HomeMy WebLinkAbout08-1853HOLLY MARIE CROCKETT, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 08- / 9 -4?-3 CIVIL TERM
KENNETH EDWARD BOHR,
Defendant CUSTODY
COMPLAINT FOR CUSTODY
1. Plaintiff is Holly Crockett, hereinafter referred to as Mother. Mother resides at 11
South High Street, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. Defendant is Kenneth Borh, hereinafter referred to as Father. Father resides at 1312
Berry Hill Street, Harrisburg, Dauphin County, Pennsylvania 17104.
3. Mother seeks primary physical custody of the minor child:
Name Present Residence Age
Elyssa Bohr 1312 Berry Hill Street 1.29.99 DOB, 9 yrs old
Harrisburg PA
Elyssa was born out of wedlock.
Elyssa is presently in the custody of Father as a result of his refusal to return Elyssa to
Mother's custody following an agreed upon visit.
During her lifetime, Elyssa has resided with the following persons and at the following
addresses:
Name Address Date
Holly Crockett 116 Ross Ave birth - 4/99
Kenneth Bohr New Cumberland, PA
Donna Crockett
Holly Crockett 116 Ross Ave 4/99 - 8/99
Donna Crockett New Cumberland, PA
Holly Crockett 116 Ross Ave 8/99 - 4/05
Kenneth Bohr New Cumberland, PA
Donna Crockett
Holly Crockett 116 Ross Ave 4/05 - autumn 2005
Donna Crockett New Cumberland, PA
Holly Crockett 116 Ross Ave autumn 2005 - autumn 2006
New Cumberland, PA
Holly Crockett 116 Ross Ave autumn 2006 - 1/07
Chris Havens New Cumberland, PA
Holly Crockett 116 Ross Ave 1/07-11/07
Chris Havens New Cumberland, PA
Dominick Havens
Holly Crockett 11 South High St 11/07 - 3/1/08
Chris Havens Mechanicsburg, PA
Dominick Havens
Kenneth Bohr 1312 Berry Hill Street 3/1/08 - present
Cindy Bohr Harrisburg, PA
Daniel
Hector
Elijah
Myrna
Brooklyn
Cavemen
5. Mother lives with the following persons:
Name Relationship
Donna Crockett Maternal Grandmother
Chris Havens Boyfriend
Dominick Havens Son with Boyfriend
6. It is believed that Father lives with the following persons:
Name Relationship
Cindy Bohr Wife
Daniel Wife's son
Hector Wife's son
Elijah Wife's son
Myrna Wife's daughter
Brooklyn Wife's son
Caveman Wife's son
Elyssa Daughter with Plaintiff
7. Mother has not participated as a party or witness, or in another capacity, in other
custody litigation concerning the custody of Elyssa in this or another court.
8. Mother has no information of a custody proceeding concerning Elyssa pending in a
court of this Commonwealth.
9. Mother does not know of a person not a party to the proceedings who has physical
custody of Elyssa or claims to have custody or visitation rights with respect to Elyssa.
10. Elyssa's best interest and permanent welfare will be served by granting the relief
requested for reasons including, but not limited to the following:
a. Since Elyssa was born, Mother has been her primary caretaker and has been
responsible for her emotional, physical, educational, financial and medical needs.
b. Mother is fully capable of caring for Elyssa on a primary basis and has done so
since her birth.
c. Mother is willing to communicate with and work cooperatively with Father to co-
parent Elyssa and will encourage their father/daughter relationship. For the past
three years, Mother has been cooperative in working with Father to ensure that he
has liberal periods of partial custody with Elyssa and has, in fact, encouraged him
to spend more time with her in order to help enhance their father/daughter
relationship.
