HomeMy WebLinkAbout08-1593Howard B. Krug, Esquire
PA Atty. ID No. 16826
PURCELL, KRUG & HALLER
1719 N. Front Street
Harrisburg, PA 17102
Telephone: (717)234-4178
Email: hkrugpr)kh.com
SARA E. THUMA-CROOM,
Plaintiff
vs.
PAUL L. CROOM, II,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Of
IN CUSTODY
CIVIL ACTION - LAW
COMPLAINT FOR CUSTODY
NOW COMES Plaintiff, Sara E. Thuma-Croom, by her attorneys, Purcell, Krug &
Haller, and files the following Custody Complaint:
1. The Plaintiff is Sara E. Thuma-Croom, an adult individual who currently
resides at 2021 Verona Drive, Harrisburg, Dauphin County, Pennsylvania.
2. The Defendant is Paul L. Croom, II, an adult individual who currently resides
at 106A Forbes Avenue, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff seeks custody of the following child:
Name
Sojourner Q. Croom
Present Residence
2021 Verona Drive
Harrisburg, PA 17110
1
Date of Birth/Age
December 6, 2006 (1)
4. The child was not born out of wedlock.
5. The child is presently in the primary custody of Plaintiff, Sara E. Thuma-
Croom, who currently resides at 2021 Verona Drive, Harrisburg, Dauphin County,
Pennsylvania.
6. During the past five (5) years, the child has resided with the following persons
at the following addresses:
Name Address Dates
Paul L. Croom, II 106A Forbes Avenue 12/06/2006
Sara E. Thuma-Croom Carlisle, PA 17013 to 02/25/2008
Sara E. Thuma-Croom 2021 Verona Drive 02/25/2008
Harrisburg, PA 17110 to Present
7. The mother of the child is Plaintiff, Sara E. Thuma-Croom, who currently
resides at 2021 Verona Drive, Harrisburg, Dauphin County, Pennsylvania. She is
married to the Defendant.
8. The father of the child is Defendant, Paul L. Croom, II, who currently resides
at 106A Forbes Avenue, Carlisle, Cumberland County, Pennsylvania. He is married to
the Plaintiff.
9. The relationship of Plaintiff to the child is that of Mother.
Plaintiff currently resides with the following persons:
Name Relationship
Sojourner Q. Croom Daughter
Mr. and Mrs. Samuel Thuma Plaintiff's parents
2
10. The relationship of Defendant to the child is that of Father.
Defendant currently resides with the following persons:
Name
N/A.
Relationship
11. Plaintiff has not participated as a party or witness, or in another capacity, in
other litigation concerning the custody of the child in this or another court.
12. Plaintiff has no information of a custody proceeding concerning the child
pending in a court of this Commonwealth or any other state.
13. Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the child or claims to have custody or visitation rights with respect to
the child.
14. The best interests and permanent welfare of the child will be served by
granting the relief requested because: Plaintiff has been the primary nurturer of the
child, who continues to breast feed at fifteen (15) months In addition Defendant is
leaving the geographical area in June and possibly leave the country thereafter as part
of his employment.
WHEREFORE, Plaintiff requests the court to grant her custody of Sojourner Q.
Croom.
L,
By:
Date: 3 G - 0O
rd g, Esquire
19 North Front Stree
Harrisburg, PA 17102
I.D. No. 16826
(717) 234-4178
Attorney for Plaintiff
R
VERIFICATION
1, Sara E. Thuma-Groom , hereby verify that the
facts contained in the foregoing Complaint in Custody are true
and correct to the best of my knowledge, information and belief.
I understand that false statements made herein are subject to the penalties of
18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
Date: 3/6/2008
CERTIFICATE OF SERVICE
I, Angela S. Shaffer, employee for the law firm of Purcell, Krug & Haller, counsel
for Plaintiff, Sara E. Thuma-Croom, hereby certify that service of the foregoing
CUSTODY COMPLAINT was made on the following via certified mail, return receipt
requested, restricted delivery, on March 11? . 2008:
Paul L. Croom, II
106A Forbes Avenue
Carlisle, PA 17013
Defendant
-alt if, 21??
Angela S. Shaffer
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SARA E. THUMA-CROOM IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2008-1593 CIVIL ACTION LAW
PAUL L. CROOM, II
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Thursday, March 13, 2008 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at- 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, April 10, 2008 at 9:00 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Dawn S. Sunda 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
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SARA E. THUMA-CROOM IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 2008-1593 CIVIL ACTION LAW
PAUL L. CR.OOM, II
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this _ 1,0) day of Vqt, 2008, upon
consideration of the attached Custody Conciliation Report, W is ordered and directed as follows:
1. In the event the parties are not able to reach an agreement as to ongoing custody
arrangement" for the Child through the mediation process, a hearing date is reserved for the .,5 ?-
day of , 2008, at : y5 o'clock ot- in. in Court Room number
of th Cu erland County Court House. The hearing date will be reserved until ten (10) days
prior to the date scheduled in this paragraph, by which date counsel for the parties shall contact the
Court to either cancel or confirm the hearing date. If the hearing date is not confirmed by the parties or
counsel on or before that date, the hearing will be automatically cancelled. In the event a hearing is
necessary, the Mother shall be deemed to 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 each party's position on custody, a list of witnesses who are expected to testify and a
summary of the anticipated testimony of each witness. These Memoranda shall be filed at least seven
(7) days prior to the hearing date.
2. The Mother, Sara E. Thuma-Croom, and the Father, Paul L. Croom, Il, shall have shared
legal custody of Sojourner Q. Croom, born December 6, 2006. Major decisions concerning the Child
including, but not necessarily limited to, her health, welfare, education, religious training and
upbringing shall be made jointly by the parties after discussion and consultation with a view toward
obtaining and following a harmonious policy in the Child's best interest. Neither party shall impair the
other party's rights to shared legal custody of the Child. Neither party shall attempt to alienate the
affections of the Child from the other party. Each party shall notify the other of any activity or
circumstance concerning the Child that could reasonably be expected to be of concern to the other.
Day to day decisions shall be the responsibility of the parent then having physical custody. With
regard to any emergency decisions which must be made, the parent having physical custody of the
Child at the time of the emergency shall be permitted to make any immediate decisions necessitated
thereby. However, that parent shall inform the other of the emergency and consult with him or her as
soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and
full information from any doctor, dentist, teacher, professional or authority and to have copies of any
reports or information given to either party as a parent as authorized by statute.
3. The parties shall participate in a course of mediation with Arnold Shienvold, Ph.D. or other
professional selected by agreement. The purpose of the mediation shall be to assist the parties in
resolving their conflict regarding whether a primary or shared custodial arrangement would best serve
the needs of the Child.
4. In the event either party elects to obtain a custody evaluation, that parent may initiate the
evaluation and the other party shall cooperate in scheduling timely appointments for themselves and
the Child. The party initiating the evaluation shall be initially responsible to pay all costs but reserves
the right to seek a further apportionment of the costs by the Court at a later date.
5. Upon completion of mediation, counsel for either party may contact the conciliator to
schedule an additional custody conciliation conference if the parties and counsel agree that it would be
a useful alternative to the hearing.
cc: oward B. Krug, Esquire - Counsel for Mother
Carol J. Lindsay Esquire - Counsel for Father
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SARA E. THUMA-CROOM
Plaintiff
vs.
PAUL L. CROOM, II
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2008-1593 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Sojourner Q. Croom December 6, 2006 Mother
2. A custody conciliation conference was held on April 16, 2008, with the following
individuals in attendance: the Mother, Sara E. Thuma-Croom, with her counsel, Howard B. Krug,
Esquire, and the Father, Paul L. Croom, II, with his counsel, Carol J. Lindsay, Esquire.
3. The Mother filed this Complaint for Custody seeking primary physical custody of the
Child. The Father has applied for specialized training and subsequent reassignment through the
military and is awaiting notice as to whether his application has been accepted which could require
relocation as early as June, 2008.
4. Although the parties were able to agree to engage in a course of mediation with Arnold
Shienvold, Ph.D. to assist them in resolving their different perspectives on primary versus shared
custodial arrangements, the Father's counsel requested that a hearing date be reserved in the event the
mediation process is not completely successful. The Father's concern focuses on the fact that the
parties were unable to reach an agreement as to temporary custody arrangements pending mediation
and the fact that he may have :limited time prior to being reassigned in the military if his application is
accepted.
5. The Mother's position on custody is as follows: The Mother believes that as the Child is
presently continuing to breast feed at 15 months of age, it is not appropriate at this time to provide
overnight periods of custody to the Father or initiate a shared custody arrangement. The Mother
believes that the experts at the present time support a primary custodial arrangement for a child of this
young age and that overnight periods of custody with the Father would disrupt the necessary Mother-
Child bond. The Mother also feels that a shared arrangement should not be implemented at this time in
light of the Father's application to leave the area within the near future. The Mother proposed that the
Father have approximately three (3) hours of time with the Child during weekday evenings and six (6)
to seven (7) hours with the Child on both Saturday and Sunday on alternating weekends. The Mother
was not willing to extend her proposal on a temporary basis pending mediation.
6. The Father's position on custody is as follows: The Father believes it is important for the
Child to bond with both parents and that therefore a shared custody arrangement would better serve the
Child's needs. The Father stated that he had provided substantial care for the Child prior to the parties'
separation including bathing and the nighttime routine. The Father does not agree with the Mother's
reliance on certain literature concerning child rearing and instead believes that the Child's pediatrician
supports the fact that the Mother could express milk enabling the Father to have overnight custodial
periods. The Father does not feel that the Mother's continued nursing constitutes a barrier either
nutritionally or emotionally to a shared custody schedule. While agreeable to a gradually increasing
schedule, the Father believes it is important to initiate overnight periods of custody as soon as possible.
7. The conciliator recommends an Order in the form as attached scheduling a reserved hearing
date in the event the parties are unable to resolve the issues through mediation prior to that time. The
Father requests that the hearing be scheduled in approximately six (6) weeks in light of his expected
relocation. It is anticipated that the Father's counsel may file a Petition for Special Relief seeking an
Order for immediate temporary overnight periods of custody as the parties were unable to reach an
agreement on this issue at the conference.
Date Dawn S. Sunday, Esquire
Custody Conciliator
a
,#ir
SARA E. THUMA-CROOM, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
PAUL L. CROOM, II, :
DEFENDANT 08-1593 CIVIL TERM
ORDER OF COURT
AND NOW, this rl*%-., day of July, 2008, following a hearing on the
merits, IT IS ORDERED:
(1) Sara E. Thuma-Croom and Paul L. Croom, II, shall have shared legal
custody of their daughter Sojourner Q. Croom, born December 6, 2006.
(2) Sojourner shall be with her mother except for the following periods when she
shall be with her father until he leaves this area on a new assignment by the United
States Marine Corps:'
(a) Starting Friday, July 11, 2008, on alternate weekends from
Friday when he is finished work until Monday morning before he goes to
work.
(b) Starting Wednesday, July 9, 2008, on every Wednesday from
when he is finished work until Thursday morning before he goes to work.
(c) Starting Thursday, July 24, 2008, on every Thursday following
the weekend he does not have Sojourner from when he is finished work
until Friday morning before he goes to work. (The mother shall have
Sojourner on Thanksgiving Day.)
The father anticipates reassigned in mid-January, 2009 to Virginia Beach,
Virginia, for approximately two and a half months, and then to Camp Lejeune,
Jacksonville, North Carolina, for two to three years.
(d) On Labor Day, Monday, September 1, 2008, from 9:00 a.m.
until 7:00 p.m.
(e) On Wednesday, October 1, 2008, when he is finished work until
he goes to work on Monday, October 6, 2008, during which period he may
take Sojourner to Colorado.
(f) On Christmas Day, December 25, 2008, from 2:00 p.m. until
7:00 p.m.
(g) From after he finishes work on Monday, December 29, 2008,
until he goes to work on Monday, January 5, 2009, during which period he
may take Sojourner to Europe.
(3) The mother shall immediately sign and give to the father any documents
presented to her that are necessary for the issuance of a United States passport to
Sojourner.
By the ourt,
Edgar B. Bayley, J.
Howard Krug, Esquire /
For Plaintiff u,
Carol Lindsay, Esquire
For Defendant ?- D - o
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SARA E. THUMA-CROOM,
Plaintiff
V.
PAUL L. CROOM, II,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08-1593
IN CUSTODY
PETITION FOR MODIFICATION
AND NOW, comes Paul L. Croom, II, by and through his counsel, Saidis, Flower
& Lindsay and petitions this Honorable Court as follows:
1. The parties hereto are parents of a child, Sojourner Q. Croom, born
December 6, 2006.
2. After a hearing on July 7, 2008, the Court of Common Pleas of
Cumberland County issued an Order providing shared legal custody of Sojourner to
both of her parents and shared physical custody of the child as set out in the Order, a
copy of which is attached hereto as Exhibit "A".
3. Petitioner is an officer in the United States Marine Corps who is due to be
reassigned to Virginia Beach, Virginia on or about January 25, 2009.
4. Petitioner's reassignment will require a modification of the Custody
SAMIS,
FLOWER &
LINDSAY
ATIOBNETS•AMAW
26 West High Street
Carlisle, PA
Order.
5. Since the child is not of school age and since the child has a close and
loving relationship with both parents, Petitioner seeks shared legal and physical
custody of the child who would spend a week with each parent on rotation.
WHEREFORE, Petitioner prays this Honorable Court to set a hearing and after
the hearing to provide to him shared legal and physical custody of his child .
SAIDIS, FLOWER & LINDSAY
Carol J. Lind y, E quire
ID No. 446
26 West Hig Street
Carlisle, PA 17013
(717) 243-6222
Attorney for Plaintiff
SAIDIS,
FLOWER &
LINDSAY
ATFURNM AT•LAW
26 West High Street
Carlisle, PA
SARA E. THUMA-CROOM, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
PAUL L. CROOK II,
DEFENDANT 08-1593 CIVIL TERM
ORDER OF COURT
AND NOW, this r1JTt-N day of July, 2008, following a hearing on the
merits, IT IS ORDERED:
(1) Sara E. Thuma-Croom and Paul L. Croom, II, shall have shared legal
custody of their daughter Sojourner Q. Croom, born December 6, 2006.
(2) Sojourner shall be with her mother except for the following periods when she
shall be with her father until he leaves this area on a new assignment by the United
States Marine Corps:'
(a) Starting Friday, July 11, 2008, on alternate weekends from
Friday when he is finished work until Monday morning before he goes to
work.
(b) Starting Wednesday, July 9, 2008, on every Wednesday from
when he is finished work until Thursday morning before he goes to work.
(c) Starting Thursday, July 24, 2008, on every Thursday following
the weekend he does not have Sojourner from when he is finished work
until Friday morning before he goes to work. (The mother shall have
Sojourner on Thanksgiving Day.)
' The father anticipates reassigned in mid-January, 2009 to Virginia Beach,
Virginia, for approximately two and a half months, and then to Camp Lejeune,
Jacksonville, North Carolina, for two to three years.
(d) On Labor Day, Monday, September 1, 2008, from 9:00 a.m.
until 7:00 p.m.
(e) On Wednesday, October 1, 2008, when he is finished work until
he goes to work on Monday, October 6, 2008, during which period he may
take Sojourner to Colorado.
(f) On Christmas Day, December 25, 2008, from 2:00 p.m. until
7:00 p.m.
(g) From after he finishes work on Monday, December 29, 2008,
until he goes to work on Monday, January 5, 2009, during which period he
may take Sojourner to Europe.
(3) The mother shall immediately sign and give to the father any documents
presented to her that are necessary for the issuance of a United States passport to
Sojourner.
By the
Edgar B. Bayley, J.
Howard Krug, Esquire
For Plaintiff
Carol Lindsay, Esquire
For Defendant
sal
rRUE COPY FROM RECORD
Testimony whereof, l here unto set my hand
.d the seal of said Co at Carlisle, Pa..
i ay 12
Prothonow
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.
§4904, relating to unsworn falsifications to authorities.
Paul L. Croom, II
Date: /( Oe--rmc-zz Z00%
SAMIS,
FLOWER &
LINDSAY
ATTOWW%?-AT
26 West High Street
Carlisle, PA
CERTIFICATE OF SERVICE
On this day of October, 2008, I, Carol J. Lindsay, Esquire, of the law firm of
SAIDIS, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached
document was served on the following individuals, via first class mail, postage prepaid,
addressed as follows:
Howard B. Krug, Esquire
PURCELL, KRUG & HALLER
1719 North Front Street
Harrisburg, PA 17102-2305
SAIDIS, FLOWER & LINDSAY
Carol J. Lindsay, Esquire
Supreme Court ID No. 44693
26 West High Street
Carlisle, PA 17013
717-243-6222
SAIDIS,
FLOWER &
LINDSAY
ATIORNM-AMAW
26 West High Street
Carlisle, PA
0
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SARA E. THUMA-CROOM IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2008-1593 CIVIL ACTION LAW
PAUL L. CROOM, II
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Thursday, October 23, 2008 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Friday, November 14, 2008 at 11:30 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/ Dawn S. Sunday, Esq. /31S
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
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SARA E. THUMA-CROOM IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. 2008-1593 CIVIL ACTION LAW
PAUL L. CROOM, II
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this 3 rd day of 1, 2008, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. A he ng is scheduled in Court Room No. 2 of the Cumberland County Court House on the
l 1 bk-day of Lis A ^` , 200g, at which time testimony will be taken. For
purposes of the hearing, the F ther, Paul L. Croom, II, shall be deemed to 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 each party's position on custody, a list of witnesses who are
expected to testify at the hearing, and a summary of the anticipated testimony of each witness at least
five days prior to the hearing date.
2. Pending further Order of Court or agreement of the parties, the prior Order of this Court
dated July 7, 2008 shall continue in effect.
3. Prior to the hearing scheduled in this Order, counsel for either party may contact the
conciliator to schedule a custody conciliation conference or a conference call with counsel, if the
parties agree that it would be useful to resolve the outstanding custody issues without the necessity of
the hearing.
BY THE
Edgarlt-*ayley J.
i
cc: Howard Krug, Esquire - Counsel for Mother
Carol J. Lindsay, Esquire - Counsel for Father )
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SARA E. THUMA-CROOM
Plaintiff
VS.
PAUL L. CROOM, II
Defendant
Prior Judge: Edgar B. Bayley
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2008-1593 CIVIL, ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Mother/Father
Sojourner Q. Croom December 6, 2006
2. A custody conciliation conference was held on November 14, 2008, with the following
Howard B. Krug,
individuals in attendance: the Mother, Sara wth E. Thuma-Coom, with her his counsels Carol J. Lindsay, Esquire.
Esquire, and the Father, Paul L. Croom, II,
3. This Court previously entered an Order in this matter on July 7, 2008, after a hearing, under
which the Father and Mother had shared physical custody on a nearly equal basis. At the time of that
hearing, it was anticipated that the Father, who is in the military, would be reassigned to Virginia
Beach, Virginia in January 2009 and thereafter to Jacksonville, North Carolina prior to deployment.
9 are
The Father's plans to relocate to Virginia Beach, teachran school in Juary
to the0c0urrent
definite and, as the parties have been unable
custody schedule, the Father filed this Petition for Modification.
4. The parties were not able to reach an agreement at the conference and it will be necessary to
schedule a hearing.
5. The Father's position on custody is as follows: The Father believes it would be best for the
Child to continue to spend substantial periods of time with both parents following his move to
Virginia, although the schedule would need to change due to the distance between Virginia Beach and
central Pennsylvania. The Father proposed an alternating weekly arrangement with the exchange to
take place every weekend. At such time as the Father begins his assignment in North Carolina on
April 8, 2009, the Father proposed an alternating bi-weekly schedule to reduce the Child's travel time
in light of the greater distance. The Father indicated that he has adequate living quarters both in
Virginia, where he will have a suite for himself and the Child, and in North Carolina, where he will
have an apartment or a house. The Father anticipates being deployed to Afghanistan or Iraq in late
summer and recognizes that the Child will be in the Mother's custody full-time during his
unavailability.
6. The Mother's position on custody is as follows: The Mother believes that the Child's needs
would be best met by minimizing travel time and exchanging custody for alternating weekend periods
of partial custody at the Father's parents' residence in Philadelphia. The Mother believes that it would
be detrimental for the Child to spend six (6) or more hours in the car every weekend, or even every two
weeks, but did indicate her willingness to consult with a child development expert. The Mother
expressed concern regarding the Child's living accommodations while with the Father, particularly in
Virginia where he will have limited space.
7. Several options were discussed in an effort to address both parties' concerns, including the
possibility of splitting the Child's travel time into two (2) days or making adjustments to the frequency
of exchanges for weekly periods of custody. The parties indicated their willingness to continue
working toward a resolution but requested that a hearing be scheduled due to the Father's impending
relocation on January 25, 2009. Accordingly, the conciliator submits an Order scheduling a hearing in
this matter. It is anticipated that the hearing will require at least one-half day. It should be noted that,
in addition to the Father's unavailability after his departure on January 25, 2009, the Father will also be
unavailable to attend the hearing from January 12 through January 22.
g- '1we
Date Dawn S. Sunday, Esquire
Custody Conciliator
SARA E. THUMA-CROOM,
PLAINTIFF
V.
PAUL L. CROOM, Il,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: 08-1593 CIVIL TERM
ORDER OF COURT
AND NOW, this L9 *--? day of February, 2009, following a hearing on
the merits, IT IS ORDERED:
(1) All prior custody orders are vacated and replaced with this order.
(2) Sara E. Thuma-Croom and Paul L. Croom, II, shall have shared legal
custody of their daughter Sojourner Q. Croom, born December 6, 2006.
(3) Sojourner shall be with her mother except for the following periods when she
shall be with her father:
(a) Until he leaves his Virginia Beach, Virginia, assignment: on alternating
weeks with exchanges on Sundays at noon in Falmouth, Virginia. The first
exchange shall be on February 28, 2009.
(b) After he moves to his new assignment in Jacksonville, North Carolina,
until he deploys with his unit overseas: during four separate two week periods
and a separate one week period. He shall notify the mother immediately upon
learning when each such period shall take place. Exchanges shall be on
Sundays at noon in Richmond, Virginia.
(c) After he returns to Jacksonville following his deployment, on
alternating two week periods with exchanges on Sundays at noon in Richmond,
Virginia.
(4) Travel to the exchanges may be made by either the parent or a family
member.
(5) For exchanges in Falmouth, the mother or family member, at the exchange,
shall be paid $20 toward transportation costs. For exchanges in Richmond, the mother
or family member shall be paid, at the exchange, $30. For exchanges in Richmond, if
the mother or family member chooses to break up the trip for Sojourner by staying in a
hotel that evening, she or the family member shall be paid, at the exchange, an
additional $80.
