HomeMy WebLinkAbout08-0601
RONALD R. COON, JR. : IN THE COURT OF COMMON PLEAS OF C,.,,beAa.J
Plaintiff COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
CHRYSTAL O'MALLEY, :No. 08 - & 0/ CIVIL
Defendant : IN CUSTODY
COMPLAINT FOR CUSTODY
1. The plaintiff is Ronald R. Coon, Jr., residing at 317 Hogestown Road, Cumberland
County, Mechanicsburg, Pennsylvania 17050.
2. The defendant is Chrystal O'Malley, residing at 1255 Shumaker Road, Blain, Perry
County, Pennsylvania 17006.
3. Plaintiff seeks custody of the following children:
Name Present Residence DOB Age
Jeremiah F. Coon 317 Hogestown Road 10/17/06 1 year 2 months
Mechanicsburg, PA
The child was born out of wedlock
The child is presently in the custody of Ronald R. Coon, Jr., who resides at 317
Hogestown Road, Cumberland County, Pennsylvania.
During the past five years, the child has resided with the following persons and at the
following addresses:
List All Persons List All Addresses Dates
Ronald R. Coon, Jr. 317 Hogestown Road 10/17/06 to present
Mechanicsburg, PA
The mother of the child is Chrystal O'Malley, currently residing at 1255 Shumaker Road,
Blain,, PA.
She is unmarried.
The father of the child is Ronald R. Coon, Jr., currently residing at 317 Hogestown Road,
Mechanicsburg, PA.
He is unmarried.
4. The relationship of plaintiff to the child is that of Father.
The plaintiff currently resides with the following persons.
Name Relationship
No One
5. The relationship of defendant to the child is that of Mother.
The defendant currently resides with the following persons.
Name Relationship
Betsy Hockenberry Mother
6. Plaintiff has not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of the children in this or another court. The court, term,
and number, and its relationship to this action is:
Plaintiff has no information of a custody proceeding concerning the children pending in a
court of this Commonwealth.
Plaintiff does know of a person not a party to the proceeding that has claims to have
custody or visitation rights with respect to the children.
7. The best interest and permanent welfare of the child will be served by granting the relief
request because:
Plaintiff has undertaken and performed the primary parental responsibilities for the child.
Plaintiff is best able to provide the care and nurture which the child needs for healthy
development.
Plaintiff desires to maintain the family household which has been established, and the
continued stability of the household is in the best interest of the child.
A Court ordered determination of custody is required to avoid continuing conflict
between the parties regarding parental responsibility for custody and support.
Each parent whose parental rights to the children have not been terminated and the person
who has physical custody of the child has been named as parties to this action. All other
persons, named below, who are known to have or claim a right to custody or visitation of
the children will be given notice of the pendency of this action and the right to intervene:
Name Address Basis of Claim
N/A
WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody in
Plaintiff with agreed upon visitation in Defendant.
Date: Z? fl"
Respectfully submitted,
ROMINGER & ASSOCIATES
Vincent M. Monfredo, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID #206671
Attorney for Plaintiff
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
unsworn falsification to authorities.
Date: ,. MUST -'-'
Ronald R. Coon, Jr., Plain iff
CIO
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RONALD R. COON, JR. IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
CHRYSTAL O'MALLEY
DF,FF,NDANT
2008-601 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, February 01, 2008 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, March 07, 2008 at 9:00 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ John . Man an r. Es q.
Custody Conciliator ig,
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
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APR 0 22008rl D?
RONALD R. COON, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 08-601 CIVIL ACTION LAW
CHRYSTAL O'MALLEY, IN CUSTODY
Defendant
ORDER OF COURT
AND NOW this day of April, 2008, upon consideration of the attached Custody
Conciliation Report, it is Ordered and Directed as follows:
Legal Custody: The Father, Ronald R. Coon, Jr., and the Mother, Chrystal O'Malley, shall
have shared legal custody of Jeremiah F. Coon, born 10/17/2006. The parties shall have an
equal right to make all major non-emergency decisions affecting the Child's general well-being
including, but not limited to, all decisions regarding 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 of the other parent. To the extent one
parent has possession of any such records or information, that parent shall be required to share
the same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
2. Physical Custody: Father shall have primary physical custody of the Child subject to Mother's
partial physical custody as follows:
a. Mother shall have physical custody every Monday and Wednesday from 12:00
pm until 6:00 pm and every Saturday from 9:00 am until 8:00 pm.
b. Mother shall have physical custody of the Child at such other times as the
parties may mutually agree.
