 18 Pa.C.S. §3130 CT (relating to conduct relating to sex offenders) 18 Pa.C.S. §3301 -- - (relating to arson and related offenses) 18 Pa.C.S. §4302 (relating to incest) 18 Pa.C.S. §4303 IT IT (relating to concealing death of child) ITT 18 Pa.C.S. §4304 r- (relating to endangering welfare of children) 18 Pa.C.S. §4305 I- (relating to dealing in infant children) 18 Pa.C.S. §5902(b) CT IT (relating to prostitution and related offenses) 18 Pa.C.S. §5903 r— 17 (c) or (d) (relating to obscene and other sexual materials and performances) 18 Pa.C.S. §6301 CT 17 (relating to corruption of minors) 18 Pa.C.S. §6312 I I (relating to sexual abuse of children) ��- 18 Pa.C.S. §6318 IT (relating to unlawful contact with minor) 18 Pa.C.S. §6320 I r (relating to sexual exploitation of children) 23 Pa.C.S. §6114 IT I! (relating to contempt for violation of Protection order or agreement) Driving under the (7/rl it A 40 influence of drugs or alcohol Manufacture, sale, IT 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 Self Other Date all that household apply member A finding of abuse by a Children &Youth Agency or similar agency in Pennsylvania or similar statute in another jurisdiction ET Abusive conduct as defined under the I r Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction Other: E 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child : 5. If you are aware that the other party or members of the 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 ALICIA R. RININGER IN THE COURT OF COMMON PLEAS OF_2 PLAINTIFF CUMBERLAND COUNTY, PENNSYLVAMA 2003-5877 CIVIL ACTION LAW ,r— I :;,-), STEVEN R. BROWN ` —' •` DEFENDANT IN CUSTODY > : > .c . y ORDER OF COURT AND NOW, Monday, December 02,2013 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney,Esq. , the conciliator, at 4th Floor,Cumberland County Courthouse,Carlisle on Tuesday,January 07,2014 3:30 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/ Jacqueline M. Verney, Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association �fS1 32 South Bedford Street Carlisle, Pennsylvania 17013 ` Telephone (717) 249-3166 'a . �INIAI 8Z. 3lf3 --r r1l 4 3 M� ALICIA R.RININGER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : 2003-5877 CIVIL ACTION-LAW STEVEN R.BROWN, Defendant : IN CUSTODY ORDER OF COURT AND NOW,this /D day of 11/? Anti 2 , 2014, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated July 11, 2011 and July 28, 2009 shall remain in full force and effect with the following modifications and additions. 2. The parties shall cooperate with counseling for the child with Mr. Keck. Father shall be responsible for contacting Mr. Keck to reinstate the counseling. 3. The parties shall cooperate with co-parenting counseling with Mr. Keck. Father shall be responsible for contacting Mr. Keck to begin the counseling. 4. Mother shall file a Criminal History affidavit for herself and the members of her household within 14 days of the date of this Order and serve a copy on Father's counsel. 5. This Order is entered pursuant to an agreement of the parties at 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. Another Conciliation Conference is scheduled for Tuesday, February 11,2014 at 9:30 a.m. BY T,3" O RT, Edward E. Guido, J. cc: 9'ew F. Deyo, Esquire, Counsel for Father = 5 ,/Alicia R. Rininger, pro se 198 Black Gap Road Lot 130 L> ' Fayetteville, PA 17222 _, ' ecri'es rea t /he/if _ 4-. ALICIA R.RININGER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : 2003-5877 CIVIL ACTION-LAW • • STEVEN R.BROWN, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido,J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyler Steven Brown December 8, 2000 Father 2. A Conciliation Conference was held January 7, 2014 with the following individuals in attendance: Father, Steven R. Brown,with his counsel, Drew F. Deyo, Esquire and Mother, Alicia R. Rininger,pro se. 3. The Honorable Edward E. Guido previously entered Orders of Court dated July 11, 2011 reinstating the Order of Court of July 28, 2009 providing for shared legal custody,Father having primary physical custody and Mother having alternating weekends, Thursday to Monday during the school year and week on/week off during the summer. 4. The parties agreed to an Order in the form as attached. _ Y Date acqu ne M. Verney, Esquire Custody Conciliator ALICIA R.RININGER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : 2003-5877 CIVIL ACTION-LAW STEVEN R.BROWN, • Defendant : IN CUSTODY ORDER OF COURT AND NOW,this 1.44A1\day of I- e ls/wel2 ,2014,upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: _ 1. _ - • 6 - •. - - -s 'usge i -;e -, - J a clay of couatxeeilitter _ • . -- :- • Mu .arties are • -- • - a emen wit the Court and the other party • - ••' - t vania 'u e o ivi 'roce•ure c -4. 2. A Hearing is scheduled in Court oom. o. , of the Cumberland County Court House, on the "'t`day of , 2014, at 1• 30 o'clock, / . M., at which time testimony will be taken. For purposes of this Hearing, Father shall be deemed to be the moving party and shall proceed initially with testimony. 3. The prior Orders of Court dated July 11, 2011, July 28, 2009 and January 10,2014 shall remain in full force and effect. 4. 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 TH• OU'T, / Edward E. Guido, J. CS cc:pfew F. Deyo, Esquire, Counsel for Father -o a Alicia R. Rininger,pro se w rTi �,x- 198 Black Gap Roads OD c; Lot 130 c ,�-- Fayetteville, PA 17222 �t� mac? <-: CffiDi'es ""_ a �s�iflr) y • ALICIA R.RININGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : 2003-5877 CIVIL ACTION-LAW • STEVEN R.BROWN, Defendant : IN CUSTODY PRIOR JUDGE: Edward E. Guido,J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8,the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Kyler Steven Brown December 8,2000 Father 2. A Conciliation Conference was held February 11, 2014 with the following individuals in attendance: Father, Steven R. Brown,with his counsel, Drew F. Deyo and Mother, Alicia R. Rininger,pro se,by telephone. 3. The Honorable Edward E. Guido previously entered an Orders of Court dated July 11,2011,July 28, 2009 and January 10, 2014 providing for shared legal custody, Father having primary physical custody and Mother having Thursday to Monday during the school year and and Thursday to Tuesday during the summer. Mother was to submit a criminal history affidavit for herself and household members within 14 days of the Order of Court dated January 10, 2014. 4. Father filed a Petition to Modify Custody. 