(6) The parent not having Sojourner shall have twice a week telephone contact
with her.
(7) When father is deployed overseas, he may communicate with Sojourner
twice a week by telephone or a computer link. He shall communicate with the mother
by email, to which she shall respond to set up the time and means of such
communication.
(8) Either parent may travel with Sojourner to other countries. Sojourner's
passport shall remain with the father except during such times as the mother may travel
with her to a country where a passport is needed.
(9) When a parent is traveling with Sojourner in other countries or the United
States, that parent shall notify the other parent where they will be during such travels. If
the travel includes air flights, the other parent shall be notified of the airline, flight
numbers, and points and times of departure and arrival.
(10) When the father is deployed overseas, the mother shall allow Sojourner to
be with her paternal grandparents, either individually or together, for two weekends
each month, starting as early as Friday at noon, and ending as late as Sunday at 5:00
p.m. The mother and the grandparents shall make the arrangements for these periods.
A grandparent shall provide all transportation.
By the
Edgar B. Bayley, J.
? Howard Krug, Esquire
For Plaintiff
v Carol Lindsay, Esquire
For Defendant
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SARA E. THUMA-CROOM, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
PAUL L. CROOM, II,
DEFENDANT 08-1593 CIVIL TERM
AMENDED ORDER OF COURT
AND NOW, this `-"day of February, 2009, paragraph 3(a) of this
court's order of February 19, 2009, is amended as follows:
(a) Until he leaves his Virginia Beach, Virginia, assignment: on alternating
weeks with exchanges on Sundays at noon in Falmouth, Virginia. The first
exchange shall be on March 1, 2009.
All other provisions of this court's order of February 19, 2009, shall remain in full
force and effect.
? Howard Krug, Esquire
Fo Plaintiff
Carol Lindsay, Esquire
For Defendant
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Howard B. Krug, Esquire
PA Supreme Court ID# 16826
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Phone: (717) 234-4178
Fax: (717) 234-0409
hkruaD-Dkh.com
SARA E. THUMA-CROOM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
PAUL L. CROOM, II,
Defendant
NO. 2008-1593 CIVIL TERM
CIVIL ACTION - CUSTODY
PETITION FOR TRANSFER OF VENUE
AND NOW, comes the Plaintiff, Sara E. Thuma-Croom, by and through her
attorneys, Purcell, Krug & Haller, and requests this Court to transfer this action to the
Court of Common Pleas of Dauphin County:
1. Petitioner/Plaintiff is Sara Thuma-Croom, Mother of the minor child
(hereinafter referred to as "Mother")
2. Mother resides at 2021 Verona Drive, Harrisburg, Dauphin County,
Pennsylvania. She has resided at this address since March, 2008.
3. Respondent/Defendant is Paul L. Croom, II, Father of the minor child
(hereinafter referred to as "Father")
4. Father resides at 65 Blackwood Road, Camp LeJeune, North Carolina. He
has resided at this address since September, 2009.
5. The parties are the natural parents of one child, Sojourner Q. Croom, born
December 6, 2006 (hereinafter referred to as "Sojourner")
6. On February 19, 2009, an Order of Court was entered awarding shared legal
custody and partial physical custody to Father, which is at present, occurring on an
alternating two week cycle. A true and correct copy of the Order is attached hereto as
Exhibit "A".
7. Since this action was commenced, all parties have moved from Cumberland
County.
8. Cumberland County is no longer a convenient forum for Mother.
9. The time and expense associated with travel of Mother and her counsel to
Carlisle for proceedings relative to this matter is unreasonable and unnecessary under
the circumstances described herein.
10. This case was previously assigned to the Honorable Edgar Bayley, who is
retiring at the end of this year.
11. Since a new judge would necessarily be assigned to any future action,
Petitioner submits that it is an appropriate time to make the transfer requested.
12. Pa.R.C.P. 1915.2 authorizes the Court to transfer venue in an action to any
county where the action could be brought if it determines that it is an inconvenient
forum under the circumstances and the court of another county is the more appropriate
forum.
13. Since Mother is the only party residing in Pennsylvania, and she has resided
in Dauphin County for more than a year and a half, the Court of Common Pleas of
Dauphin County would be the more appropriate forum.
2
14. There are presently no pending matters in this case.
15. The concurrence of Respondent's counsel, Carol Lindsay, has been sought
and she does not consent to the relief requested herein.
WHEREFORE, Petitioner respectfully requests this Honorable Court to transfer
this action to the Court of Common Pleas of Dauphin County.
PURCE KR
Date: Iii - )? 2,0-0 q
D
1719 V/ Front St.
Harri urg, PA 17102
717 234-4178
hkrug(a pkh.com
Counsel for Petitioner
3
SARA E. THUMA-CROOM,
PLAINTIFF
V.
PAUL L. CROOM, II,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: 08-1593 CIVIL TERM
ORDER OF COURT
AND NOW, this I!R *-N day of February, 2009, following a hearing on
the merits, IT IS ORDERED:
(1) All prior custody orders are vacated and replaced with this order.
(2) Sara E. Thuma-Croom and Paul L. Croom, II, shall have shared legal
custody of their daughter Sojourner Q. Croom, born December 6, 2006.
(3) Sojourner shall be with her mother except for the following periods when she
shall be with her father:
(a) Until he leaves his Virginia Beach, Virginia, assignment: on alternating
weeks with exchanges on Sundays at noon in Falmouth, Virginia. The first
exchange shall be on February 28, 2009.
(b) After he moves to his new assignment in Jacksonville, North Carolina,
until he deploys with his unit overseas: during four separate two week periods
and a separate one week period. He shall notify the mother immediately upon
learning when each such period shall take place. Exchanges shall be on
Sundays at noon in Richmond, Virginia.
(c) After he returns to Jacksonville following his deployment, on
alternating two week periods with exchanges on Sundays at noon in Richmond,
Virginia.
(4) Travel to the exchanges may be made by either the parent or a family
member.
(5) For exchanges in Falmouth, the mother or family member, at the exchange,
shall be paid $20 toward transportation costs. For exchanges in Richmond, the mother
or family member shall be paid, at the exchange, $30. For exchanges in Richmond, if
the mother or family member chooses to break up the trip for Sojourner by staying in a
hotel that evening, she or the family member shall be paid, at the exchange, an
additional $80.
(6) The parent not having Sojourner shall have twice a week telephone contact
with her.
(7) When father is deployed overseas, he may communicate with Sojourner
twice a week by telephone or a computer link. He shall communicate with the mother
by email, to which she shall respond to set up the time and means of such
communication.
(8) Either parent may travel with Sojourner to other countries. Sojourner's
passport shall remain with the father except during such times as the mother may travel
with her to a country where a passport is needed.
(9) When a parent is traveling with Sojourner in other countries or the United
States, that parent shall notify the other parent where they will be during such travels. If
the travel includes air flights, the other parent shall be notified of the airline, flight
numbers, and points and times of departure and arrival.
(10) When the father is deployed overseas, the mother shall allow Sojourner to
be with her paternal grandparents, either individually or together, for two weekends
each month, starting as early as Friday at noon, and ending as late as Sunday at 5:00
p.m. The mother and the grandparents shall make the arrangements for these periods.
A grandparent shall provide all transportation.
Howard Krug, Esquire
For Plaintiff
Carol Lindsay, Esquire
For Defendant
sal
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20H DEC 17 AM 10, 2 2
DEC 1 d 2009
SARA E. THUMA-CROOM,
Plaintiff
vs.
PAUL L. CROOM, II,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008-1593 CIVIL TERM
IN CUSTODY
CIVIL ACTION - LAW
RULE TO SHOW CAUSE
AND NOW, this 2 -4-A day of Jz4A-44-r' 2009, Respondent,
Paul L. Croom, II is directed to show cause, if any, why the relief requested in Petitioner's
Petition to Transfer Venue should not be granted.
RULE RETURNABLE
Zo
days from the date of service.
BY THE COURT:
Distribut' :
Carol Lindsay, Esquire
26 West High Street
Carlisle, PA 17013
Counsel for Respondent
Howard B. Krug, Esquire
1719 N. Front Street
Harrisburg, PA 17102
Counsel for Petitioner
I LL ?4i il«7?
HE -1,"'NOICAPY
2009 GE-C 22 Ai"I 10: 4
1TV
SARA E. THUMA-CROOM,
Plaintiff
V.
PAUL L. CROOK II,
Defendant
CIVIL ACTION - CUSTODY
c7 N
NOTICE TO PLEAD COUNTER-CLAIM Cdr TI
TO: Sara E. Thuma-Croom
c/o Howard B. Krug, Esquire
1719 North Front Street C") 0
Harrisburg, PA 17102 -? '
You are hereby notified to file a written response to the enclosed Answer to Petition
for Transfer of Venue and Counter-claim within twenty (20) days from service hereof or a
judgment may be entered against you.
SAIDIS, FLOWER & LINDSAY
SAIDIS,
LIlVDSAY
TIAW
26 West High Street
Carlisle, PA
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008-1593 CIVIL TERM
Carol J. Lindsd A, s ulre
Attorney Id. X44 3
26 West Hig Street
Carlisle, PA 17013
(717) 243-6222
Counsel for Plaintiff
SARA E. THUMA-CROOM,
Plaintiff
V.
PAUL L. CROOK II,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008-1593 CIVIL TERM
CIVIL ACTION - CUSTODY
ANSWER TO PETITION FOR TRANSFER OF VENUE
AND COUNTER-CLAIM
NOW comes the Defendant, Paul L. Croom, II, by and through his counsel, Saidis,
Flower & Lindsay and answers the Petition for Transfer of Venue with New Matter, as
follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted. By way of further answer, Respondent is a Captain in the United
States Marine Corps stationed at Camp LeJeune, Jacksonville, North Carolina. He was
assigned there on April 6, 2009.
5. Admitted.
6. Admitted.
7. Admitted.
SA DIS,
FtiOWER &
LE'gDSAY
ATMW&TW-j&
26 West High Street
Carlisle, PA
8. Denied that Cumberland County is no longer a convenient forum for Mother.
As set out in Paragraph 2 of the Petition, Petitioner resides in Harrisburg, Dauphin County,
Pennsylvania, 17 to 20 miles from Carlisle, Pennsylvania.
9. Denied that the time and expense associated with travel of Mother and her
counsel to Carlisle for proceedings is unreasonable and unnecessary given the proximity of
Petitioner's home and her attorney's practice to Carlisle, Pennsylvania.
10. Admitted.
11. Admitted that a new Judge will be required for the case. Denied that
Dauphin County is a more convenient forum. By way of further answer, Respondent has
resided at Camp LeJeune, Jacksonville, North Carolina for at least six (6) months and the
courts servicing Jacksonville would be substantially more convenient for Father than
Dauphin County as a venue would be for Mother.
12. Admitted. By way of further answer, North Carolina is as appropriate a
forum as is Dauphin County, Pennsylvania. By way of further answer, the only professional
treating with her child is her physician at Dunham U.S. Army Health Clinic in Carlisle,
Cumberland County, Pennsylvania.
13. Denied. By way of further answer Petitioner's inconvenience at traveling 20
miles to Carlisle, Pennsylvania for any court proceedings is vastly exceeded by the difficulty
of Respondent reaching Cumberland County, Pennsylvania, a distance of between 468 and
528 miles, depending on the route taken.
14. Admitted. By way of further answer, however, there is a Counter-claim
raised with the answer to this Petition.
15. Admitted.
COUNTERCLAIM
16. The averments in the answers to Paragraphs 1 through 15 of the Petition to
SAMIS,
FI ONVER &
LINDSAY
26 West High Street
Carlisle, PA
Transfer Venue are incorporated herein as if set out in full.
17. As this Honorable Court can deduce from the Court's Order of February 19,
2009, Respondent, a Marine Corps Captain at the time of the Court's Order was transferred
by the Marines to Virginia Beach, Virginia for a brief time before transfer to Jacksonville,
North Carolina prior to a deployment overseas.
18. Respondent was deployed to Iraq on May 15, 2009 and returned stateside
on or about September 20, 2009.
19. Since Respondent's return the parties have been following the Court's Order
of February 19, 2009.
20. Respondent is set to deploy for an additional tour, this one for seven (7)
months, in Afghanistan commencing in September 2010. Because his Unit is in pre-
deployment training, Respondent's schedule has been somewhat disrupted for training
exercises and the like. In order to maximize his time with his child, Respondent has
attempted to negotiate with Petitioner a restructuring of the custodial time between January
2010 and September 2010. Petitioner will not agree to a schedule which would result in the
equal custody arrangement envisioned by Judge Bayley.
21. At the time of the entry of the Court's Order on February 19, 2009,
Respondent had remarried an Austrian national, Martina Croom, who has a daughter.
Since the Court's Order of February 19, 2009, Respondent and Martina are expecting a
child of their own and Sojourner Croom, the subject of the Court's Order, has become
bonded with her stepmother and stepsister since she has been in their company for half the
time for nearly a year.
22. In the Order of February 19, 2009, the Court made provision for the child,
SAMIS,
FLOWER &
LINDSAY
,vuw
26 West High Street
Carlisle, PA
Sojourner, to be in the custody of her paternal grandparents, during deployment, for two (2)
weekends each month from Friday to Sunday.
23. Respondent seeks to continue his custodial time by permitting his Wife to
care for Sojourner while he is in Afghanistan in light of the child's bonding with her
stepmother and stepsister and the birth of a new child due just prior to Respondent's
deployment to Afghanistan.
24. Upon information and belief Petitioner is not employed outside of her home
and therefore is able to spend substantial time with her daughter during her custodial
periods.
25. Respondent seeks an order permitting him to delegate to his Wife the
obligation for caring for Sojourner pursuant to the Court's Order during his deployment in
Afghanistan.
26. Respondent believes and therefore avers that it is in the best interest of his
child that she continues to be bonded in two (2) households despite his need to service his
country overseas.
WHEREFORE, Respondent prays that this Honorable Court to deny the Petition for
a change of venue, to order a restructuring of the custodial time between the parties
pending deployment and to modify the Court's Order of February 19, 2009 to permit equal
sharing of custody during deployment.
Respectfully submitted,
SAIDIS, FLOWER & LINDSAY
C&617. Lindsay, sgGire
Attorney Id. 44
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Counsel for Plaintiff
SAIDIS,
FLOWER &
LINDSAY
26 West High Street
Carlisle, PA
Dated: January 11, 2010
VERIFICATION
I, Carol J. Lindsay, attorney for Paul L. Croom, II, verify that the statements made in
the foregoing document are true and correct and certify that I am authorized to do so, and that
the person having knowledge of matters alleged in this pleadings is outside the jurisdiction of
the Court and her Verification cannot be obtained within the time allowed for filing the
pleading. I understand that false statements herein are made subject to the penalties of 18
Pa. C.S. § 4904, relating to unsworn falsification to authorities.
1
(141-11#--r
Carol J. Lindsay squire, attorney for
Paul L. Croo ` , I
SAIDIS,
FLOWER &
LINDSAY
ATIOMM-M-1AAW
26 West High Street
Carlisle, PA
CERTIFICATE OF SERVICE
I hereby certify that on this f? day of January, 2010, a true and correct copy of
the foregoing document was served upon the party listed below, via First Class Mail,
postage prepaid, addressed as follows:
Howard B. Krug, Esquire
1719 North Front Street
Harrisburg, PA 17102
SAIDIS, FLOWER & LINDSAY
Carol J. Lindsay, quire
Supreme Court No. 44693
26 West High Street
Carlisle, PA 17013
717-243-6222
SAID?IS,
FLOWER &
LINDSAY
26 West High Street
Carlisle, PA
FiLEL?:; = CE
-?' hf-
OTARY
MOAN 13 PI-11 1: 25
C* ?
Howard B. Krug, Esquire
ID #16826
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
hkrug@pkh.com
SARA E. THUMA-CROOM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
PAUL L. CROOM, II,
Defendant
NO. 2008-1593 CIVIL TERM
CIVIL ACTION - CUSTODY
MOTION TO MAKE RULE ABSOLUTE
AND NOW, comes Plaintiff, Sara E. Thuma-Croom, who moves this Court to make a
Rule issued on December 22, 2009 absolute, and, in support thereof, avers the following:
1. On December 17, 2009, a Petition for Transfer of Venue was filed by Plaintiff.
2. A Rule to Show Cause was issued on December 22, 2009, giving Defendant
twenty days to file a responsive pleading.
3. The Order indicates that a copy was mailed to Defendant's counsel, Carol
Lindsay, Esquire, on December 22, 2009.
4. The Honorable Edgar B. Bayley had been previously assigned to this case.
L-1
5. No objection has been filed by Defendant.
WHEREFORE, Plaintiff moves this Honorable Court to make the December 22, 2009
Rule absolute and enter an Order directing transfer of venue of the above-captioned action
from Cumberland County to Dauphin County, Pennsylvania.
PURCELL, KRUG & HALLER
By:
A'®r g, Esquire`
8Nichole M. Staley O'Gorman, Esquire
ID #78966
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: Attorneys for Plaintiff
CERTIFICATE OF SERVICE
I, Kimberly S. DeFalco, Legal Assistant to Nichole M. Staley O'Gorman, hereby certify
that a true and correct copy of the foregoing document was served upon the Defendant, by
sending a copy of the same via first class U.S. Mail to:
Carol Lindsay, Esquire
26 West High Street
Carlisle, PA 17013
Kimberly S. De co, Legal Assistant to
Nichole M. Staley O'Gorman, Esquire
PURCELL, KRUG & HALLER
I.D. No. 78966
DATE: \ I t ;?\ 1 C
SARA E. THUMA-CROOM, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 08-1593 CIVIL
PAUL L. CROOM, II,
Defendant IN CUSTODY
ORDER
AND NOW, this -" ' day of January, 2010, the petition of the plaintiff for transfer of
venue is DENIED. The matters raised in the defendant's counterclaim are referred to
conciliation.
BY THE COURT,
4 4 wz
Kevi A. Hess, P. J.
Howard B. Krug, Esquire
For the Plaintiff
--It"arol J. Lindsay, Esquire
For the Defendant
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SARA E. THUMA-CROOM IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
PAUL L. CROOK II
DEFENDANT
2008-1593 CIVIL ACTION LAW
. IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, January 19, 2010 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on _ _Monday, February 15, 2010 at 12:00 PM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: /s/ Dawn S. Sunda Es .
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
t
IARY
2010 JAN 21 Ptl 2: 4 4
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APO' V
2010FLEB-l All1f:ALL
Howard B. Krug, Esquire
ID #16826
Nichole M. Staley O'Gorman, Esquire
ID #78966
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
hkrugCa)_pkh.com
SARA E. THUMA-CROOM,
Plaintiff
V.
PAUL L. CROOK II,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008-1593 CIVIL TERM
CIVIL ACTION - CUSTODY
PRELIMINARY OBJECTIONS OF PLAINTIFF
TO COUNTER-CLAIM RAISED BY DEFENDANT
IN ANSWER TO PETITION FOR TRANSFER OF VENUE
AND NOW, comes Plaintiff, Sara E. Thuma-Croom, by her attorneys, Purcell, Krug and
Haller, and who files the files the following preliminary objections:
1. Plaintiff, Sara E. Thuma-Croom (hereinafter "Mother"), filed a Petition for Transfer
of Venue in the above-captioned case on December 17, 2009.
2. Defendant, Paul L. Croom (hereinafter "Father"), filed his Answer to Petition for
Transfer of Venue and Counter-Claim on January 11, 2010.
3. Father's pleading includes a Notice to Plead directing Mother to respond within
20 days of service "or a judgment may be entered against you."
4. The above-captioned action is a child custody action subject to Pennsylvania
Rules of Civil Procedure 1915.1 et seq.
Order.
5. In his Counterclaim, Father asks the Court to modify the existing Child Custody
6. Father's request should have been filed as a Petition for Modification pursuant to
Pa. R.C.P. 1915.1 et. seq.
7. The Rules of Civil Procedure do not require Mother to file and Answer to a
Petition for Modification. Pa. R.C.P. 1915.5.
8. Furthermore, the Rules do not permit Father to take a default judgment on such
an action.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to dismiss
Defendant's Counterclaim for failure to confirm to Pa. R.C.P. 19151. et. seq..
PURCELL, KRUG & HALLER
DATE: a/' f U
By lie Z1\1
Howar . Kru , squire
ID #1 26
Nichole M. Staley O'Gorman, Esquire
ID #78966
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
Attorneys for Plaintiff
CERTIFICATE OF SERVICE
I, Kimberly S. DeFalco, Legal Assistant to Nichole M. Staley O'Gorman, hereby certify
that a true and correct copy of the foregoing document was served upon the Defendant, by
sending a copy of the same via first class U.S. Mail to:
Carol Lindsay, Esquire
26 West High Street
Carlisle, PA 17013
Kimberly S. DeF I o, Legal Assistant to
Nichole M. Staley O'Gorman, Esquire
PURCELL, KRUG & HALLER
I.D. No. 78966
DATE: g- t ? 10
FEB ? 9 2010 6
SARA E. THUMA-CROOM IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. : 2008-1593 CIVIL ACTION LAP
;z
PAUL L. CROOM, II N,
Defendant IN CUSTODY
J Y 7?
p?
V
ORDER OF COURT
AND NOW, this /4' day of /;:4wn, , 2010, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated February 19, 2009 shall continue in effect as modified
by this Order.
2. Until the time of the Father's deployment which is expected to occur in September 2010, the
parties shall have custody of the Child as follows:
February 21 through March 6 with Mother
March 21 through March 27 with Mother
April 4 through May 1 with Mother
May 16 through May 22 with Mother
May 30 through June 26 with Mother
July 11 through July 24 with Mother
August 8 through 25 with Mother
March 6 through March 21 with Father
March 27 through April 4 with Father
May 1 through May 16 with Father
May 22 through May 30 with Father
June 26 through July 11 with Father
July 24 through August 8 with Father
August 25 through September 11 with Father
This amended schedule was established to accommodate the Father's schedule of military training and
preparation for deployment. In the event the Father is deployed before September 11 during his last
period of custody as specified above, the Child shall return to the Mother's custody on the day
immediately following the Father's departure. In the event the Father is deployed after September 11,
2010, the parties shall revert to the alternating bi-weekly schedule following the Father's last period of
custody specified above.
3. When the exchanges of custody take place on Sundays, the parties shall meet at the selected
exchange point in Richmond, Virginia at 12:00 noon. On the four days that exchanges take place on
Saturday, the parties shall exchange custody of the Child at 3:00 p.m. with the exchange taking place
on March 6 and May 1 in Falmouth, Virginia, and on March 27 and May 22 in Richmond, Virginia.