3. In regard to Mother's Monday and Wednesday custodial periods, Mother shall pick the Child
up at day care at 12:00 pm and Father shall pick the Child up at maternal aunt's residence or at
such other locations as the parties may mutually agree at 6:00 pm. In regard to Mother's
Saturday custodial period, the exchange location shall be at the East End Deli in Landisburg,
PA, absent mutual agreement.
4. The non-custodial parent shall have liberal telephone contact with the Child on a reasonable
basis. Each parent shall provide the other parent with an operable telephone number at which
the parent can communicate with the Child.
5. Holidays and Birthdays: The parents shall determine Holidays and Birthdays as mutually
agreed upon.
6. Neither party may say or do anything nor permit a third party to do or say anything that may
estrange the Child from the other party, or injure the opinion of the Child as to the other party,
or may hamper the free and natural development of the Child's love or affection for the other
party. To the extent possible, both parties shall not allow third parties to disparage the other
parent in the presence of the Child.
7. In the event of a medical emergency, the custodial party shall notify the other party as soon as
practicable after the emergency is handled.
8. In the event the custodial parent should take the Child out of state, the custodial parent shall
notify the non-custodial parent within twenty-four hours of departure of the intended
destination and a telephone number at which they can be reached.
9. Counseling: Mother shall continue with her counseling, follow any and all recommendations
of her therapist and give authorization for Father to have input regarding her treatment. Mother
shall additionally supply Father with progress reports regarding her treatment in order for
Father to assess Mother's ability to have expanded custodial time with her Child.
10. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify
the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of
this Order shall control.
11. A status update conciliation conference is hereby scheduled for May 1, 2008 at 10:00 am at the
Court of Common Pleas in Carlisle, Pennsylvania 17013 to determine the appropriateness of
expanding Mother's custodial time and overnight custodial periods.
By the Co
J.
Distribution:
/Thomas Gould, Esquire
.Vincent Monfredo, Esquire
v,-'1ohn J. Mangan, Esquire
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RONALD R. COON, JR.,
Plaintiff
V.
CHRYSTAL O'MALLEY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 08-601
CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
1. The pertinent information pertaining to the Child who is the subject of this litigation is
as follows:
Name Date of Birth Currently in the Custody of
Jeremiah F. Coon 10/17/2006 Primary Father
2. A Conciliation Conference was held with regard to this matter on March 31, 2008 with
the following individuals in attendance:
The Mother, Chrystal O'Malley, with her counsel, Thomas Gould, Esq.
The Father, Ronald Coon, Jr., with his counsel, Vincent Monfredo, Esq.
3. The parties agreed to the entry of an Order in the form as attached.
II /A Date John J. an , Esquire
Custo Co ciliator
11
MAY 0 2 2008
RONALD R. COON, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 08-601 CIVIL ACTION LAW
CHRYSTAL O'MALLEY, IN CUSTODY
Defendant
Prior Judge: Edward E. Guido, J.
ORDER OF COURT
day of May, 2008, upon consideration of the attached Custody
AND NOW this to*-
Conciliation Report, it is Ordered and Directed as follows:
The prior Order of Court dated April 4, 2008 is hereby VACATED.
