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HomeMy WebLinkAbout04-0082LEROY A. CRAMER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. MARIE L. REED DEFENDANT 04-82 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Thursday, July 13, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, August 25, 2006 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Es q. 41(1 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?WV ry LEROY A. CRAMER, Plaintiff V. MARIE L. REED, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. O V- TX CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY I. Plaintiff is Leroy A. Cramer, an adult individual currently residing at 810 Greenspring Road, Newville, Cumberland County, Pennsylvania. 2. Defendant is Marie L. Reed, an adult individual currently resides at an undisclosed location in Cumberland County. Service of this Complaint will be made by hand delivery to Defendant at the Domestic Relations Office at the time of the parties' support conference on January 8, 2003. At that time, a mailing address will be obtained. 3. The parties are the natural parents of one (1) child, namely, Timothy Paul Reed, born May 5, 2002. The child was born out of wedlock. 4. For the past five (5) years, or since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: NAME ADDRESS DATES Plaintiff Roxbury Ridge Apartments Birth to Defendant Shippensburg, PA December 2002 Plaintiff Quality Inn December 2002 to Defendant Shippensburg January 2003 NAME ADDRESS Plaintiff 2 Tressler Drive Apartments Defendant Loysville, PA Plaintiff unknown Cumberland County, PA DATES January 2003 to August 2003 August 2003 to Present The natural mother of the child is Marie L. Reed who resides as aforesaid. She is 5 6. 7 8. single. The natural father of the child is Leroy A. Cramer who resides as aforesaid. He is single. The relationship of the Plaintiff to the child is that of natural father. The Plaintiff currently resides with his friends, David and Gloria Anderson and their son, Joshua. The relationship of the Defendant to the child is that of natural mother. It is believed that Defendant currently resides alone with the child. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the child. Plaintiff has no information of any custody proceedings concerning the child pending in any Court of this Commonwealth. 9. It is in the best interest and permanent welfare of the child to grant the relief requested because: a) Plaintiff is best able to provide for the financial, emotional and physical needs of the child; b) Defendant has shown an inability to provide for the financial, physical, or emotional needs of the child in that it is believed that she has no stable residence or stable employment; C) From the time of the child's birth through August 2003, when the parties separated, Plaintiff made several attempts to care equally for the child and to take equal responsibility for the child; d) Since August 2003, Defendant has remained in an undisclosed location with the child and refuses to allow the Plaintiff to have contact with the child. 10. Plaintiff does not know any person not a party to this proceeding who claims to have custody or visitation rights with respect to the child. WHEREFORE, Plaintiff requests your Honorable Court to schedule a Custody Conciliation Conference followed by a hearing at which time he should be granted primary physical custody of the child. Respectfully submitted, Mary atas, Esquire Attorne o Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsifications to authorities. DATE: G'? LEROY A. CRAMER, Plaintiff ^'C CJ? - Y C CV LEROY A. CRAMER IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. 04-82 CIVIL ACTION LAW MARIE L. REED IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday January 14, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before -Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor Cumberland County Courthouse, Carlisle on Thursday, January 29, 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/ Hubert X. Gilroy,Esq. U 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 17 9A? _ `h7.?. rJ LEROY A. CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW MARIE L. REED, : NO. 04-82 Defendant : IN CUSTODY COURT ORDER AND NOW, this ?61 day , 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The father, Leroy A. Cramer, and the mother, Marie L. Reed, shall enjoy shared legal custody of Timothy Paul Reed, born May 5, 2002. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy periods of temporary physical custody of the minor child as follows: a. For the weekend of February 20, 2004 from Saturday February 21, 2004 at 9:00 a.m. until Sunday February 22, 2004 at 8:00 p.m. b. Starting the weekend of March 5, 2004 and continuing on alternating weekends thereafter, from Friday evening at 5:00 p.m. until Sunday evening at 7:00 p.m. c. At such other times as agreed upon by the parties. 4. The parties shall alternate custody of the minor child on major holidays with the time frame between 9:00 a.m. and 7:00 p.m. The father shall have Easter, July 4 and Thanksgiving in even numbered years and the mother shall have New Years Day, Memorial Day and Labor Day on even numbered years. The parties shall alternate those holidays thereafter. 5. For the Christmas holiday, the parties shall divide the holiday between two time frames, segment A being December 24 at noon until December 25 at noon and segment B being December 25 at noon until December 26 at noon. The parties shall alternate custody on those time frames with mother having segment A and father having segment B in 2004. 6. Both parties shall enjoy at least one week of vacation with the minor child during the summer. The parent shall give the other parent at least 30 days notice as to when they intend to exercise said vacation. 7. The mother shall always have custody of the minor child on Mother's Day and the father shall always have custody of the minor child on Father's Day, the time frame to be from 9:00 a.m. until 7:00 p.m. 8. The parties may modify the above order as they agree. Absent an agreement, this order shall control. In the event either party desires to modify this order, that party may petition the court to have the case again scheduled with the Custody Conciliator for a conference. BY CO T v °? G Judge cc: Jessica Diamondstone, Esquire 3 Qz,o, Mary Lou Mathis, Esquire° L ?.? .. _..CE C F THE 00"111,' L? cB 2 6 2GGb ti LEROY A. CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW MARIE L. REED, : NO. 04-82 Defendant : IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. Based upon a telephone conference that the Conciliator conducted with legal counsel for the parties, the Conciliator recommends an order in the form as attached. -Q2d b DATE Z?/)/ Hubert X. G' roy, Esquire Custody C ciliator SHERIFF'S RETURN - NOT SERVED CASE NO: 2004-00082 T COMMONWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN FULTON COUNTY NATIONAL BANK VS STEPHEN D CRAMER, ET AL ROBERT WOLLYUNG CoM14,rtiana Ili- 0q. 1?1'70 , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: CRAMER STEPHEN D but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT-MORT FORECLS NOT SERVED , as to the within named DEFENDANT CRAMER STEPHEN D 264 HOSTETTER AVENUE SHIPPENSBURG, PA 17257 RETURNED AT REQUEST OF ATTORNEY. Sheriff's Costs: Docketing Service Affidavit Surcharge So answers: 00 00 2) E 00 - BERT WOLLYUNG, erif 00 00 00 MARKIAN R SLOBODIAN ESQ 05/18/2004 Sworn and subscribed to before me this day of/' Notary I Notarial Seal Richard D. McCarty, Notary Public Chmnbasburg Bmo, P'ranldin County My Commission Expires Jan. 29, 2007 SHERIFF'S RETURN - NOT SERVED CASE NO: 2004-00082 T COMMONWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN FULTON COUNTY NATIONAL BANK VS STEPHEN D CRAMER, ET AL ROBERT WOLLYUNG ?'?mFuclarc? ?.uunEJ ? vy- iy-ro , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: CRAMER PAMELA G but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT-MORT FORECLS NOT SERVED , as to the within named DEFENDANT CRAMER PAMELA G 264 HOSTETTER AVENUE SHIPPENSBURG, PA 17257 RETURNED AT REQUEST OF ATTORNEY. Sheriff's Costs: Docketing Service Affidavit Surcharge So answers: 00 00//?ti rG1/r 00 OBERT WOLLYUNG, S ff 00 00 00 MARKIAN R SLOBODIAN ESQ 05/18/2004 Sworn an?d/ subscribed to before me this ?b day of Notary ?Y poylic in ('qumy ld an. 29,2W7 0;W LEROY A. CRAMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW MARIE L. REED, : NO. 04-082 CIVIL TERM Defendant : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW, comes Petitioner, Leroy A. Cramer, by and through his legal counsel of record, Marylou Matas, Esquire, and the law firm of Griffie & Associates petitions the Court as follows: 1. Your Petitioner is the above-named Plaintiff, Leroy A. Cramer, an adult individual currently residing at 810 Greenspring Road, Newville, Cumberland County, Pennsylvania. 2. Your Respondent is the above-named Defendant, Marie L. Reed, an adult individual whose mailing address is 7 Pine Road, Apt. 606, Mount Holly Springs, Cumberland County, Pennsylvania. 3. The parties are the natural parents of one child, Timothy Paul Reed, born May 5, 2002. 4. The parties are subject to an Order of Court dated March 2, 2004, a copy of which is attached hereto and incorporated herein by reference; as Exhibit "A." 5. Since the entry of the aforementioned Order, the child has continued to reside in Cumberland County, Pennsylvania, thus providing this Court with ongoing jurisdiction of these proceedings. 6. Since the entry of the aforementioned Order, the Petitioner consistently has exercised his periods of custody on alternating weekends frorn Friday at 5:00 p.m. until Sunday at 7:00 p.m. 7. Since the entry of the aforementioned Order, Petitioner has discovered that Cumberland County Children and Youth Services provides continuing ongoing services to Respondent in her home causing Petitioner to question Respondent's ability to properly care for the child. 8. Respondent dresses the child inappropriately, dropping him off to Petitioner with several layers of heavy clothing on during the warmer months. 9. Respondent does not feed the child appropriately, providing only liquids, sometimes sour, from a bottle when the child is able to eat solid foods and drink from a cup. 10. Respondent frequently takes the child to the emergency room after she receives custody of him on Sunday evenings, despite the fact that the child arrives to her in good condition. 11. Respondent does not have transportation. 12. Respondent is not employed. 13. Respondent does not have a telephone connection in her home. 14. Respondent has exhibited an inability to provide the most basic needs to the child. 15. Petitioner desires to establish more contact with the child to provide that the child is appropriately cared for. 16. It is in the best interest and permanent welfare to provide Petitioner with primary periods of custody. WHEREFORE, Petitioner requests your Honorable Court to schedule a conciliation conference at which time an order should be entered providing him with additional periods of custody with the child. Respectfully submitted, / aA'-0 Marylou atas, Esq ire Attorney r Plaintiff/Petitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsifications to authorities. 6 C?,zdq DATE: LEROY A. CRAMER, Petitioner/Plaintiff LEROY A. CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW MARIE L. REED, : NO. 04-82 Defendant : IN CUSTODY COURT ORDER AND NOW, this I 1? day of-?'2 , 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The father, Leroy A. Cramer, and the mother, Marie L. Reed, shall enjoy shared legal custody of Timothy Paul Reed, born May 5, 2002. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy periods of temporary physical custody of the minor child as follows: a. For the weekend of February 20, 2004 from Saturday February 21, 2004 at 9:00 a.m. until Sunday February 22, 2004 at 8:00 p.m. b. Starting the weekend of March 5, 2004 and continuing on alternating weekends thereafter, from Friday evening at 5:00 p.m. until Sunday evening at 7:00 p.m. c. At such other times as agreed upon by the parties. 4. The parties shall alternate custody of the minor child on major holidays with the time frame between 9:00 a.m. and 7:00 p.m. The father shall have Easter, July 4 and Thanksgiving in even numbered years and the mother shall have New Years Day, Memorial Day and Labor Day on even numbered years. The parties shall alternate those holidays thereafter. 5. For the Christmas holiday, the parties shall divide the holiday between two time frames, segment A being December 24 at noon until December 25 at noon and segment B being December 25 at noon until December 26 at noon. EXHIBIT "A" The parties shall alternate custody on those time frames with mother having segment A and father having segment B in 2004. 6. Both parties shall enjoy at least one week of vacation with the minor child during the summer. The parent shall give the other parent at least 30 days notice as to when they intend to exercise said vacation. 7. The mother shall always have custody of the minor child on Mother's Day and the father shall always have custody of the minor child on Father's Day, the time frame to be from 9:00 a.m. until 7:00 p.m. 8. The parties may modify the above order as they agree. Absent an agreement, this order shall control. In the event either party desires to modify this order, that party may petition the court to have the case again scheduled with the Custody Conciliator for a conference. BY CO T _ 1 ? Judge cc: Jessica Diamondstone, Esquire q Mary Lou Mathis, Esquire 0 ^ :.: tI)a Bavl Ot ;r°x?:3 ?L F7;:Y9 i t tndt+4lfi . 1!"Wr fly ?-8 2 6 2604 LEROY A. CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v - : CIVIL ACTION - LAW MARIE L. REED, : NO. 04-82 Defendant : IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVH RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. Based upon a telephone conference that the Conciliator conducted with legal counsel for the parties, the Conciliator recommends an order in the form as attached. a 2r b DATE Hubert X. Custody C Esquire p Q r-3 v, c? =o Ern -f u LEROY A. CRAMER, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION-LAW V. :CUSTODY MARIE L. REED, ; NO. 04-082 CIVIL TERM Defendant TO THE PROTHONOTARY OF SAID COURT: PLEASE withdraw the appearance of Mid Penn Legal Services as attorney of record for the Defendant, Marie L. Reed, in the above captioned matter. Resppeecttffu/llpy gm tte by, Jess ca Diamondstone, Esq. Dated: (?•/$ ??? Mid Penn Legal Services 8 Irvine Row Carlisle, PA 17013 of the Family Law Clinic as attorney of record on PLEASE enter the appearance behalf of the Defendant, Marie L. Reed, in the above captioned matter. Respe tfully submitted by: 1_ Jaso C. Evans Certi ted Legal intern 4RE9RT THOMAS I . PLACE LUCY JOHNSTON-WALSH ALINE MACDONALD-FOX FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2'968 x? ?; cv i j C? co ,i to _i za: O o ?? N C.? LEROY A. CRAMER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 04-82 CIVIL ACTION LAW MARIE L. REED IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday June 22, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor Cumberland County Courthouse, Carlisle on Friday, July 16, 2004 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/ Hubert X Crilrov,E5q mhc Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717)249-3166 -467 -INN ur:o ^,na cz , nr uoz .'ll?',,, Qaila Y JUL 2 8 2004 r/ LEROY A. CRAMER,. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW MARIE L. REED, NO. 2004 - 82 Defendant IN CUSTODY COURT ORDER AND NOW, this Z?day of _, 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed that this Courts prior order of March 2, 2004 is modified as follows: 1. Father's periods of weekend visitation shall now be 3 out of 4 weekends from Friday at 5:00 p.m. until Monday at noon. On the fourth weekend, father shall have visitation for one day from 10:00 a.m. until 7:00 p.m. on Saturday unless agreed otherwise by the parties. This schedule is subject to the understanding that father will accommodate any family or any other social events that mother would have on the weekend that would normally include the minor child. Additionally, the parties may modify the Saturday time on the fourth weekend to change it to Sunday or some other times as the parties may agree. 2. This is a shared custody arrangement such that both parents have the ability to obtain all medical records relating to the minor child. Both parents shall sign necessary releases in order for the other parent to obtain said records. 3. Both parents shall make their homes available for the other parent to reasonably inspect the home. 4. In the event mother's schedule changes relative to employment or otherwise would require a modification of this order or in the event circumstances change such that father desires to modify this order, either party may contact the Custody Conciliator directly to schedule another conference in this case. BY THE COUIU, Judge r cc: Jason Evans, Dickinson Family Law Clinic Marylou Matas, Esquire )IQ 7 ?jd 0 J V;NVNI ;cIN d 10 :1 Wd R liii UR AdVI NDHIOUd 31-11 d0 30L?a0-Q311d LEROY A. CRAMER, Plaintiff v MARIE L. REED, Defendant Prior Judge: Edgar B. Bayley, Jr. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 2004 - 82. : IN CUSTODY CONCILIATION CONFERENCE SUMPvIARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Timothy Paul Reed, born May 5, 2002. 2. A Conciliation Conference was held on July 16, 2004, with the following individuals in attendance: The father, Leroy A. Cramer, with his counsel, Marylou Matas, Esquire, and the mother, Marie L. Reed, who appeared with her student attorney, Jason Evans of the Dickinson School of Law, Family Law Clinic. 3. The parties agreed to the entry of an order in the farm as attached. DATE Hubert X. Gilroy, quue Custody Concilior LEROY CRAMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO.: 2004-82 MARIE REED, Defendant IN CUSTODY PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Plaintiff in the above captioned case. Date: 0 5 RespectibIly submitted, ROMINGER, BAYLEY & WHARE TO THE PROTHONOTARY: Karl E. 1Rominger, Esquire 155 South Hanover Street Carlisle. PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff Please withdraw my appearance on behalf of the Plaintiff in the above captioned case. Date: Respectfully submitted, GRIFFIE & ASSOCIATES -n J'6'0 - Marylor atas, Esquire ?-?} ;J I i .: y .-i L... ..:: {._: FEB 2 2 2005 PYk LEROY A. CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW MARIE L. REED, NO. 2004-82 Defendant IN CUSTODY COURT ORDER AND NOW, this I Aay of February, 2005, upon consideration of the attached Custody Conciliation report, the prior Custody Orders entered in this case are vacated and the following temporary Custody Order is entered: 1. The Mother, Marie L. Reed, and the Father, Leroy A. Cramer, shall enjoy shared legal custody of Timothy Paul Cramer, born May 5, 2002. 2. Physical custody shall be handled with the Mother having physical custody of the minor child each weekday from 9:30 a.m. until 3:30 p.m. Additionally, one out of every four weekends Mother shall also have custody during the day from 9:30 a.m. until 3:30 p.m. The Father shall enjoy physical custody at all other times unless agreed otherwise by the parties. 3. Mother shall pursue the completion of an evaluation at Helen Stevens Mental Health Center. Upon completion of that evaluation, legal counsel for the Mother may contact the Conciliator directly to schedule a conference call with the Conciliator and counsel for the Father. At that time and in the event the parties are unable to reach an agreement, the Conciliator may refer this case to the Court for a hearing and may also recommend any modification of the existing Custody Order if the Conciliator deems appropriate. BY , cc:?opglas Boorstein Judge Edward E. Guido rl E. Rominger, Esquire 09C? O2• LEROY A. CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW MARIE L. REED, NO. 2004-82 Defendant IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1415.3-8(b), the undersigned Custody Conciliator submits the following report: 1. 2. 3 The pertinent information pertaining to the child who is the subject of this litigation is as follows: Timothy Paul Reed, born May 5, 2002. A Conciliation Conference was held on February 18, 2005, with the following individuals in attendance: The Father, Leroy A. Cramer, with his counsel, Karl E. Rominger, Esquire, and the Mother, Marie L. Reed, with her student attorney, Douglas Boorstein, of the Dickinson School of Law Family Law Clinic. There is a prior Order in this case from July 2004. Since the Order of July 2004, Children Services got involved in this case and the matter went before the Master, James D. Flower, Esquire, who temporarily recommended that Father maintain primary custody of the minor child subject to Mother seeing the child every day during the week. Judge Edward E. Guido ratified that provision in an Order dated January 25, 2005. 4. Mother is scheduled to have an evaluation at Stevens Mental Health Center, and the Conciliator recommended that matters in this case be put on hold pending Mother's completion of the evaluation. The Conciliator also impressed upon the Father the need to abide by the existing recommendation and Custody Order which is that Mother will have custody of the minor child every weekday from 9:30 a.m. until 3:30 p.m. The Conciliator also impressed upon the Father the need to insure that other people in the Father's household are not referred to as having a family relationship with the minor child because that type of conduct would cause confusion in the future. With those understandings, the parties are satisfied to delay any scheduling of a hearing in this case pending completion of an evaluation by the Mother. 5. The Conciliator recommends an Order in the form as attached. DATE Hubert X. Gilr , Esquire Custody Conc . for Leroy CRAMER, Plaintiff V. Marie REED, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO. 04-82 CIVIL TERM MOTION FOR CONTINUANCE Plaintiff, Ms. Marie Reed, by and through her attorneys, the Family Law Clinic, represents the following: 1, On July 21, 2005, plaintiff, by letter, requested a telephone custody conciliation conference as permitted by this court's order of February 23, 2005. At the telephone custody conciliation conference, the plaintiff requested a hearing before this Court. Thereafter, on August 30, 2005, the court scheduled a hearing in this matter for October 10, 2005. 2. The current custody order provides plaintiff with primary physical custody and provides defendant with periods of partial custody. The parties share legal custody. 3. Defendant is represented by the Family Law Clinic of the Dickinson School of Law. The law school is not in session on October 10, 2005. Neither the supervising attorney nor the certified legal intern representing Defendant will be available on October 10, 2005. 