The Mother agrees that she will depart from her residence for the exchanges of custody on Saturdays
by 10:00 a.m.
4. The non-custodial parent shall be entitled to have daily telephone contact with the Child.
The Mother's daily telephone contact shall take place at 7:30 a.m. on days when she is not
communicating with the Child by Skype and the Father's telephone contacts shall take place at 8:00
a.m. on days when he is not communicating with the Child by Skype.
5. The parties shall continue to cooperate in attempting to establish a custodial schedule
whereby the Child will spend time with the Father's immediate family members in North Carolina
during the period of the Father's deployment. The parties shall determine whether they agree to
consult with a child development expert/psychologist to obtain information and guidance as to the
amount of contact which will be necessary to maintain the Child's bonds to the Father's immediate
family during his absence while maximizing time with the Mother as she is available during that
period. If in agreement as to consultation, the parties shall select the professional by mutual consent.
6. Counsel for either party may contact the conciliator within 90 days of the date of this Order
to schedule an additional custody conciliation conference to address the issue of the custodial schedule
during the Father's deployment further.
7. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT,
Kevin A/ ess J.
cc: ole Staley O'Gorman, Esquire - Counsel for Mother
Carol J. Lindsay, Esquire - Counsel for Father
e6
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SARA E. THUMA-CROOM
Plaintiff
VS.
PAUL L. CROOM, II
Defendant
Prior Judge: Kevin A. Hess
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2008-1593 CIVIL ACTION LAW
: IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Sojourner Croom December 6, 2006 Mother/Father
2. A custody conciliation conference was held on February 16, 2010, with the following
individuals in attendance: the Mother, Sara E. Thuma-Croom, with her counsel, Nichole Staley
O'Gorman, Esquire, and the Father's counsel, Carol J. Lindsay, Esquire. The Father, Paul L. Croom,
is currently in the Marines stationed at Camp LeJeune, North Carolina and participated in the
conference by telephone.
3. The parties agreed to entry of an Order in the form as attached.
Date Dawn S. Sunday, Esquire
Custody Conciliator
i
APR U 9N10
SARA E. THUMA-CROOM
Plaintiff
vs.
PAUL L. CROOM, II
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2008-1593
IN CUSTODY
CIVIL ACTION L
,w
r
r{4
ORDER OF COURT
AND NOW, this day of 11 -to A?4? j , 2010, upon
\
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
A hearing is scheduled in Court Room No. '/'- of the Cumberland County Court House on
the 1 day of `2010, at /; o'clock o m., at which time testimony will be
taken. For purposes Of the Wearing, the Father, Paul L. CrooI, shall be deemed to 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 each party's position on custody, a list of witnesses
who are expected to testify at the hearing and a summary of the anticipated testimony of each witness.
These Memoranda shall be filed at least seven days prior to the hearing date.
BY THE COURT,
Kevin A. ess J.
cc: >khole Staley O'Gorman, Esquire - Counsel for Mother
/Carol J. Lindsay, Esquire - Counsel for Father
(26 F1 ES elrx$L L -cc
All, a--'16
SARA E. THUMA-CROOM
Plaintiff
vs.
PAUL L. CROOM, II
Defendant
Prior Judge: Kevin A. Hess
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2008-1593 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Sojourner Croom December 6, 2006 Mother/Father
2. A custody conciliation conference was initially held on February 16, 2010, at which time the
parties were able to reach an agreement as to modified custodial arrangements through the time of the
Father's deployment which is expected to occur in September 2010. Another issue, which was raised
in the Father's Counter-Claim was the custodial schedule during the period of the Father's deployment.
At the present time, the parties share physical custody of the Child, who is three years old, on an
alternating two week schedule, as the Father resides at Camp LeJeune in North Carolina. In a prior
Order dated February 19, 2009 regarding a former deployment of the Father, the Court ordered that the
Child be in the custody of her paternal grandparents during deployment for two weekends each month.
The Father seeks to continue the shared custody schedule during his upcoming deployment so that the
Child maintains her bond with the Father's wife and their soon to be born child, this Child's half
sibling. The parties were unable to reach an agreement as to a schedule during deployment but agreed,
as reflected in the February 2010 Order, to continue cooperating in an attempt to establish a custodial
schedule during deployment and also to consider the possibility of consulting with a child development
expert to obtain information as to the amount of contact necessary to maintain the Child's bonds to the
Father's immediate family while maximizing time with the Mother. Counsel for the parties scheduled
a telephone conference with the conciliator, which was held on April 1, 2010, at which time it was
determined that it will be necessary to schedule a hearing on the issues of the custodial schedule during
the Father's period of deployment. While the Mother's counsel sought a follow-up custody
conciliation conference in a final attempt to assist the parties in reaching an agreement on the schedule,
the Father's counsel expressed concern that the issue be finally resolved by the Court before
September 2010. The parties will continue to work toward resolution, however, and will cancel the
hearing if they are successful.
2. The Father's position on custody is as follows: The Father believes that the alternating two
week schedule should continue during the period of his military deployment so that the Child
maintains her familiarity with the Father's immediate family, including his wife and the Child's half
sibling, who is expected to be born in the near future. The anticipated duration of the Father's
upcoming deployment is seven months. The Father believes that it would be in the best interests of the
Child to maintain the bonds which she has already established with the Father's family to prevent
major adjustments as the Child is reintegrated into his family following deployment. The Father is
willing to consult with a child development expert for guidance, but believes that the parties should
select an expert in the Father's area of residence (North Carolina) as he is limited by his military duties
and the Mother is currently not working outside the home.
3. The Mother's position on custody is as follows: The Mother believes that the Child should
be with her primarily during the Father's period of deployment with some type of limited custodial
periods with the Father's wife and other child. The Mother noted that she is available at all times for
the Child and feels it is best for the Child to be with a biological parent as much as possible. The
Mother is willing to obtain guidance from a child development expert as well but felt that the parties
should select an expert in the local area so that the expert is familiar to the Court and is available to
provide information to the Court, if necessary.
4. The conciliator recommends an Order in the form as attached scheduling a hearing on the
issue of the custodial arrangements during the time of the Father's military deployment. The Father's
counsel requested that the hearing be scheduled in July due to the Father's military schedule and
counsel's unavailability in June. It is anticipated that the hearing will require one half day.
Date Dawn . unday, Esquire
Custody Conciliator
SARA E. THUMA-CROOM,
Plaintiff
v.
PAUL L. CROOM, II,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008-1593 -CIVIL TERM
CIVIL ACTION -CUSTODY
PRAECIPE
Please withdraw the Counterclaim of the Defendant to the Petition for Transfer of
Venue filed by the Plaintiff on December 17, 2009. The Counterclaim was filed on January
11, 2010.
SAIDIS SULLIVAN LAW
~ --_.
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Carol J. Lindsay, Es uire
Attorney Id. 446
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Counsel for Defendant
Paul L. Croom, II
SAIDIS,
FIAWER ~
LINDSAY
AT[C)RNEYS•AT•IAW
26 West High Street
Carlisle, PA
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CERTIFICATE OF SERVICE
I hereby certify that on this ~ day of July, 2010, a true and correct copy of the
foregoing document was served upon the party listed below, via First Class Mail, postage
prepaid, addressed as follows:
Nichole M. Staley O'Gorman, Esquire
PURCELL, KRUG & HALLER
1719 North Front Street
Harrisburg, PA 17102-2305
SAIDIS SULLIVAN LAW
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Carol J. Lindsay, Esquire
Supreme Court ID No. 44693
26 West High Street
Carlisle, PA 17013
717-243-6222
SAIDIS,
FIAWER ~
LINDSAY
nr~owvExs•nr uw
26 West High Street
Carlisle, PA
7a~o .~~~ -8 Rt~l r~ bS
Nichole M. Staley O'Gorman, Esquire ClJt,r ..i~i~`
f :. ~,: ,S
PA Supreme Court ID# 79866
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
Phone: (717) 234-4178
Fax: (717) 234-0409
nstaleyCc~pkh.com
SARA E. THUMA-GROOM n/k/a
SARA E. THUMA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
PAUL L. GROOM, II,
Defendant
NO. 2008-1593 CIVIL TERM
CIVIL ACTION -CUSTODY
PRE-TRIAL MEMORANDUM OF SARA E. THUMA-GROOM
AND NOW, comes Sara E. Thuma, by and through her attorneys, Purcell, Krug
& Haller, and files the following Pre-Trial Memorandum pursuant to the Court's Order
dated April 12, 2010:
1. Factual Background: Sojourner Groom was born on December 6, 2006 and
is now 3 % years old. Her parents separated in February, 2008 after 5 '/2 years of
marriage. Following separation, Mother and child moved to her parents' home in
Harrisburg and continue to reside there. On January 22, 2009, Father announced that
on January 23~d he would marry "Martina", a woman previously unknown to Mother.
Father is a Captain in the United States Marine Corps. In January, 2009 he was
transferred from the Carlisle area to Virginia Beach, Virginia. In April, 2009, he was
reassigned to Camp LeJeune, North Carolina. In May, 2009, he was deployed to Iraq.
He returned in September, 2009 to North Carolina where he currently resides with his
wife and her daughter. Father and his wife are expecting their first child in August,
2010.
The instant matter arises as a result of Father's receipt of notice that he will be
deployed overseas again. Until just a few days ago, a seven month deployment to
Afghanistan was anticipated in September, 2010. However, on July 1St, Father's
counsel advised that he had been transferred to a new unit and no longer expected to
be deployed until January of 2011. During his deployment, Father is opposed to the
child remaining in Mother's primary care. According to his Counterclaim, he prefers to
"delegate" his parental responsibilities to his current wife instead. Anticipating a
September deployment, Mother enrolled the child in apre-school program at The
Londonderry School in Harrisburg. The program begins on September 7th. School
selection was made by mutual agreement after consultation with Father.
2. Procedural History: Mother filed a complaint in custody on March 10, 2008.
The parties participated in mediation with Dr. Arnold Sheinvold, but were ultimately
unable to reach an agreement. Following a hearing in July 2008, the Honorable Judge
Bayley entered an Order granting primary physical custody to Mother, with Father
having periods of custody every other Friday evening to Monday morning, every
Wednesday evening to Thursday morning and every other Thursday evening to Friday
morning.
Approximately three months later, Father petitioned for modification of the Order
in view of several anticipated changes. He was to relocate to Virginia Beach, Virginia in
2
January 2009, deploy to Iraq thereafter and relocate to North Carolina immediately
upon return from Iraq. On February 19, 2009, Judge Bayley entered an Order granting
the parties shared physical and legal custody, with a week on/week off schedule while
Father was in Virginia and a two week on/two week off schedule when he relocated to
North Carolina. While he was deployed, the paternal grandparents were to have
custody two weekends per month.
In December 2009, Mother filed a Petition to Transfer Venue to Dauphin County,
as she currently resides there and neither party has resided in Cumberland County for
some time. The Court denied Mother's request. Father filed a Counterclaim to
Mother's Petition requesting a modification of custody for the period before and during
his deployment. It is Father's Counterclaim that is presently before the Court.
3. Witnesses: Plaintiff anticipates calling some or all of the following witnesses:
a. Sara E. Thuma
b. Dr. Arnold Stolberg - as to his evaluation of the parties, the minor
child and Mr. Croom's current wife and his recommendation as to
custody prior to and during Mr. Croom's upcoming deployment.
c. Philip Thuma - as to his observations at custodial exchanges.
d. Stephanie Seltzer - as to her observations at custodial exchanges.
4. Summary of Mother's Position: Since Sojourner is now approaching four
years of age, Mother strongly believes that she should begin a structured pre-school
program. Mother and her counsel were preparing a custody modification petition to
3
request the needed custodial changes to accommodate preschool when Father
announced his deployment plans and filed his Counterclaim. Whether Father deploys
in September or January, Mother wants the existing custodial schedule to be modified
to allow Sojourner to attend the Londonderry School in September. Dr. Arnold Stolberg
has performed an evaluation of the parties and child and advises that the child's
developmental needs will not be appropriately met if she is not enrolled in such a
program in the Fall. Mother opposes Father's plan to keep the current two week on/two
week off schedule and enroll the child in apre-school program in both locations, as it
will be impossible for the child to realize the full benefit of either program or to develop
social relationships with her classmates and teachers. Father's plan is inconsistent with
Dr. Stolberg's recommendation. Beginning in September, Mother believes it is in the
best interest of Sojourner for her to have primary physical custody and for Father and
his family to have one long weekend each month. Mother has enrolled Sojourner in a
three day pre-school program (Tuesday, Wednesday and Thursday) to accommodate
monthly extended visits with Father's family without disruption to the educational
program.
9,
717 234-4178
nstaley(cz~pkh.com
Counsel for Plaintiff, Sara E. Thuma
Date: ~ .- / / ~,
r
PUR~ELL, KRUG AND HALLER
By
Ni o e M. t ey an, Esquire
ID 79866
17 9 N. Fron St.
H rrisbur PA 17102
CERTIFICATE OF SERVICE
I, Kimberly S. DeFalco, Legal Assistant, hereby certify that a true and correct copy of
the foregoing document was served upon the Defendant, by sending a copy of the same via
first class U.S. Mail to:
Carol J. Lindsay, Esquire
Saidis Sullivan Law
26 West High Street
Carlisle, PA 17013
Kimberly S. D a co, Legal Assistant
1719 North Fro Street
Harrisburg, PA 17102
(717) 234-4178
DATE: ~ ~ ~ ` ~ (J
SARA E. THUMA-CROOM, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION -LAW
NO.08-1593 CIVIL
PAUL L. CROOM, II,
Defendant IN CUSTODY
IN RE: MODIFICATION OF CUSTODY
ORDER
AND NOW, this 9 `day of July, 2010, after telephone conference with counsel,
hearing in the above-captioned matter is set for Thursday, October 21, 2010, at 9:30 a.m. in
Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA.
BY THE COURT,
.~ /-
Kevin A. ess, P. J.
icole Staley-O'Gorman, Esquire
Fou~r the Plaintiff
Carol J. Lindsay, Esquire
For the Defendant
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SARA E, THUMMA-GROOM
PLAINTIFF
V.
PAUL L. GROOM, II
DEFENDANT
AND NOW, 1
it is hereby directed that parties aY
at 39 West Main Street, Meg
for aPre-Hearing Custody Confer
if this cannot be accomplished, to
order. Failure to appear at the coy
The court hereby directs
Special Relief orders, and Cu
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2008-1593 CIVIL ACTION LAW
TN CUSTODY
ORDER OF COURT
2010
upon consideration of the attached Complaint,
their respective counsel appear before Dawn S. Sunday, Esq. ,the conciliator,
inicsburg, PA 17055 on Monday, August 02, 2010 at 3:00 PM
ce. At such conference, an effort will be made to resolve the issues in dispute; or
;fine and narrow the issues to be heard by the court, and to enter into a temporary
may provide grounds for entry of a temporary or permanent order.
parties to furnish any and all existing Protection from Abuse orders,
orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Dawn S. Sunda Es .
Custody Conciliator
The Court of Com on 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
avaiiable to disabled individ als having business before the court, please contact our office. All. arrangements
must be made at least 72 hou s prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOUSHOULD~
HAVE AN ATTORNEY O]
FORTH BELOW TO FIND
7- tq •to Cer•~- cs~p~
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EKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
)UT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association ~ -' `-~-'
~•~ ~d 32 South Bedford Street. -r .~~
-~ Carlisle, Pennsylvania 17013 `_~
t Telephone (717) 249-3166 ~ `-~'
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SARA E. TIUMA-CROOM, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 08-1593 CIVIL
PAUL L. CROOM, II,
Defendant IN CUSTODY
IN RE: MODIFICATION OF CUSTODY
ORDER
AND NOW, this /Z " day of November, 2010, continued hearing in the above-
captioned matter is set for Wednesday, December 29, 2010, at 1:30 p.m. in Courtroom Number
4, Cumberland County Courthouse, Carlisle, PA.
BY THE COURT,
Nicole Staley-O'Gorman, Esquire
For the Plaintiff
Carol J. Lindsay, Esquire
For the Defendant
:rim
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DEC 1 U 2010
SARA E. THUMA-CROOM IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSY LVANIA
vs. 2008-1593 CIVIL ACTION L4W
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ro
PAUL L. CROOM, II t
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Defendant IN CUSTODY w -.4C)
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ORDER
AND NOW, this 3rd day of December, 2010 , the conciliator, having received no
request from counsel for either party to reschedule the custody conciliation conference originally set
for August 2, 2010, hereby relinquishes jurisdiction pursuant to a letter to counsel dated July 29, 2010.
FOR THE COURT,
Dawn S. Sunday, Esquire
Custody Conciliator
1
SARA E. THUMA-CROOM, n/k/a
SARA E. THUMA,
Plaintiff
V.
PAUL L. CROOM, II,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008-1593 - CIVIL TERM
CIVIL ACTION - CUSTODY
ORDER OF COURT
AND NOW, this 29'' day of December, 2010, after consultation with counsel in
chambers, it is hereby ORDERED AND DIRECTED as follows:
Paul L. Croom, II, hereinafter "Father", shall have custody of his daughter, Sojourner
Q. Croom, bom December 6, 2006, for his pre-deployment leave from Saturday, January 1,
2011 at 11:00 AM until Sunday, January 16, 2011 at noon. On January 1, 2011, Father will
pick up Sojourner in Harrisburg, Pennsylvania at a location of Sara E. Thuma's (hereinafter
"Mother") choosing. On January 16, 2011, the exchange will be at the Glen Allen, Virginia
exchange location currently in use by the parties.
BY THE COURT,
SAIDIS
SULLIVAN
LAW
26 West High Street
Carlisle, PA
Distribution:
Nichole M. Staley O'Gorman, Esquire
Carol J. Lindsay, Esquire
Z4 c
Kevin . Hess, P.J.'
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SARA E. THUMA-CROOM n/k/a,
SARA E. THUMA,
Plaintiff
V.
PAUL L. CROOK II,
Defendant
AND NOW, this s'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 2008-1593 CIVIL TERM n
rn-
CIVIL ACTION - CUSTODY 70t
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C) -n
ORDER OF COURT C; .2- C-)
day of Qt.,,,Q., , 2011, with reorcbbo ?<
the minor child SOJOURNER Q. CROOM (DOB 12/6/06), it is hereby ORDERED AND
DECREED as follows:
1. Legal Custody: The parties will share legal custody. Major decisions
concerning the child, including, but not necessarily limited to, issues related to health,
welfare, education, religious training and upbringing shall be made by the parties jointly,
after discussion and consultation with each other, with a view toward obtaining and
following a harmonious policy in the child's best interest. Neither party shall permit
these decisions to be made by third parties. Each party agrees not to impair the other
party's rights to shared legal custody of the child. Each party shall notify the other of
any activity or circumstance concerning their child that could reasonably be expected to
be of concern to the other. Day to day decisions shall be the responsibility of the parent
then having physical custody. With regard to any emergency decisions which must be
made, the parent having physical custody of the child at the time of the emergency shall
be permitted to make any immediate decision necessitated thereby. However, that
parent shall inform the other of the emergency and consult with him or her as soon as
I
possible. In accordance with 23 Pa. C.S.A. § 5309, each party shall be entitled to
complete and full information from any doctor, dentist, teacher, professional or authority
and to have copies of any reports or information given to either party as a parent as
authorized by statute. If early enrollment in kindergarten is contemplated, the parties
will make such a decision jointly.
2. Physical Custody:
a. Mother shall have primary physical custody of Sojourner.
b. Until February 20, 2011 or the date of Father's deployment,
whichever comes first, Father shall have periods of partial custody
as follows:
i. For Father's pre-deployment leave from Saturday,
January 1, 2011, at 11:00 a.m. until Sunday, January 16,
2011, at noon. On January 1, 2011, Father will pick up
Sojourner in Harrisburg at a location of Mother's choosing.
On January 16, 2011, the exchange will be at the Glen
Allen, Virginia exchange location currently in use by the
parties.
ii. From Sunday, February 6, 2011, until Sunday, February 20,
2011, exchanges will occur at noon at the Richmond,
Virginia exchange location currently in use by the parties.
iii. The child shall be returned to Mother on the day following
I
Father's deployment. If Father is deployed after February
20th, the parties will see to it that Sojourner is in Father's
custody for a period commencing two days before
deployment and ending the day after deployment when she
will be returned to Mother. If the exchange date occurs on a
week day, Father, his wife or his parents will be responsible
for all transportation.
C. Following Father's return from deployment, he shall have periods of
partial custody as follows:
i. Fall: One two-week period each fall beginning at 2:00 p.m.
on the Sunday prior to Thanksgiving and ending on Sunday
at 2:00 p.m. two weeks thereafter. After Sojourner begins
kindergarten, and only in the event school attendance policy
will allow it, the custodial period shall be a one-week period
and extend from 2:00 p.m. on the Sunday prior to
Thanksgiving break and end on the Sunday following
Thanksgiving break at 2:00 p.m.
ii. Winter: For 2011, Father shall have the child from
December 24th at 2:00 p.m. until January 1St at 2:00 p.m.
Thereafter, Father's custodial period shall begin at an
agreed time following the close of school which reasonably
allows for travel and end at 2:00 p.m. on December 30th
iii. Spring: One two-week period each spring beginning at 2:00
p.m. on the Sunday prior to Easter and ending on Sunday at
2:00 p.m. two weeks thereafter. After Sojourner begins
kindergarten, and only in the event school attendance policy
will allow it, this custodial period shall be a one-week period
commencing the Sunday prior to the first day of spring break
and ending on the following Sunday at 2:00 p.m.
iv. Summer:
(a) For most of the summer of 2011, Father will be
deployed to Afghanistan.
(b) In 2012, and in following years, Father shall have
custody of the child for eight weeks during the
summer to be taken in four-week blocks
separated by a week in which custody will be with
Mother. The first four-week block will commence
the second Sunday after the last day of school.
Custody of the child shall return to Mother at least
three days prior to the beginning of the school
year, or on the Sunday at the end of the second
four-week block, whichever comes first.
d. Following Father's anticipated return from deployment in August,
2011, Father's family shall be entitled to pick up Sojourner one day
prior to his return from deployment, and Father shall have custody
for up to two weeks thereafter. Sojourner shall be returned to her
Mother's custody no later than 2:00 p.m. on the Sunday prior to the
start of the 2011-2012 school year. If Father returns after the
school year has commenced but before October 15th, he shall be
entitled to up to two weeks of custody, but the fall custodial period
will be shortened to one week. If Father returns after October 15th
this custodial period shall replace the next scheduled fall, winter or
spring custodial period.
e. During the calendar months when Father does not have a custodial
period, Paternal Grandparents shall have the option to have one
weekend during each of those months at times to be agreed by
mother and Grandparents, but as early as 12:00 noon on Friday to
as late as 5:00 p.m. on Sunday. Grandparents shall propose
weekends they wish to exercise no less than sixty days in advance.