5. Father's position is as follows: Father seeks shared legal and primary physical custody with Mother having periods of physical custody as agreed. Father asserts that Mother refuses to communicate with him regarding the child,that she has refused to cooperate with court-ordered counseling for the child and co-parenting counseling, and that Mother has permitted a person to move into her home who has an extensive criminal history. Father maintains that Mother has failed to submit the criminal history affidavit. 6. Mother's position on custody is as follows: Mother seeks to maintain the status quo. She asserts that the Prothonotary's office told her the affidavit was not to be files with it. She maintains that Father has not submitted his affidavit to her and that Father has criminal charges pending. She asserts that she has attempted to comply with counseling but when she contacted the counselor he indicated a new counselor needed to be obtained as his office no longer accepts Father's insurance. 7. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the status quo. It is expected that the Hearing will require one-half day. Date /Jacqueline M. Verney, Esquire Custody Conciliator ALICIA R. RININGER : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PA 3 vs. : NO. 2003-5877 CIVIL TERM ! --, __ STEVEN R. BROWN, Defendant : CIVIL ACTION—LAW IN CUSTOpr:, PETITION FOR SPECIAL RELIEF AND NOW, comes Petitioner, Steven Brown, by and through his attorney, Drew F. Deyo, Esquire, and avers the following in support of this Petition for Emergency Relief 1. Petitioner is Steven R. Brown,who currently resides at 7001 Olde Scotland Road, Shippensburg,PA 17257. 2. Respondent is Alicia R. Rininger, an adult individual residing at 198 Black Gap Road, Lot 130, Fayetteville, PA 17222. 3. The parties are the natural parents of Kyler S. Brown, born December 8, 2000. 4. The minor child currently resides with Petitioner at 7001 Olde Scotland Road, Shippensburg, PA 17257, but spends every other weekend with Respondent at 198 Black Gap Road, Lot 130, Fayetteville, PA 17222. 5. The Mother of the minor child is Respondent, Alicia R. Rininger, who currently resides at 198 Black Gap Road, Lot 130, Fayetteville, PA 17222 6. The Father of the minor child is Petitioner, Steven R. Brown, who currently resides at 7001 Olde Scotland Road, Shippensburg, PA 17257. 7. On July 28, 2009, the Honorable Judge Edward Guido entered an Order awarding Petitioner primary physical custody of the minor child, and on July 11, 2011, entered an additional Order requiring the parties, as well as the child,to participate in counseling. True and 1.40 rd. cb, 044 3 o a3gF correct copies of these Orders are attached to this petition as Attachments A and B, respectively. 8. The best interests and permanent welfare of the child will be served by granting the emergency relief requested because: (a) On Sunday, January 26, 2014, during Respondent's period of custody, the minor child found marijuana and paraphernalia in Respondent's home. Sean Connor, Respondent's boyfriend, blamed the minor child for possessing the marijuana, and sent a message to Petitioner stating the same. Mr. Connor then threatened harm upon Petitioner in the presence of the minor child, and told the minor child that if the minor child ever comes back to the home, Mr. Connor would"make [the minor child's] life a living hell." The minor child promptly called Petitioner to pick him up from Respondent's home, which Petitioner did. (b) Since the incident on January 26, 2014, the minor child has refused to go to Respondent's house because Mr. Connor is still living there; the minor child has spent time with Respondent at alternative locations. Mother's next weekend of custody begins March 6, 2014. (c) The minor child has missed two custody weekends at Respondent's home since the incident on January 26, 2014 involving Mr. Connor. (d) It is believed and therefore averred that Mr. Connor has an extensive criminal history, including crimes that fall under the purview of 23 Pa.C.S. §5329. (e) Despite an Order from Conciliator Jacqueline Verney, Esquire,that the parties provide Criminal History Affidavits, Petitioner has yet to receive an Affidavit from Respondent or her boyfriend, Mr. Connor. 9. There is a custody hearing currently scheduled for April 9, 2014. 10. Petitioner is filing this Emergency Petition because it is in the child's best interest to remain in Petitioner's custody until a hearing, and there are three scheduled weekends of custody at Respondent's residence before the hearing set for April 9, 2014. 11. It is believed and therefore averred that Respondent's residence is not safe for the minor child because the minor child is exposed to drug use at Respondent's home, and because Mr. Connor, who is known to have an extensive criminal history, has failed to provide a Criminal History Affidavit. 12. In addition, the minor child refuses to go to Respondent's residence. WHEREFORE, Petitioner respectfully requests this Honorable Court to enter an Emergency Order granting him full primary physical custody of the minor child, and to suspend Respondent's periods of weekend custody until a hearing in this matter. Respectfully submitted, DEMO & KULLING Date: February 28, 2014 Drew F. Deyo, E • ire 401 East Louther Street Carlisle, PA 17013 (717) 386-5639 Supreme Court ID# 308857 Attorney for Petitioner, Steven R. Brown 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. Steven R. Brown Petitioner ALICIA R. RININGER : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PA vs. : NO. 2003-5877 CIVIL TERM • • STEVEN R. BROWN, Defendant : CIVIL ACTION—LAW IN CUSTODY CERTIFICATE OF SERVICE I, Drew F. Deyo, Esquire, do hereby certify that I served copies of the Petition for Special Relief upon Plaintiff/Respondent by U.S. Mail, First Class, postage prepaid, addressed as follows: Alicia Rininger 198 Black Gap Road, Lot 130 Fayetteville, PA 17222 Respectfully submitted, DEYO & KULLING Date: February 28, 2014 D -w F. Deyo •squire 401 East Louther Carlisle, PA 17013 (717) 386-5639 Supreme Court ID# 308857 Attorney for Petitioner, Steven R. Brown . . • 1 . ALICIA R. RININGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS : NO. 2003-5877 CIVIL TERM STEVEN R. BROWN, : CIVIL ACTION - LAW Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 28th day of July, 2009, after hearing, all prior custody orders are vacated and replaced with the following : 1 . The Mother, Alicia Rene Rininger and the Father, Steven Ray Brown, shall have shared legal custody of Kyler Steven Brown, born December 8 , 2000 . Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child' s general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 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 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 . Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist , teacher or authority and copies of any reports given to them as parents including, but not limited to: Medical records, birth certificates, school or educational attendance records or report cards . Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, sports, children' s parties, musical presentations, back-to-school nights, and the like. The parties shall cooperate with the child' s counselor. 2 . Father shall have primary physical custody of Kyler Steven Brown at all times, except when Kyler is in the partial physical custody of his mother according to the following schedule : a. During the summer on alternating weeks from Thursday at 5 : 00 p.m. until Tuesday at 5 : 00 p.m. The transfer to be at the Shippensburg Police Station and to be accomplished without the participation of either parent . No videotaping is permitted. b. During the school year on alternating weekends from Thursday after school until Monday at the beginning of school . Mother is to pick the child up from school on Thursday and deliver the child to school on Monday. c. Thanksgiving, Easter, Memorial Day, Fourth of July and Labor Day shall be shared such that Father shall always have physical custody from 9 : 00 a .m. to 3 : 00 p.m. and Mother shall always have physical custody from 3 : 00 p.m. to 9 : 00 p. m. In addition, Father shall have custody of the child on trick or treat night from 6 : 00 p.m. to 8 : 30 p.m. d. Christmas shall be divided into two blocks : Block A shall be from Christmas Eve at 12 noon until Christmas Day at 12 noon, and Block B Shall be from Christmas Day at 12 noon to December 26 at 12 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years . Father shall have Block A in even numbered years and Block B in odd numbered years . e . Both Father and Mother shall each have up to two weeks of vacation with Kyler each summer. The first parent to notify the other parent in writing of a chosen week shall have priority for that week. All vacation weeks must be chosen by May 1 of each year. 3 . During Mother ' s time of physical custody, she shall ensure that the child attends all sport practices, games, meets, etc . If Mother is unable to see that the child attends said functions, she shall notify Father at least 24 hours in advance so that he may transport the child to said functions . 4 . The custodial parent shall ensure that the child makes telephone contact with the noncustodial parent every Wednesday and Sunday evening between 8 : 00 and 9 : 00 p .m. The calls are to be made from the custodial parent ' s cell phone so that the records may be produced in court . 5 . The parties shall e-mail each other on a daily basis to discuss matters concerning their son. The e-mail shall be initiated by the custodial parent and responded to by the noncustodial parent . Copies of all e-mails shall be preserved to be presented as an exhibit in any future proceedings . 6 . Neither party may smoke in their homes or in their cars when the child is present . 7 . Neither party shall permit contact between the child and the Oasis of Love Church or attend that church ' s functions 8 . Neither party shall do or say or permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child' s love and respect for the other parent . 9 . Neither party may consume alcohol to the point of intoxication or illegal or non-prescribed drugs prior to or during their periods of custody. . By tc Court Edward . Guid•, J. Krystal J. MacIntyre, Certified Legal Intern Anne MacDonald-Fox, Esquire Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 For the Plaintiff Kara W. Haggerty, Esquire Abom & Kutulakis 2 West High Street Carlisle, PA 17013 For the Defendant :mlc 4t.'011 cop' R 6 ;t4'l'ItttagA, hereunto Set my tiaiD, zta th; co tn. *It Ca!'"-'fideo rktik 0,a .0 • J9// Jb Pro.21000.., ALICIA (BROWN) RININGER, : IN THE COURT OF COMMON PLKM OF now ALICIA RENE GUYER, : CUMBERLAND COUNTY, PENNSYLVANIA. Plaintiff STEVEN- RAY BROWN, : CIVIL ACTION - LAW Defendant : NO. 2003 -5877 CIVIL TERM ORDER OF COURT AND NOW, this llth day of July, 2011 , after several hearings in this matter, this Court has serionn concerns about the emotional well-being of the parties ' child, Kyler Steven Brown, as a result of the parents ' total inability to agree upon. anything. The child has been required to attend counseling, there have been allecjations of physical and mental abuse going back and forth, and mother and dad cannot even agree upon the time of day. The child' s primary residence is in Franklin • County. We believe that Children and Youth involvement. is ne.cessary for the emotional well-being of this child.. it; a renult , we are making a copy of this order available to Franklin County Children and. Youth. By the Court ( Edward E. Guido, J. U,dYr(!):. Brouwer, CL1 Kara. W. Haggerty, Knqui.re Megan. taenmeyer, Enquire For the Defendant Famil y Law Clinic For the Plaintiff : if b. TRUEcopyrr°elht; ):1LIn Testimonywhereoherunetyid and the seal of said Co rt at Carlislo, Pa. ei.3,164, Prothonotary ALICIA (BROWN) RININGER, IN THE COURT OF COMMON PLEAS OF now ALICIA RENE GUYER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • V. STEVEN RAY BROWN, CIVIL ACTION - LAW Defendant NO. 2003-5877 CIVIL TERM ORDER OF COURT AND NOW, this 11th day of July, 2011, after hearing we are satisfied that father is not a danger to the child, and based upon the testimony of Mr. Keck, that the child has overcome his anxiety about reunification. Consequently, the custody order of July 28 , 2009, shall be reinstated. It is further ordered and directed as follows : 1 . Kyler shall have unlimited access to call or talk to either parent while in the custody of the other parent. He is to be allowed to have his own cell phone and to keep it in his possession at all times . If I find that either party violates any portion of the order but particularly that one, I will come down hard in a contempt proceeding. 2 . The child shall participate in counseling with Mr. Keck until he is successfully discharged. The custodial parent shall make sure that he makes all of those sessions . 