4. Pursuant to Cumberland County Rule of Court 20?8.2(d), defendants counsel attempted to seek concurrence from opposing counsel. Counsel for plaintiff does not concur in this motion for continuance. WHEREFORE, Defendant respectfully requests a continuance in the above- captioned manner. Respectfully Submitted, Date: September 15, 2005 - Dou as es Boorstein Certifie Legal Intern a 4'! V O As& PLACE ROB ZT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle. PA 17013 717/243-2968 LEROY A. CRAMER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND ('OUNTY. PENNSYLVANIA V. MARIE L. REED DFFF.NDANT 04-0082 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, October 24, 2008 , upon consideration of the attached Complaint. it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq, the conciliator at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, December 01, 2005 at 9:30 AM fora 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 herehy 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 hearinLy. FOR THE COURT, By /sl Hubert X. Gilroy. Es N 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 10 YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONF, GO TO OR TELF PHONL I HE OFFICE SFT FORTH BELOW TO FIND OUT WHERE YOU CAN CET LEGAL I IELP. Cumberland County Bar Association 3? South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 z ? 44-r '41 -,?7 s,r ?,i S-(Z =5C - r,71 PR-E cEIVEI? t 0 T 2 0 2005 LEROY A. CRAMER IN THE COURT OF COMMON CUMBERLAND COUNTY, PENNSYLVANIA V. MARIE L. REED : NO. 2004 - 0082 CIVIL TERM ORDER OF COURT AND NOW, this 19T" day of OCTOBER, 2005, the Petition for Contempt shall be referred to conciliation as required by Local Rules of Court. Court, Edward E. Guido, J. Family Law Clinic 45 North Pitt Street Carlisle, Pa. 17013 For the Petitioner Karl E. Rominger, Esquire For the Plaintiff Court Administrator :sld n <" O Q (7 ?j c iv t?'7{Ti r tT'l ..p R7? C„tU "C r om _ LEROY CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW IN CUSTODY MARIE REED, Defendant tt :NO. 04-82 CIVIL TERM ?2rfti?Ci?C OY ?erv?(.N_ I, Douglas James Boorstein, hereby certify that on the 151' day of September, 2005, I served a true and correct copy of a Motion for Continuance dated September 15, 2005 on Karl Rominger, Esq., attorney for Plaintiff. Service was accomplished by first class U.S. mail, postage prepaid, addressed as follows: Karl Rominger, Esq. Rominger, Bayley & Whare 155 South Hanover Street Carlisle, PA 17013 Date: 7 Z 245 Doug s J es Boorstein Certi led L gal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 N m N C:n L .1 ECE; ED AUG 2 5 ms LEROY A. CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW MARIE L. REED, : NO. 2004-82 Defendant : IN CUSTODY COURT ORDER AND NOW, this 36 day of August, 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Court mom No. 5 of the Cumberland County Courthouse on the / 0 ON day of 0 r. 2005, at Z. JV / .m. At this hearing, the Father shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth the history of custody in this case, the issues currently before the Court, a list of witnesses who will be called to testify on behalf of each party, and a summary of the anticipated testimony of each witness. This Memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's prior Order of February 3, 2005 shall remain in effect subject to the following clarifications: A. The Mother's alternating weekend custody shall be on both Saturday and Sunday from 9:30 a.m. until 3:30 p.m. B. Mother shall also have custody on Labor Day this year in light of Father exercising custody on Memorial Day. Judge Edward E. Guido Cc: V61ouglas Boorstein, Esquire Arl E. Rominger, Esquire l \, ?f'.Q Z ;V I`ll >"di'3 LEROY A. CRAMER, Plaintiff v MARIE L. REED, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2004-82 : IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The Conciliator consulted with legal counsel for the parties in a telephone conference on August 22, 2005. At that time, the Father requested that a hearing be scheduled. Father is dissatisfied with the exiting February 3, 2005 Order and believes that Mother is still exhibiting conduct which is not in the best interest of the child. Father believes the Order should be modified by reducing Mother's time. Mother has a number of concerns also with respect to the existing custodial arrangement, and those concerns may be aired at the hearing if they are not resolved prior to the hearing. 2. The hearing is required and the Conciliator recommends an Order in the form as attached. Date: 9- a --G v r u?/ l ert X. G' oy, Esquire Custody ciliator C? 2ECU. c] Leroy CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . : CIVIL ACTION - LAW IN CUSTODY Marie REED, Defendant :NO. 04-82 CIVIL TERM ORDER OF COURT AND NOW, this W%ay of ' 2005, upon consideration of the attached Motion for Continuance, the motion is granted. 11 The hearing is scheduled in Courtroom Number ? for the r Y day of 12005, at-LA .3 Pending tlX-4 gQQ@§ or further Order of Court, the custody order dated February 23, 2005 as clarified on August 30, 2005, shall remain in full force and effect. 5 Q'6 S-ew Date Judge F, ?C5 All C-C :I I Wv 03 d3S 9002 XtrVIONO'r,1C'Ud 3Hl 30 30L-L40-C131fd LEROY CRAMER, Plaintiff V. MARIE REED, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO. 04-82 CIVIL TERM CERTIFICATE OF SERVICE I, Douglas James Boorstein, hereby certify that on the 14`h day of October, 2005, I served a true and correct copy of a Petition for Contempt dated October 13, 2005 on Karl Rominger, Esq., attorney for Plaintiff. Service was accomplished by first class U.S. mail, postage prepaid, addressed as follows: Karl Rominger, Esq. Rominger, Bayley & Whare 155 South Hanover Street Carlisle, PA 17013 ld l©S Date: 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 FAMILY LAW CLINIC t', 5...> ," i? ?? ? .l -. ?.?.I Gr tr: LEROY A. CRAMER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. MARIE L. REED NO. 2004 - 0082 CIVIL TERM ORDER OF COURT AND NOW, this 19TH day of OCTOBER, 2005, the Petition for Contempt shall be referred to conciliation as required by Local Rules of Court. Court, Edward E. Guido, J. .41mily Law Clinic 45 North Pitt Street Carlisle, Pa. 17013 For the Petitioner Xrl E. Rominger, Esquire For the Plaintiff Court Administrator sld IQ40 3 j :: .. ?. ?.-ti '} ?_ - i "1 LEROY CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY MARIE REED, Defendant :NO. 04-82 CIVIL TERM I, Douglas James Boorstein, hereby certify that on the 15th day of September, 2005, I served a true and correct copy of a Motion for Continuance dated September 15, 2005 on Karl Rominger, Esq., attorney for Plaintiff. Service was accomplished by first class U.S. mail, postage prepaid, addressed as follows: Karl Rominger, Esq. Rominger, Bayley & Whare 155 South Hanover Street Carlisle, PA 17013 Date: 1'L' S 1 ? Doug s Ja es Boorstein Certi ied L 'gal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 A? Gy c :? 'J ?--? cr?? t/x ? -r? p :"t . ?1 r t` ? ? LL>. ,? ? ??? R? --, Y \1 [„?4 y C ?? RECEIVED DC 2005 LEROY A. CRAMER, : IN THE COURT OF COMMON PLEAS OF PlaintifflRespodent : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW :CUSTODY MARIE L. REED, Defendant/Petitioner :NO. 04-82 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Marie Reed, Defendant/Petitioner, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certify that we believe the party is unable to pay the costs and that we are providing free legal service to the party. J Date: /1"61(1 ? Douglas J. Boorstein Certified Legal Intern THOMAS CE ROBERT E. INS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 Phone: (717)243-2968 Fax: (717) 243-3639 6 `"? ti ?? (...??' j r...1 ?.? __ :. : t:.,:?Y ... i 1 --? ?.. RECEIVED LEROY A. CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respodent : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW :CUSTODY MARIE L. REED, Defendant/Petitioner :NO. 04-82 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Marie Reed, Defendant/Petitioner, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certify that we believe the party is unable to pay the costs and that we are providing free legal service to the party. r V ' Date: t /, 3 G(".- `5' ?`' ; l ` I rv / Douglas J. Boorstein Certified Legal Intern l3 [/ // THOMAS ._P. ACE ROBERT E. INS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 Phone: (717)243-2968 Fax: (717) 243-3639 LEROY A. CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respodent : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW :CUSTODY MARIE L. REED, Defendant/Petitioner :NO. 04-82 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Marie Reed, Defendant/Petitioner, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certify that we believe the party is unable to pay the costs and that we are providing free legal service to the party. l Date: k or, V Douglas J. Boorstein Certified Legal Intern THOMAS E ACE ROBERT E. INS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 Phone: (717)243-2968 Fax: (717) 243-3639 k LEROY A. CRAMER PLAINTIFF V. MARIE L. REED DEFENDANT IN THE. COURT OF COMMON PLEAS Of CUMBERLAND COUNTY, PENNSYLVANIA 04-0082 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW. Monday, October 24, 2005 upon consideration of the anached Complaint, it is hereby directed that parties and their respective counsel appear betbre Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, December 01, 2005 at 9:30 AM fora Pre-Hearing Custody Confcrence. At such confercnce, an effort veill be made to resolve the issues in dispute, or if this cannot he acconhplishcd, to define and narrow the issues to be heard by the court., and to enter into a temporary order. Ail 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 Tull: COURT. _ L ?? B} h/ Hubert X. GrlroyI - Esq. ('ustodV Conciliator ? The Court of Common Pleas of Cumberland County is required by law no 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 conterence or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY ATONCF. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR 1 ELFPIIONt I HE OFFICE SFT FORTH BELOW TO FIND OUT WHERF. YOU CAN GIST I FGAL HELP. Cumberland County par Association 32 South Bedford Street Carlisle, Pennsylania 17013 Telephone (717) 249-3166 2 s> sue. Sf' 0/ 1 RECEIVET? I f OCT 2 0 2005 LEROY A. CRAMER IN THE COURT OF COMMON CUMBERLAND COUNTY. PENNSYLVANIA V. MARIE L. REED : NO. 2004 - 0082 CIVIL TERM ORDER OF COURT AND NOW, this 19TH day of OCTOBER, 2005, the Petition for Contempt shall be referred to conciliation as required by Local Rules of Court. Court, Edward E. Guido, J. Family Law Clinic 45 North Pitt Street Carlisle, Pa. 17013 For the Petitioner Karl E. Rominger, Esquire For the Plaintiff Court Administrator Ad ?y?, LEROY A. CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS CIVIL ACTION - LAW MARIE L. REED, NO. 2004-82 Defendant IN CUSTODY ORDER OF COURT AND NOW, this 24th day of October, 2005, after hearing we enter the following order which shall replace all prior custody orders which are vacated: 1. The Mother, Marie L. Reed, and the Father, Leroy A. Cramer, shall have shared legal and physical custody of their child Timothy Paul Cramer, born May 5, 2002. 2. Mother shall have physical custody of the child during the following periods: at 5:00 p.m. A. Every Tuesday from 1:00 a.m. until Thursday B. Every fourth weekend from Friday at 5:30 until Sunday at 6:00 p.m. C. Mother's Day weekend from Friday at 5:30 p.m. until Sunday at 6:00 p.m. D. From Christmas Eve at 5:00 p.m. until noon on Christmas Day in even numbered years and from Christmas Day at noon until 9:00 a.m. the day after Christmas in odd numbered years. E. From 9:00 a.m. until 5:00 p.m. on the following holidays on an alternating basis: New Year's Day, Easter, Memorial Day, Fourth of July, and Labor day. 3. Father shall have physical custody of the child at all other times. 4. The parties can change the terms of this order by agreement. Otherwise, this order shall control. 5. Exchanges of custody shall be in the parking lot of the Huntsdale Fire Department on the Pine Road in Huntsdale. 