Grandparents shall be responsible for all travel and the costs of
same.
3. During Father's deployment, the following accommodations shall be made
to allow the child to spend time with Father's family:
a. The child will be with Father's wife, Martina Croom-Schoefberger,
as follows:
i. During the child's spring recess, from 2:00 p.m. on Sunday,
April 17, 2011 to 2:00 p.m. on Sunday, April 24, 2011; and
ii. From Sunday, June 19, 2011 at 2:00 p.m. to Sunday, June
26, 2011, the exchanges being at 2:00 p.m.
iii. The child shall not travel outside the United States during
these periods of custody.
b. Paternal Grandparents shall be entitled to one weekend during the
month of July at times to be agreed by Mother and Grandparents,
but as early as 12:00 noon on Friday and as late as 5:00 p.m. on
Sunday. If Father will not return from deployment by the end of
August, Grandparents shall also be entitled to one weekend during
the month of August. Grandparents shall be responsible for all
transportation, at their own expense, for these custodial periods.
Notice of the weekends selected shall be given to Mother no later
than May 1, 2011.
4. Father shall provide Mother the dates of his deployment and return as
soon as he receives them.
5. Unless otherwise set forth herein, all custodial exchanges shall occur in
Glen Allen, Virginia.
6. Each parent and any stepparent shall be entitled to daily contact with the
child. The parties will cooperate to schedule mutually convenient times for such
contact, which may occur by the non-custodial parent's choice of telephone or Skype.
7. The parties will engage in Intensive Co-Parenting Training with a mutually
agreed upon professional. All associated out-of-pocket expense will be shared equally
by the parties. The Co-Parenting Trainer must be able to conduct most meetings by
Skype, telephone or other long distance means.
8. The parties will appoint a mutually acceptable Parenting Coordinator
("PC"). All associated out-of-pocket expenses will be shared equally by the parties
unless otherwise allocated by the PC in accordance with the terms of his appointment.
The PC must be able to conduct most meetings by Skype, telephone or other long
distance means. The authority of the PC shall be governed by the terms of a separate
Order to be entered after consultation by counsel for the parties with the PC.
9. The parents will communicate with each other about routine and
exceptional child development matters on an at least weekly basis by procedures to be
developed by their Intensive Co-Parenting Trainer. The parties will cooperate to
schedule mutually convenient times for such contact. During Father's deployment, this
contact will occur as often as his schedule permits.
10. Neither parent shall engage in a course of conduct designed to alienate
the child from the other parent or the other parent's extended family. To the extent
possible, the parties will prevent third parties from engaging in such conduct.
11. Father with ensure that Sojourner understands and differentiates between
Mother and her stepmother, and the word "Mother" shall not be used to identify
stepmother. Mother and Father agree to behave cordially to members of the other's
family.
12. Should childcare be necessary, each parent shall exercise care in
responsibly choosing childcare providers. The telephone number and address of the
childcare provider shall be provided to the other parent in advance. Likewise, if the
child will be spending the night at a location other than a parent's primary residence, the
address and telephone number shall be provided to the other parent, in advance.
13. When possible, both parties will notify the other of a pending relocation of
more than fifty (50) miles from their present residence within ninety (90) days of the
move. The ninety-day notice is designed to afford the parents an opportunity to
renegotiate the custodial arrangements or to have the matter listed for a Court hearing.
If the military provides Father with less than ninety days' notice of relocation, said notice
shall be provided to Mother upon receipt.
14. The child's passport shall be held by the parent having physical custody of
the child.
BY THE COURT,
Kevin A./Hess, P.J.
?Nichole M. Staley O'Gorman, Esquire
For the Plaintiff
`Carol Lindsay, Esquire
For the Defendant
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SARA E. THUMA-CROOM, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PEVSV,-VAIRIA
V. CIVIL ACTION - LAW r
NO. 08-1593 r r*t
PAUL L. CROOM, II, ,
Defendant IN CUSTODY
.
Hess
J ° n
.
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PETITION FOR SPECIAL RELIEF `
AND NOW, comes Paul L. Croom, II, by and through his counsel, Saidis, Sullivan &
Rogers and petitions this Honorable Court as follows:
1. The parties hereto are parents of a child, Sojourner Q. Croom, born
December 6, 2006.
2. The parties are subject to an Order of Court dated January 3, 2011, relative
to physical and legal custody of their daughter, a copy of which is attached hereto as
Exhibit "A".
3. Petitioner is an officer in the United States Marine Corps who was assigned
to active duty in Afghanistan from approximately February 2011, but was withdrawn from
the area and returned to Camp Lejeune, North Carolina effective approximately June 30,
2011 in order to prepare for follow-on assignment to Okinawa, Japan.
4. At the time of the drafting of the Order of January 3, 2011, Petitioner was not
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Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
anticipating a return home until approximately mid to late August 2011.
5. The current Order of Court does not provide for a period of custody for
summer 2011 for Petitioner with the child, presumably due to the assumption that Petitioner
would not be available to exercise custody with the child.
6. The current Order of Court provides as follows:
oLm %70.14 pd
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Paragraph 2(c)(iv) Summer:
(a) For most of the summer of 2011, Father will be deployed to Afghanistan.
(b) In 2012, and in following years, Father shall have custody of the child for eight
weeks during the summer to be taken in four-week blocks separated by a week in
which custody will be with Mother. The first four-week block will commence the
second Sunday after the last day of school. Custody of the child shall return to
Mother at least three days prior to the beginning of the school year, o on the Sunday
at the end of the second four week block, whichever comes first.
2(d) Following Father's anticipated return from deployment in August, 2011,
Father's family shall be entitled to pick up Sojourner one day prior to his return from
deployment, and Father shall have custody for up to two weeks thereafter.
Sojourner shall be returned to her Mother's custody no later than 2:00pm on the
Sunday prior to the start of the 2011-2012 school year.
5. Unless otherwise set forth herein, all custodial exchanges shall occur in Glen
Allen, Virginia.
7. The current Order presumes that Petitioner will begin any period of custody
for summer 2011 in mid to late August with no option provided in the event he is returned
home earlier, and has time to exercise custody of his daughter for other periods of time.
8. Petitioner returned home approximately July 2, 2011, and the Marine Corps
will station him, and his wife and two other minor children, in Okinawa, Japan beginning on
or about August 24, 2011, for a period of approximately three years.
9. When Petitioner learned of his imminent return home to the States, he
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Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
contacted Respondent on May 25, 2011 to advise her of the return and to request periods
of summer custody with the parties' daughter, to begin upon his return and to continue
through his departure.
10. Petitioner has requested a period of summer custody to include
approximately six weeks for 2011, which is approximately the time he, and his wife and two
other minor children, are available to spend with the parties' daughter before moving to
Okinawa.
11. Petitioner believes, and therefore avers, that Paragraph 2(c)(iv) provides him
with eight weeks of custody during the summer months that he is available to spend time
with the child and that summer 2011 is separately delineated by subparagraph 2(c)(iv)(a)
because it was not presumed that Petitioner would be available to exercise custody.
12. Petitioner is available today and should be entitled to exercise custody
pursuant to the terms set forth in subparagraph. 2(c)(iv)(b) regarding summers, except that
Petitioner's custody period will comprise six-and-a-half consecutive weeks vice only four to
accommodate the reduced summertime available.
13. In the most recent correspondence between Petitioner and Respondent,
Respondent has denied Petitioner periods of custody for more than two weeks during the
summer 2011, relying upon her reading of the Court Order and insisting that the current
Order provides for Petitioner to exercise only those two weeks for this summer.
14. Petitioner believes, and therefore avers, that Respondent is employed and
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& Rogers
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works daily, while the child is cared for by a third party.
15. Petitioner believes, and therefore avers, that the child is not enrolled in any
daycare or preschool program during the summer but instead is cared for by Respondent's
mother, a schoolteacher who is not employed during the summer and who is available each
day to provide care, transportation, and other services for the child and Respondent.
16. Pursuant to the Order of Court, Petitioner's wife was entitled to exercise one
week of custody from June 19 through June 26.
17. The parties were negotiating a summer custody schedule and Petitioner
relinquished this period of time for his family, anticipating that the child would spend an
additional week with him upon his homecoming on July 2, 2011, or during the summer.
18. Respondent has gained an additional uninterrupted week of summer custody
with the child from June 19 through June 26, 2011, that she otherwise would not have
enjoyed with the parties' daughter had Petitioner not already agreed to this.
19. Petitioner, his wife and his two other minor children have a scheduled trip to
Austria, with a departing date of July 8, 2011 and a return date of July 28, 2011.
20. Petitioner has a ticket purchased for the minor child at issue but Respondent
has refused to allow her to attend this trip as scheduled.
21 Upon notice of Petitioner's return from Afghanistan and requested
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Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
homecoming time with the child, Respondent notified Petitioner that she had a planned
vacation to visit with family in Connecticut from Thursday, July 7 through Wednesday, July
13 that she was unwilling to change to accommodate Petitioner's brief time home.
22. As recently as July 1, Respondent has indicated to Petitioner that he may
exercise custody of the child from July 2 through July 23; this time directly conflicts with
Respondent's planned vacation time.
23. By letter dated July 5, 2011 from Respondent's counsel, Respondent
confirms her intention to travel for her vacation after Petitioner offered her another option for
summer plans that would allow each party to spend time with their child for the summer, but
Respondent does not confirm that she will meet to exchange the child as Petitioner
requested or allow Petitioner to exercise custody for any extended period of time.
24. Petitioner has offered multiple options to accommodate both Respondent's
planned trip and his vacation to Austria (with some modifications on his part), but
Respondent indicates that she will abide by her interpretation of the Court's Order and offer
Petitioner two weeks for the summer, with an additional week for the time his wife
relinquished.
25. Petitioner remains on active duty and will be moved from stationing in Camp
Lejeune, North Carolina to Okinawa, Japan for a three-year obligation there on or about
August 24, 2011.
26. Petitioner is concerned that Respondent continues to attempt to frustrate his
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
limited periods of in-person contact with his daughter over this six week period and that her
ongoing attempts to do so delay his personal relationship with his daughter.
27. A copy of this Petition has been forwarded to Respondent's counsel of
record, Nichole O'Gorman, Esquire, who does not concur with the relief requested.
WHEREFORE, Petitioner requests your Honorable Court to review and enforce the
prior Order in this matter and to Order as follows:
That Petitioner is entitled to summer custody in 2011, beginning July 8 and
continuing through August 23, without interruption;
2. Custody exchanges are to occur at 1 p.m. at Dulles International Airport on
July 8, and 2 p.m. in Harrisburg, Pennsylvania on August 23.
SAIDIS, SULLIVAN & ROGERS
i
Mares Ma", Esqu'Ire
ID No.
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Attorney for Plaintiff
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
i
SARA E. THUMA-CROOM n/k/a, : IN THE COURT OF COMMON PLEAS OF
SARA E. THUMA, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. :NO. 2008-1593 CIVIL TERM l `
C
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PAUL L. CROOM
II r rnr
,
,
Defendant : CIVIL ACTION - CUSTODY rTi ,
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ORDER OF COURT
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AND NOW, this S' vx
day of Qa.,.d«. , 2011, with re rC o v
70,E
the minor child SOJOURNER Q. CROOM (DOB 1216106), it is hereby ORDERED AND
DECREED as follows:
Legal Custody: The parties will share legal custody. Major decisions
concerning the child, including, but not necessarily limited to, issues related to health,
welfare, education, religious training and upbringing shall be made by the parties jointly,
after discussion and consultation with each other, with a view toward obtaining and
following a harmonious policy in the child's best interest. Neither party shall permit
these decisions to be made by third parties. Each party agrees not to impair the other
party's rights to shared legal custody of the child. Each party shall notify the other of
any activity or circumstance concerning their child that could reasonably be expected to
be of concern to the other. Day to day decisions shall be the responsibility of the parent
then having physical custody. With regard to any emergency decisions which must be
made, the parent having physical custody of the child at the time of the emergency shall
be permitted to make any immediate decision necessitated thereby. However, that
parent shall inform the other of the emergency and consult with him or her as soon as
possible. In accordance with 23 Pa. C.S.A. § 5309, each party shall be entitled to
complete and full information from any doctor, dentist, teacher, professional or authority
and to have copies of any reports or information given to either party as a parent as
authorized by statute. If early enrollment in kindergarten is contemplated, the parties
will make such a decision jointly.
2. Physical Custody:
a. Mother shall have primary physical custody of Sojourner.
b. Until February 20, 2011 or the date of Father's deployment,
whichever comes first, Father shall have periods of partial custody
as follows:
i. For Father's pre-deployment leave from Saturday,
January 1, 2011, at 11:00 a.m. until Sunday, January 16,
2011, at noon. On January 1, 2011, Father will pick up
Sojourner in Harrisburg at a location of Mother's choosing.
On January 16, 2011, the exchange will be at the Glen
Allen, Virginia exchange location currently in use by the
parties.
ii. From Sunday, February 6, 2011, until Sunday, February 20,
2011, exchanges will occur at noon at the Richmond,
Virginia exchange location currently in use by the parties.
iii. The child shall be returned to Mother on the day following
Father's deployment. If Father is deployed after February
2&, the parties will see to it that Sojourner is in Father's
custody for a period commencing two days before
deployment and ending the day after deployment when she
will be returned to Mother. If the exchange date occurs on a
week day, Father, his wife or his parents will be responsible
for all transportation.
C. Following Father's return from deployment, he shall have periods of
partial custody as follows:
i. Fall: One two-week period each fall beginning at 2:00 p.m.
on the Sunday prior to Thanksgiving and ending on Sunday
at 2:00 p.m. two weeks thereafter. After Sojourner begins
kindergarten, and only in the event school attendance policy
will allow it, the custodial period shall be a one-week period
and extend from 2:00 p.m. on the Sunday prior to
Thanksgiving break and end on the Sunday following
Thanksgiving break at 2:00 p.m.
ii. Winter: For 2011, Father shall have the child from
December 24"' at 2:00 p.m. until January 1*1 at 2:00 p.m.
Thereafter, Father's custodial period shall begin at an
agreed time following the close of school which reasonably
allows for travel and end at 2:00 p.m. on December 30"'.
iii. Spring: One two-week period each spring beginning at 2:00
p.m. on the Sunday prior to Easter and ending on Sunday at
2:00 p.m. two weeks thereafter. After Sojourner begins
kindergarten, and only in the event school attendance policy
will allow it, this custodial period shall be a one-week period
commencing the Sunday prior to the first day of spring break
and ending on the following Sunday at 2:00 p.m.
iv. Summer:
(a) For most of the summer of 2011, Father will be
deployed to Afghanistan.
(b) In 2012, and in following years, Father shall have
custody of the child for eight weeks during the
summer to be taken in four-week blocks
separated by a week in which custody will be with
Mother. The first four-week block will commence
the second Sunday after the last day of school.
Custody of the child shall return to Mother at least
three days prior to the beginning of the school
year, or on the Sunday at the end of the second
four-week block, whichever comes first.
d. Following Father's anticipated return from deployment in August,
2011, Father's family shall be entitled to pick up Sojourner one day
prior to his return from deployment, and Father shall have custody
for up to two weeks thereafter. Sojourner shall be returned to her
Mother's custody no later than 2:00 p.m. on the Sunday prior to the
start of the 2011-2012 school year. If Father returns after the
school year has commenced but before October 15"', he shall be
entitled to up to two weeks of custody, but the fall custodial period
will be shortened to one week. If Father returns after October 15tH,
this custodial period shall replace the next scheduled fall, winter or
spring custodial period.
e. During the calendar months when Father does not have a custodial
period, Paternal Grandparents shall have the option to have one
weekend during each of those months at times to be agreed by
mother and Grandparents, but as early as 12:00 noon on Friday to
as late as 5:00 p.m. on Sunday. Grandparents shall propose
weekends they wish to exercise no less than sixty days in advance.
Grandparents shall be responsible for all travel and the costs of
same.
3. During Father's deployment, the following accommodations shall be made
to allow the child to spend time with Father's family:
a. The child will be with Father's wife, Martina Croom-Schoefberger,
as follows:
i. During the child's spring recess, from 2:00 p.m. on Sunday,
April 17, 2011 to 2:00 p.m. on Sunday, April 24, 2011; and
ii. From Sunday, June 19, 2011 at 2:00 p.m. to Sunday, June
26, 2011, the exchanges being at 2:00 p.m.
iii. The child shall not travel outside the United States during
these periods of custody.
b. Patemal Grandparents shall be entitled to one weekend during the
month of July at times to be agreed by Mother and Grandparents,
but as early as 12:00 noon on Friday and as late as 5:00 p.m. on
Sunday. If Father will not return from deployment by the end of
August, Grandparents shall also be entitled to one weekend during
the month of August. Grandparents shall be responsible for all
transportation, at their own expense, for these custodial periods.
Notice of the weekends selected shall be given to Mother no later
than May 1, 2011.
4. Father shall provide Mother the dates of his deployment and return as
soon as he receives them.
5. Unless otherwise set forth herein, all custodial exchanges shall occur in
Glen Allen, Virginia.
6. Each parent and any stepparent shall be entitled to daily contact with the
child. The parties will cooperate to schedule mutually convenient times for such
contact, which may occur by the non-custodial parent's choice of telephone or Skype.
7. The parties will engage in Intensive Co-Parenting Training with a mutually
agreed upon professional. All associated out-of-pocket expense will be shared equally
by the parties. The Co-Parenting Trainer must be able to conduct most meetings by
Skype, telephone or other long distance means.
8. The parties will appoint a mutually acceptable Parenting Coordinator
("PC"). All associated out-of-pocket expenses will be shared equally by the parties
unless otherwise allocated by the PC in accordance with the terms of his appointment.
The PC must be able to conduct most meetings by Skype, telephone or other long
distance means. The authority of the PC shall be governed by the terms of a separate
Order to be entered after consultation by counsel for the parties with the PC.
9. The parents will communicate with each other about routine and
exceptional child development matters on an at least weekly basis by procedures to be
developed by their Intensive Co-Parenting Trainer. The parties will cooperate to
schedule mutually convenient times for such contact. During Father's deployment, this
contact will occur as often as his schedule permits.
10. Neither parent shall engage in a course of conduct designed to alienate
the child from the other parent or the other parent's extended family. To the extent
possible, the parties will prevent third parties from engaging in such conduct.
11. Father with ensure that Sojourner understands and differentiates between
Mother and her stepmother, and the word "Mother" shall not be used to identify
stepmother. Mother and Father agree to behave cordially to members of the other's
family.
12. Should childcare be necessary, each parent shall exercise care in
responsibly choosing childcare providers. The telephone number and address of the
childcare provider shall be provided to the other parent in advance. Likewise, if the
child will be spending the night at a location other than a parent's primary residence, the
address and telephone number shall be provided to the other parent, in advance.
13. When possible, both parties will notify the other of a pending relocation of
more than fifty (50) miles from their present residence within ninety (90) days of the
move. The ninety-day notice is designed to afford the parents an opportunity to
renegotiate the custodial arrangements or to have the matter listed for a Court hearing.
If the military provides Father with less than ninety days' notice of relocation, said notice
shall be provided to Mother upon receipt.
14. The child's passport shall be held by the parent having physical custody of
the child.
?Nichole M. Staley O'Gorman, Esquire
For the Plaintiff
`Carol Lindsay, Esquire
For the Defendant
abed
OI'?
BY THE COURT,
VERIFICATION
I, Marylou Matas, Esquire, attorney for Petitioner, Paul L. Croom, II, verify that the
statements made in the foregoing Petition for Special Relief are true and correct and certify
that I am authorized to do so, and that the persons' having knowledge of matters alleged in
this pleadings are outside the jurisdiction of the Court and their Verification cannot be obtained
within the time allowed for filing the pleading. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to
authorities.
Ile-
ai)?tas-, E ire for Petitioner
Date: ?/ ?
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
CERTIFICATE OF SERVICE
On this f? day of July 2011, I, Marylou Matas, Esquire, of the law firm of
SAIDIS, SULLIVAN & ROGERS hereby certify that on this date a copy of the attached
document was served on the following individuals, via first class mail and facsimile and email,
postage prepaid, addressed as follows:
Nichole M. Staley O'Gorman, Esquire
1820 Linglestown Road
Harrisburg, PA 17110
Fax: (717) 236-9779
SAIDIS, SULLIVAN & ROGERS
k-
Mar?oa*s, Eiqu)i-e'-
Supreme'GGuh ID No. 84919
26 West High Street
Carlisle, PA 17013
717-243-6222
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
E
I' PRA HONG
TAR Y
Nichole M. Staley O'Gorman, Esquire
ID #79866
1820 Linglestown Road
Harrisburg, PA 17110
(717) 236-9777
nogorman@staleyogormanlaw.com
?v I I XX t I AN 11: t B
rUpFNNSY?UVCOUNTY
N!A
SARA E. THUMA-CROOM,
n/k/a SARA E. THUMA,
Plaintiff
V.
PAUL L. CROOK II,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 2008-1593 CIVIL TERM
CIVIL ACTION - CUSTODY
RESPONSE TO DEFENDANT'S PETITION FOR SPECIAL RELIEF
AND NOW, comes Plaintiff, Sara E. Thuma, by and through her attorney,
Nichole M. Staley O'Gorman, and files the following response to Defendant's Petition:
1. Admitted.
2. Denied. The most recent Court Order is dated January 5, 2011. In
further response, most of this Order, including the provisions for custody during the
summer of 2011, was based on an agreement of the parties reached after a partial
hearing on a Mother's petition to modify custody.
3. Admitted in part. Based upon the representations of counsel for
Petitioner, it is believed that Father has returned from Afghanistan and will be
reassigned to Okinawa, Japan at the end of August. However, counsel advised that he
returned on July 3, 2011.
4. Denied. At the time the parties were negotiating the terms of the current
Order, Father represented that he might return from Afghanistan in early August. The
2011 summer custody schedule was negotiated on this basis.
5. Denied. Paragraph 2(d) addresses custody for the summer of 2011 and
provides that Father is to have two weeks following his return from deployment in
August.
6. Denied. The Court's Order speaks for itself. The quoted provisions
represent only a portion of the Order.
7. Denied. When negotiation the 2011 summer custody schedule, there was
never a presumption that the two weeks agreed upon would be the only two weeks
Father would be home.
8. Denied upon information and belief. Petitioner's counsel reported that
Father was returning home on July 3, 2011. Mother has been given various departure
dates, ranging from August 17th to August 24th. Despite that Father will be relocating
from North Carolina to Japan, he will still be able to exercise custody pursuant to the
terms of the January 5, 2011 Order.