2. Legal Custody: The Father, Ronald R. Coon, Jr., and the Mother, Chrystal O'Malley, shall
have shared legal custody of Jeremiah F. Coon, born 10/17/2006. The parties shall have an
equal right to make all major non-emergency decisions affecting the Child's general well-being
including, but not limited to, all decisions regarding 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 of the other parent. To the extent one
parent has possession of any such records or information, that parent shall be required to share
the same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
3. Physical Custody: Father shall have primary physical custody of the Child subject to Mother's
partial physical custody as follows:
a. Commencing May 5, 2008, Mother shall have physical custody of the Child
every Monday from 5:00 pm until 8:00 pm and every Wednesday froml2:00 pm
until 6:00 pm. Mother shall pick the Child up at day care to begin her period of
custody and Father shall pick the Child up at maternal aunt's residence or at
such other locations as the parties may mutually agree upon.
b. Commencing May 9, 2008, Mother shall have physical custody of the Child
every Friday at 5:00 pm until Saturday 5:00 pm. Mother shall pick the Child up
at day care on Friday and Father shall pick the Child up at the East End Deli in
Landisburg, PA on Saturday, absent mutual agreement otherwise. It is
understood that for the first Friday overnight, Father may come to Mother's
residence at a reasonable hour to ascertain whether there are appropriate
sleeping arrangements for the Child.
C. Mother shall have physical custody of the Child at such other times as the
parties may mutually agree.
4. The non-custodial parent shall have liberal telephone contact with the Child on a reasonable
basis. Each parent shall provide the other parent with an operable telephone number at which
the parent can communicate with the Child.
5. Holidays and Birthdays: Mother shall have physical custody of the Child on Mother's Day
weekend until Sunday 5:00 pm. The parents shall determine all other Holidays and Birthdays
as mutually agreed upon or shall be addressed at the next status conference.
6. Neither party may say or do anything nor permit a third party to do or say anything that may
estrange the Child from the other party, or injure the opinion of the Child as to the other party,
or may hamper the free and natural development of the Child's love or affection for the other
party. To the extent possible, both parties shall not allow third parties to disparage the other
parent in the presence of the Child.
7. In the event of a medical emergency, the custodial party shall notify the other party as soon as
practicable after the emergency is handled.
In the event the custodial parent should take the Child out of state, the custodial parent shall
notify the non-custodial parent within twenty-four hours of departure of the intended
destination and a telephone number at which they can be reached.
9. Counseling: Mother shall continue with her counseling, follow any and all recommendations
of her therapist and give authorization for Father to provide information to the therapist
regarding her treatment. Mother shall additionally continue in her efforts to supply Father with
progress reports regarding her treatment in order for Father to assess Mother's ability to have
expanded custodial time with her Child. In the alternative, Mother shall discuss with her
treating professionals whether it is possible for the professionals to give a verbal update to
Father on her treatment progress.
10. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify
the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of
this Order shall control.
11. A status update conciliation conference is hereby scheduled for July 1, 2008 at 1:00 pm at the
Court of Common Pleas in Carlisle, Pennsylvania 17013.
gistribution:
?Thomas Gould, Esquire
.Vincent Monfredo, Esquire
,/fohn J. Mangan, Esquire
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RONALD R. COON, JR.,
Plaintiff
V.
CHRYSTAL O'MALLEY,
Defendant
Prior Judge: Edward E. Guido, J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 08-601 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
1. The pertinent information pertaining to the Child who is the subject of this litigation is
as follows:
Name Date of Birth Currently in the Custody of
Jeremiah F. Coon 10/17/2006 Primary Father
2. A Conciliation Conference was held with regard to this matter on March 31, 2008, an
Order was entered April 4, 2008 and a status update Conciliation Conference was held on May 1, 2008
with the following individuals in attendance:
The Mother, Chrystal O'Malley, with her counsel, Thomas Gould, Esq.
The Father, Ronald Coon, Jr., with his counsel, Vincent Monfredo, Esq.
3. The parties agreed to the entry of an Order in the form as attached.
?
5
Date
Mangan, Esquire
v Conciliator /
JUL 0 2 2008
RONALD R. COON, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 08-601 CIVIL ACTION LAW
CHRYSTAL O'MALLEY, IN CUSTODY
Defendant
Prior Judge: Edward E. Guido, J.
ORDER OF COURT
AND NOW this day of July 2008, upon consideration of the attached Custody
Conciliation Report, it is Ordered and Directed as follows:
The prior Orders of Court dated April 4, 2008 and May 6, 2008 are hereby VACATED.