3 . The parents are directed to begin co-parent counseling with an agreed upon counselor. If the parties cannot agree, they shall counsel with Mr. Keck. By the Court„ Edward E. Guido, J. Garret Brouwer, CLI TRUE COPY FROM RECORD Megan Riesmeyer, Esquire in Testimony whereof,I here unto set my hand Family Law Clinic and the seal of said Cou at lisle,Pa. For the Plaintiff kOs !.S/1`day of 2011._ lacct. .Dp Prothonotary Kara W. Haggerty, Esquire For the Defendant : lfh ALICIA R. RININGER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : 2003-5877 CIVIL ACTION- LAW STEVEN R. BROWN, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this /e day of Lin A/ 2 , 2014, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of Court dated July 11, 2011 and July 28, 2009 shall remain in full force and effect with the following modifications and additions. 2. The parties shall cooperate with counseling for the child with Mr. Keck. Father shall be responsible for contacting Mr. Keck to reinstate the counseling. 3. The parties shall cooperate with co-parenting counseling with Mr. Keck. Father shall be responsible for contacting Mr. Keck to begin the counseling. 4. Mother shall file a Criminal History affidavit for herself and the members of her household within 14 days of the date of this Order and serve a copy on Father's counsel. 5. This Order is entered pursuant to an agreement of the parties at 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. Another Conciliation Conference is scheduled for Tuesday,February 11, 2014 at 9:30 a.m. BY TIE' O RT, Edward E. Guido, J. cc: Drew F. Deyo, Esquire, Counsel for Father Alicia R. Rininger, pro se 198 Black Gap Road Lot 130 PA 17222 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand • and th�se f said Co rt at Carlisle, Pa. This y of .20 Prothorfotary 2>/c C-! • 1(,c_2, Q g , , IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA • Vs : No. n3 5 � CIVILefRl o (1 CIVIL ACTION - LAW Defendant IN CUSTODY ry Ywk. 't � 1t c-' X -- m�d1 e.L% CRIMINAL RECORD/ABUSE HISTORY VERIFICATION ��3 c,, '�v Q.-+r► penalties I, , hereby swear or affirm, subject to penali o€) law including 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities that: 1. 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 Crime Self Other Date of Sentence all that household conviction, apply member guilty plea, no contest plea or pending charges 18 Pa.C.S. Ch. 25 17 (relating to criminal homicide) 18 Pa.C.S. §2702 ❑ r (relating to aggravated assault) IT 18 Pa.C.S. §2706 Il IT (relating to terroristic threats) IT 18 Pa.C.S. §2709.1 ❑ I (relating to stalking) 18 Pa.C.S. §2901 ❑ IT (relating to kidnapping) 18 Pa.C.S. §2902 ❑ (relating to unlawful restraint) 18 Pa.C.S. §2903 (relating to false imprisonment) 18 Pa.C.S. §2910 (relating to luring a child into a motor vehicle or structure) 18 Pa.C.S. §3121 ❑ (relating to rape) ❑ 18 Pa.C.S. §3122.1 ❑ ❑ relating to statutory sexual assault) 18 Pa.C.S. §3123 ❑ E (relating to involuntary deviate sexual intercourse) El 18 Pa.C.S. §3124.1 ❑ E I (relating to sexual assault) 18 Pa.C.S. §3125 ❑ (relating to aggravated indecent assault) ❑ 18 Pa.C.S. §3126 ❑1 ❑ (relating to indecent assault) 18 Pa.C.S. §3127 ❑ (relating to indecent exposure) e. • 18 Pa.C.S. §3129 IT r (relating to sexual intercourse with animalsl 18 Pa.C.S. §3130 I! (relating to conduct relating to sex offenders), CJ 18 Pa.C.S. §3301 (relating to arson and related offenses) C 18 Pa.C.S. §4302 ❑ I' (relating to incest) 18 Pa.C.S. §4303 ❑ C (relating to concealing death of child) 18 Pa.C.S. §4304 C IT (relating to endangering welfare of children) 18 Pa.C.S. §4305 IT IT (relating to dealing in infant children) n 18 Pa.C.S. §5902(b) r! ❑ (relating to prostitution and related offenses) n 18 Pa.C.S. §5903 IT (c) or(dl (relating to obscene and other sexual materials and performances) 18 Pa.C.S. §6301 ❑ IT (relating to corruption of minors) El 18 Pa.C.S. §6312 El IT (relating to sexual abuse of children) C 18 Pa.C.S. §6318 r! El (relating to unlawful contact with minor) E 18 Pa.C.S. §6320 C C (relating to sexual exploitation of children) 23 Pa.C.S. §6114 ❑ 2-1 ) —0 (relating to contempt for violation of Protection order or agreement) Driving under the El t Q q AXI) influence of drugs Are-g,Nie.d or alcohol El Manufacture, sale, C 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 Self Other Date all that household apply member A finding of abuse by a Children &Youth E l Agency or similar agency in Pennsylvania or similar statute in another iurisdiction Abusive conduct as defined under the C 12--t`03 Protection from Abuse Act in Pennsylvania or similar statute in `PFA discbo-ri,, -2-2-Q5 another jurisdiction Other: E 3. Please list any evaluation, ounseling or other treatment received following conviction or finding of abuse: '7/O _ Ar m 015 rrt CIRSS 2Oo4 1A e.f' in5 mot- r S • 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 4,�.} �. ,,� criminal / abuse history, please explain: SQ t t�n C0` 2-28 "7 i /4); ie. r-;i n,(' 4) �' 1,e'_', /P Gu tJ e - See. a t+uce 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 Franklin County Court of Common Pleas Court Summary Connor,Sean Nolan DOB:02/28/1971 Sex:Male Camp Hill,PA 170010200 Eyes:Blue Aliases: Hair.Red or Auburn Connor,Sean Race:Caucasian Connor,Sean N. Sean,Nolan Conner Sean,Nolan Connor Closed Franklin CP-28-CR-0000887-1995 Proc Status:Migrated Case DC No: OTN:E5673920 Arrest Dt:07/17/1995 Disp Date: 11/15/1995 Disp Judge:Migrated,Judge Def Atty:Dean,Paul T.-(PD) Sea No Statute Grade Description Disposition Sentence DL Sentence Time Program Period Sentence Length 1 18§2702 Aggravated Assault Guilty Plea 11/15/1995 Other 1 18§2701 Simple Assault Guilty Plea 11/15/1995 Other 2 18§2701 Simple Assault Quashed,Dismissed, Demurrer Sustained 3 18§2705 M2 Recklessly Endangering Another Quashed,Dismissed, Person Demurrer Sustained 4 18§2709 S Harassment/Strike,Shove,Kick,Etc. Quashed,Dismissed, Demurrer Sustained CP-28-CR-0001069-1995 Proc Status:Migrated Case DC No: OTN:E5987472 Arrest Dt:07/06/1995 Disp Date:02/27/1996 Disp Judge:Migrated,Judge Def Atty:Unidentified Attorney-(PR) Sea No Statute Grade Description Disposition 1 18§3921 Theft By Unlaw Taking-Movable Prop Quashed,Dismissed, Demurrer Sustained 2 18§3925 Receiving Stolen Property Quashed,Dismissed, Demurrer Sustained CP-28-CR-0001754-2002 Proc Status:Migrated Case DC No: OTN:L1352890 Arrest Dt: 10/06/2002 Disp Date: Disp Judge: Def Atty:Unidentified Attorney-(PR) Sea No Statute Grade Description Disposition 1 75§3731 M2 Driving Under The Influence Of Alcohol 1 75§3731 M2 Driving Under The Influence Of Alcohol 2 75§3736 S Reckless Driving 3 75§3714 S Careless Driving 4 75§3309 S Disregard Traffic Lane(Single) AOPC 3541 REV. 11/29/2011 Page 1 of 3 Printed:4/23/2012 8:46 AM Recent entries made in the court filing offices may not be immediately reflected on the court summary report. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assume any liability for inaccurate or delayed data, errors or omissions on these reports. Court Summary Report information should not be used in place of a criminal history background check which can only be provided by the Pennsylvania State Police. Moreover an employer who does not comply with the provisions of the Criminal History Record Information Act may be subject to civil liability as set forth in 18 Pa.C.S.Section 9183. Please note that if the offense disposition information is blank, this only means that there is not a "final disposition" recorded in the Common Pleas Criminal Court Case Management System for this offense. In such an instance, you must view the public web docket sheet of the case wherein the offense is charged in order to determine what the most up-to-date disposition information is for the offense. Franklin County Court of Common Pleas • ft.- r ,� Court Summary Connor,Sean Nolan(Continued) Closed(Continued) Franklin(Continued) Sea No Statute Grade Description Disposition 5 75§3304 S Improp Pass Right 6 18§2705 M2 Recklessly Endangering Another Person 7 18§2709 S Harassment/Strike,Shove,Kick,Etc. 8 18§5503 Disorderly Conduct-Unreasonable Noise CP-28-CR-0000704-2003 Proc Status:Completed DC No: OTN:L1522194 Arrest Dt:04/12/2003 Disp Date:05/13/2011 Disp Judge:Walsh,Richard J. Def Atty:Unidentified Attorney-(PR) Sea No Statute Grade Description Disposition Sentence Dt. Sentence Type Proaram Period Sentence Lenath 1 18§2701 M2 Simple Assault Nob Contendere 2 18§2701 M2 Simple Assault Nob Contendere 12/31/2003 Confinement 12/31/2003 Other 3 18§2903 M2 False Imprisonment Nolle Prossed 4 18§2709 S Harassment-Subject Other to Withdrawn Pursuant to Physical Contact Pa.R.Crim.P.561(B) 5 18§2701 M1 Simple Assault Nolle Prossed CP-28-CR-0000831-2006 Proc Status:Penalty Imposed DC No: OTN:K1442011 Arrest Dt:05/16/2006 Disp Date:04/30/2007 Disp Judge:Walsh,Richard J. Def Atty:Thomas,Scott J.-(PD) Sea No Statute Grade Description Disposition 1 18§3928 M2 Unauth Use Motor/Other Vehicles Dismissed-Rule 586 (Satisfaction/Agreement) 2 18§2701 M2 Simple Assault Dismissed-Rule 586 (Satisfaction/Agreement) 3 18§2709 S Harassment-Subject Other to Withdrawn Pursuant to Physical Contact Pa.R.Crim.P.561(B) CP-28-CR-0001425-2007 Proc Status:Completed DC No: OTN:K5864950 Arrest Dt:06/11/2007 Disp Date: 10/22/2008 Disp Judge:Walker,John R. DefAtty:Kulla,Stephen-(PR) Sea No Statute Grade Description Disposition 1 18§3121 Fl Rape Unconscious Victim Nolle Prossed 2 18§3502 Fl Burglary Guilty Plea 3 18§3126 M2 lndec Asslt-W/O Cons Of Other Nolle Prossed 4 18§3124.1 F2 Sexual Assault Nolle Prossed AOPC 3541 REV. 11/29/2011 Page 2 of 3 Printed:4/23/2012 8:46 AM Recent entries made in the court filing offices may not be immediately reflected on the court summary report. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assume any liability for inaccurate or delayed data, errors or omissions on these reports. Court Summary Report information should not be used in place of a criminal history background check which can only be provided by the Pennsylvania State Police. Moreover an employer who does not comply with the provisions of the Criminal History Record Information Act may be subject to civil liability as set forth in 18 Pa.C.S.Section 9183. Please note that if the offense disposition information is blank, this only means that there is not a "final disposition" recorded in the Common Pleas Criminal Court Case Management System for this offense. In such an instance, you must view the public web docket sheet of the case wherein the offense is charged in order to determine what the most up-to-date disposition information is for the offense. Franklin County Court of Common Pleas Court Summary Connor,Sean Nolan(Continued) Closed(Continued) Franklin(Continued) CP-28-CR-0001426-2007 Proc Status:Completed DC No: OTN:K5864972 Arrest Dt:06/12/2007 Disp Date: 10/22/2008 Disp Judge:Walker,John R. Def Atty:Kulla,Stephen-(PR) Sea No Statute Grade Description Disposition 1 18§3124.1 F2 Sexual Assault Nolle Prossed(Case Dismissed) 2 18§3121 Fl Rape Forcible Compulsion Nolle Prossed(Case Dismissed) 3 18§3123 Fl IDS!Forcible Compulsion Nolte Prossed(Case Dismissed) 4 18§3126 M2 Indec Asslt-W/O Cons Of Other Nolle Prossed(Case Dismissed) CP-28-CR-0001819-2007 Proc Status:Sentenced/Penalty imposed DC No: OTN:L3739956 Arrest Dt:09/17/2007 Disp Date:06/20/2008 Disp Judge:Herman,Douglas W. Def Atty:Kulla,Stephen-(PR) Sea No Statute Grade Description Disposition 1 18§3921 M1 Theft By Unlaw Taking-Movable Prop Nolle Prossed 2 18§3925 M1 Receiving Stolen Property Nolle Prossed CP-28-CR-0000097-2008 Proc Status:Sentenced/Penalty Imposed DC No: OTN:K2712835 Arrest Dt:01/06/2008 Disp Date:06/20/2008 Disp Judge:Herman,Douglas W. Def Atty:Kulla,Stephen-(PR) Sea No Statute Grade Description Disposition 1 18§3921 M1 Theft By Unlaw Taking-Movable Prop Nolle Prossed Cumberland CP-21-CR-0001204-1995 Proc Status:Migrated Final Disposition DC No: OTN:E0033051 Arrest Dt: Disp Date:01/23/1996 Disp Judge:Hess,Kevin A. Def Atty:Jones,James Kennedy-(PR) Sea No Statute Grade Description Disposition 1 18§2701 M2 Simple Assault Guilty 2 18§5504 Harassment/Stalking By Comm/Add Guilty Other Manners 3 Migrated§LOAQ1658 S DISORDERLY CONDUCT Guilty PROHIBITED AOPC 3541 REV. 11/29/2011 Page 3 of 3 Printed:4/23/2012 8:46 AM Recent entries made in the court filing offices may not be immediately reflected on the court summary report. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assume any liability for inaccurate or delayed data, errors or omissions on these reports. Court Summary Report information should not be used in place of a criminal history background check which can only be provided by the Pennsylvania State Police. Moreover an employer who does not comply with the provisions of the Criminal History Record Information Act may be subject to civil liability as set forth in 18 Pa.C.S.Section 9183. Please note that if the offense disposition information is blank, this only means that there is not a "final disposition" recorded in the Common Pleas Criminal Court Case Management System for this offense. In such an instance, you must view the public web docket sheet of the case wherein the offense is charged in order to determine what the most up-to-date disposition information is for the offense. Chambersburg man accused of sexual assault enters no-contest plea to burgl... rl n rn o aThc•I■�# 'i*tidetlitlet ors Chambersburg man accused of sexual assault enters no- . Clout e.rsbnr} contest plea to burglary charge • Sexual Assan It October 03,2008 13} DC)N AIN S • Inde�a,tusaiilt Cl IAM13ERSlti ERG,Pa.