6. If either party takes the child for medical attention, the other By fied within 24 hours. Edward E. Guido, J. Vk`°rl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 /Ouglas Boorstein, Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 m l c ~ (`j??} n !? ' _ :G LEROY A. CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS CIVIL ACTION - LAW MARIE L. REED, NO. 2004-82 Defendant IN CUSTODY AMENDED ORDER OF COURT AND NOW, this 1st day of November, 2005, the order of October 24th, 2005, is hereby amended to reflect that the Mother shall have physical custody of the Child every Tuesday from 11:00 a.m. until Thursday at 5:00 p.m. and every fourth weekend from Friday at 5:30 p.m. until Sunday at 6:00 p.m. All other provisions of the previous order shall r n full force and effect. By th Court, I/ Edward E. Guido, J. /arl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 /Douglas Boorstein, Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 aQ? :mlc FJiA a':-i ? r., n kill 'fir 1 1 :6 WV Z- RON 3001 AVViiJ tiiJ -?.??) 3141 i0 Jl::J4,0--111 fly LEROY CRAMER, Plaintiff/Respondent V. MARIE REED, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO. 04-82 CIVIL TERM MOTION TO WITHDRAW PETITION FOR CONTEMPT Defendant/Petitioner, Marie Reed (Mother) by and through her attorneys, the Family Law Clinic, represents the following: On October 13, 2005, Mother filed a Petition For Civil Contempt For Disobedience of a Custody Order (Petition). A true and correct copy is attached as "Exhibit A." 2. On October 19, 2005, an Order of Court was entered referring Mother's Petition to conciliation. A further Order of Court dated October 24. 2005 scheduled the Conciliation for December 1, 2005, at 9:30 a.m. A true and correct copy of the October 24, 2005 order is attached as Exhibit "B." 3. On October 24, 2005, the Court held a custody hearing in this matter. 4. Following that hearing, the Court issued an Order on October 27, 2005, which was amended by further Order of Court on November 2, 2005. 5. Mother has advised her legal counsel that Plaintiff/Respondent Leroy Cramer (Father) has been providing Mother with her custodial periods as required by these new custody orders. 6. Since Father is currently complying with the court orders established October 27, 2005 and November 2, 2005, Mother has authorized her legal counsel to withdraw her Petition for Civil Contempt filed October 13, 2005. 7. Pursuant to Cumberland County Rule of Court 208.2(4), the concurrence of Father's counsel with this petition has been obtained. WHEREFORE, Defendant/Petitioner requests that this Court dismiss without prejudice the Petition For Civil Contempt For Disobedience of a Custody Order filed October 13, 2005. Respectfully Submitted, Date:© h?Q?trG Doug; s J es Boorstein Cert' ied ?egal Intern THO PACE ROBERT . RAINS LUCY J014NSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 7171243-2968 VERIFICATION I verify that the statements made in this Motion are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date; 1 ,3? :'(K1S 4olla ames Boorstein Legallntern LEROY A. CRAMER, Plaintiff/Respodent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW CUSTODY MARIE L. REED, Defendant/Petitioner NO. 04-82 CIVIL TERM NOTICE AND ORDER TO APPEAR Legal proceedings have been brought against you alleging you have willfully disobeyed an order of court for partial 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 October 24, 2005, at 12:30 p.m., in Courtroom Number Five, at the Cumberland County Courthouse. 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. Mid-Penn Legal Services 401 East Louther Street, Suite 301 Carlisle, PA 17013 (717) 243-9400 BY THE COURT: J. I LEROY A. CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respodent : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW CUSTODY MARIE L. REED, Defendant/Petitioner :NO. 04-82 CIVIL TERM - PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF A. CUSTODY ORDER 'u The Petition of Marie L. Reed respectfully represents: 1. A Custody Conciliation was held on February 18, 2005. As a result, this Court issued an order on February 23, 2005 awarding Petitioner, hereinafter Mother, periods of custody of the minor child, Timothy Paul Cramer, as follows: a. Physical custody of the child from 9:30 a.m. to 3:30 p.m. each weekday and, b. Physical custody one out of every four weekends, from 9:30 a.m. until 3:30 p.m. on Saturday and from 9:30 a.m. until 3:30 p.m. on Sunday. 2. Respondent, hereinafter Father, was awarded custody during all other times. A true and correct copy of the February 23, 2005 Order is attached to this petition as "Exhibit A." 3. On August 22, 2005, another Custody Conciliation was held via teleconference. 4. At this Custody Conciliation, Father requested that a hearing be held in this matter. A hearing has been scheduled for October 24, 2005 at 12:30 p.m. before the Honorable Edward E. Guido. 5. Following the conciliation on August 22, 2005, the Court entered an Order dated August 30, 2005 clarifying its Order of February 23, 2005, indicating once again that Mother had physical custody of the child every fourth weekend on both Saturday and Sunday. The Order also indicated that Mother should have custody on Labor Day, September 5, 2005. A true and correct copy of the August 30, 2005, Order is attached to this petition as "Exhibit B." 6. Father has repeatedly violated these Orders as outlined below: a. On Sunday, April 17, 2005, part of a "fourth weekend," Father did not give custody of Timothy to Mother. Father has not given Mother compensatory time for this missed day. b. On Sunday, May 15, 2005, part of a "fourth weekend," Father did not give custody of Timothy to Mother. Father has not given Mother compensatory time for this missed day. C. On Monday, May 30, 2005, Memorial Day, Father did not give custody of Timothy to Mother. Father has not given Mother compensatory time for this missed day. d. On Sunday, June 12, 2005, part of a "fourth weekend," Father did not give custody of Timothy to Mother. Father has not given Mother compensatory time for this missed day. On Saturday, July 9, 2005, part of a "fourth weekend," Father did not give custody of Timothy to Mother. Father has not given Mother compensatory time for this missed day. On Sunday, July 10, 2005, part of a "fourth weekend," Father did not give custody of Timothy to Mother. Father has not given Mother compensatory time for this missed day. g. On Sunday, August 7, 2005, part of a "fourth weekend," Father did not give custody of Timothy to Mother. Father has not given Mother compensatory time for this missed day_ h. On Sunday, September 4, 2005, part of a "fourth weekend," Father did not give custody of Timothy to Mother. Father has not given Mother compensatory time for this missed day. On Monday, September 5, 2005, Father did not give custody of Timothy to Mother. Father has not given Mother compensatory time for this missed day. Pursuant to Cumberland County Rule of Court 208.2(d), counsel for defendant sought but did not obtain concurrence from opposing counsel. WHEREFORE, Petitioner requests that Respondent be held in contempt of Court, and that Petitioner be awarded compensatory time or such other relief described in the statute as this Court deems appropriate. Petitioner further requests that this Petition for Civil Contempt be addressed at the Custody Hearing, scheduled for October 24, 2005, at 12:30 p.m. Respectfully Submitted, Date: _ilG,ht t? Doug,'s 13oorstein CertiPickegal Intern TH PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 Phone: (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 unsworn falsification to authorities. T Date. r 01 l U-2 0 Marie L. Reed Petitioner rte. LEROY A. CRAMER PLAINTIFF V. MARIE L. REED DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PF,NNSYLVANIA 04-0082 CIVIL, ACTION LAW IN CUSTODY ORDER ON COURT AND NOW, - Monday, October 24, 2005 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at _ 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, December 01, 2005 at 9:30 AM fora 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 he 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 mad 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 TI E COU RT, By: Js/ Hubert X.._Gilroy, Esq_ CUStod)' Conciliator The Court ofCommon 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 TOOK TELEPHONETHE OFFICE SET FORTH BELOW TO FIND OUT Wl{ERE YOU CAN GET LEGAL HELP. Cumberland Countv Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (7171 149-3166 rr?? T?2'''tc, e ` 9 > i t b In T-;stir v I h:,110 unlc set try hand and iha sC,ai of Z,-,'d court a!' Car!:"Ie, Pa. This ...5........ day af....t°:?.......,e?" Prothonotary -, :, A NOV 3 0 2005 LEROY CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW IN CUSTODY MARIE REED, Defendant :NO. 04-82 CIVIL TERM ORDER OF COURT AND NOW, this 1 0 day of Pe 2005, upon consideration of the attached Motion to Withdraw the Petition for Civil Contempt of a Custody Order, the Motion is granted. The Petition for Civil Contempt of a Custody Order filed October 13, 2005 is dismissed without prejudice. The conciliation conference scheduled for December 1, 2005 at 9:30 a.m. is canceled. THE COURT: Date /)- f- OS (A'-pt-4 Judge ?: iJ ? °?! I ??J1? ,. -? ? , -{;-. LEROY CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION- LAW IN CUSTODY MARIE REED, Defendant :NO. 04-82 CIVIL TERM CERTIFICATE OF SERVICE I, Douglas James Boorstein, hereby certify that on the 30`n day of November, 2005, at approximately 2:50 p.m., I served a true and correct copy of a Motion to Withdraw Petition for Contempt dated November 30, 2005 on Karl Rominger, Esq., attorney for Plaintiff. Service was accomplished by hand delivery to a competent adult at the offices of Rominger, Bayley & Whare, located at: 155 South Hanover Street Carlisle, PA 17013 Date: t 02 1 -er Dou S J es Boorstein Certified 4alIntern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ? ? A _ C . ` ?I ?? } HF,07M5 y LEROY A. CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 04-0082 CIVIL ACTION - LAW MARIE L. REED, IN CUSTODY Defendant ORDER 4 i Y- AND NOW, THIS day of December, 2005, the Conciliator being advised that the parties have resolved the issues in this case and that the Conciliation Conference can be cancelled, the Conciliator relinquishes jurisdiction. / it X. Gilroy, Esquire Custody Conciliator ?; _.,, ??? ?:,: i'_. STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF LEROY A. CRAMER, Plaintiff V. MARIE L. REED, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2004 -82 CIVIL TERM : IN CUSTODY PETITION FOR MODIFICATION AND NOW comes the plaintiff, Leroy A. Cramer, by his attorney, Stacy B. Wolf, Esquire, and presents the following complaint for custody, representing as follows: 1. The plaintiff/petitioner is Leroy A. Cramer, an adult individual residing at Betty Nelson Trailer Court, Lot 8A, Box 17, Carlisle, Cumberland County, Pennsylvania 17015. 2. The defendant/respondent is Marie L. Reed, an adult individual with an unknown mailing address. 3. The parties are the natural parents of one minor child, namely: N= Present Residence Age Timothy P. Cramer Betty Nelson Trailer Court 4 years Lot 8A, Box 17, Carlisle, PA 17013 4. The child is presently the subject of an Order for Custody issued October 24, 2005, providing for shared legal and physical custody of the child with Mother having periods of temporary physical custody every Tuesday from 11:00 a.m. until Thursday at 5:00 p.m., every fourth week end, and pursuant to a holiday schedule and with Father having physical custody of the child at all other times. A true and correct copy of the order of which modification is sought is attached hereto as Exhibit A. 5. Father seeks a modification of custody based upon developments that have occurred since the issuance of said custody order. 