2. Legal Custody: The Father, Ronald R. Coon, Jr., and the Mother, Chrystal O'Malley, shall
have shared legal custody of Jeremiah F. Coon, born 10/17/2006. The parties shall have an
equal right to make all major non-emergency decisions affecting the Child's general well-being
including, but not limited to, all decisions regarding 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 of the other parent. To the extent one
parent has possession of any such records or information, that parent shall be required to share
the same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
3. Physical Custody: Father shall have primary physical custody of the Child subject to Mother's
partial physical custody pursuant to a rotating two week schedule as follows:
a. Week one: Commencing Monday July 7, 2008, Mother shall have physical
custody of the Child Monday picking the Child up from day care at 12:30 pm (if
Mother is not working), or if Mother is working, after work Monday afternoon
until Tuesday morning July 8, 2008 whereby Mother shall transport the Child to
day care no later than 8:00 am. On Friday July 11, 2008, Mother shall pick the
child up from day care at 12:30 pm if Mother is not working, or after work
Friday afternoon if she is working, and have physical custody until Sunday July
13, 2008 at 7:00 pm. The Sunday exchange shall be at the East End Deli in
Landisburg, PA.
b. Week two: Mother shall have physical custody of the Child Wednesday July 16
whereby she shall pick the Child up at day care at 12:30 if she is not working, or
after work Wednesday afternoon if she is working, and have custody of the
Child until Thursday morning July 17, 2008 whereby Mother shall transport the
Child to day care no later than 8:00 am.
C. The parties may modify this schedule by mutual agreement as necessary or
proper as long as it is in the Child's best interest.
4. The non-custodial parent shall have liberal telephone contact with the Child on a reasonable
basis. Each parent shall provide the other parent with an operable telephone number at which
the parent can communicate with the Child.
5. Holidays and Birthdays: The parents shall arrange the Holidays and Birthdays as mutually
agreed upon or in the absence of agreement, the parents shall abide by the attached holiday
schedule. The holiday schedule shall take precedence over the regular physical custody
schedule.
6. Neither party may say or do anything nor permit a third party to do or say anything that may
estrange the Child from the other party, or injure the opinion of the Child as to the other party,
or may hamper the free and natural development of the Child's love or affection for the other
party. To the extent possible, both parties shall not allow third parties to disparage the other
parent in the presence of the Child.
7. In the event of a medical emergency, the custodial party shall notify the other party as soon as
practicable after the emergency is handled.
In the event the custodial parent should take the Child out of state, the custodial parent shall
notify the non-custodial parent within twenty-four hours of departure of the intended
destination and a telephone number at which they can be reached.
9. Counseling: Mother shall continue with her counseling, follow any and all recommendations
of her therapist and give authorization for Father to provide information to the therapist
regarding her treatment. Mother shall additionally continue in her efforts to supply Father with
progress reports regarding her treatment in order for Father to assess Mother's ability to have
expanded custodial time with her Child. In the alternative, Mother shall discuss with her
treating professionals whether it is possible for the professionals to give a verbal update to
Father on her treatment progress.
10. Each parent shall have two non-consecutive weeks (i.e. no more than seven days in a row) of
vacation per year with the Child. The requesting parent shall give the other parent 30 days
advance notice of the requested time and this vacation week shall supersede the regular
physical custody schedule. In the event the parties schedule conflicting vacations, the party
first providing written notice shall have the choice of vacation. Prior to departure, the parties
will provide each other with information regarding the intended vacation destination and a
telephone number at which they can be reached during their vacation. The parties may
expand/alter this vacation time by mutual agreement.
11. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify
the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of
this Order shall control.
J.