-A Chambersburg man charged with sexually assaulting two - C • Sl w sns,urg women on the same night last year entered a no-contest plea to a burglary charge Thursday and was sentenced to state prison. p 1 Sean Nolan Connor,39,of G7 North Ave.,was to be tried next week on charges of Tweet • Man sentenced in sexual assault rape of an unconscious victim,burglary,indecent assault and sexual assault in one case;and forcible rape.sexual assault involuntary deviate sexual intercourse and indecent assault in another. Pa.man gnu ti of sexual assault Connor entered the plea to the first-degree felony burglary charge before Judge John R.Walker and was sentenced to two to four years in prison,Assistant District Attorney Lauren Sulcove said. Juries chosen for 3 chatge'ii in 'The victims wanted to avoid going to trial,if possible,and this was one way of accomplishing that,"Sulcove said "It rape cases was going to be difficult for them to relive it"had the case proceeded to trial,she said. The affidavits of probable cause stated that the women and Connor were at a Chambersburg bar June 9, 2007,and that he accompanied them back to the one woman's home on Mont Alto Road. One woman,a 33-year-old from Shippensburg,Pa.,knew Connor,Pennsylvania State Police said.The 27-year-old who lived on Mont Alto Road had not met him before that night,police said. At about 6 a.m.,Connor asked the Shippensburg woman to give him a ride back to his vehicle at Razzl''s in Chambersburg,police said.Once in the vehicle,however,he forced her to have sexual intercourse,police said. One affidavit stated that the woman drove Connor to Chambersburg and be told her he needed to return to the Mont Alto Road house to get his cell phone. The other woman told police she was passed out,but awoke to find Connor having sexual intercourse with her,police said.The Shippensburg woman told police that the'27-year-old was passed out and was in no condition to have given her consent to have sex,according to the affidavit. Walker's sentence included a provision that Connor have no contact with the women,Sulcove said. he ra id_ma i L co m Copp fight 2012 The l ierald-Mail lades by keyword j index by Pate I Privacy Policy i Tenn:,of Service Chambersburg man accused of sexual assault enters no-contest plea to burgl... • Cumberland County Court of Common Pleas jI ' Court Summary Guyer,Alicia Rene DOB:08/03/1977 Sex:Female Shippensburg,PA 17257 Eyes:Unknown Aliases: Hair:Blond or Strawberry Alicia Guyer Race:Caucasian Alicia Rene Guyer Closed Cumberland CP-21-CR-0002175-2006 Proc Status:Sentenced/Penalty Imposed DC No: OTN:K1289212 Arrest Dt: Disp Date:01/30/2007 Disp Judge:Bayley,Edgar B. Def Atty:Waller,Arla M.-(PD) Seq No Statute Grade Description Disposition Sentence Dt. Sentence Type Program Period Sentence Length 1 18§901 F Criminal Attempt-Acq Or Obt Poss Quashed Of Contr Subs Misre 2 63§390-8 M Procure For Self/Other Drug By Guilty Plea Forgery 01/30/2007 Probation Other Min:6 Month(s)Max:6 Month(s) Franklin CP-28-CR-0001587-2009 Proc Status:Sentenced/Penalty Imposed DC No: OTN:K8188154 Arrest Dt: Disp Date: 12/21/2009 Disp Judge:Van Horn,Carol L. Def Atty:Necaster,Steven Nicholas-(PD) Seq No Statute Grade Description Disposition Sentence Dt. Sentence Type Program Period Sentence Length 1 18§4906 M3 False Reports-Reported Offense Guilty Plea Did Not Occur 01/27/2010 Probation Monthly Min:12 Month(s)Max:12 Month(s) CP-28-SA-0000055-2006 Proc Status:Sentenced/Penalty Imposed DC No: OTN: Arrest Dt: Disp Date:07/27/2006 Disp Judge:Van Horn,Carol L. Seq No Statute Grade Description Disposition 1 18§2709 S Harassment-Course of Conduct Guilty W/No Legitimate Purpose CPCMS 3541 1 Printed:2/26/2014 10:35 PM Recent entries made in the court filing offices may not be immediately reflected on the court summary report. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assume any liability for inaccurate or delayed data, errors or omissions on these reports. Court Summary Report information should not be used in place of a criminal history background check which can only be provided by the Pennsylvania State Police. Moreover an employer who does not comply with the provisions of the Criminal History Record Information Act may be subject to civil liability as set forth in 18 Pa.C.S.Section 9183. Please note that if the offense disposition information is blank, this only means that there is not a "final disposition" recorded in the Common Pleas Criminal Court Case Management System for this offense. In such an instance, you must view the public web docket sheet of the case wherein the offense is charged in order to determine what the most up-to-date disposition information is for the offense. Magisterial District Court 09-3-01 Public Court Summary Rininger,Alicia R. DOB:08/03/1977 Sex:Female Shippensburg,PA 17257 Eyes:Unknown Hair:Blond or Strawberry Race:White Aliases:Alicia Rene Brown,Alicia R Guyer,Alicia Rene Guyer-Rininger,Alicia Renee Rininger Court:MDJ-09-3-01 Closed MJ-09301-TR-0000032-2011 Processing Status:Completed OTN: Arrest Date: Disp.Event Date:01/10/2011 Last Action: Last Action Date: Next Action: Next Action Date: Statute Grade Description Disposition Counts 75§1501 §§A S Driving W/O A License Guilty Plea 1 County:Cumberland Closed MJ-09102-CR-0000280-2006 Processing Status:Case Transferred to OTN:K 128921-2 Arrest Date: Court of Common Pleas Disp.Event Date:08/16/2006 Last Action:Preliminary Hearing Last Action Date:08/16/2006 Next Action: Next Action Date: Bail Type:Monetary Bail Amount:$1,000.00 Bail Status:Posted Statute Grade Description Disposition Counts 18§901 §§A F ATTEMPT ACQ OR OBT POSS OF CONTR Waived for Court 1 SUBS MISRE Statewide Closed Franklin MJ-39304-NT-0000128-2006 Processing Status:Case Transferred to OTN: Arrest Date: Court of Common Pleas Disp.Event Date:04/25/2006 Last Action:Summary Trial Last Action Date:04/24/2006 Next Action: Next Action Date: Statute Grade Description, Disposition Counts 18§2709§§A3 S Harassment-Course of Conduct W/No Guilty 1 Legitimate Purpose MJ-39304-CR-0000248-2008 Processing Status:Completed OTN:K 626470-5 Arrest Date: Disp.Event Date:01/07/2009 Last Action:Preliminary Hearing Last Action Date:01/06/2009 Next Action: Next Action Date: Bail Type:Nonmonetary Bail Amount:$0.00 Bail Status:Posted Statute Grade Description Disposition Counts MDJS 1210 1 Printed:02/26/2014 10:19:35PM Recent entries made in the court filing offices may not be immediately reflected on the court summary report. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these reports. Court summary report information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. 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. Please note that if the offense disposition information is blank, this only means that there is not a "final disposition" recorded in the Magisterial District Court Case Management System for this offense. In such an instance, you must view the public web docket sheet of the case wherein the offense Public Court Summary Rininger,Alicia R. DOB:08/03/1977 Sex:Female Shippensburg,PA 17257 Eyes:Unknown Hair:Blond or Strawberry Race:White Statewide Closed Franklin Statute Grade Description Disposition Counts 18§2709§§A7 M3 Harassment-Comm.Repeatedly in Withdrawn 1 Another Manner MJ-39201-CR-0000423-2009 Processing Status:Case Transferred to OTN:K 818815-4 Arrest Date: Court of Common Pleas Disp.Event Date:09/08/2009 Last Action:Preliminary Hearing Last Action Date:09/08/2009 Next Action: Next Action Date: Bail Type:ROR Bail Amount:$0.00 Bail Status:Posted Statute Grade Description Disposition Counts 18§4906§§B1 M3 False Reports-Reported Offense Did Not Waived for Court 1 Occur MJ-39304-TR-0001546-2009 Processing Status:Completed OTN: Arrest Date: Disp.Event Date:09/16/2009 Last Action:Summary Trial Last Action Date:09/16/2009 Next Action: Next Action Date: Statute Grade Description Disposition Counts 75§3362§§A3-10 S Exceed Max Speed Lim Estb By 10 MPH Guilty 1 MJ-39304-NT-0000095-2011 Processing Status:Completed OTN: Arrest Date: Disp.Event Date:03/28/2011 Last Action:Summary Trial Last Action Date:03/28/2011 Next Action: Next Action Date: Statute Grade Description Disposition Counts 18§5503§§Al S Disorderly Conduct Engage In Fighting Not Guilty 1 MDJS 1210 2 Printed:02/26/2014 10:19:35PM Recent entries made in the court filing offices may not be immediately reflected on the court summary report. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data errors or omissions on these reports. Court summary report information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. 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. Please note that if the offense disposition information is blank, this only means that there is not a "final disposition" recorded in the Magisterial District Court Case Management System for this offense. In such an instance, you must view the public web docket sheet of the case wherein the offense • Magisterial District Court 39-3-07 Public Court Summary Rininger,Alicia R DOB:08/03/1977 Sex:Female Fayetteville,PA 17222 Eyes: Hair: Race:White Aliases:Alicia Rene Rininger Court:MDJ-39-3-07 Closed MJ-39307-TR-0001042-2013 Processing Status:Completed OTN: Arrest Date: Disp.Event Date:04/10/2013 Last Action: Last Action Date: Next Action: Next Action Date: Statute Grade Description Disposition Counts 75§3362§§A1.1-18 S Exceed 65 MPH For All Vehicles By 18 Guilty Plea 1 MPH County:Franklin Closed MJ-39305-TR-0000487-2010 Processing Status:Completed OTN: Arrest Date: Disp.Event Date:06/11/2010 Last Action: Last Action Date: Next Action: Next Action Date: Statute Grade Description Disposition Counts 75§3111 §§A S Obedience to Traffic-Control Devices Guilty Plea 1 MJ-39304-TR-0001089-2010 Processing Status:Completed OTN: Arrest Date: Disp.Event Date:09/01/2010 Last Action:Summary Trial Last Action Date:09/01/2010 Next Action: Next Action Date: Statute Grade Description Disposition Counts 75§3309§§1 S Disregard Traffic Lane(Single) Not Guilty 1 MDJS 1210 1 Printed:02/26/2014 10:18:36PM Recent entries made in the court filing offices may not be immediately reflected on the court summary report. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these reports, Court summary report information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. 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. Please note that if the offense disposition information is blank, this only means that there is not a "final disposition" recorded in the Magisterial District Court Case Management System for this offense. In such an instance, you must view the public web docket sheet of the case wherein the offense ALICIA R. RININGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. • STEVEN R. BROWN, : NO. 2003 -5877 CIVIL TERM Defendant • • ORDER OF COURT AND NOW, this 4TH day of MARCH, 2014, upon consideration of the within Petition for Special Relief, said Petition is hereby GRANTED in part. Plaintiff is directed to file a CRIMINAL RECORD/ABUSE HISTORY verification for herself and all members of her household. In all other respects the request is DENIED. B., e Court, Edward E. Guido, J. Alicia Rininger 198 Black Gap Road, Lot 130 Fayetteville, Pa. 17222 rew F. Deyo, Esquire 401 East Louther Street Carlisle, Pa. 17013 Court Administrator — LE_ :sld C-Of ICS /r2-1 LECL c_- r ' 3/41 PI ALICIA R. RININGER, IN THE COURT OF COMMON PLEPJ 0 Plaintiff CUMBERLAND COUNTY, PENN v. : No. 2003 -5877 CIVIL TERM STEVEN R. BROWN, Defendant . IN CUSTODY c.n STIPULATION AGREEMENT AS TO CUSTODY 1. The parties hereto agree that the best interest and continuing welfare of the Child would be best served with the custody arrangement as follows: A. Mother, Alicia R. Rininger, and Father, Steven R. Brown, shall have shared legal custody of Kyler Steven Brown, born December 8, 2000. All decisions affecting the Child's growth and development, including but not limited to medical treatment, education, and religious training, are major decisions which Father and Mother shall make jointly after discussion and consultation with each other. B. As provided by 23 Pa. C.S.A. §5309(a), each parent shall have full and complete access to the Child's mental, dental, religious and school records. This includes the names, addresses and telephone numbers of all medical and other providers. C. Both parents shall be entitled to full participation in all educational and medical treatment