6. Father has a good relationship with the child and shares a strong bond with him 7. The child has been accepted at the Head Start school program in Newville, Pennsylvania and registration is scheduled for Thursday, August 31, 2006 at 1:00p.m. 8. Based on Mother's prior action on May 25, 2006 in refusing to take the child to school for a weather related make-up day even though fully aware of such make-up day, Father has concern that Mother will not take the child for the Head Start registration on Thursday, August 31, 2006. 9. The child will be attending school Monday through Thursday mornings from 9:00 a.m. until 1:00 p.m 10. Father avers that the basis for his actions concerning his child is solely motivated by his concern for the child's best interests and permanent welfare. 11. Father believes and therefore avers that it would be in the best interests of the child for the Court to issue an order granting primary physical custody of the child to Father with periods of visitation to Mother on an alternating week end basis. 12. Father believes and therefore avers that the best interests and permanent welfare of the child would be best served by the entry of an order as aforesaid. WHEREFORE, Plaintiff Leroy A. Cramer, prays this Honorable Court enter an Order granting primary physical custody of Timothy to Father with periods of alternating week end visitation to Mother, and any other relief the Court deems appropriate. Respectfully submitted, Dated: July -U, 2006 Wolf Wolf By: Stacy B. WMf, squire 10 West High Street Carlisle, PA 17013 Supreme Court I.D. No. 88732 (717) 241-4436 Attorney for Plaintiff VERIFICATION I, the plaintiff in the above-referenced action, do hereby verify that the facts set forth in this petition are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.-S. §4904, relating to unworn falsification to authorities. July (o , 2006 C_? Leroy A. Cramer LEROY A. CRAMER, VS MARIE L. REED, {{?? b _ )t __ o 1+5 l ??- : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004-82 IN CUSTODY ORDER OF COURT AND NOW, this 24th day of October, 2005, after hearing we enter the following order which shall replace all prior custody orders which are vacated: 1. The Mother, Marie L. Reed, and the Father, Leroy A. Cramer, shall have shared legal and physical custody of their child Timothy Paul Cramer, born May 5, 2002. 2. Mother shall have physical custody of the child during the following periods: Plaintiff Defendant A. Every Tuesday fromg1:00 a.-m. until Thursday at 5:00 p.m. B. Every fourth weekend from Friday at 5:301• until Sunday at 6:00 p.m. C. Mother's Day weekend from Friday at 5:30 p.m. until Sunday at 6:00 p.m. D. From Christmas Eve at 5:00 p.m. until noon on Christmas Day in even numbered years and from Christmas Day at noon until 9:00 a.m. the day after Christmas in odd numbered years. E. From 9:00 a.m. until 5:00 p.m. on the following holidays on an alternating basis: New Year's Day, Easter, Memorial Day, Fourth of July, and Labor day. 3. Father shall have physical custody of the child at all other times. 4. The parties can change the terms of this order by agreement. Otherwise, this order shall control. 5. Exchanges of custody shall be in the parking lot of the Huntsdale Fire Department on the Pine Road in Huntsdale. 6. If either party takes the child for medical attention, the other party Mall be notified within 24 hours. By th Court, Edward E. Guido, J. Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Douglas Boorstein, Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 :mlc > ' > r? ca { t`' t ? !4 t! T iii P' 41i1a:'01ary STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF LEROY A. CRAMER, Plaintiff V. MARIE L. REED, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2004 -82 CIVIL TERM : IN CUSTODY CERTIFICATE OF SERVICE I, the undersigned, hereby certify that I served a copy of the foregoing Petition for Modification on the following party on this date and in the manner indicated. SERVICE BY FIRST CLASS MAIL: Douglas Boorstein, Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Date: July 4 , 2006 Stacy B. Wo , Esquire Attorney for Plaintiff ? ? [?^ 4( 1 \ O Q ? C ? Q ??. ,s LEROY CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY MARIE L. REED, Defendant. : NO. 2004-82 CIVIL TERM CUSTODY AGREEMENT THIS AGREEMENT, made this day of August 2006, between Leroy Cramer (Father) and Marie L. Reed (Mother) concerns the custody of their child: Timothy P. Cramer, born May 5, 2002. Mother and Father desire to enter into an agreement regarding the custody of their child. The order of November 1, 2005 shall remain in full force and effect with the following modifications: 1. Mother shall take the child to registration for the Head Start school program in Newville on Thursday, August 31, 2006 at 1:00 p.m. 2. Beginning September 5, 2005, Mother shall pick up the child at Head Start in Newville at 1:00 p.m. on Tuesdays. Mother shall drop the child off at Head Start on Wednesdays and Thursdays at 9:00 a.m., and will pick him up from the Head Start program at 1:00 p.m. on those days. This provision shall not apply during Head Start holidays and vacation periods. 3. Mother shall take the child to his pediatrician to have his tuberculosis test checked on the date specified by the pediatrician. 4. The parties intend to be bound by the terms of this agreement and intend for this Agreement to be made an Order of Court. r Leroy Cramer, Plaintiff ./44mx Tamara Fox Certified Legal Intern Counsel for Defendant 4SROBE. S . PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Counsel for Plaintiff FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 Fax(717)243-3639 I f) ? -'-3'9zd. ane . Reed, Defendant C) o cY 7 ©` ;f t?s w .r` PR is '=? C7 rn D --G RECT... ,IU AUG 9 8 2,006 IRV- &4 LEROY A. CRAMER, Plaintiff VS. MARIE L. REED, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2004-82 : IN CUSTODY ORDER CIVIL ACTION - LAW 4 AND NOW, this day of August, 2006, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. ert X. Gilroy, Esquire Custody Conciliator y M _ i_ M 7., ? 7 C cm . Cr_ N __j LL; CD o O P V N .4 14R RE7EIVED AUG BY. Leroy Cramer IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Marie L. Reed, Defendant : NO. 2004-82 CIVIL TERM ORDER OF COURT AND NOW, this *11 day of August 2006, the attached Custody Agreement is approved and entered as an Order of Court. BY THE COURT: J J O? r ' CO A '01 .C Wd 6Z SIR 9001 AbV, Oi\0 liuW ]"Hl jo 3.. ilt7-CT Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant LEROY CRAMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 04-82 CIVIL ACTION - LAW MARIE REED, Defendant IN CUSTODY DEFENDANT'S PETITION TO MODIFY 1. Defendant is Marie Reed ("Mother"), an adult individual currently residing at 26 East Main Street, Newville, Cumberland County, Pennsylvania. 2. Plaintiff is Leroy Cramer ("Father"), an adult individual currently residing at 810 Green Spring Road, Newville, Cumberland County, Pennsylvania. 3. Defendant seeks custody of the child, Timothy Paul Reed, a.k.a. Timothy Paul Cramer, who was born on May 5, 2002. The child was born out of wedlock. 4. The current Orders which are controlling and in effect are dated October 24, 2005, as amended on November 1, 2005, and August 29, 2006. 5. Father has primary physical custody of the child and has refused Mother any visitation with the child for several months but for short periods of time during the child's counseling appointments. 6. Mother moved to Newville to be closer to the child based on the representation of the child's counselor that if Mother lived closer she could see the child more often after school. 7. Mother desires a shared physical custody schedule and believes the child wants to be with her more often. 8. It is in the child's best interest to have a strong relationship with his mother, and Mother feels Father and the Andersons (the friends who he lives with) are alienating Mother from the child. 9. Mother is concerned about scars she has seen on the child's face and their origin. 10. Defendant does not know of any person not a party to thesd proceedings who claims to have custody or visitation rights with respect to the child. 11. Judges Balyley, Guido and Ebert have all signed Orders in this matter. Judge Guido held the only hearing in this matter in October of 2005, and Judge Ebert signed the last Order of August 29, 2006. 12. Stacy Wolf, Esquire, has been notified in advance of the filing of this Petition and indicated she will accept service, but no concurrence was indicated. WHEREFORE, Defendant requests your Honorable Court to set a time and place for a hearing at which Defendant requests the Court to grant Defendant shared physical custody of the child. MARTSON LAW OFFICES By 1: 1 VT Y? Jennifer L. ars, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 December 23, 2008 Attorneys for Defendant VERIFICATION The foregoing Petition to Modify Custody is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Marie Reed CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Petition to Modify Custody was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Stacy B. Wolf, Esquire 10 West High Street Carlisle, PA 17013 MARTSON LAW OFFICES Y ( Trigia D. Eckenroad \ Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: December 23, 2008 cn v?' LEROY CRAMER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2004-82 CIVIL ACTION LAW MARIE REED IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, January 06, 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 Thursday, February OS, 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 Custodv orders to the conciliator 48 hours prior to scheduled hearinp,. FOR THE COURT, By: /s/ john . Man an r, Es q. 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 MAR 2 3 2009G n LEROY CRAMER, Plaintiff V. MARIE REED, Defendant Prior Judge: M. L. Ebert, J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 04-82 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW this day of March 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. All prior Orders entered in this matter are hereby VACATED and replaced with this Order. 2. Legal Custody: The Father, Leroy Cramer, and the Mother, Marie Reed, shall have shared legal custody of Timothy P. Cramer, born 5/05/2002. 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. Father is specifically directed to make sure that Mother receives copies of Timothy's report cards and progress reports. Father shall also make sure that Mother receives, or notify Mother to purchase, school photographs of Timothy. 3. Physical Custody: Father shall have primary physical custody of the Child subject to Mother's physical visitation as follows: a. Mother shall have visitation with Timothy every other Monday from 7:00 pm until 8:00 pm at Franklin Family Services in Carlisle. Upon the recommendation of Timothy's counselor, Mother shall additional time with Timothy. b. Mother shall have supervised physical custody of the Child at such other times as the parties may mutually agree. 4. Counseling: The parties have agreed, and are directed, to continue Timothy in his counseling at Franklin Family Services until successfully discharged. The parties shall follow the recommendations of Timothy's counselor. Mother has agreed, and is directed, to have a mental health psychiatric evaluation at the Stevens Center, or some other appropriate facility, and to follow the recommendations that flow from the evaluation, including but not limited to taking medication as recommended. 