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Distribution:
,/Thomas Gould, Esquire
Aincent Monfredo, Esquire
ohn J. Mangan, Esquire
HOLIDAYS AND
SPECIAL DAYS TEWES EVEN
YEARS ODD
YEARS
Easter Da 1 S Half From 8 am until 2 m Father Mother
Easter Da 2n Half From 2 m until 8 m Mother Father
Memorial Da From 10 am until 8 m Mother Father
Independence Da From 10 am until 8 m Father Mother
Labor Da From 10 am until 8 m Mother Father
Halloween From one hour before trick or
treating to one hour after trick or
treatin Father mother
Thanksgiving 1 S
Half From 8 am Thanksgiving Day to 2
m on Thanksgiving Da Father Mother
Thanksgiving 2°
half From 2 pm on Thanksgiving Day to
noon the day after Thanksgiving Da Mother Father
Christmas 1 S Half From noon on 12/24 to noon on
12/25 Father Mother
Christmas 2° Half From noon on 12/25 to noon on
12/26 Mother Father
New Year's From 6 pm 12/31 until noon January
1St (with the 12/31 year to control the
even/odd determination) Mother Father
Mother's Da From 10 am until 8 m Mother Mother
Father's Da From 10 am until 8 m Father 71 Father
RONALD R. COON, JR.,
Plaintiff
V.
CHRYSTAL O'MALLEY,
Defendant
Prior Judge: Edward E. Guido, J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 08-601 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
1. The pertinent information pertaining to the Child who is the subject of this litigation is
as follows:
Name Date of Birth Currently in the Custody of
Jeremiah F. Coon 10/17/2006 Primary Father
2. A Conciliation Conference was held with regard to this matter on March 31, 2008, an
Order was entered April 4, 2008, a status update Conciliation Conference was held on May 1, 2008, an
Order of Court issued May 6, 2008 and a status update conference held on July 1, 2008 with the
following individuals in attendance:
The Mother, Chrystal O'Malley, with her counsel, Thomas Gould, Esq.
The Father, Ronald Coon, Jr., with his counsel, Vincent Monfredo, Esq.
3. The parties agreed to the entry of an Order in the form as attached.
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Cust dy tnciliator
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RONALD R. COON, JR. IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
CRYSTAL O'MALLEY
DEFENDANT
2008-601 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, October 13, 2009 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, November 18, 2009 y at 1:00 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.
FOR THE COURT,
By: /s/ John J. Mangan, Jr., Es q. , IAN
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
N PF tt. t {f T
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2009 OCT 1 3 PM 3 2 J
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NOV 2 3 2009 3 0
RONALD R. COON, JR.,
Plaintiff
V.
CHRYSTAL O'MALLEY,
Defendant
Prior Judge: Edward E. Guido, J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 08-601 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW this day of November 2009, upon consideration of the attached Custody
Conciliation Report, it is Ordered and Directed as follows:
1. All prior Orders of Court entered in this matter are hereby VACATED and replaced with this
Order.
2. Legal Custody: The Father, Ronald R. Coon, Jr., and the Mother, Chrystal O'Malley, shall
have shared legal custody of Jeremiah F. Coon, born 10/17/2006. The parties shall have an
equal right to make all major non-emergency decisions affecting the Child's general well-being
including, but not limited to, all decisions regarding 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 of the other parent. To the extent one
parent has possession of any such records or information, that parent shall be required to share
the same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent.
3. Physical Custody: Father shall have primary physical custody of the Child subject to Mother's
partial physical custody pursuant to a schedule as follows:
a. Commencing Friday 11/27/09, Mother shall have physical custody of the Child
every other Friday at 12:30 pm picking the Child up from day care (or if there is
no day care, from Wal-Mart in Mechanicsburg) until Sunday at 7:00 pm with the
parents meeting Sunday at Wal-Mart in Mechanicsburg at 7:00 pm.
b. Mother shall have physical custody every Wednesday whereby she shall pick
the Child up at day care at 12:30 am until Thursday morning whereby Mother
shall transport the Child to day care no later than 8:00 am.
C. The parties may modify this schedule by mutual agreement as necessary or
proper as long as it is in the Child's best interest.
4. The non-custodial parent shall have liberal telephone contact with the Child on a reasonable
basis. Each parent shall provide the other parent with an operable telephone number at which
the parent can communicate with the Child.
5. Holidays and Birthdays: The parents shall arrange the Holidays and Birthdays as mutually
agreed upon or in the absence of agreement, the parents shall abide by the attached holiday
schedule. The holiday schedule shall take precedence over the regular physical custody
schedule.