10. Father has not acted in Elyssa's best interests in ways including but not limited to the
following:
a. Father was initially uninvolved in the primary caretaking duties for Elyssa from
the time she was born until she was about six years old.
b. In early March 2008, Father took Elyssa for an agreed upon visit and has since
refused to return Elyssa to Mother's custody
c. Father has refused to allow Mother to speak to or see Elyssa since the beginning
of March.
d. Father removed Elyssa from the school she has attended since kindergarten and
without Mother's agreement or knowledge, transferred Elyssa to the Harrisburg
School District. Mother only learned of Elyssa's new school, Scott Elementary
School, by contacting Fishing Creek Elementary School to determine where they
transferred Elyssa's school records.
e. Father lives in a home with his wife and six of her eight children and lives in an
unsafe area of Harrisburg city.
f. Father does not supervise the children and allows them to walk in Harrisburg city
without an adult present.
g. Father does not have appropriate transportation available to transport all of the
children in his home and Mother worries about Elyssa's safety with Father on a
primary basis.
h. Father took Elyssa for an agreed visit in early March and subsequently refused to
return Elyssa to Mother's custody.
12. Every person with rights to custody or having actual physical custody of Elyssa has
been named as parties to this action.
WHEREFORE, Mother requests this Court to grant her the following relief:
1. That the parties shall share legal custody of Elyssa.
2. That Mother shall have primary physical custody of Elyssa.
3. That Father shall have periods of partial custody at times and places agreed upon
by the parties.
4. That the non-custodial parent shall have reasonable telephone contact with Elyssa
while she is with the other parent.
5. That the parties shall have an appropriate holiday schedule so that both parents
can spend time with Elyssa during various holidays.
6. Any other relief this Court finds just and equitable.
Respectfully submitted,
essica Holst, Esquire
MidPenn Legal Services
401 East Louther Street
Carlisle, PA 17013
(717) 243-9400
VERIFICATION
The above-named PLAINTIFF, Holly Crockett, verifies that
the statements made in the above COMPLAINT FOR CUSTODY are true
and correct. Plaintiff understands that false statements herein
are made subject to the penalties of 18 Pa. C.S. §4904, relating
to unsworn falsification to authorities.
Date: > o -? Cn , oQ.C
Holly Marie Crockett
HOLLY MARIE CROCKETT, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 08- CIVIL TERM
KENNETH EDWARD BOHR,
Defendant CUSTODY
AFFIDAVIT OF SERVICE BY MAIL
I, Jessica Holst, do hereby swear that I served Kenneth Bohr, with a Complaint For
Custody on March 24, 2008 by certified mail, return receipt, restricted delivery, to the person
and addresses below:
Kenneth Bohr
1312 Berry Hill Street
Harrisburg, PA 17104
I, Jessica Holst, verify that the statements made in this Affidavit of Service are true and
correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
Date: 3 oZ ??' U ?' Signature:
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HOLLY MARIE CROCKETT,
Plaintiff
vs.
KENNETH EDWARD BOHR,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08- lJ','-'3 CIVIL TERM
: CUSTODY
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Holly Crockett, Plaintiff, to proceed in forma ap uperis.
I, Jessica Holst, attorney for the party proceeding in forma ap uperis, certify that I believe
the party is unable to pay the costs and that I am providing free legal services to the party.
J ica olst, Esquire
MidPenn Legal Services
401 East Louther Street
Carlisle, PA 17013
(717) 243-9400
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HOLLY MARIE CROCKETT,
Plaintiff
VS.
KENNETH EDWARD BOHR,
Defendant
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08- / 3,?-3 CIVIL TERM
: CUSTODY
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Holly Crockett, Plaintiff, to proceed in forma au eris.
I, Jessica Holst, attorney for the party proceeding in forma ap uperis, certify that I believe
the party is unable to pay the costs and that I am providing free legal services to the party.
JEsquire
MidPenn Legal Services
401 East Louther Street
Carlisle, PA 17013
(717) 243-9400
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HOLLY MARIE CROCKETT,
Plaintiff
vs.