5. The Mother shall have telephone contact with the Child on a reasonable basis, as long as the communication is appropriate. .f 6. Holidays: Father shall allow Mother to have appropriate time with Timothy during the major holidays, as long as Timothy's counselor recommends said contact would be in his best interest. 7. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other parry, 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. 8. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 9. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 10. In the event that Mother should comply with the recommendations of her psychiatric evaluation and that Timothy's counselor feels that increased time with Mother is appropriate, either party may directly contact the assigned conciliator to schedule a status conference. 11. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, \ ? -J. D" t ibution: 'fer Spears, Esquire Wolf, Esquire hn J. Mangan, Esquire 4 'e? 6 ?i =6 R 12 NVW 6002 .? LEROY CRAMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 04-82 CIVIL ACTION LAW MARIE REED, IN CUSTODY Defendant Prior Judge: M. L. Ebert, J. CUSTODY CONCIIdATION 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 Date of Birth Timothy P. Cramer 05/05/2002 Currently in the Custody of Primary Father 2. A Conciliation Conference was held with regard to this matter on February 05, 2009 and continued until February 26, 2009 with the following individuals in attendance: The Mother, Marie Reed, with her counsel, Jennifer Spears, Esq. The Father, Leroy Cramer, with his counsel, Stacy Wolf, Esq. 3. The parties agreed to the entry of an Order in the form as attached. rz -a7 Date J angan, E ustody Conciliator TA BOM & &u i ULAKIS Michelle L. Sommer, Esquire Attomey I.D. #: 93034 2 West High Street Carlisle, PA 17013 (717) 249-09(X) LEROY CRAMER, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. NO. 04-0082 MARIE REED, CIVIL ACTION - LAW Defendant/Respondent IN CUSTODY TO THE M.L. EBERT, JR., JUDGE OF SAID COURT: AND NOW, comes the Petitioners, DAVID & GLORIA ANDERSON, by and through their attorney, Michelle L. Sommer, Esquire, of ABOM & KUTULAKIS, L.L.P., and respectfully petitions to intervene and requests a continuance in the above custody action, and in support thereof avers the following: 1. Petitioners are David & Gloria Anderson, who currently resides at 810 Greenspring Road, Newville, Cumberland County, Pennsylvania. 2. Respondent/Plaintiff is Leroy Cramer, who currently resides at 127 Long Road, Apartment #3, Newville, Cumberland County, Pennsylvania and is represented by Stacy Wolf, Esquire, of Wolf & Wolf. 3. Respondent/Defendant is Marie Reed, who currently resides at 26 East Main Street, Newville, Cumberland County, Pennsylvania and is represented by Jennifer Spears, Esquire, of Martson Law Offices. 4. The minor child, Timothy Cramer, (D/O/B May 5, 2002), currently resides with the Petitioners at 810 Greenspring Road, Newville, Cumberland County, Pennsylvania. 5. The minor child has resided with the Petitioners since February 9, 2007 when Cumberland County Children and Youth removed the child from the Mother's care and placed the child with the Father. 6. It is believed and therefore averred that Father felt as if he could not properly care for the minor child and asked the Petitioners to take the minor child into their home, which they did on February 9, 2007. 7. Respondent/Plaintiff is Leroy Cramer signed a Medical Release on March 28, 2008 for the Petitioners, David and Gloria Anderson on behalf of his minor child. (A copy of the Release is attached hereto as `Exhibit A'). 8. Cumberland County Children & Youth did not issue an Order for Custody; however, closed the file. 9. Father became unemployed in July 2008 and the Petitioners returned the minor child to the Father; however, the child only remained with his Father for approximately 20-days. 10. Father then gave back the minor child to the Petitioners and Cumberland County Children & Youth was aware that the minor child would be residing with them at their home at 810 Greenspring Road, Newville, Cumberland County, Pennsylvania and issued a letter on September 11, 2008, stating that "no further Agency services are required at this time due to Timothy living full time at the home of Gloria Anderson and that Ms. Anderson is ensuring the safety and wellbeing of Timothy." (A copy of the Letter from Cumberland County Children & Youth Services is attached hereto as `Exhibit B'). 11. A Custody Conciliation Conference was held February 26, 2009, and Petitioners and Respondents were all present; however, the Petitioners were not allowed to be present in the Conciliation Conference since they were not a named party. (A copy of the Court Order is attached hereto as `Exhibit C'). 12. It is believed and therefore averred that Attorney Jennifer Spears filed the Emergency Petition for Special Relief after she was contacted by undersigned counsel for the Petitioners asking if Mother would consent to an Involuntary Termination of her Parental Rights in order for Petitioners to pursue adoption of the minor child. 13. It is believed and therefore averred that it is in the minor child's best interest to be adopted by the petitioners; therefore they have begun the process to adopt the minor child. 14. It is believed and therefore averred that during the telephone conversation with undersigned counsel, Attorney Spears only then became aware that the minor child had in fact been living with the Petitioners and not with his biological Father as was stated by him at the Conciliation on February 26, 2009. 15. Despite their averment to the contrary, the Respondents and their Counsel do know of a person(s) or a parry to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child; therefore the Petitioners should be allowed to intervene in the Emergency Petition for Special Relief since they are a party to this action and have allowed the minor child to reside in their home since February 9, 2007. 16. Jennifer Spears, counsel for the Respondent/Defendant Marie Reed, has not been contacted since she will likely object to the filing of this Motion due to the recent letter requesting an emergency Conciliation Conference on her client's behalf. 17. Undersigned counsel has contacted Stacy Wolfe, counsel for the Respondent/Plaintiff Leroy Cramer, who does not oppose the filing of these Motions. 18. Undersigned Counsel for the Petitioners would ask to be present for the Emergency Conciliation Conference scheduled for Friday, June 26, 2009 at 1:00 p.m. before Conciliator Mangan; however, she is unavailable and will be out-of-the office that day and would ask for a Continuance for the Conciliation Conference scheduled for that day so the Petitioners can be present. WHEREFORE, the Petitioners requests that this Court allow them to intervene in the above docketed custody matter since the minor child has in fact resided with them since February 9, 2007. It is further requested that this Court grant the continuance request so that counsel for the Petitioners can be present for the Conciliation Conference. DATE Oq Respectfully submitted, ABOM&KUTULAKi4 L.L.P. MM Y?- - hwzt? Michelle L. Somm , Esquire Supreme Court ID 93034 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Petitioners I, David & Gloria Anderson, verify that the statements made in this Motion to Intervene and Motion for Continuance and 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 ?O Jc? - D q 0?? G David Anderson Date ,?" a Gloria Anderson WOLF & WOLF NATHAN C. WOLF PHONE 717-241-4436 ATTORNEYS AT LAW 10 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 wolfandwolfa embaMmail.com STAGY B. WOLF FACSIMILE 717-241-4437 RELEASE I, Leroy A. Cramer, hereby authorize Gloria A. Anderson and David L. Anderson to make and attend any medical, including mental and behavioral health, appointments, to sign any necessary documents concerning any such care, and to be recipients of information released regarding my child, Timothy P. Cramer. I also authorize Leslie A. Cover to be present and to be the recipient of information released to her at any medical, including mental and behavioral health, appointments regarding my child, Timothy P. Cramer. I, Leroy A. Cramer, also acknowledge and understand the following: a. I understand this authorization maybe revoked in writing at anytime, except to the extent that action has been taken in reliance on this authorization. b. All medical, including mental and behavioral health employees, officers, and contractors are hereby released from any legal responsibility or liability for disclosure of the above information to the extent indicated and authorized. c. I understand all medical, including mental and behavioral health employees, officers, and contractors and their Providers will not condition treatment, payment, enrollment or eligibility on the provision of this authorization. d. I understand that I may inspect or copy my child's personal health information and may also refuse to sign this authorization. e. Information disclosed pursuant to this authorization is subject to redisclosure by the recipient and is no longer protected by federal privacy regulations. ATE LEROY A. CRAIVIER COMMONWEALTH OF PENNSYLVANIA : . ss: COUNTY OF CUMBERLAND On this, the 2- Y day of ,, J, , 2008, before me, the undersigned officer, personally appeared LEROY A. CRAMER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. V Notarial Seal -? `- Notary rc Ncit an C. war, Notary Public CmWeBoro, curnberlandCaunty EXHIBIT "A" coon Expires Apr. 19.20108 Member. Pennsylvania Association Of Notaries CUMBERLAND COUNTY CHILDREN AND YOUTH SERVICES September 11, 2008 Leroy Cramer 127 Long Rd #3 Newville, PA 17241 Protecting Children - Preserving Families - Promoting Well-being Human Services Building, 16 West High Street, Suite 200, Carlisle, PA 17013-2961 Telephone: 717-240-6120 or 1-888-697-0371, Extension 6120 Fax: (717) 240-6433 Email: CCCY@ccpa.net RE: Timothy Cramer Dear Mr. Cramer: Cumberland County Children and Youth Services has completed our initial assessment concerning your child, and we have determined that no further Agency services are required at this time due to.Timothy living full time at the home of Gloria Anderson and that Ms. Anderson is ensuring the safety and wellbeing of Timothy. If the child is in your care for visitation please continue to follow the Agency's safety plan. Mr. Cramer will ensure the child's basic needs for food, shelter, and clothing is met. Mr. Cramer will supervise the child at all times. Furthermore, Mr. Cramer will provide a safe environment for the child that does not have trash or clutter. If the child should leave the care of Ms. Anderson permanently, please contact the Agency with the new location of the child. While your case has been closed with the Agency, Cumberland County Children and Youth Services does suggest that you comply with the following recommendations. You and all members of the household need to continue to abide by the CPS (child abuse) law as you have been doing, and refrain from the use of physical discipline that causes injury to any child in your care It was truly a pleasure working with you and your child and I wish you all the best of luck. If the Agency receives further referrals on your family in the future, the Agency is required to investigate them. If you have any questions or require assistance in the future, please feel free to contact the Agency. Thank you for your cooperation in this matter. ncerely, Megan Garrison Intake Caseworker CC: Gloria Anderson EXHIBIT "B" PEAR 2 3 ZOWj4 LEROY CRAMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 04-82 CIVIL ACTION LAW MARIE REED, IN CUSTODY Defendant Prior Judge: M. L. Ebert, J. ORDER OF COURT AND NOW this JAday of March 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: All prior Orders entered in this matter are hereby VACATED and replaced with this Order. 