9. Admitted. Based on discussions between the parties and counsel,
Mother traveled to her brother's home in Centerville, Virginia on July 2, 2011 so that
Father's wife could pick up Sojourner the following day in Glen Allen, Virginia.
However, Petitioner's wife then inexplicably refused to meet Mother for the exchange.
After being told that she was going to see her Father, the child missed his homecoming.
10. It is admitted that Father has requested custody for the remainder of the
summer despite that no portion of the Order affords him more than four consecutive
weeks of custody. At trial, Dr. Arnold Stolberg testified that it was best for summer
custody periods not to exceed three weeks at a time. The four week periods were not
to begin until the summer of 2012 when the child would be 5 % years old. It is denied
that Father's move to Japan is at all relevant. Whether he is in North Carolina or
Japan, it is feasible for him to exercise custody pursuant to the terms of the existing
Custody Order.
11. There is no reasonable basis upon which Petitioner could assert that
Paragraph 2(c)(iv) gives him eight weeks of custody during the summer of 2011.
Paragraph 2(d) of the Court Order provides for custody during the summer of 2011.
12. Denied. Respondent's response to Paragraph 11 is incorporated by
reference. In further response, the child would have been in Father's custody but for
his wife's refusal to pick her up on July 2, 2011.
13. Denied. On the basis of the existing Court Order, Mother, Sojourner and
several members of Mother's family made plans for a short family vacation in
Connecticut. This vacation was scheduled to occur on July 7th-13th. Provided that
Father was willing to accommodate Mother's existing vacation plans, Mother has at all
times been willing to expand Father's 2011 summer custodial period in light of his early
return.
14. Admitted. Respondent works as a part time housekeeper at a local bed
and breakfast, and the child is cared for by her maternal grandmother during those
periods of time.
15. Denied. The child is enrolled in a few weeks of camp at The Londonderry
School, and Father was notified by email on April 27th. While Respondent's Mother is a
school teacher and is providing care for Sojourner this summer, she is not "available
each day to provide care, transportation and other services for the child and
Respondent."
16. Admitted. In further response, the parties agreed to forgo this period of
custody so that Father could have an extra week of custody upon his return. It is also
believed that Father's wife did not want to exercise this period of custody in view of the
travel required for the exchange.
17. Admitted.
18. Admitted. In further response, Respondent remains willing to allow
Petitioner to have this extra week of custody during the remainder of the summer.
19. Admitted upon information provided by Petitioner's counsel.
20. Denied. Pursuant to an email from Father dated June 30t", attached
hereto as Exhibit "A", no flight has been booked. In further response, Father made his
travel plans without consulting with Mother. She has always been willing to
accommodate his trip to Austria provided that he accommodates her family vacation to
Connecticut.
21. Denied as stated. Respondent made vacation plans some time ago in
reliance on the January 2011 Court Order. Inasmuch as several families are taking this
trip, and taking time off work to do it, she is not able to unilaterally change the dates.
This is the only summer vacation she will be taking with the child, and because of the
uncertainty surrounding Father's return date, the trip ended up being shortened to July
8-12.
22. Denied as stated. To the extent that the averment implies that Mother
does not actually have vacation plans, it is specifically denied. Mother respects that the
Court Order provides Father with two weeks of vacation time in the summer of 2011
upon his return from Afghanistan. Coupled with the week his wife agreed to forgo in
June, the offer of July 2-23, 2011 represented three weeks of vacation time. In further
response, Mother offered additional time to Father if he would agree to allow her to take
her scheduled family vacation.
23. Denied as stated. Mother agreed to travel to Virginia to conduct a July 2nd
exchange. Even though no return date was agreed upon, Mother's counsel spoke to
Father's counsel at 3:30 p.m. on Friday, July 1St and advised that Mother would begin
traveling to Virginia that evening for the exchange. Later that evening, Father's wife
called and advised that she would not meet her. It is presumed that the balance of
Petitioner's averment refers to an offer he made on July 1St which required Mother to
travel to Dulles International Airport on Thursday, July 14, 2011. Because of her work
commitments, she is unable to conduct a mid-week, midday exchange. She offered to
conduct an exchange on Saturday, July 16, 2011, as the flights Petitioner would need
to and from Austria were available. However, Petitioner refuses to entertain a July 16,
2011 exchange simply because it is two days later.
24. Denied. This averment is a gross distortion of the truth. Provided that
Petitioner would accommodate Mother's vacation, Mother has at all times offered to
permit Father to have additional time during the summer in view of his early return.
However, Father has refused to do this unless Mother takes additional time off work to
conduct mid-week exchanges.
25. Admitted on information and belief.
26. Denied. Father would already have custodial time with his daughter but
for his wife's refusal to pick her up. Mother has at all times attempted to negotiate
reasonable terms for custody this summer.
27. Admitted. In further response, Mother's counsel has advised that she will
be out of the office from July 9-July 16, 2011 and has strongly encouraged meaningful
negotiation of a custody schedule prior to her departure. Instead, Father continues to
stubbornly insist on a July 14th exchange that Mother cannot accommodate.
WHEREFORE, Respondent respectfully requests this Honorable Court to deny
the relief requested.
Date: ql?) I I
B
N ole M. St or n, Esquire
1 #79866
1820 Linglestown Road
Harrisburg, PA 17110
(717) 236-9777
nogorman@staleyogormanlaw.com
Counsel for Respondent
VERIFICATION
I, Nichole M. Staley O'Gorman, Esquire, hereby verify that the facts
contained in the foregoing document are true and correct to the best of my
knowledge, information and belief based upon the information provided to me by my
client, Sara Thuma, who is presently not available to provide her own verification
prior to the filing of this document.
I understand that false statements made herein are subject to the penalties of
18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
of
Date:
---------- Forwarded message ----------
From: Paul Croom <paul.croom.iina gmail com>
Date: Thu, Jun 30, 2011 at 10:37 PM
Subject: Re: Austria trip
To: Sara Thuma Croom <sara.thumacroomna gmail com>
Cc: Martina Croom-Schoefberger <martina.croomschoefberg_erggmail com>
Sara,
We don't have a flight itinerary, because we still have not, to my
knowledge, agreed on a custody arrangement for this summer. I'm more
than happy to work through things between us (without the lawyers).
Actually, I would prefer to do so. Please let me know your desires and
concerns, and we can work through a best solution for all of us.
Thanks.
Pi
On 7/1/11, Sara Thuma Croom <sara.thumacroom(cr?gmail.com> wrote:
> Hi,
> Please send Sojourner's flight itinerary and the address(es) of where she
> will be staying along with phone numbers.
> Thanks,
> Sara
CERTIFICATE OF SERVICE
I, Allison Gossett, Legal Assistant to Nichole M. Staley O'Gorman, Esquire,
hereby certify that a true and correct copy of the foregoing Response to Defendant's
Petition for Special Relief was served upon Petitioner's counsel, Marylou Matas,
Esquire, by sending a copy of the same via first-class U.S. mail to:
Marylou Matas, Esquire
Saidis, Sullivan & Rogers
26 West High Street
Carlisle, PA 17013
?l/LirV V , /
Allison Gossett
Legal Assistant
Date: 11 ?/I 11
SARA E. THUMA-CROOM, IN THE COURT OF COMMON PLEAS OFc ,,
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Plaintiff CUMBERLAND COUNTY, PENNSYLVAVA ° _i
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VS. CIVIL ACTION - LAW xm -n
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NO. 08-1593 CIVIL r
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PAUL L. CROOM, II, =-n
Defendant IN CUSTODY =C:> C)
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IN RE: PETITION FOR SPECIAL RELIEF -
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ORDER
AND NOW, this day of July, 2011, following review of the within petition for
special relief and the response filed thereto, and following conference call with counsel, it is
directed that the mother, Sara E. Thuma-Croom, will transport the child, Sojourner Q. Croom,
born December 6, 2006, to the Dulles Airport area during the late afternoon/early evening of July
13, 2011, so that the child may commence a period of partial custody in the father, Paul L.
Croom, II. The father shall have custody of Sojourner until August 20, 2011, on which date
custody shall be transferred to the mother.
'Nicole Staley-O'Gorman, Esquire
For the Plaintiff
Marylou Matas, Esquire
For the Defendant
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BY THE COURT,
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SARA E. THUMA-CROOM, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVAOR '-'n
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V. CIVIL ACTION - LAW F N
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NO. 08-1593 °
PAUL L. CROOM, II, ?o i C)-q
Defendant IN CUSTODY y.c tv o
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PRAECIPE TO WITHDRAW APPEARANCE
TO THE PROTHONOTARY:
Please withdraw my appearance as counsel of record for the Defendant, Paul L. Croom,
SAIDIS, SULLIVAN & ROGERS
hlx,,? , It?a/a
Maryltfu Ia s, Esquire
Supreme Court ID No. 84919
26 West High Street
Carlisle, PA 17013
717-243-6222
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Plaintiff, Paul L. Croom, II, in the above
captioned case.
Paul L. Croom, Il, pro se
Dated: 2 2 A-u 6- 2-o i
CERTIFICATE OF SERVICE
I hereby certify that on this day of , 2011, a true and correct copy
of the foregoing document was served upon the party listed below, via First Class Mail, postage
prepaid, addressed as follows:
Nichole M. Staley O'Gorman, Esquire
1820 Linglestown Road
Harrisburg, PA 17110
Fax: (717) 236-9779
SAIDIS, SULLIVAN & ROGERS
,--x la,?tx L V aje?2
Ma s, Esquire
Supreme ourt ID No. 84919
26 West High Street
Carlisle, PA 17013
717-243-6222
Nichole M. Staley O'Gorman, Esquire
ID #79866
1820 Linglestown Road
Harrisburg, PA 17110
(717) 236-9777
nogorman@staleyogormanlaw.com
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ACT
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SARA E. THUMA-CROOM n/k/a
SARA E. THUMA,
Plaintiff
PAUL L. CROOM, II,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: No. 2008-1593
CIVIL ACTION - LAW
IN CHILD CUSTODY
MOTION FOR ENTRY OF ORDER OF COURT
AND NOW, comes Plaintiff, Sara E. Thuma, by and through her attorney, Nichole
M. Staley O'Gorman, Esquire, and submits the following Motion for Entry of Order of
Court:
1. Movant is Sara E. Thuma, Plaintiff in the above captioned child custody
action (hereinafter "Mother").
2. Respondent is Paul L. Croom, II, Defendant in the above captioned child
custody action (hereinaftelr "Father").
3. The parties are the parents of one minor child; Sojourner Q. Croom (DOB
12/6/06).
4. Pursuant to the Order of Court dated January 5, 2011, the parties were to
select a mutually acceptable Parenting Coordinator. A true and correct copy of the
Order of Court dated January 5, 2011 is attached hereto, made a part hereof and
marked "Exhibit A".
5. Pursuant to this Order, the parties have selected Melissa P. Greevy,
Esquire as their Parenting Coordinator and have memorialized their selection in the
attached stipulation appearing in the proposed order.
6. Defendant is unrepresented and concurs in this Motion.
7. The Honorable Kevin A. Hess has previously ruled in this matter.
WHEREFORE, Mbvant respectfully requests this Honorable Court to enter the
attached stipulation as an Order of Court.
Date: By^??1
Nichole M. St ey 'G an, Esquire
1 20 Linglestown Road
Harrisburg, PA 17110
717 236-9777
nogorman(&-staleyogormanlaw.com
Attorney for Plaintiff
?I
it
(13
SARA E. THUMA-CROOM n/k/a, : IN THE COURT OF COMMON PLEAS OF
SARA E. THUMA, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. :NO. 2008-1593 CIVIL TERM
PAUL L. CROOK II,
Defendant : CIVIL ACTION - CUSTODY
ORDER OF COURT
AND NOW, this day of 2011, with regard to
the minor child SOJOURNtR Q. CROOM (DOB 12/6/06), it is hereby ORDERED AND
DECREED as follows:
Legal Custodly: The parties will share legal custody. Major decisions
concerning the child, including, but not necessarily limited to, issues related to health,
welfare, education, religious training and upbringing shall be made by the parties jointly,
after discussion and consultation with each other, with a view toward obtaining and
following a harmonious policy in the child's best interest. Neither party shall permit
these decisions to be made by third parties. Each party agrees not to impair the other
party's rights to shared legal custody of the child. Each party shall notify the other of
any activity or circumstance concerning their child that could reasonably be expected to
be of concern to the other. Day to day decisions shall be the responsibility of the parent
then having physical custody. With regard to any emergency decisions which must be
made, the parent having physical custody of the child at the time of the emergency shall
be permitted to make any immediate decision necessitated thereby. However, that
parent shall inform the othe? of the emergency and consult with him or her as soon as
III'i
possible. In accordance with 23 Pa. C.S.A. § 5309, each party shall be entitled to
complete and full information from any doctor, dentist, teacher, professional or authority
and to have copies of any',reports or information given to either party as a parent as
authorized by statute. If early enrollment in kindergarten is contemplated, the parties
will make such a decision jointly.
2. Physical Cugtody:
a. Mother shall have primary physical custody of Sojourner.
b. Until February 20, 2011 or the date of Father's deployment,
whichever comes first, Father shall have periods of partial custody
as follows:
For Father's pre-deployment leave from Saturday,
January 1, 2011, at 11:00 a.m. until Sunday, January 16,
2011, at noon. On January 1, 2011, Father will pick up
Sojourner in Harrisburg at a location of Mother's choosing.
On January 16, 2011, the exchange will be at the Glen
Allen, Virginia exchange location currently in use by the
(parties.
ii. From Sunday, February 6, 2011, until Sunday, February 20,
2011, exchanges will occur at noon at the Richmond,
Virginia exchange location currently in use by the parties.
iii. ? he child shall be returned to Mother on the day following
I
?I
?I
Father's deployment. If Father is deployed after February
20th, the parties will see to it that Sojourner is in Father's
custody for a period commencing two days before
deployment and ending the day after deployment when she
will be returned to Mother. If the exchange date occurs on a
week day, Father, his wife or his parents will be responsible
for all transportation.
C. Following Father's return from deployment, he shall have periods of
partial' custody as follows:
Fall: One two-week period each fall beginning at 2:00 p.m.
on the Sunday prior to Thanksgiving and ending on Sunday
at 2:00 p.m. two weeks thereafter. After Sojourner begins
kindergarten, and only in the event school attendance policy
will allow it, the custodial period shall be a one-week period
,and extend from 2:00 p.m. on the Sunday prior to
Thanksgiving break and end on the Sunday following
Thanksgiving break at 2:00 p.m.
inter: For 2011, Father shall have the child from
December 24th at 2:00 p.m. until January 1St at 2:00 p.m.
Thereafter, Father's custodial period shall begin at an
agreed time following the close of school which reasonably
allows for travel and end at 2:00 p.m. on December 30tH
iii. S 'nn : One two-week period each spring beginning at 2:00
p.m. on the Sunday prior to Easter and ending on Sunday at
2:00 p.m. two weeks thereafter. After Sojourner begins
kindergarten, and only in the event school attendance policy
will allow it, this custodial period shall be a one-week period
commencing the Sunday prior to the first day of spring break
and ending on the following Sunday at 2:00 p.m.
iv. Summer:
(a) For most of the summer of 2011, Father will be
deployed to Afghanistan.
(b) In 2012, and in following years, Father shall have
custody of the child for eight weeks during the
summer to be taken in four-week blocks
separated by a week in which custody will be with
Mother. The first four-week block will commence
the second Sunday after the last day of school.
Custody of the child shall return to Mother at least
three days prior to the beginning of the school
year, or on the Sunday at the end of the second
four-week block, whichever comes first.
d. Follo ing Father's anticipated return from deployment in August,
2011, Father's family shall be entitled to pick up Sojourner one day
prior tb his return from deployment, and Father shall have custody
for up to two weeks thereafter. Sojourner shall be returned to her
Mother's custody no later than 2:00 p.m. on the Sunday prior to the
start of the 2011-2012 school year. If Father returns after the
schoolI year has commenced but before October 15th, he shall be
entitled to up to two weeks of custody, but the fall custodial period
will be shortened to one week. If Father returns after October 15th
this custodial period shall replace the next scheduled fall, winter or
spring] custodial period.
e. During the calendar months when Father does not have a custodial
period, Paternal Grandparents shall have the option to have one
weekend during each of those months at times to be agreed by
mother and Grandparents, but as early as 12:00 noon on Friday to
as late as 5:00 p.m. on Sunday. Grandparents shall propose
week Ilnds they wish to exercise no less than sixty days in advance.
Grandparents shall be responsible for all travel and the costs of
same.)
3. During Father's deployment, the following accommodations shall be made
to allow the child to spend time with Father's family:
a. The child will be with Father's wife, Martina Croom-Schoefberger,
as follows:
During the child's spring recess, from 2:00 p.m. on Sunday,
April 17,2011 to 2:00 p.m. on Sunday, April 24, 2011; and
From Sunday, June 19, 2011 at 2:00 p.m. to Sunday, June
26, 2011, the exchanges being at 2:00 p.m.
iii. The child shall not travel outside the United States during
these periods of custody.
b. Paternal Grandparents shall be entitled to one weekend during the
months of July at times to be agreed by Mother and Grandparents,
but as early as 12:00 noon on Friday and as late as 5:00 p.m. on
Sunday. If Father will not return from deployment by the end of
August, Grandparents shall also be entitled to one weekend during
the month of August. Grandparents shall be responsible for all
transportation, at their own expense, for these custodial periods.
Noticd of the weekends selected shall be given to Mother no later
than May 1, 2011.
4. Father shall provide Mother the dates of his deployment and return as
soon as he receives them.
lll
5. Unless otherwise set forth herein, all custodial exchanges shall occur in
Glen Allen, Virginia.
6. Each parent and any stepparent shall be entitled to daily contact with the
child. The parties will cooperate to schedule mutually convenient times for such
l
contact, which may occur y the non-custodial parent's choice of telephone or Skype.
7. The parties Will engage in Intensive Co-Parenting Training with a mutually
agreed upon professionals All associated out-of-pocket expense will be shared equally
by the parties. The Co-Parenting Trainer must be able to conduct most meetings by
Skype, telephone or other) long distance means.
8. The parties will appoint a mutually acceptable Parenting Coordinator
("PC"). All associated out+of-pocket expenses will be shared equally by the parties
unless otherwise allocated by the PC in accordance with the terms of his appointment.
The PC must be able to conduct most meetings by Skype, telephone or other long
distance means. The authority of the PC shall be governed by the terms of a separate
Order to be entered after consultation by counsel for the parties with the PC.
9. The parents will communicate with each other about routine and
exceptional child development matters on an at least weekly basis by procedures to be
developed by their Intensive Co-Parenting Trainer. The parties will cooperate to
schedule mutually convenient times for such contact. During Father's deployment, this
contact will occur as often as his schedule permits.
10. Neither parent shall engage in a course of conduct designed to alienate
the child from the other pa I?ent or the other parent's extended family. To the extent
possible, the parties will prevent third parties from engaging in such conduct.
11. Father with ehsure that Sojourner understands and differentiates between
Mother and her stepmother, and the word "Mother" shall not be used to identify
stepmother. Mother and F ther agree to behave cordially to members of the other's
family.
12. Should childcare be necessary, each parent shall exercise care in
responsibly choosing childcare providers. The telephone number and address of the
childcare provider shall bej provided to the other parent in advance. Likewise, if the
child will be spending the night at a location other than a parent's primary residence, the
address and telephone number shall be provided to the other parent, in advance.
13. When possible, both parties will notify the other of a pending relocation of
,I
more than fifty (50) miles from their present residence within ninety (90) days of the
move. The ninety-day notice is designed to afford the parents an opportunity to
renegotiate the custodial arrangements or to have the matter listed for a Court hearing.
If the military provides Father with less than ninety days' notice of relocation, said notice
shall be provided to Mother upon receipt.
14. The child's passport shall be held by the parent having physical custody of
the child.
BY THE COURT,
Kevin A. ess, P.J.
Nichole M. Staley O'Gorman, Esquire TRUE COPY FROM RECORD
For the Plaintiff in Testimony whwed, I hero unto sst my hand
and the seal of said courl at Comft, ft
This ??N` of ,, In h
ZO.U---
Carol Lindsay, Esquire 810"0"
For the Defendant
CERTIFICATE OF SERVICE
I, Allison C. Gossett, Legal Assistant to Nichole M. Staley O'Gorman, hereby
certify that a true and corf rect copy of the foregoing document was served upon the
Defendant, by sending a (,copy of the same via first class U.S. Mail and email to:
Paul L. Croom, II (via email)
Paul. Croom.I14-gmail.com
Paul.Croom(c-usmc.mil
Melissa P. Greevy, Esquire
301 Market Street
Lemoyne, PA 17043
Allison C. Gossett, Legal Assistant to
Nichole M. Staley O'Gorman, Esquire
I.D. No. 79866
DATE: l
SARA E. THUMA-CROOM n/k/a
SARA E. THUMA,
Plaintiff
V.
PAUL L. CROOM, II,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2008-1593 CIVIL TERM
CIVIL ACTION - CUSTODY
ORDER FOR PARENTING COORDINATION
AND NOW, the Court finding that it is in the best interest of the child,
SOJOURNER Q. CROOM (DOB 12/6/06), that a Parenting Coordinator be appointed to
assist the parties in implementing the custodial arrangement set forth in the Custody
Order dated January 5, 2011 and in resolving related parenting issues, the following
Stipulated Order is entered:
1. APPOINTMENT AND TERM:
MELISSA P. GREEVY, EQUIRE is appointed as the Parties' Parenting
Coordinator for a term of twelve months, or until the resignation of the Parenting
Coordinator or termination of the appointment by the Court, whichever first occurs. The
Court shall have authority to sanction a party for non-compliance with the Parenting
Coordinator's Terms of Engagement.
Legal counsel for Plaintiff shall provide copies of all Orders, Pleadings and
Custody Evaluations in this case to the Parenting Coordinator within ten (10) days of the
date hereof.
2. ROLE OF THE PARENTING COORDINATOR:
A. Parenting Coordination involves two components:
1) The Parenting Coordinator shall attempt to resolve issues arising
out of the custody order through facilitation, mediation and consultation, all of which are
non-decision-making functions;
2) If it is apparent to the Parenting Coordinator that continued similar
efforts are unlikely to resolve the issue(s), the Parenting Coordinator shall have the
authority to resolve the dispute by providing a Decision for the parties on the issue(s).
B. The Parenting Coordinator will not function as the psychotherapist,
counselor, attorney or advocate for the parties, or the parties' child, or family. However,
the Parenting Coordinator is permitted and encouraged to facilitate communication and
agreement between the parties whenever possible, and shall always act in a manner
conducive to the best interests of the child.