planning meetings and evaluations with regard to the minor child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher, or authority and copies of any reports given to them as parents including but not limited to: medical records, birth certificates, school or educational attendance records, or report cards. D. Each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extra-curricular activities, sports, children's parties, musical presentations, back-to-school nights, and the like. E. Primary physical custody shall be with Father at all times, with Mother exercising custody/visitation at times when the parties are able to mutually agree. a. In addition, Thanksgiving, Easter, Memorial Day, Fourth of July Labor Day, and Kyler's birthday, shall be shared such that Father shall always have physical custody from 9:00 a.m.to 3:00 p.m. and Mother shall always have physical custody from 3:00 p.m. to 9:00 p.m. b. Christmas shall be divided into two blocks: Block A shall be from Christmas Eve at 12 noon until Christmas Day at 12 noon, and Block B shall be from Christmas Day at 12 noon to December 26 at 12 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. c. Mother shall exercise custody on Mother's Day from 9 a.m. until 9 P.m.. F. Both Father and Mother shall have up to two weeks of vacation with Kyler each summer. The first parent to notify the other parent in writing of a chosen week shall have priority for that week. All vacation weeks must be chosen by May 1 of each year. G. The parties shall both have liberal electronic communication with Kyler when he is in the custody of the other parent, including, but not limited to, telephone, skype, chattime, and email communication. He is allowed to have his own cell phone and to keep it in his possession at all times. 1-1: Father shall ensure that the child makes telephone contact with Mother every Wednesday and Sunday evening between 8:00 and 9:00 p.m. I. Neither party may smoke in their homes or in their cars when the child is present. J. Neither party will use illegal drugs or alcohol to the point of intoxication immediately before or during their periods of physical custody and shall keep third parties from similar activity to the extent possible. K. Neither party shall do or permit a third party to do or say anything that would estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. L. 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. M. 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. 2. 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 fully explain the terms of this agreement. Father is represented by Drew F. Deyo, Esquire and Mother is not represented. A. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. Consented to: Date 3/71 Date Date Date ALICIA R. RININGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2003-5877 CIVIL TERM STEVEN R. BROWN, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this / 7214 , day of in/14CA , 2014, upon consideration of the within Stipulation for Custody, which is incorporated herein by reference, IT IS HEREBY ORDERED AND DECREED that the contents of said Stipulation are hereby adopted as an Order of Court with full weight and effect as if they had been set forth in full hereinafter. Distribution: 1.1) -rew F. Deyo, Esquire Alicia Rininger, pro se, 198 Black Gap Road, Lot 130, Fayetteville , PA 17222. ecy-s4e..s tzLL 3 t 9 . ALICIA R. RININGER, Plaintiff v. STEVEN R. BROWN, Defendant : IN THE COURT OF COMMON PLEAS OF *� : CUMBERLAND COUNTY, PENNSYT,NI rnCD m -v No. 2003 -5877 CIVIL TERM "" ti) ,- > — r-.z n° IN CUSTODY =© MOTION TO WITHDRAW AS COUNSEL -4� AND NOW, comes Drew F. Deyo, Esquire, attorney for Defendant, Steven R. Brown, and in support of this Motion to Withdraw as Counsel, avers as follows: 1. Undersigned believes irreconcilable differences have arisen between Defendant and Undersigned. 2. Despite several messages, Defendant refuses to stay in contact with Undersigned. 3. Defendant has an outstanding bill owed to Undersigned for services already performed. 4. Undersigned notified Defendant of this Motion to Withdraw, but Defendant still refuses to contact Undersigned. 5. The parties in this matter signed a Custody Stipulation on March 7, 2014, and said Stipulation became an Order of Court on March 17, 2014. 6. In sum, Defendant has failed to pay Undersigned for his services; Defendant refuses to communicate or stay in contact with Undersigned, despite several messages; and Undersigned believes that irreconcilable differences have arisen between Defendant and Undersigned, to such an extent, that Undersigned can no longer properly represent Defendant. WHEREFORE, Attorney Drew F. Deyo, Esquire, respectfully requests that he be allowed to withdraw as counsel for Defendant, Steven Brown, in the above - captioned case. Date: t 1 (0 (4 / Respectfully Submitted, DEYO & KULLING Dr-w F. Deyo, Esquire 401 East Louther Street, Suite 209 Carlisle, PA 17013 (717) 386 -5639 Attorney I.D. # 308857 Attorney for Defendant, Steven Brown VERIFICATION Drew F. Deyo, Esquire, states that he is the Attorney for Steven Brown in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon the his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: 1 Cp l LI rew F. Deyo, Esquire Attorney for Defendant ALICIA R. RININGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2003 -5877 CIVIL TERM STEVEN R. BROWN, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Drew F. Deyo, Esquire, attorney for Defendant, Steven Brown, do hereby certify that I this day served a copy of this Motion to Withdraw as Counsel upon the following via first class United States mail, postage prepaid, addressed as follows: Date: Alicia R. Rininger 198 Black Gap Road, Lot 130 Fayetteville, PA 17222 Steven R. Brown 7001 Olde Scotland Road Shippensburg, PA 17257 Respectfully Submitted, DEYO & KULLING Dre ,! . Deyo, Esquire 401 East Louther Street, Suite 209 Carlisle, PA 17013 (717) 386 -5639 Attorney I.D. # 308857 Attorney for Defendant, Steven Brown ALICIA R. RININGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2003 -5877 CIVIL TERM STEVEN R. BROWN, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 29TH day of APRIL, 2014, a Rule is issued upon Defendant to Show Cause why the Motion to Withdraw as counsel should not be granted. Rule returnable twenty (20) days after service. Drew F. Deyo, Esquire Xicia R. Rininger ✓ Steven R. Brown :sld 1ES filai.LEC , Edward E. Guido, J. c, P" c .,CZ CO ern • r �n qti .: c CD =q r t? .1 .C" Y —. >'