2. Legal Custody: The Father, Leroy Cramer, and the Mother, Marie Reed, shall have shared legal custody of Timothy P. Cramer, born 5/05/2002. 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. Father is specifically directed to make sure that Mother receives copies of Timothy's report cards and progress reports. Father shall also make sure that Mother receives, or notify Mother to purchase, school photographs of Timothy. 3. Physical Custody: Father shall have primary physical custody of the Child subject to Mother's physical visitation as follows: a. Mother shall have visitation with Timothy every other Monday from 7:00 pm until 8:00 pm at Franklin Family Services in Carlisle. Upon the recommendation of Timothy's counselor, Mother shall additional time with Timothy. b. Mother shall have supervised physical custody of the Child at such other times as the parties may mutually agree. 4. Counseling: The parties have agreed, and are directed, to continue Timothy in his counseling at Franklin Family Services until successfully discharged. The parties shall follow the recommendations of Timothy's counselor. Mother has agreed, and is directed, to have a mental health psychiatric evaluation at the Stevens Center, or some other appropriate facility, and to follow the recommendations that flow from the evaluation, including but not limited to taking medication as recommended. 5. The Mother shall have telephone contact with the Child on a reasonable basis, as communication is appropriate. EXHIBIT "C" 6. Holidays: Father shall allow Mother to have appropriate time with Timothy during the major holidays, as long as Timothy's counselor recommends said contact would be in his best interest. 7. Neither parry 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 parries shall not allow third parties to disparage the other parent in the presence of the Child. 8. In the event of a medical emergency, the custodial parry shall notify the other party as soon as possible after the emergency is handled. 9. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consumelbe under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 10. In the event that Mother should comply with the recommendations of her psychiatric evaluation and that Timothy's counselor feels that increased time with Mother is appropriate, either party may directly contact the assigned conciliator to schedule a status conference. 11. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, 1,5?A.4, I F1 Distribution: Jennifer Spears, Esquire Stacy Wolf, Esquire John J. Mangan, Esquire u LEROY CRAMER, Plaintiff V. MARIE REED, Defendant Prior Judge: M. L. Ebert, J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 04-82 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 Timothy P. Cramer 05/05/2002 Primary Father 2. A Conciliation Conference was held with regard to this matter on February 05, 2009 and continued until February 26, 2009 with the following individuals in attendance: The Mother, Marie Reed, with her counsel, Jennifer Spears, Esq. The Father, Leroy Cramer, with his counsel, Stacy Wolf, Esq. 3. The parties agreed to the entry of an Order in the form as attached. Date T G J .4angan, Es e Custody Conciliator AND NOW, this 22"d day of June 2009, I, Michelle L. Sommer, Esquire, of Abom & Kutulakis, LLP., hereby certify that I did serve a true and correct copy of the foregoing Motion to Intervene and Motion for Continuance, upon the Respondents and Conciliator by depositing, or causing to be deposited, same in the United States, postage prepaid addressed to the following: Stacy Wolf, Esquire Wolf & Wolf, Attorneys at Law 10 West High Street Carlisle, PA 17013 Attorney for the Respondent Jennifer L. Spears, Esquire Martson Law Offices 10 East High Street Carlisle, PA 17013 Attorney for the Respondent John J. Mangan, Esquire Bayley & Mangan 17 West South Street Carlisle, PA 17013 Custody Conciliator Respectfully submitted, ABOM & KUTULAKisy L.L.P. Michelle L. So r, Esquire Supreme Court ID No. 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for the Petitioners l; IC 4..1 OF TH i_ i 2009 . UIN 2 2 P li 3: G u Mom CSZ' KuTUr_aicis Michelle L Sommer, Esquire Attorn y LD. No.: 86914 2 Vest Higb Street Carlisle, Pennglvania 17013 (717) 249-0900 LEROY CRAMER, Plaintiff/Respondent V. MARIE REED, Defendant/Respondent TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 04-0082 CIVIL ACTION - LAW IN CUSTODY PRAECIPE TO WITHDRAW AND DISMISS Please withdraw the Petition to Intervene in the above-captioned matter and mark as dismissed. Respectfully submitted, Date: 4 u ll"1 ABOM & KUT ULAKIS, L.L.P. A'W&'a - &.n) Michelle L. Som , Esquire 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney ID No. 93034 - - CERTIFICATE OF SERVICE AND NOW, I, Michelle L. Sommer, Esquire, of ABOM & KU['ULAKIS, L.L.P., hereby certify that I did serve or cause to be served a true and correct copy of the foregoing Praecipe to Withdraw and Dismiss via first class mail addressed as follows: Stacy Wolf, Esquire Wolf & Wolf, Attorneys at Law 10 West High Street Carlisle, PA 17013 Attorney for the Respondent Jennifer L. Spears, Esquire Martson Law Offices 10 East High Street Carlisle, PA 17013 Attorney for the Respondent John J. Mangan, Esquire Bayley & Mangan 17 West South Street Carlisle, PA 17013 Custody Conciliator DATE: T?llL I LM Michelle L. Sommer squire HIED-4;r=,s';E , 00h. OF THE F , 0", H"" TA V 2009 JUL -6 AN 1 ! : 10 cuM%")- L) C- uNTy PEINJ l4loy c? JUL 0 6 2009( Q LEROY CRAMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 04-82 CIVIL ACTION LAW MARIE REED, IN CUSTODY Defendant Prior Judge: M. L. Ebert, J. ORDER OF COURT AND NOW this / (,. day of July 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. All prior Orders entered in this matter are hereby VACATED and replaced with this Order. 2. This Order is entered pursuant to a Custod Conciliation Conference. A Custody Hearing is hereby scheduled on the 3y day of d; 2009 at 9.t& am/giv in Courtroom number 5 in the Cumberland County Court of Common Pleas, Carlisle, PA 17013 at which time testimony will be taken in regard to the Anderson's assertion of legal standing for Timothy and also a hearing in regard to the overall physical custody of Timothy Cramer. 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 (and the Anderson's) 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. 3. Legal Custody: The Father, Leroy Cramer, and the Mother, Marie Reed, shall have shared legal custody of Timothy P. Cramer, born 5/05/2002. 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. Father is specifically directed to make sure that Mother receives copies of Timothy's report cards and progress reports. Father shall also make sure that Mother receives, or notify Mother to purchase, school photographs of Timothy. 4. Physical Custody: Pending further Order of Court, Father shall have primary physical custody of the Child subject to Mother's physical visitation as follows: a. Mother shall have visitation with Timothy every other Monday from 7:00 pm until 8:00 pm at Franklin Family Services in Carlisle. Upon the recommendation of Timothy's counselor, Mother shall additional time with Timothy. b. Mother shall have supervised physical custody of the Child at such other times as the parties may mutually agree. 5. Counseling: The parties have agreed, and are directed, to continue Timothy in his counseling at Franklin Family Services until successfully discharged. The parties shall follow the recommendations of Timothy's counselor. Mother has agreed, and is directed, to follow the recommendations that flow from her psychiatric evaluation, including but not limited to, taking medication as recommended. 6. The Mother and Father shall have telephone contact with the Child on a reasonable basis, as long as the communication is appropriate. 7. Holidays: Father and Mother shall have appropriate time with Timothy during the major holidays, as long as Timothy's counselor recommends said contact with Mother would be in his best interest. 8. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 9. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 10. During any periods of custody or visitation, the parties 'shall not possess or use non-prescribed controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 11. In the event that Mother should comply with the recommendations of her psychiatric evaluation and that Timothy's counselor feels that increased time with Mother is appropriate, either party may directly contact the assigned conciliator to schedule a status conference. 12. A status update conference with the assigned conciliator is hereby scheduled for July 23, 2009 at 9:00 am at the Court of Common Pleas, Carlisle, PA 17013. 13. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, 7t 1?-A J. tnbution: fer Spears, Esquire Stacy Wolf, Esquire ?//??ehcl?c'`3cmii?; E-sgezire?¦e 'ha Q?-r?-?.?e4L ohn J. Mangan, Esquire l: t-£S ry%a l 1.C.. ??lSl?Oq LEROY CRAMER, Plaintiff V. MARIE REED, Defendant Prior Judge: M. L. Ebert, J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 04-82 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 Timothy P. Cramer 05/05/2002 Primary Father 2. A Conciliation Conference was held with regard to this matter on February 05, 2009 and continued until February 26, 2009, an Order of Court issued March 24, 2009, a telephone conference held May 12, 2009, a conciliation conference held July 1, 2009 with the following individuals in attendance: The Mother, Marie Reed, did not appear but was represented by her counsel, Jennifer Spears, Esq. The Father, Leroy Cramer, with his counsel, Nathaniel Wolf, Esq. David and Gloria Anderson, with their counsel, Michelle Sommer, Esq. 3. Mother's position on custody is as follows: Mother at this point has very limited contact with Timothy. Mother only sees Timothy in a therapeutic setting one hour every two weeks. Mother would like to have additional time with Timothy. Mother has moved closer to where the Child is in order to see him more. Mother indicates that she would be agreeable to have Mother's cousin, Danielle Villaronga, supervise her visits. Mother has followed through in getting a psychiatric evaluation and is going to a medication management appointment on July 17, 2009. At the time of the conciliation held July 1, 2009, Mother's counsel was not in a position to oppose or concur with the Anderson's assertion of legal standing in regard to custody of Timothy. Mother's counsel indicates that Mother is actively addressing Mother's mental health issues. 4. Father's position on custody is as follows: Father desires a defined schedule for visitation/custody of Timothy. Apparently, the Andersons and Mr. Cramer had been working the custody schedule informally in the past, but recently there has been some disruption in the Anderson's and Mr. Cramer's relationship. Mr. Cramer indicates the he does not necessarily oppose the Anderson's assertion of legal standing for custody of Timothy. Father still has on- going concerns regarding Mother's mental state and does not feel Mother should have additional time with Timothy. Father indicates that Timothy's therapist is recommending a decrease or cessation of Mother's contact with Timothy 5. The Anderson's position on custody is as follows: the Anderson's indicate that they have been the primary custodians of Timothy since February of 2007. The Anderson's have concerns about Mother and Father's ability to parent Timothy: The Anderson's may have power of attorney for Mr. Cramer. Mr. Cramer may have some mental limitations as well. The Anderson's indicate that they would like to adopt Timothy and have filed a Motion to Intervene in the instant custody matter. The Anderson's indicate that they have been addressing mental health/emotional concerns with Timothy on a regular basis. 