3. PARENTING COORDINATOR'S AUTHORITY:
The Parenting Coordinator, in order to implement the custodial arrangement set
forth in the Custody Order and resolve related parenting issues about which they do not
agree, is authorized to make decisions about issues that may include, but are not limited
to, the following:
A. Dates, times, places and conditions for transitions between households;
B. Temporary variation from the schedule for a special event or particular
circumstance;
C. Minor adjustments to the physical custody schedule as set forth in the
current Custody Order;
D. School issues, apart from school selection;
E. Child's participation in recreation, enrichment, and extracurricular
activities, programs and travel;
F. Child-care arrangements;
G. Clothing, equipment, toys and personal possessions of the child;
H. Behavioral management of the child;
1. Information exchange (school, health, social, etc.) and communication
with or about the child;
J. Coordination of existing or court-related services for either of the parties
or child (e.g. Psychological testing, alcohol or drug monitoring/testing, psychotherapy,
anger management, parenting class, etc.). This shall include the selection of a co-
parenting counselor;
K. Coordination of the child's non-emergency medical evaluations and
treatment;
L. Other related custody issues that the parties mutually agree, in writing, to
submit to their Parenting Coordinator.
4. EXCLUSIONS FROM PARENTING COORDINATOR'S AUTHORITY:
A. The following specific issues are excluded from the Parenting
Coordinator's function and decision-making authority, except as provided in
subparagraph (B) herein below:
1) A change in legal custody decision-making authority set forth in
the Custody Order;
2) A change in primary physical custody (residential parenting time)
set forth in the Custody Order;
3) A change in the Court-ordered custody schedule (parenting time)
that substantially reduces or expands the child's time with one or both parties;
4) A change in the geographic residence of the child (relocation) that
would render implementation of the current Custody Order impossible or impracticable;
5) Determination of financial issues, other than allocation of the
Parenting Coordinator's fees;
B. The parties may mutually agree in writing to submit any of the
excluded issues set forth above to the Parenting Coordinator for facilitation and
recommendation. The parties shall also have the option to agree, at the time an
excluded issue is submitted to the Parenting Coordinator, to allow the Parenting
Coordinator's decision to be binding upon them. If they have not made such an
agreement at the time the issue is submitted, the Parenting Coordinator's
recommendation shall only become binding upon subsequent written agreement
of the parties.
5. NON-CONFIDENTIALITY OF COMMUNICATIONS:
No communications of the parties and/or their lawyers with the Parenting
Coordinator are confidential. The Parenting Coordinator may communicate in writing
with the Court regarding any matter, and shall send contemporaneous copies of any
such communication to the parties and legal counsel.
6. SOURCES OF INFORMATION:
Each party shall provide the Parenting Coordinator with all information that the
Parenting Coordinator requests, including signed HIPPA releases and other forms
requested. The Parenting Coordinator is authorized to contact any professional or other
individual as the Parenting Coordinator deems necessary (e.g. the child, therapists,
physicians, childcare providers, teachers, family members, etc.).
7. COMMUNICATION WITH THE PARENTING COORDINATOR:
A. Protocol:
The Parenting Coordinator shall determine the protocol of all communications,
interviews, and sessions, including who shall or may attend the sessions (including the
child), and whether the sessions will be conducted in person or by other means. Where
domestic violence or abuse, as defined under 23 Pa. C.S. § 6102, is alleged, the
T_
protocols should include measures addressing the safety of all participants, unless the
Court deems the measures unnecessary.
B. Oral and Written Communications With The Parenting Coordinator:
The parties and their attorneys shall have the right to receive, but not to initiate,
oral ex-parte (one-sided) communications from the Parenting Coordinator, but the fact of
such communication shall be known to the other party. Any party or legal counsel may
communicate in writing with the Parenting Coordinator provided a copy is sent to the
other party simultaneously. Any documents, tape recordings or other material which one
party gives to the Parenting Coordinator must also be made available to the other party
or his/her legal counsel for inspection and copying. In accordance with paragraph 5
hereinabove, no such communications are confidential.
C. Written Communications Between the Parenting Coordinator and
Appointing Judge:
1) The Parenting Coordinator will have the ability to initiate written
communication with the Appointing Judge, and shall contemporaneously send copies to
both attorneys
(a) in the event of non-compliance of a party with any provision of
this Appointment Order (including provisions relating to the compensation of the
Parenting Coordinator); and /or
(b) detailing the Parenting Coordinator's reasons for withdrawing
from service in the case.
2) Absent an emergency affecting the child's health or welfare, any
communication from the Parenting Coordinator to the court shall be in writing, and shall
be copied simultaneously to the parties (or, if represented, counsel). If the Parenting
Coordinator has communicated orally with the Court on an emergency basis, the
Parenting Coordinator promptly shall communicate to the parties (or, if represented,
counsel) in writing the substance of the oral communication.
8. PARENTING COORDINATION DECISION-MAKING PROCESS:
A. Prior to the Parenting Coordinator making a Decision, the Parenting
Coordinator shall provide a notice and opportunity for each of the parties to be heard,
unless exigent circumstances render contact with both parties impracticable or
potentially dangerous to a party and/or the child. In the event a party is given advance
written notice of a session but does not attend, the Parenting Coordinator may make a
Decision despite that party's absence.
T
B. Decisions:
1) The Parenting Coordinator's Decisions may be communicated to
the parties orally, but must be confirmed in writing as soon as practicable and filed in the
Prothonotary's Office at the parties' above-captioned custody docket;
2) The Parenting Coordinator's Decisions shall be binding upon the
parties unless and until revised by Court Order.
9. JUDICIAL REVIEW:
A. Review of Decisions:
Any party seeking judicial review of a Parenting Coordinator's Decision must file
a Petition for a de novo hearing within 30 days of the filing of the Decision, specifically
stating the issue(s) and attaching a copy of the Decision. The Petition must be served
on the other party and Parenting Coordinator in accordance with the Rules of Civil
Procedure. The hearing before the Court shall be de novo. The Court shall hear the
case on the record, and shall render a decision within the time periods set forth in Rule
1915.4.
B. New Court Proceedings:
Prior to filing any new motion, petition or complaint with the Court involving non-
emergency custody or parenting of the child within the scope of the Parenting
Coordinator's authority, the parties shall participate in no fewer than two sessions with
the Parenting Coordinator to attempt resolution of the specific disputed issue(s) and to
permit a Decision to be made to the extent authorized by paragraph 3 hereinabove.
C. The procedures set forth in this Section 9 are mandatory, and may not be
waived by the parties.
10. QUASI-JUDICIAL IMMUNITY:
The Court-appointed Parenting Coordinator is an Officer of the Court, and has
quasi-judicial immunity, as such the Parenting Coordinator cannot be sued based on her
actions performed within the scope of this Custody Appointment Order.
11. CHILD ABUSE REPORTING:
The Parenting Coordinator is a person required to report suspected child abuse
pursuant to 23 Pa. C.S.A. §6311.
12. TESTIMONY:
The Parenting Coordinator cannot be compelled to testify in any proceeding
absent a Court Order. In the event the Parenting Coordinator elects or is required to
testify, she shall be compensated commensurate with her rate by one or both of the
parties as the Court deems appropriate.
13. ALLOCATION OF FEES:
The parties will share the obligation to pay the fees of the Parenting Coordinator:
50% Mother, 50% Father. Fees may be reallocated by the Court or the Parenting
Coordinator if he/she determines that one party has disproportionately caused the need
for the service. The Parenting Coordinator may, in her discretion, charge parties for
missed sessions or sessions cancelled less than twenty-four hours prior to the
scheduled session.
14. TERMINATION/WITHDRAWAL OF PARENTING COORDINATOR:
A. Neither party may unilaterally terminate the Parenting Coordinator's
services without Court approval, nor may the parties do so by mutual agreement without
Court approval.
B. The Parenting Coordinator may withdraw from service at any time, upon
ten days' written notice to the parties, all counsel of record, and the Court.
C. Dissatisfaction with the Parenting Coordinator's Decisions is not grounds
for termination. The opposing party and Parenting Coordinator shall be given notice of
any petition for termination. The Court may rule on the petition(s) submitted, or may
schedule argument or an evidentiary hearing.
15. ACCEPTANCE:
A. The parties acknowledge that each has reviewed this Agreement and had
the opportunity to consult with legal counsel.
B. Each party agrees to the appointment of Melissa P. Greevy, Esquire
as Parenting Coordinator, and agrees to fully cooperate with the Parenting Coordinator
in compliance with this Appointment Order.
16. This Order shall not be effective until accepted by the Parenting Coordinator as
evidenced by her signature below:
SIGNATU 5 ?
Moth
Date: 11 Z /?
Fath r
Date: 3 M" j/
T
Attorney for Father:
.1 f/ I
Date:
I agree to my appointment as the Pare ' g Coordinator for the parties as set
forth above.
i •2?l 1
Date Parenting Coordinator
ORDER
The above Agreement is entered as a Court Order.
SO ORDERED BY THE COURT:
70,
a13ate
Distribution:
? Nichole M. Staley O'Gorman, Esquire
Paul L. Croom, II, pro se
Melissa P. Greevy, Esquire
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20121KIR20 AM11:37
CUMBERLAND COUNTY
PENNSYLVANIA
SARA E. THUMA-CROOM
n/k/a SARA THUMA,
Plaintiff
V.
PAUL L. CROOM, II,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2008-1593 CIVIL TERM
: CIVIL ACTION - CUSTODY
DECISION
The undersigned Parenting Coordinator submits the following Decision after meeting
with the parties. The Parenting Coordination process initially involves efforts which mediated
agreements between the parents, prior to the Parenting Coordinator making decisions which are
limited in scope by this Court's Order of December 30, 2011. It is noted that the Order was
entered upon the consent of both parties. The parents reached agreements on the following
topics which the Parenting Coordinator recommends become binding additions to this Court's
Order of Custody dated January 5, 2011.
AGREEMENTS:
1. Father is presently stationed in Okinawa. Daily Skype contact will be 7:00 a.m.
(prevailing Harrisburg, Pennsylvania time) Monday through Thursday; 7:30 p.m. Fridays and
Saturdays (prevailing Harrisburg, Pennsylvania time); and 6:30 p.m. Sundays (prevailing
Harrisburg, Pennsylvania time).
2. Father will have custody in Pennsylvania from April 29, 2012 through May 6,
2012.
3. Father will have custody from December 23, 2012 through January 6, 2013. One
of these two weeks reflects the parties' agreement to move a week of Father's custody from the
fall, as provided in paragraph 2 (c) (i).
4. Allergy Testing. The parties agree that Mother will arrange for Sojourner to
have a consultation with an allergist.
NO.,2008-1593 CIVIL TERM
DECISIONS:
1. Father would like Sojourner to have her dental health monitored and cared for by
a pediatric dentist. Neither party indicated that there were any outstanding dental needs, other
than routine care at this time. Sojourner presently sees a general dental practitioner. Mother
reported that she inquired whether the general dentist recommended a pediatric dentist and was
told that referrals for pediatric dentists are generally made if the patient has extreme anxiety
about dental care or sedation is needed for dental procedures. Mother is comfortable with the
present arrangement for Sojourner's dental care.
Paragraph 3(K) grants the decision-making authority concerning the coordination of the
child's non-emergency medical evaluations and treatment. It is the decision of the Parenting
Coordinator that Sojourner's regular dental needs shall continue to be provided for by the
general dentist whom she should continue to see on a regular basis as per the dentist's
recommendation. Should special needs arise, this topic may be revisited.
2. Physical Custody Schedule. Since the entry of the Custody Order of January 5,
2011, substantial changes have occurred. Father is presently stationed in Okinawa, and will
likely remain there for two and one-half years. The present Order provides summer custodial
time for two (2) four-week segments with Father, with a one-week break in between for Mother.
The flight time between New York and Okinawa is approximately 24 to 30 hours. Both parties
are concerned with the amount of time Sojourner would spend on an airplane if she were to
travel to Okinawa. Father proposes to collapse nine weeks of the custodial time granted in the
present Order into one visit to occur in Japan. Key elements driving Father's concerns are:
A. Reduction of time for Sojourner to be with his family, if he is required to
use custodial time in the United States.
B. Father's loss of the ability to use leave time with his family in Okinawa if
it is necessary to use leave time in the United States to see Sojourner.
C. Minimizing the amount of lengthy airline flights that Sojourner will need to
experience in carrying out the custodial schedule.
D. Cost of the airline flights.
E. Father also notes that he believes that summer is the best opportunity for
Sojourner to spend time with his wife's daughter.
Both parties agree that the amount of time that Sojourner would miss from school to
adjust the custodial schedule is a concern around which they must both work.
Mother does not want to increase the amount of time that Sojourner is away from her by
expanding the summer schedule beyond the present four weeks per visit. Mother also is of the
opinion that Sojourner should not fly unaccompanied on a flight of this duration.
Because the present circumstances of the parties' geography constitutes a substantial
change from the conditions which existed at the time that the present Order was entered and
because the complexities of transportation and duration of flights are significant, the Parenting
Coordinator informed the parties at a session on March 1, 2012 that the request to modify the
custodial schedule is beyond the scope of the Parenting Coordinator's authority. It is the
NO.?2008-1593 CIVIL TERM
Parenting Coordinator's opinion that this matter should be dealt with by the Court, following a
Petition to Modify Custody, which will apparently be filed by Father. It is noted that Father will
be in Pennsylvania from April 29, 2012 through May 6, 2012. Accordingly, he has made it
known that his preference is that any hearing be scheduled during this time. It is also noted that
Father will be attending military instruction in San Diego, California from May 6, 2012 through
May 18, 2012. It is the Parenting Coordinator's recommendation that the parties be permitted to
bypass a return to Custody Conciliation before a hearing in scheduled in this matter.
3. Paragraph 11 of the January 5, 2011 Order. Mother would like to reopen
the topic of paragraph 11 of the current Order. Mother believes that the language contained in
this paragraph is not expansive enough to incorporate the concerns addressed in the Custody
Evaluation on this topic. She would like the Order amended to include other derivatives of
Mother. Father indicates that he is compliant with this paragraph. There is some debate as to
whether this paragraph was written by mutual agreement through the parties' counsel or was
selected by Judge Hess. However, because this topic was addressed in an Order that is more
than one year old, the Parenting Coordinator declines to modify this paragraph in the absence
of an agreement of the parties. Thus, this may be addressed at a future hearing which will be
scheduled to address the custodial schedule.
4. A copy of this Decision was provided to the parties via email before its transmittal
to the Court. It is the goal that by doing so the parties are treated equally with regard to the time
frames required by paragraph 9 (a) of the Order for Parenting Coordination.
BY THE COURT:
Kevin A. Hess, P. J.
Distribution:
Counsel for Plaintiff - Nichole Staley O'Gorman, Esquire, 1820 Linglestown Road, Harrisburg, PA 17110
Sara E. Thuma via email to: sara.thuma.croom@gmail.com
Paul L. Croom, 11, via email to: paul.croom.ll@gmail and paul.croom@usmc.mil
meussa reel vreevy, t=squire
Parenting Coordinator
SARA E. THUMA-CROOM
Plaintiff
vs.
PAUL L. CROOM, II
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2008-1593
CIVIL ACTION LAW
IN CUSTODY
Defendant
ORDER OF COURT
AND NOW, this .Z / _ day of !'n A r , 2012, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Orders of this Court shall continue in effect as modified by this Order.
2. The Father shall have partial physical custody of the Child, while he is stationed in Japan,
from June 16 through July 28, 2012 and from December 22, 2012 through January 26, 2013.
3. The Father shall be responsible for making arrangements for the Child's flights on which
she shall be accompanied by either the Father or a designated member of the Father's family and
paying all costs associated with the air travel. The Mother shall be responsible to transport the Child to
and from the airport designated by the Father, which shall be limited to John F. Kennedy International
Airport, Philadelphia International Airport or Washington-Dulles International Airport.
4. The Father shall be entitled to have additional periods of custody with the Child at any time
the Father travels to the Central Pennsylvania area, with the specific arrangements to be made by
agreement between the parties.
5. In the event the Father is deployed during a period of partial custody in Japan, the Father
shall be responsible to make the necessary arrangements for the Child's return trip to the United States
if it would be unsafe for the Child to remain at the Father's location. Otherwise, the Father shall
ensure that the Child is returned as planned and no later than the end of his regular custodial period.
6. The Father shall ensure that the Child does not refer to her stepmother as "mother" or any
other form of the word "mother" in English or another language.
7. The parties shall cooperate in attempting to establish partial custodial arrangements for the
Father after the end of the 2012-2013 school year by agreement. If the parties are unable to reach an
agreement, either party may file a petition with the Court based upon the circumstances of the Child
and the parties at the time.
8. 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,
Kevin A. Hiss J.
cc: ? Nichole M. Staley O'Gorman Esquire - Counsel
Paul L. Croom II - Father
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SARA E. THUMA-GROOM
Plaintiff
vs.
PAUL L. CROOM, II
Defendant
Prior Judge: Kevin A. Hess
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2008-1593 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Sojourner Q. Croom December 6, 2006 Mother
2. A custody conciliation conference was held on May 2, 2012, with the following individuals
in attendance: the Mother, Sara E. Thuma-Croom, with her counsel, Nichole M. Staley O'Gorman
Esquire, and the Father, Paul L. Croom II, who is not represented by counsel in this matter.
3. The Father filed this Petition to Modify the partial physical custody schedule due to his
current military placement in Japan. Several options for resolution were discussed at the conference
and the conciliator agreed to hold the matter open so that the Father and Mother could continue
working toward a plan which would be acceptable to both. Due to time constraints concerning the
Father's need to obtain plane tickets between the United States and Japan during the upcoming months,
the Mother's counsel and the Father forwarded emails of their ongoing negotiations to the conciliator.
4. Based on the positions of the parties as reflected in their emails and at the conciliation
conference, the conciliator recommends an Order in the form as attached which reflects an agreement
between the parties as to the basic format for partial custody over the next 12 months. The remaining
details related to minor differences in travel arrangements are the recommendations of the conciliator
based upon the overall circumstances and the parties' discussions. Due to the more immediate need to
confirm the schedule for the Child's upcoming flights to Japan, the parties' respective requests for
modification of the existing Order on non-travel related issues (specifically, the Father's request that
the Child be provided with tutoring in German while in the United States and the Mother's request that
the schedule for the paternal grandparents' weekend periods of custody be reduced), are not addressed
in the recommended Order. It should be noted that the parties' discussions at the conciliation
conference reflected a willingness to cooperate on both issues. It is anticipated that these issues will be
raised at the time the parties attempt to establish a partial custody schedule beyond the end of the 2012-
2013 school year, if not previously resolved by agreement.
gc) ?Ij
Date Dawn S. Sunday, Esquire
Custody Conciliator
SARA E. THUMA-CROOM, :IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. 08-1593
PAUL L. CROOM, II, rn o - -,
Defendant, Pro Se
IN CUSTODY z f-t- C-1 ?.
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PETITION FO R MODIFICATION OF CUSTODY
AND NOW, comes Defendant, Paul L. Croom II ("Father"), and petitions this
Honorable Court to modify custody due to changed circumstances for the following
reasons:
1. The parties hereto are the natural parents of Sojourner Q. Croom, born
December 6, 2006.
2. Father is a Captain in the United States Marine Corps [USMC]. In August 2011,
the Marine Corps transferred Father from Camp Lejeune, North Carolina toOkinawa,
Japan. Father is accompanied in Japan by his wife, their four-month-old daughter
andtwo-year old son, and his eight-year-old step-daughter. Father is not due for
Permanent Change of Station (PCS) orders until 2014.
3. On January 5, 2011, Mother was granted primary custody of Sojourner,
pursuant Father's deployment to Afghanistan in February 2011 and likely transfer to a
new, but yet unknown, duty station upon his return.A true and correct copy of the
January 5, 20110rder is attached hereto, and incorporated herein as Exhibit "A."
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4. Mother and Sojourner residewith Mother's parents in Harrisburg,
Pennsylvania.
5. Under the terms of the January 5, 2011 Order, Father is entitled to physical
custody of Sojourner for one (1) week in the fall, approximately one (1) week during
winter holidays, one (1) week during spring, and two (2) four-week periods during
summers.
6. As a result of Father's USMC assignment to Japan, Sojourner's best interests
necessitate modifying the January 5, 2011 Order concerning Father's physical custody
because:
a. Travel distance between Okinawa and Harrisburg is nearly 8,000 miles,
with a total travel time of in excess of 24 hours, rendering multiple trips between
locations unreasonably burdensome for Sojourner;
b. Father's two, four-week summer periods in Japan, separated by a one-
week period with Mother in Pennsylvania, would result in Sojourner
unreasonably traveling over 72 hours covering nearly 25,000 miles within a
single week;
c. The 13-hour (14-hour during Daylight Saving Time) time difference
between Harrisburg and Okinawa negatively impacts Sojourner's ability to
acclimate to the time difference and her ability to gain any reasonable level of
quality time or enjoyment during the four, one-week trips to either location;
d. Sojourner's inability to travel unaccompanied due to her age and
maturity render the costs of multiple one-week trips (i.e., two adult roundtrip
tickets per visit) exorbitant and impracticable.
7. On March 26, 2012, Father filed a Petition with the Court requesting that
Sojourner's custody periods with him, totaling eleven (11) weeks, be changed from five
(5) separate periods to two (2) periods comprising one uninterrupted period of nine (9)
weeks with Father during summers and one period of two (2) weeks during winter
break,the two-week winter custody period conditioned on Sojourner's school permitting
her to take an additional week offin conjunction with winter recess.
8. On May 21, 2012, in response to Father's modification petition, and upon the
recommendation of Dawn Sunday as court-appointed custody conciliator, the Court
ordered partial custody to Father for six (6) weeks in summer 2012 (June 16 through July
28) and five (5) weeks during the winter 2012-2013 (December 22, 2012 through
January 26, 2013), a total of eleven (11) weeks. The Court also ordered that Father be
entitled to additional periods of custody at any time he travels to the Central
Pennsylvania area. These adjustments reflected the necessity of determining a tenable
custody solution that appropriately considered the significant financial and logistical
implications of Japan-US travel, and Sojourner's age and academic requirements. The
Court Order further provided that either party may petition the Court for modification,
should Father and Mother fail to reach agreement regarding Father's physical custody
for periods beyond the end of the 2011-2012 school year. A true and correct copy of
the May 21, 20120rder is attached hereto and incorporated herein as Exhibit "B."
9. Despite efforts to the contrary, Father and Mother have been unable to reach
anagreement for Father's partial custody periodsfor summer 2013 and forward that
maximizes Sojourner's times and enjoyment with Father, Sojourner's three sibling and
step-mother, with all of whom Sojourner is close.