6. Neither party may say or do anything nor permit a third party to do or say anything that may
estrange the Child from the other party, or injure the opinion of the Child as to the other party,
or may hamper the free and natural development of the Child's love or affection for the other
party. To the extent possible, both parties shall not allow third parties to disparage the other
parent in the presence of the Child.
7. In the event of a medical emergency, the custodial party shall notify the other party as soon as
practicable after the emergency is handled.
In the event the custodial parent should take the Child out of state, the custodial parent shall
notify the non-custodial parent within twenty-four hours of departure of the intended
destination and a telephone number at which they can be reached.
9. Counseling: Mother shall continue with her counseling, follow any and all recommendations
of her therapist and give authorization for Father to provide information to the therapist
regarding her treatment. Mother shall additionally continue in her efforts to supply Father with
progress reports regarding her treatment in order for Father to assess Mother's ability to have
expanded custodial time with her Child. In the alternative, Mother shall discuss with her
treating professionals whether it is possible for the professionals to give a verbal update to
Father on her treatment progress.
10. Each parent shall have two non-consecutive weeks (i.e. no more than seven days in a row) of
vacation per year with the Child. The requesting parent shall give the other parent 30 days
advance notice of the requested time and this vacation week shall supersede the regular
physical custody schedule. In the event the parties schedule conflicting vacations, the party
first providing written notice shall have the choice of vacation. Prior to departure, the parties
will provide each other with information regarding the intended vacation destination and a
telephone number at which they can be reached during their vacation. The parties may
expand/alter this vacation time by mutual agreement.
11. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify
the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of
this Order shall control.
J.
Distribution:
Ronald Coon, Jr., 6503 Salem Park Circle, Mechanicsburg, PA 17050 - 1 l
Chrystal O'Malley, P.O. Box 797, New Kingstown, PA 17072
John J. Mangan, Esquire
HOLIDAYS AND
SPECIAL DAYS TIMES EVEN
YEARS ODD
YEARS
Easter Day 1St Half From 8 am until 2 m Father Mother
Easter Day 2n Half From 2 m until 8 m Mother Father
Memorial Day From 10 am until 8 pm Mother Father
Independence Day From 10 am until 8 m Father Mother
Labor Day From 10 am until 8 m Mother Father
Halloween From one hour before trick or
treating to one hour after trick or
treating Father Mother
Thanksgiving 0
Half From 8 am Thanksgiving Day to 2
m on Thanksgiving Da Father Mother
Thanksgiving 2n
half From 2 pm on Thanksgiving Day to
noon the day after Thanksgiving Day Mother Father
Christmas Pt Half From noon on 12/24 to noon on
12/25 Father Mother
Christmas 2" Half From noon on 12/25 to noon on
12/26 Mother Father
New Year's From 6 pm 12/31 until noon January
1St (with the 12/31 year to control the
even/odd determination) Mother Father
Mother's Day From 10 am until 8 m Mother Mother
Father's Day From 10 am until 8 pm Father Father
• !
RONALD R. COON, JR.,
Plaintiff
V.
CHRYSTAL O'MALLEY,
Defendant
Prior Judge: Edward E. Guido, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
The pertinent information pertaining to the Child who is the subject of this litigation is
as follows:
Name
Jeremiah F. Coon
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 08-601
CIVIL ACTION LAW
IN CUSTODY
Date of Birth Currentlv in the Custody of
10/17/2006 Primary Father
2. A Conciliation Conference was held with regard to this matter on March 31, 2008, an
Order was entered April 4, 2008, a status update Conciliation Conference was held on May 1, 2008, an
Order of Court issued May 6, 2008, a status update conference held on July 1, 2008, an Order issued
July 3, 2008, Mother filed a petition to modify and a conference was held November 18, 2009 with the
following individuals in attendance:
The Mother, Chrystal O'Malley, pro se
The Father, Ronald Coon, Jr., pro se
3. The parties agreed to the entry of an Order in the form as attached. "Oe
Date Jo angan, Esquire
C tod Conciliator
r1?L,', -
IHE
2009 NOV 24+ At'i d 1: 2U