6. The undersigned recommends scheduling a hearing to address standing of the Anderson's and to address the custody situation on the merits. The undersigned further recommends the entry of an Order as outlined and attached. Date Jo l Esquir Cu od onciliator r ? `,-r+ -?4 +* ? , - ?y ?;,., t"Y v?Y ? L`" 1` ` ? `t?' 'JUL '7 ?009- LEROY CRAMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 04-82 CIVIL ACTION LAW MARIE REED, IN CUSTODY Defendant Prior Judge: M. L. Ebert, J. ORDER OF COURT AND NOW this 11 day of July 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. All prior Orders entered in this matter are hereby VACATED and replaced with this Order. G15 2. This Order is entered pursuant to a Custody Conciliation Conference. A Custody Hearing is hereby scheduled on the 30th day of October 2009 at 9:00 am in Courtroom number 5 in the Cumberland County Court of Common Pleas, Carlisle, PA 17013 at which time testimony will be taken in regard to the instant custody matter. 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. 3. Legal Custody: The Father, Leroy Cramer, and the Mother, Marie Reed, shall have shared legal custody of Timothy P. Cramer, born 5/05/2002. 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. Father is specifically directed to make sure that Mother receives copies of Timothy's report cards and progress reports. Father shall also make sure that Mother receives, or notify Mother to purchase, school photographs of Timothy. 4. Physical Custody: Pending further Order of Court, Father shall have primary physical custody of the Child subject to Mother's physical visitation as follows: a. Mother shall have visitation with Timothy every other Monday from 7:00 pm until 8:00 pm at Franklin Family Services in Carlisle. Upon the recommendation of Timothy's counselor, Mother shall additional time with Timothy. b. Commencing July 25, 2009, Mother shall have supervised physical custody/visitation of the Child every Saturday from 12:00 pm until 2:00 pm at mutually agreed upon locations. In the absence of agreement, the parties shall meet at Letort Park in Carlisle or if it is raining, at McDonald's on Walnut Bottom Rd. C. Mother shall have additional custody of Timothy at such other times as the parties may mutually agree. Counseling: The parties have agreed, and are directed, to continue Timothy in his counseling at Franklin Family Services until successfully discharged. The parties shall follow the recommendations of Timothy's counselor. Mother has agreed, and is directed, to follow the recommendations that flow from her psychiatric evaluation, including but not limited to, taking medication as recommended. 6. The Mother shall have telephone contact with the Child on a reasonable basis, as long as the communication is appropriate. 7. Holidays: Mother shall have appropriate time with Timothy during the major holidays, as long as Timothy's counselor recommends said contact with Mother would be in his best interest. 8. Neither parry may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 9. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 10. During any periods of custody or visitation, the parties shall not possess or use non-prescribed controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 11. In the event that Mother should comply with the recommendations of her psychiatric evaluation and that Timothy's counselor feels that increased time with Mother is appropriate, either party may directly contact the assigned conciliator to schedule a status conference. 12. A telephonic status update conference with the assigned conciliator is hereby scheduled for August 19, 2009 at 1:00 pm. 13. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order. by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, * J. D. tribution: nJ nnifer Spears, Esquire l?T than Wolf, Esquire hn J. Mangan, Esquire CT his rm?I' LEA- 7/z7/0? ?rl LEROY CRAMER, Plaintiff V. MARIE REED, Defendant Prior Judge: M. L. Ebert, J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 04-82 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: The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Timothy P. Cramer 05/05/2002 Currently in the Custody of Primary Father 2. A Conciliation Conference was held with regard to this matter on February 05, 2009 and continued until February 26, 2009, an Order of Court issued March 24, 2009, a telephone conference held May 12, 2009, a conciliation conference held July 1, 2009, an Order issued July14, 2009 and a conciliation conference was held July 23, 2009 with the following individuals in attendance: The Mother, Marie Reed, with her counsel, Jennifer Spears, Esq. The Father, Leroy Cramer, with his counsel, Nathan Wolf, Esq. 3. The parties agreed to the entry of an Order as outlined pending conciliation, hearing or further Order of Court. The undersigned further recommends the entry of an Order as outlined and attached. Date John J 411 an, Esquire Custo y onciliator FILED-Di C. E OF THE F^, - ; ",!i_ CRY 2009 JUL 27 Ph 1:33 C Cl m",_r?z 'it 1 11'. SEP o 7 zooy a LEROY CRAMER, Plaintiff V. MARIE REED, Defendant Prior Judge: M. L. Ebert, J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 04-82 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW this 15? day of September 2009, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. All prior Orders entered in this matter are hereby VACATED and replaced with this Order. QS 2. This Order is entered pursuant to a Custody Conciliation Conference. A Custody Hearing is hereby scheduled on the 30th day of October 2009 at 9:00 am in Courtroom number 5 in the Cumberland County Court of Common Pleas, Carlisle, PA 17013 at which time testimony will be taken in regard to the instant custody matter. For purposes of this hearing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each parry 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. 3. Legal Custody: The Father, Leroy Cramer, and the Mother, Marie Reed, shall have shared legal custody of Timothy P. Cramer, born 5/05/2002. 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. Father is specifically directed to make sure that Mother receives copies of Timothy's report cards and progress reports. Father shall also make sure that Mother receives, or notify Mother to purchase, school photographs of Timothy. 4. Physical Custody: Pending further Order of Court, Father shall have primary physical custody of the Child subject to Mother's physical visitation as follows: a. Mother shall have visitation with Timothy every other Monday from 7:00 pm until 8:00 pm at Franklin Family Services in Carlisle. Upon the recommendation of Timothy's counselor, Mother shall additional time with Timothy. b. Commencing July 25, 2009, Mother shall have supervised physical custody/visitation of the Child one time per weekend for an eight (8) hour period at mutually agreed upon locations. In the absence of agreement, the parties shall meet at Letort Park in Carlisle or if it is raining, at McDonald's on Walnut Bottom Rd. C. Mother shall have additional custody of Timothy at such other times as the parties may mutually agree. 5. Counseling: The parties have agreed, and are directed, to continue Timothy in his counseling at Franklin Family Services until successfully discharged. The parties shall follow the recommendations of Timothy's counselor. Mother has agreed, and is directed, to follow the recommendations that flow from her psychiatric evaluation, including but not limited to, taking medication as recommended. 6. The Mother shall have telephone contact with the Child on a reasonable basis, as long as the communication is appropriate. 7. Holidays: Mother shall have appropriate time with Timothy during the major holidays, as long as Timothy's counselor recommends said contact with Mother would be in his best interest. 8. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Child. 9. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 10. During any periods of custody or visitation, the parties shall not possess or use non-prescribed controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 11. In the event that Mother should comply with the recommendations of her psychiatric evaluation and that Timothy's counselor feels that increased time with Mother is appropriate, either party may directly contact the assigned conciliator to schedule a status conference. 12. A telephonic status update conference with the assigned conciliator is hereby scheduled for October 7, 2009 at 2:00 pm. 13. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. D" tribution: ennifer Spears, Esquire ./lT than Wolf, Esquire /John J. Mangan, Esquire Qa F1;U P"VML&?(_ 4/a/oq - By the Court, V J. LEROY CRAMER, Plaintiff V. MARIE REED, Defendant Prior Judge: M. L. Ebert, J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 04-82 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 Timothy P. Cramer 05/05/2002 Primary Father 2. A Conciliation Conference was held with regard to this matter on February 05, 2009 and continued until February 26, 2009, an Order of Court issued March 24, 2009, a telephone conference held May 12, 2009, a conciliation conference held July 1, 2009, an Order issued Julyl4, 2009, a conciliation conference was held July 23, 2009, an Order was issued July 27, 2009 and a telephonic status conference was held August 19 with the following individuals in attendance: The Mother, Marie Reed, through her counsel, Jennifer Spears, Esq. The Father, Leroy Cramer, through his counsel, Nathan Wolf, Esq. 3. The parties agreed to the entry of an Order as outlined pending conciliation, hearing or further Order of Court. The undersigned further recommends the entry of an Order as outlined and attached. V2 Z/, Date K61 John J. ,Esquire Custod Piator OF THE ar F ^^'OTARY 2009 SEP -2 Ah 8: 03 r`,' r'+ FTILESTfients\13274 M Reed\13274.1.CustodyA3274.I.FRA Revised 10/5109 3:21PM LEROY CRAMER, Plaintiff v. MARIE REED, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-82 CIVIL ACTION - LAW : IN CUSTODY PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please withdraw the appearance of Jennifer L. Spears, Esquire, of Martson Law Offices, on behalf of the Defendant in the above action. MARTSON LAW OFFICES By Jennifer . S ears, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: S Attorneys for Defendant Please enter the appearance of the Family Law Clinic on behalf of the Defendant in the above action. Date: 10/1/avt FAMILY LAW CLINIC Irmo am Trong, Certifi J Thomas Place, Esquire 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Attorneys for Defendant R i r. OP TH. P,2 2009 OCT 2 1 AM (Q: 3 6 LEROY CRAMER, Plaintiff V. MARIE L. REED, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CUSTODY : NO. 04 - 82 CIVIL TERM CERTIFICATE OF SERVICE I, Lam D. Truong, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Praecipe to withdrawal appearance of Jennifer L. Spears, Esquire, of Martson Law Offices and the Praecipe to enter the appearance of the Family Law Clinic on the Plaintiffs attorneys of record, Wolf and Wolf Attorneys at Law, at 10 West High St., Carlisle, PA 17013, by depositing a copy of the same in the United States mail, first class, on this the 21th day of October 2009. am D. Truong Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 FILED .. .-.?? OF . THE R,,0 , . ,Nx,)T CRY 2009 OCT 21 A 11C: 36