10. Father believes Sojourner's interests would best be served by condensing
the number of Father's physical custody periods from five (5), under the current Court
Order to one (1) summer period of nine (9) consecutive weeks and one (1) winter period
of (2) consecutive weeks, with physical custody exchanges occurring at a mutually
agreed upon location at or near Father's arrival and departure airport, unless the parties
mutually agree to a different location.
11. Resolution of these matters is financially time-critical for Father, aspricing
for trans-continental air travel continues to rise as the summer approaches.
WHEREFORE, Father requests that this Honorable Court modify its January 5,
2011 Order of Court, and order that:
1. A conciliation conference be scheduled for a date most immediate as
practical and permit Father to participate via telephone Skvpe or other electronic
means.
2. Should it be necessary, a hearing on the merits be scheduled on December
19, 20 or 21, 2012 to accommodate Father's presence In the United States to
accompany Soiourner to Japan for the winter custody period, so he may be physically
presgnt for the proceedings.
3. Father is entitled to physical custody periods as follows:
a. Nine (9) consecutive, uninterrupted weeks in summer 2013 and
forward, beginning the second Sunday after school's end;
b. Two (2) consecutive, uninterrupted weeks in conjunction with the
winter holiday period in 2012-2013 and following years, provided Sojourner's
school permits, schedule to be agreed upon between the parties.
c. Physical custody exchanges are to occur at a mutually agreed upon,
public location, near or at Father's arrival airport, including John F. Kennedy
International Airport, Newark-Liberty International Airport, Philadelphia
International Airport, Washington-Dulles International Airport, or Baltimore-
Washington International Airport.
00.14. e, r
Paul L. Croom II
Pro Se
(Addresses on following page)
Until 28 October-
Captain Paul L. Croom II
S-2/Intelligence
WTI 1-13 (LN#2101)
PO Box 99200
From 28 October on-
Captain Paul L. Croom II
PSC 557
Box 2871
FPO, AP 96379
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. §4904, relating to unsworn falsifications to authorities.
P-J f- - C.-
Paul L. Croom II
Date: October 9, 2012
CERTIFICATE OF SERVICE
On this 9th day of October 2012, I, Paul L. Croom II, acting Pro Se, hereby certify
that on this date a copy of the attached document was served on the following individuals,
via first class mail, postage prepaid, addressed as follows:
Nichole M. Staley O`Gorman, Esquire
1820 Linglestown Road
Harrisburg, PA 17110
(717) 236-9777
Vo..-I L . Z. 9-
Paul L. Croom II
Until 28 October-
Captain Paul L. Croom II
S-2/Intelligence
WTI 1-13 (LN#2101)
PO Box 99200
From 28 October on-
Captain Paul L. Croom II
PSC 557
Box 2871
FPO, AP 96379
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SARKE. THUMA-CROOM Mda, : IN THE COLNtT OF COMMON PLEAS OF
SARA' E. THUMA, : cLUBERLAND COUNTY, PENNSYLVANIA
Plaintff
v. : NO. 2008.1593 CIVIL TERM c
r.
PAUL L. CROON, it,
?r
Defendant : CIVIL ACTION - CUSTODY o
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AND NOW, this day of_____;?.?, , 2Q11, with
the minor chili SOJOURNER CL CROON (DOB 12MM), it Is hereby ORDERED AND
DECREED as follows:
L" Ct?Eodv: The pumas will shore legal ctatody. M8W decisions
concerning the child, intruding, but not necessarily knifed to, issues r+ssate d to health,
welfare, education, religious training and upbrirov shelf be nude by the penes jointly,
alt udiscussion and consultation with each other, with a view toward obtai " and
follotiwing a harmonious policy in to child's best Interest. NWW party shall psmnit
these decisions to be made by third parties. Each party agrees not to Impair the odw
party's rights to shared legal custody of the child. Each party shat notify the other of
any activity or circumstance concerMng their child that oodd reasonably be expected to
be of concern to the other. Day to day decisions shall be the responsibility of the parent
then having physics! custody. With regard to any emergency decisions which must be
made, the parent having physical custody of the child at the time of the emergency shell
be permitted to make any immediate decision necessitated thereby. However, that
parent shall inform the other of the emergency and consult with him or her as soon as
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Father's deployment. if FLOW Is deployed February
2&, the parties will see to it that Sojourner Is In Father's
custody for a period conrrrrerr 'two days befb/e
deployment and erx" the day aflar d" yrnsrrt when she
will be returned to Mother. If the exal mge dale occurs on a
week day, Father, his wMe or his parents will be MWW*ibb
for all traon.
C. Following Father's return from deployment, he shall have periods of
partial custody as follows:
L EM: One two4awk period each fill beginning at 2:00 p.m.
on the Sunday prior to Thanksgiving and ending on Sunday
at 2:00 P.M. two weeks ti'r edW. After Sojourner begins
kindergarten, and only In the event schod all endence poky
vAN allow it, the custodial period shall be a onemeek period
and extend from 2:00 p.m. on the Sunday prior to
Thanksgiving break and and on the Sunday following
Thanksgiving break at 2:00 p.m.
H. For 2011, Father shall have the Child from
December 241" at 2:00 p.m. until January Id at 2:00 p.m.
Thereafter, Father's custodial period shah begin at an
agreed time Mowing the dose of school which reasonably
allows for travel and end at 2:00 p.m. on December 30.
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prior to his return from daployment, and Father shall how custody
for up to two weeks thensetNr. Sojourner shah be returned to her
MoRher's custody no later than 2:00 p.m. on the Sundry prior to the
start of the 2011-2012 school year. If Father returns after the
school year has oorrammad but batons Octatm I e, he shall be
entitled to up to two weeks of custody, but the fall custodial period
will be shortened to one week. If Father returns after October 15th,
this custodial period shall replace the neat sdwxkAsd fall, winter or
spring custodial period.
e, During the calendar months when Father does not have a custodial
period, Paternal Grarndparerds shall have the option to have one
weekend during each of those months at times to be agreed by
mother and Grandparents, but as early as 12:00 noon on Friday to
as late as 5:00 p.m. on Sunday. Grandpeesrnts shall propose
weekends they wish to sxsrel a no less than sixty deya in advance.
Grandparerds shall be responsible for all travel and the costs of
same.
I During Father's deployment, the following acoommodatbrhs shah be made
to allow the child to spend time with Father's family:
a. The chill will be with Father's wits, Mw*w Cmom4 *xwnwpsr,
as follows:
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7. The parties wt8 engage in Intensive Co-Parorilrq Training with a mutually
agreed upon professional. AN associated out-o lxx*et expense will be shared equally
by the panties. The Co-Parenting Trainer must be slob to conduct most meetings by
Skype, telephone or other long distance means.
8. The parties wiN appoint a mutually aoospW* Pwwft g Coordinator
("PC"). All associated out-af-podost ewes WIN be shared egtX* by the parties
unless otherwise allocated by the PC In accordance with the terns of his appoinbra t.
The PC must be able to conduct most meetings by 3kype, telephone or other long
distance means. The authority of the PC shall be governed by the farms of a separate
Order to be entered after consultation by counsel for the pattbs with the PC.
9. The parents will communicate with each other about nx*m and
exceptional child development mettem on an at bast weeldy basis by procedures to be
developed by their Intensive Co-Parenting Trainer. The parties will cooperate to
schedule mutually convenient times for such contact. During Father's deployment, this
contact will occur as often as his schedule permits.
10. Neither parent shall engage in a course of oonduct designed to alienate
the child from the other parent or the other parent's extended family. To the extent
posslbb, the parties will prevent third parties from engaging In such conduct.
11. Father with ensure that Sojourner understands and dlflbrerrliebse beN2ween
Mother and her slepmother, and the word "Mother" shall not be used to identify
stepmother. Mother and Father agree to behave cordially to members of the other's
family.
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BY THE COURT,
I, Marylou Mates, Esquire, aftney for Petittioner, Paul L. Croon, ii, verify that the
statements made in the foregoing Petition for Special Reef are true and oared and oertify
that I am authorized to do so, and that the persons' having knowledge of matters alleged in
this pleadings are outside the jurisdiction of the Court and their Verification cannot be obtained
within the time allowed for filing the pleading. I understand that false statements herein are
made subject to the penalties of 1S Pa. C.S. § 4904, relating to unswom falsification to
authorities.
Ebqdre for Petitioner
Date: • ;1/ ? /20t'
Law Offices of
Saidis
SU1HVan
& Rogers
26 West High S"oec
Carlisle, PA 17013
Lx. Ar, a -'°t
CEACATE OF SOME
On the ?p day of My 2011, I, Mwyj0u A4SW, Eoquim, of the iaw firm of
SAM#S, SULLIVAN & RQQW hsmWy GO*, OW on this d* a copy of #* afteW
d=n-ont _ on *0 WOWN , via OW c ,,f"# M ,
WPM:
Nd
His, RA 47140
Fax: (717) 23"779
SAMMS, SULLIVAN & RO RS
Law Offices of
Room"
26 West High Strm
Cadisk, PA 17013
c
SARA E. THUMA-CROOM
Plaintiff
vs.
PAUL L. GROOM, II
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
200&1593
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 2/. day of !!D6 y 2012, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Orders of this Court shall continue in effect as modified by this Order.
2. The Father shall have partial physical custody of the Child, while he is stationed in Japan,
from June 16 through July 28, 2012 and from December 22, 2012 through January 26, 2013.
3. The Father shall be responsible for making arrangements for the Child's flights on which
she shall be accompanied by either the Father or a designated member of the Father's family and
paying all costs associated with the air travel. The Mother shall be responsible to transport the Child to
and from the airport designated by the Father, which shall be limited to John F. Kennedy International
Airport, Philadelphia International Airport or Washington-Dulles International Airport.
4. The Father shall be entitled to have additional periods of custody with the Child at any time
the Father travels to the Central Pennsylvania area, with the specific arrangements to be made by
agreement between the parties.
5. In the event the Father is deployed during a period of partial custody in Japan, the Father
shall be responsible to make the necessary arrangements for the Child's return trip to the United States
if it would be unsafe for the Child to remain at the Father's location. Otherwise, the Father shall
ensure that the Child is returned as planned and no later than the end of his regular custodial period.
6. The Father shall ensure that the Child does not refer to her stepmother as "mother" or any
other form of the word "mother" in English or another language.
7. The parties shall cooperate in attempting to establish partial custodial arrangements for the
Father after the end of the 2012-2013 school year by agreement. If the parties are unable to reach an
agreement, either party may file a petition with the Court based upon the circumstances of the Child
and the parties at the time.
CXP* ffB, Q• I
8. The Parties Way 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,
Kevin A. J.
cc: ? Nichole M. Staley O'Gorman Esquin - Co el bother ` a
Paul L. Croom II - Father -,7
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SARA E. THUMA-CROOM
Plaintiff
VS.
PAUL L. GROOM, II
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2008-1593 CIVIL ACTION LAW
IN CUSTODY
Prior Judge: Kevin A. Hess
CUSTODY CONCILIATIQN SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
Sojourner Q. Croom
DATE OF EM
December 6, 2006
W"3 1
Mother
2. A custody conciliation conference was held on May 2, 2012, with the following individuals
in attendance: the Mother, Sara E. Thuma-Croom, with her counsel, Nichole M. Staley O'Gorman
Esquire, and the Father, Paul L. Croom II, who is not represented by counsel in this matter.
3. The Father filed this Petition to Modify the partial physical custody schedule due to his
current military placement in Japan. Several options for resolution were discussed at the conference
and the conciliator agreed to hold the matter open so that the Father and Mother could continue
working toward a plan which would be acceptable to both. Due to time constraints concerning the
Father's need to obtain plane tickets between the United States and Japan during the upcoming months,
the Mother's counsel and the Father forwarded emails of their ongoing negotiations to the conciliator.
4. Based on the positions of the parties as reflected in their emails and at the conciliation
conference, the conciliator recommends an Order in the form as attached which reflects an agreement
between the parties as to the basic format for partial custody over the next 12 months. The remaining
details related to minor differences in travel arrangements are the recommendations of the conciliator
based upon the overall circumstances and the parties' discussions. Due to the more immediate need to,
confirm the schedule for the Child's upcoming flights to Japan, the parties' respective requests for
;Q )Q.3
modification of the existing Order on non-travel related issues (specifically, the Father's request that
the Child be provided with tutoring in German while in the United States and the Mother's request that
the schedule for the paternal grandparents' weekend periods of custody be reduced), are not addressed
in the recommended Order. It should be noted that the parties' discussions at the conciliation
conference reflected a willingness to cooperate on both issues. It is anticiped that these issues will be
raised at the time the parties attempt to establish a partial custody schedule beyond the end of the 2012-
2013 school year, if not previously resolved by agreement.
Date h am Lca? Daum S. Sunday, Esquire `
Custody conciliator
SARA E. THUMA-GROOM IN THE COURT OF COMMON PLEAS OF
'L-~rNTIFr CUMBERLAND COUNTY, PENNSYLVANit
_~
~ - ~~ s
• 2008-1593 CIVIL ACTION LAW
~~
PAUL L. GROOM, II
W CUSTODY ---
I)I='FFNDA'~T ~ _"
ORDEK OF COURT
AND NOW, Thursday, October 18, 2012 _ _, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. ,the conciliator,
at 39 West Main Street, Ntechanicsbur PA_ ] 7055 _ _ on _ _ Tuesday, November 20, 2012 at 10:30 AM
for aPre-Hearing Custody Conference. At such conference, an effort ~-ill be made to resolve the issues in dispute; or
iE~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 ~»-der.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
SUecial Retief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR TIME COURT.
By: isi Dawn S. SundayzEs~,~_
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 infor-~nation 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 "FHE OFFICE SET
FOR'T'H BELOW 7~0 FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedf~~rd Street
\ Carlisle, Pennsylvania 17013
0 ~p~~' ~2 a~~I~f'sS~° S/ Telephone (717) 249-3166
~, Ps /~a,/PQ/
~ °~/ 9~~2
~ljc-
M
SARA E. THUMA-CROOM
Plaintiff
vs.
PAUL L. CROOM, II
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2008-1593
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this I9 day of 1>c4j ? , 2012, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The Mother, Sara E. Thuma-Croom, and the Father, Paul L. Croom II, shall have shared
legal custody of Sojourner Q. Croom, born December 6, 2006. Major decisions concerning the Child,
including, but not necessarily limited to, issues related to health, welfare, education, religious training
and upbringing shall be made by the parties jointly, after discussion and consultation with each other,
with a view toward obtaining and following a harmonious policy in the Child's s best interest. Neither
party shall permit these decisions to be made by third parties. Each party agrees not to impair the other
party's rights to shared legal custody of the Child. Each party shall notify the other of any activity or
circumstance concerning their Child that could reasonably be expected to be of concern to the other.
Day to day decisions shall be the responsibility of the parent then having physical custody. With
regard to any emergency decisions which must be made, the parent having physical custody of the
Child at the time of the emergency shall be permitted to make any immediate decision necessitated
thereby. However, that parent shall inform the other of the emergency and consult with him or her as
soon as possible. In accordance with 23 Pa. C.S.A. §5336, each party shall be entitled to complete and
full information from any doctor, dentist, teacher, professional or authority and to have copies of any
reports or information given to either party as a parent as authorized by statute.
2. The Mother shall have primary physical custody of the Child.
3. The Father shall have periods of partial physical custody as follows:
A. School Year: While Father is living in Japan, or any other international location
which the parties agree is safe for the Child, and only in the event the Child's school attendance policy
will permit it, Father shall have custody over the Child's winter school break. The custodial period
shall begin on the Saturday prior to Christmas and end on the Saturday two weeks thereafter. In the
event Father should return to the United States to reside, his custodial periods during the school year
will be as follows:
(1). Fall: Provided that the school attendance policy permits it, the custodial period
shall be a one-week period and extend from 2:00 p.m. on the Sunday prior to the Thanksgiving break
and end on the Sunday following the Thanksgiving break at 2:00 p.m.
(2). Winter: During the Child's winter school break, Father's custodial period shall
begin at an agreed time following the close of school which reasonably allows for travel and end at
2:00 p.m. on December 30tH
(3). Spring: Provided that the school attendance policy permits it, the custodial period
shall be a one-week period commencing the Sunday prior to the first day of spring break and ending
the following Sunday at 2:00 p.m.
B. Summer: While Father is living in Japan, or any other international location which
the parties agree is safe for the Child, he shall have custody for nine weeks during the Child's summer
school break, to be exercised in one five week period and one four week period separated by a one
week period of custody with Mother. The five week period shall begin on the first Saturday after the
conclusion of the school year. Father's four week period of custody shall end on the Saturday four
weeks after its beginning, or three days prior to the start of the new school year, whichever comes first.
Mother's one week period of custody shall be exercised in Japan (or other international location agreed
upon by the parties if Father relocates). The parties will share equally the cost of Mother's roundtrip
airfare for this trip; however, Father's proportionate share shall not exceed $1,000. Father shall
reimburse Mother for his proportionate share no later than 30 days prior to her departure from the
United States. Father shall be responsible for transporting the Child to and from the airport of
Mother's arrival/departure in Okinawa, Japan (or other international location agreed upon by the
parties if Father relocates) for this custodial period.
In the event Father should return to the United States to reside, Father shall have
custody of the Child for eight weeks during the summer to be taken in four week blocks separated by a
week in which custody will be with Mother. The first four week block will commence the second
Sunday after the last day of school. Custody of the Child shall be returned to Mother at least three
days prior to the beginning of the school year, or on the Sunday at the end of the second four week
block, whichever comes first.
C. During the calendar months when Father does not have a custodial period, Paternal
Grandparents shall have the option to visit with the Child one weekend per month, at times to be
agreed by Mother and Paternal Grandparents. The visits will begin as early as 5:00 p.m. on Friday and
end as late as 5:00 p.m. on Sunday. Every other Grandparent visit shall occur in the Harrisburg area,
and Paternal Grandparents shall be obligated to transport the Child to and from her scheduled activities
occurring during the Harrisburg visits. Grandparent visits shall always occur in the Harrisburg area in
the month after Father has a custodial period. In the event an opportunity with the Paternal
Grandparents arises for a special activity outside of the Harrisburg area when a visit is to occur there,
the parents shall be free to make those arrangements by mutual agreement. Grandparents shall propose
weekends they wish to exercise no less than sixty days in advance. Grandparents shall be responsible
for all travel and the costs of same.
D. While Father is living in Japan, or any other international location which the parties
agree is safe for the Child, he shall be entitled to have additional periods of custody with the Child at
any time he travels to the Central Pennsylvania area, with the specific arrangements to be made by
agreement of the parties.
4. Father shall be responsible for making arrangements for the Child's flights on which she
shall be accompanied by either Father or a designated member of the Father's family until such time as
the parties agree that the Child is sufficiently mature and emotionally ready to travel unaccompanied
on a non-stop flight. Father shall pay all costs associated with the air travel. Mother shall be
responsible to transport the Child to and from the airport designated by Father, which shall be limited
to John F. Kennedy International Airport, Newark International Airport or Philadelphia International
Airport. Other airports may be selected by mutual agreement of the parties.
5. In the event that Father is deployed during a period of partial custody in Japan, or any other
international location to which he may relocate, Father shall be responsible to make the necessary
arrangements for the Child's return trip to the United States if it would be unsafe for the Child to
remain at the Father's location. Otherwise, Father shall ensure that the Child is returned no later than
the end of his regular custodial period.
6. Father shall ensure that the Child does not refer to her stepmother as "mother" or any other
form of the word "mother" in English or in any other language.
7. Each parent shall be entitled to daily contact with the Child. The parties will cooperate to
schedule mutually convenient times for such contact, which may occur by the non-custodial parent's
choice of telephone or Skype.
8. The parties will engage in Intensive Co-Parenting Training with Susan Kurtz. All
associated out-of-pocket expense will be shared equally by the parties. The Co-Parenting Trainer must
be able to conduct most meetings by Skype, telephone or other long distance means. The parties will
schedule their first joint session to coincide with Father's time in the United States in December
provided that it is feasible for Ms. Kurtz to meet with them during this time.
9. Melissa Peel Greevy, Esquire has been appointed to serve as Parenting Coordinator ("PC").
All associated out-of-pocket expense will be shared equally by the parties unless otherwise allocated
by the PC in accordance with the terms of her appointment. The PC is hereby re-appointed for another
one year term, to expire on December 30, 2013. All other terms of the December 30, 2011
appointment order shall continue in full force and effect.
10. The parents will communicate with each other about routine and exceptional Child
development matters on an at least weekly basis by procedures to be developed by their Intensive Co-
Parenting Trainer. The parties will cooperate to schedule mutually convenient times for such contact.
11. Neither parent shall engage in a course of conduct designed to alienate the Child from the
other parent or the other parent's extended family. To the extent possible, the parties will prevent third
parties from engaging in such conduct.
12. Should childcare be necessary, each parent shall exercise care in responsibly choosing
childcare providers. The telephone number and address of the Child care provider shall be provided to
the other parent in advance. Likewise, if the Child will be spending the night at a location other than a
parent's primary residence, the address and telephone number shall be provided to the other parent, in
advance.
13. No party shall relocate the Child if such relocation will significantly impair the ability of a
non-relocating party to exercise his or her custodial rights unless (a) every person who has custodial
rights to the Child consents to the proposed relocation or (b) the Court approves the proposed
relocation. The party seeking relocation must follow the procedures required by 23 Pa.C.S. §5337.
14. The Child's passport shall be held by the parent having physical custody of the Child.
15. This Order shall replace and supersede all prior Orders of Court.
16. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT,
Kevin A. /446s J.
cc: f Nichole Staley O'Gorman Esquire - Counsel for Mother
? Paul L. Croom II - Father
,-
Cc?,°rs
17
SARA E. THUMA-GROOM
Plaintiff
vs.
PAUL L. CROOM, II
Defendant
Prior Judge: Kevin A. Hess
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2008-1593
CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Sojourner Q. Croom December 6, 2006 Mother
2. A custody conciliation conference was held on November 28, 2012 with the following
individuals in attendance: the Mother, Sara E. Thuma-Croom, with her counsel, Nichole Staley-
O'Gorman Esquire, and the Father, Paul L. Croom II, who is not represented by counsel in this matter
and who participated in the conference by telephone from his military station in Japan.
3. Following the conciliation conference, it was agreed that the Mother's counsel would
collect all prior Orders entered in this matter and forward them to the conciliator, along with the
stipulation that the parties had been working on and which formed the basis for the discussions at the
conference. Having received those documents, the conciliator submits an Order in the form as
attached which contains the agreements reached by the parties at the conference as well as any
pertinent prior terms which are to continue in effect.
Date Dawn S. Sunday, Esquire
Custody Conciliator
SARA E. THUMA - CROOM, :IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. CIVIL ACTION - LAW
NO. 08-1593
PAUL L. CROOM, II,
Defendant, Pro Se IN CUSTODY
PETITION FOR MODIFICATION OF CUSTODY
- c)
AND. NOW, comes Defendant, Paul L. Croom II ( "Father "), and petitions-"this
Honorable Court to modify custody due to changed circumstances for the following reasons:
1. The parties hereto are the natural parents of Sojourner Q. Croom, born
December 6, 2006.
2. Father is an officer in the United States Marine Corps (USMC) on active duty
since 2000. In August 2011, after being stationed in Okinawa, Japan for two years, the
Marine Corps transferred Father to Monterey, California for language instruction. Father is
due to execute Permanent Change of Station (PCS) orders to France in May 2014, for a
period of two years, accompanied by his wife, their twenty- one - month -old daughter and
three - and -a- half - year -old son, and his nine - year -old step- daughter.
3. Mother is a part-time housekeeper at the Pheasant Field Bed and Breakfast
in Carlisle, PA since 2010.
4. Mother and Sojourner have resided with Mother's parents in Harrisburg, PA
since February 2008.
b
n •
5. While married to Father, Mother stopped working in order to pursue post-
graduate studies and was awarded a master's degree in Public Health from Johns Hopkins
University in 2007.
6. Father and Mother divorced in 2008, and in February 2009, this Honorable
Court ordered shared legal and physical custody (50/50).
7. On January 5, 2011, the Court entered an Order in advance of Father's early -
2011 deployment to Afghanistan which granted Mother primary physical custody and
Father partial physical custody totaling 11 weeks annually divided over 5 periods in fall,
winter, spring and summer.
8. Father executed PCS orders to Okinawa, Japan in August 2011. The extreme
distance between Harrisburg, PA and Okinawa, and the high cost of air travel between the
two locations necessitated a change to the custody arrangement. The December 19, 2012
Order, based on the recommendations of Dawn Sunday as the court- appointed custody
conciliator, include an adjustment to the arrangement of Father's physical custody periods
to reflect one two -week period in winter, and one nine -week period in summer, interrupted
by a one -week period during which Mother is to have physical custody of Sojourner in
Japan, or any other suitable overseas Permanent Duty Station (PDS) to which Father may be
assigned.
9. During the conciliation conference, Mother argued that her employment
situation prevented her from affording the costs of overseas air travel, lodging and food. As
a temporary accommodation, Father agreed to pay 50% of Mother's air travel to an
overseas PDS, expecting that Mother would find and engage in suitable employment that
would enable her to financially support her summer visits to any future overseas PDSs. As of
the date of the filing of this petition, Mother has not, to Father's knowledge, engaged in or
sought employment commensurate with her education level and skills, although suitable
job opportunities have been available as evidenced by Exhibit 1 (attached).
10. To date, Mother has remained opposed to allowing Sojourner to fly
internationally as an Unaccompanied Minor, citing Sojourner's young age and relative
immaturity. Consequently, total expenditures on airfares, hotel accommodations and rental
vehicles to execute Father's court- ordered custody periods in the 30 months since Fall 2011
have exceeded $20,000.
11. Sojourner will be 8 years old before the Winter 2014 custody period with
Father, which will begin on December 19. The airlines that Father uses for Sojourner's
transportation allow Unaccompanied Minors beginning at age 5. Sojourner has traveled
extensively both domestically and internationally since before age 2, including trips to
Colorado, California, and three trips each to Austria and Japan. During her last several
travels, Sojourner has gone over and understands how to be independent, responsible and
self- aware, and has successfully taken the lead and demonstrated many of the processes
that will be required of her when flying as an Unaccompanied Minor. Sojourner has also
expressed that she is ready, willing and excited to fly unaccompanied, and Father believes
that Sojourner possesses the necessary maturity, responsibility and emotional readiness to
travel as an Unaccompanied Minor to and from her custody periods with Father. Otherwise,
while stationed in France over the next 24 months, and owing to an average ticket price of
$1,800 Father expects to again spend well over $20,000 to execute his custody periods with
Sojourner if she continues to be prevented from traveling unaccompanied.
WHEREFORE, Father requests that this Honorable Court modify its December 21,
2012 Order of Court, and order that:
1. A conciliation conference be scheduled for a date most immediate as practical,
and permit Father to participate via telephone, Skype or other electronic means. Father is
unavailable April 23 through April 30 due to mandatory military language testing.
2. Father be relieved of any requirement of financial support to Mother's one -week
visit during Father's summer custody periods, beginning with summer 2015.
3. Sojourner be permitted to fly as an Unaccompanied Minor to and from Father's
location when executing custody periods with Father, beginning in winter 2014.
Paul L. Croom II
Pro Se
Until 4 May- From 5 May until further notice-
Paul L. Croom II
330 Fitch Ave.
Monterey, CA 93944
Paul L. Croom II
12368 Spreading Oak Drive
Spring Hill, FL 34609
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.
§4904, relating to unsworn falsifications to authorities.
1P-4 4 , C---,0----
Paul L. Croom II
Date: April 16, 2014
CERTIFICATE OF SERVICE
On this 16th day of April 2014, I, Paul L. Croom II, acting Pro Se, hereby certify that on
this date a copy of the attached document was served on the following individuals, via first
class mail, postage prepaid, addressed.as follows:
Nichole M. Staley O'Gorman, Esquire
1820 Linglestown Road
Harrisburg, PA 17110
(717) 236 -9777
Paul L. Croom II
Until 4 May- From 5 May until further notice-
Paul L. Croom II
330 Fitch Ave.
Monterey, CA 93944
Paul L. Croom II
12368 Spreading Oak Drive
Spring Hill, FL 34609
Exhibit 1 (Thuma -Croom vs. Croom, No. 08 -1593, Petition to Modify Custody, 12 April 2014)
Original Message
From: Croom, Paul L STU (MIL) [mailto:paul.croom @dlifIc.edu]
Sent: Friday, April 04, 2014 9:11 AM
To: Cortes, Joel
Cc: PJ Croom
Subject: PA Dept of Health bachelors /masters hiring data inquiry
Importance: High
Joel,
Thanks again for taking my call today. I greatly appreciate your assistance.
As you can see below, Tasha provided me with 3 -year hiring data for public health positions requiring a
bachelor's or master's degree. If you can generate that same data for calendar (or fiscal) years 2011,
2012 and 2013, that would be extremely helpful.
My phone number is: (202)276 -1712.
Thanks again in advance, and have a great weekend!
Paul L. Croom II, USMC
Etudiant de francais
Defense Language Institute
paul.croom @dliflc.edu
1
Exhibit 1 (Thuma -Croom vs. Croom, No. 08 -1593, Petition to Modify Custody, 12 April 2014)
Original Message
From: Cortes, Joel [mailto:jcortes @pa.gov]
Sent: Wednesday, April 09, 2014 11:17 AM
To: Croom, Paul L STU (MIL)
Subject: RE: PA Dept of Health bachelors /masters hiring data inquiry
Paul,
You're welcome. Tasha had identified the following five job titles from within the PA Department of
Health (DOH), and provided the minimum experience and training requirements (METs) for those jobs to
you previously. Here are the number of positions hired 2011 -2013.
Epidemiologist - 4
Public Health Program Assistant Administrator - 36 Public Health Program Administrator - 84 Public
Health Program Manager - 25 Public Health Program Director - 9
In addition to the jobs that Tasha had previously identified, I identified these two additional DOH jobs
for you. I included the METs for these jobs below. Here are the number of positions hired 2011 -2013.
Epidemiology Program Specialist - 4
Epidemiology Research Associate - 9
I also identified the following three job titles. These are former DOH job titles that moved from DOH to
the new Dept. of Drug and Alcohol Programs on 7/1/12. I included the METs for these jobs below. Here
are the number of positions hired from 1/1/11 to 6/30/12. For more information about these jobs, or
how many vacancies have been filled since 7/1/12, you will need to contact the Dept. of Drug and
Alcohol Programs directly.
Drug & Alcohol Program Representative - 1 Drug & Alcohol Licensing Specialist -3 Drug & Alcohol
Program Analyst -1
I hope that this information is helpful to you. I'm sorry that I could not get it for you sooner.
Joel
Joel Cortes I Chief, Recruitment and Placement Section PA Dept. of Health, Bureau of Human Resources
Room 126 Health & Welfare Building
625 Forster Street I Harrisburg, PA 17120 -0701
Phone: 717.547.3183 I Fax: 717.783.2808
www.health.state.pa.us /employment
2
Exhibit 1 (Thuma-Croom vs. Croom, No. 08 -1593, Petition to Modify Custody, 12 April 2014)
Original Message
From: Croom Capt Paul L [mailto:paul.croom @ usmc.mil]
Sent: Monday, December 12, 2011 5:26 PM
To: Geyer, Tasha N
Subject: RE: Requested Information
Tasha,
Whom can I contact for information on what positions requiring a bachelor's or master's degree related
to public health have been hired for /filled in 2011, 2010, and 2009? This information would be
extremely helpful. Obviously I'm not looking for names or any other personal /sensitive information.
Thanks.
Respectfully,
PJ Croom
Captain Paul L. Croom II
Assitant ACI Officer /G -2 Plans Officer
Substance Abuse Campaign Strategist
1st Marine Aircraft Wing
Okinawa, Japan
NIPR: paul.croom @usmc.mil
SIPR: paul.croom @usmc.smil.mil
DS N: 315 - 645 - 3839/3840
COMM: 011 -81- 611 - 745 - 3839/2050
3
Exhibit 1 (Thuma -Croom vs. Croom, No. 08 -1593, Petition to Modify Custody, 12 April 2014)
Original Message
From: Geyer, Tasha N [mailto:tgeyer @pa.gov]
Sent: Tuesday, December 13, 2011 23:18
To: Croom Capt Paul L
Subject: RE: Requested Information
For 2010 -2013:
There was 1 Epidemiologist position filled in the 3 year timeframe.
There were 11 Public Health Program Assistant Administrator positions filled in the 3 year timeframe.
There were 53 Public Health Program Administrator positions filled in the 3 year timeframe.
There were 9 Public Health Program Manager positions filled in the 3 year timeframe.
There were 3 Public Health Program Director positions filled in the 3 year timeframe.
If you have any other questions, please contact me. Thank you.
Tasha Geyer I Human Resource Analyst
PA Dept. of Health I Recruitment and Placement Section
Room 126 Health & Welfare Building
625 Forster Street I Harrisburg, PA 17120 -0701
Phone: 717.346.2237 I Fax: 717.783.2808
Email: tgeyer @pa.gov <mailto:tgeyer @pa.gov>
www.health.state.pa.us < http: / /www.health.state.pa.us />
"If you are not the intended recipient of this e- mail, you are hereby notified that any dissemination or
copying of this information is strictly prohibited. If you have received this e-mail in error, immediately
notify the sender and delete the message and any attachments from your system."
4
SARA E. THUMA -CROOM
Plaintiff
vs.
PAUL L. CROOM, II
Defendant
: IN THE COURT OF COMMON PLEAS
: Bnuri u N COUNTY, PENNSYLVANIA
CUMBERLAND
G y �-
cri
-
H� t
{. -"' -a
: CIVIL ACTION - CUSTODY
y
: NO. CV CU
: 08 -1593
AFFIDAVIT PURSUANT TO 23 Pa.C.S.A. 65328 and $5329
I PAUL L. CROOM, II , hereby swear or affirm that:
(print name)
1.
1. Please state whether or not you and /or another adult living in your household have
been convicted of, pled guilty or no contest to the following crimes in Pennsylvania or any other jurisdiction,
as follows:
NO YES
Me
Adult in my Date Of
Household Conviction
❑ Contempt for violation of ❑
a Protection from Abuse
order or agreement;
Name:
❑ Driving under the
Influence of alcohol or a
controlled substance or
drugs
❑
Name:
RI ❑ Possession, sale, ❑ ❑
delivery, manufacturing Name:
or offering for sale any
controlled substance or
other drug or device;
Cil ❑ Criminal homicide; ❑ ❑
Murder; Name:
X] ❑ Aggravated Assault; ❑ ❑
Name:
❑ Stalking;
❑ Kidnapping;
❑ Unlawful restraint;
pg ❑ False imprisonment;
❑ ❑
• Name:
❑ ❑
Name:
❑ ❑
Name:
❑ ❑
Name:
NO YES
aq ❑ Luring a child into a
motor vehicle or
structure;
Me Adult in my Date Of
Household Conviction
❑ ❑
Name:
Rape, statutory sexual
assault, involuntary
deviate sexual
intercourse, sexual
assault, aggravated
indecent assault,
indecent assault,
indecent exposure,
sexual abuse of children,
sexual exploitation of
children, sexual
intercourse with an
animal, incest;
❑ ❑
Name:
❑ Sex offender non- ❑ ❑
compliance with Name:
registration
requirements, statute,
court order, probation or
parole, or other
requirements under 18
Pa. C.S.A. §3130 and 42
Pa. C.S. §9795.2•
❑ Arson and related ❑ ❑
offenses; Name:
❑ Concealing death of a
child;
❑ ❑
Name:
�. ❑ Endangering the welfare ❑ ❑
of children; Name:
❑ Trading, bartering, ❑
buying, selling or dealing
in infant children;
❑ Prostitution and related
offenses;
Name:
Name:
❑ Obscene and other
sexual materials and
performances; or
® ❑ Corruption of minors or ❑
unlawful contact with a
minor.
Name:
Name:
2. Please state whether or not you and/or another adult living in your household
have a present and/or past history involving violent or abusive conduct as follows:
NO YES
Me
Adult in my Date Of
Household Finding
X
o A finding of abuse by a
Children & Youth Agency
or similar agency in
Pennsylvania or similar
statue in another
jurisdiction
Name:
Has been subject to a o 0
Protection from Abuse Name:
order in Pennsylvania or
similar statute in another
jurisdiction
Other:
Name:
I verify that the statements made in this affidavit are true and correct. I understand that any false
statements herein are subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to
authorities.
Signature
PAUL L. CROOM II
Printed name
CRIMINAL CHARGE INFORMATION FOR INDIVIDUALS INVOLVED IN CHILD CUSTODY
CASES CAN BE FOUND BY ACCESSING THE )EN & DAVE PROGRAM AT
WWWJENDAVEPROGRAM.US
SARA E. THUMA-CROOM : IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
V.
PAUL L. CROOM, II
DEFENDANT
CUMBERLAND COUNTY, PENNSYLVANIA
2008-1593 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, April 23, 2014 , upon consideration of the attached Complaint, it is
hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq.
at 39 West Main Street, Mechanicsburg, PA 17055
on Wednesday, May 14, 2014
, the conciliator,
3:30 PM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this
cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure
to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief
orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
You must file with the Court a verification regarding any criminal record or abuse history regarding you and
anyone living in your household on or before the initial in-person contact with the court (including, but not limited to,
a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition.
No party may make a change in the residence of any child which significantly impairs the ability of the other party
to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and
Pa.R.C.P. No. 1915.17 regarding relocation.
FOR THE COURT.
By: /s/ Dawn S. Sunday, Esq.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with
Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled
individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior
to any hearing or business before the court. You must attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN
ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP,
Co-)ies Mb., I
1417 J. sh67( &Coruna()
?UAL £14con
11441/4/1:). Siuricy
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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(A)
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SARA- E • THWrot - (Loom.
I L Lk SARA E. TI-tuoti l- IN THE COURT OF COMMON PLEAS
PLAINTIFF eilmitERIANJ aturry, PENNSYLVANIA
vs. NO. d.A)8 L 59 3
?A.tL_ L. (loom. orvtI 1 l
DEFENDANT CIVIL ACTION - CUSTODY
CRIMINAL RECORD / ABUSE HISTORY VERIFICATION
1, SARA E. T I -t IAm A , hereby swear or affirm, subject to
PRINT NAME
penalties of law including 18 Pa.C.S. §4904 relating to unswom falsification to authorities that:
1. Unless indicated by my checking the "YES" box next to a crime below, neither I nor any other
member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent
where the record is publicly available pursuant to the Juvenile Act, 42 Pa.C.S. §6307 to any of the following
crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction,including pending charges:
Answer Crime Self Other Date of conviction, Sentence
Yes or No household guilty plea, no contest
member plea or pending charges
YES NO
❑ 18 Pa.C.S. Ch. 25 0 0
(relating to criminal homicide)
❑ % 18 Pa.C.S. §2702 0 0
(relating to aggravated assault)
❑ i 18 Pa.C.S. §2706 0 0
(relating to terroristic threats)
❑ W 18 Pa.C.S. §2709.1 0 0 "'D
(relating to stalking) -1).--
Rlo .
rrl ..,.. -.�
❑ 18 Pa.C.S. §2901 ❑ ❑ cin i = rj r r
(relating to kidnapping) rte.. „ 1\>k4
3s fi- r .
El 18 Pa.C.S. §2902 0 0 - cp r
(relating to unlawful restraint) �=,'�
----.1 r rz }�r
❑ 18 Pa.C.S. §2903 0 0
(relating to false imprisonment)
9-3-13
Answer
I
Yes or No
YES NO
El
Crime
18 Pa.C.S. §2910
(relating to luring a child into a
motor vehicle or structure)
ci 32' 18 Pa.C.S. §3121
(relating to rape)
0
9-3-13
Self Other Date of conviction, Sentence
household guilty plea, no contest
member plea or pending charges
O 0
O 0
18 Pa.C.S. §3122.1 0 0
(relating to statutory sexual
assault)
18 Pa.C.S. §3123 0 0
(relating to involuntary deviate
sexual Intercourse)
18 Pa.C.S. §3124.1 0 0
(relating to sexual assault)
18 Pa.C.S. §3125 0 0
(relating to aggravated Indecent
assault)
18 Pa.C.S. §3126
(relating to Indecent assault)
18 Pa.C.S. §3127
(relating to Indecent exposure)
18 Pa.C.S. §3129
(relating to sexual Intercourse
with animal)
18 Pa.C.S. §3130
(relating to conduct relating to
sex offenders)
O 0
O 0
O 0
0
e _
Answer Crime Self Other Date of conviction, Sentence
Yes or No household guilty plea, no contest
member plea or pending charges
YES NO
0
18 Pa.C.S. §3301 0 0
(relating to arson and related
offenses)
18 Pa.C.S. §4302
(relating to incest)
18 Pa.C.S. §4303
(relating to concealing death of
child)
O 0
O 0
18 Pa.C.S. §4304 0 0
(relating to endangering welfare
of children)
O 0
18 Pa.C.S. §4305
(relating to dealing In Infant
children)
18 Pa.C.S. §5902(b)
(relating to prostitution and
related offenses)
18 Pa.C.S. §5903(c) or (d)
(relating to obscene & other
sexual materials &
performances)
O 0
o 0
o jf 18 Pa.C.S. §6301 0 0
(relating to corruption of minors)
0
9-3-13
18 Pa.C.S. §6312
(relating to sexual abuse of
children)
O 0
18 Pa.C.S. §6318 0 0
(relating to unlawful contact with
minor)
Answer,
Yes or No
YES NO
Crime
18 Pa.C.S. §6320
(relating to sexual exploitation of
children)
23 Pa.C.S. §6114
(relating to contempt for violation
of protection order or agreement)
Driving under the influence of
drugs or alcohol
Manufacture, sale, delivery,
holding, offering for sale or
possession of any controlled
substance or other drug or
device
Self Other Date of conviction, Sentence
household guilty plea, no contest
member plea or pending charges
O 0
❑ ❑
2. Unless indicated by my checking the "YES" box next to an item below, neither I nor any.
other r<nember of my household have a history of violent or abusive conduct including the following:
Answer Self Other Date
household
member
Yes or No
YES NO
❑ A finding of abuse by a Children & Youth Agency or similar 0 0
agency in Pennsylvania or similar statute in another
jurisdiction
❑ Abusive conduct as defined under the Protection from ❑ 0
Abuse Act In Pennsylvania or similar statute in another
jurisdiction
❑ i Other:
9-3-13
O 0
3. Please list any evaluation, counseling or other treatment received following conviction or
finding of abuse:
4. If any conviction above applies to a household member, not a party, state that person's
/1/1/ -
name, date of birth and relationship to the child:
5. If you are aware that the other party or members of the other party's household has or
have a criminal/abuse history, please explain:
I verify that the statements made in the Criminal Record/Abuse History Verification 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 unswom falsification to authorities and can
be punishable by fine or imprisonment.
9-3-13
SA9.14 E, TH vuvin i4
Printed Name
SARA E. THUMA-CROOM IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs.
2008-1593 CIVIL ACTION LAW
PAUL L. CROOM II (..-)
Defendant IN CUSTODY--
rico c_
a- rn
ORDER OF COURT c Y ::
> (0) ,
AND NOW, this Z '" �' day of 9 L.,.... , 2014, upon nni erati:on
of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Order of this Court dated December 19, 2012 shall continue in effect as modified
by this Order.
2. Beginning in the summer of 2015, paragraph 3B of the December 19, 2012 Order shall be
modified to provide that the Mother shall be responsible to pay all costs, including airfare, for her
periods of summer custody with the Child in the location where the Father is stationed. The parties
shall continue to share the cost of the Mother's airfare for the summer period of custody in 2014.
3. The parties shall continue to explore possible options to reduce the Father's costs associated
with transportation of the Child for custodial periods with the Father while he is stationed in other
countries or at a significant distance from Pennsylvania.
4. No party shall be permitted to relocate the residence of the Child which significantly impairs
the ability to exercise custody unless every individual who has custodial rights to the Child consents to
the proposed relocation or the Court approves the proposed relocation. A person proposing to relocate
MUST comply with 23 Pa. C.S. § 5337.
5. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
cc: ,haul L. Croom II — Father
/Nichole Staley O'Gorman Esquire — Counsel for Mother
BY THE COURT,
Kevi • . ess
4
SARA E. THUMA-CROOM IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs.
PAUL L. CROOM II
Defendant
Prior Judge: Keven A. Hess
2008-1593 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
Sojourner Q. Croom
BIRTH YEAR CURRENTLY IN CUSTODY OF
2006 Mother
c�
2. A custody conciliation conference was held on May 14, 2014, with the following indi ,iduals
in attendance: the Mother, Sara E. Thuma-Croom, with her counsel, Nichole Staley O'Gorman
Esquire. The Father, Paul L. Croom II, participated by telephone from Lille, France, where heis'
currently stationed in the military. The Father is not represented by counsel in this matter. ,-E-.
Date
3. The parties agreed to entry of an Order in the form as attached.
Dawn S. Sunday, Esquire
Custody Conciliator
—
-r