KENNETH EDWARD BOHR,
Defendant
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-
CIVIL TERM
CUSTODY
PETITION FOR SPECIAL RELIEF
Petitioner, Holly Marie Crockett, by and through her counsel, MidPenn Legal Services, states the
following:
1. Petitioner is the above-named Plaintiff, hereinafter referred to as Mother, who resides at
11 South High Street, Mechanicsburg, Cumberland County, PA 17055.
2. Respondent is the above-named Defendant, and resides at 1312 Berry Hill Street,
Harrisburg, Dauphin County, Pennsylvania 17104.
3. The parties are the natural and biological parents of the minor child Elyssa Bohr, born
January 29, 1999.
4. There is no prior Custody Order in this matter. A Custody Complaint has been filed
simultaneously with the filing of this Petition for Special Relief.
5. On March 1, 2008, Defendant took Elyssa for an agreed upon visit. He has since refused
to return Elyssa to Mother's custody and Mother has been unable to speak to or see
Elyssa since that date.
6. Defendant has removed Elyssa from Fishing Creek Elementary School and transferred
her to the Harrisburg School District without Mother's agreement or knowledge. Mother
did not learn of Elyssa's new school, Scott Elementary School, until advised by Fishing
Creek Elementary School as to where they transferred Elyssa's records.
7. Defendant is not acting in Elyssa's best interests for reasons including, but not limited to,
the following:
a. Father was initially uninvolved in the primary caretaking duties for Elyssa from
the time she was born until she was about six years old.
b. In early March 2008, Father took Elyssa for an agreed upon visit and has since
refused to return Elyssa to Mother's custody
c. Father has refused to allow Mother to speak to or see Elyssa since the beginning
on March.
d. Father removed Elyssa from the school she has attended since kindergarten and
without Mother's agreement or knowledge, transferred Elyssa to the Harrisburg
School District. Mother only learned of Elyssa's new school, Scott Elementary
School, by contacting Fishing Creek Elementary School to determine where they
transferred Elyssa's school records.
e. Father lives in a home with his wife and six of her eight children and lives in an
unsafe area of Harrisburg city.
f. Father does not supervise the children and allows them to walk in Harrisburg city
without an adult present.
g. Father does not have appropriate transportation available to transport all of the
children in his home and Mother worries about Elyssa's safety with Father on a
primary basis.
h. Father took Elyssa for an agreed visit in early March and subsequently refused to
return Elyssa to Mother's custody.
8. Mother is the parent who can best provide for Elyssa for reasons including, but not
limited to, the following:
a. Since Elyssa was born, Mother has been her primary caretaker and has been
responsible for her emotional, physical, educational, financial and medical needs.
b. Mother is fully capable of caring for Elyssa on a primary basis and has done so
since her birth.
C. Mother is willing to communicate with and work cooperatively with Father to co-
parent Elyssa and will encourage their father/daughter relationship. For the past
three years, Mother has been cooperative in working with Father to ensure that he
has liberal periods of partial custody with Elyssa and has, in fact, encouraged him
to spend more time with her in order to help enhance their father/daughter
relationship.
9. Without this Court's intervention, Elyssa is at risk of being harmed by being denied
contact with Mother, the person who has been her primary caretaker since birth. Elyssa is at risk
of physical harm because Defendant resides in an unsafe area of Harrisburg city and does not
properly supervise the children.
WHEREFORE, Mother respectfully requests that the Court order the following:
a. Defendant shall immediately return the child, Elyssa Bohr, to Mother's
custody.
b. The parties shall share legal custody of Elyssa.
c. This matter shall be scheduled for a custody conciliation to determine
a more specific custody order regarding Elyssa Bohr, born January 29,
1999.
d. Until the conciliation conference, Mother shall have primary physical
custody of Elyssa.
e. Until the conciliation conference, Defendant shall have periods of
partial custody at times and places as the parties may agree.
f. That until the conciliation, Defendant shall have periods of partial
physical custody at times and places as agreed to by the parties.
g. Any other relief this Court finds just and equitable.
Respectfully submitted,
Jes a st, Esquire
MidPenn Legal Services
401 E. Louther Street
Carlisle, PA 17013
VERIFICATION
The above-named PLAINTIFF, Holly Marie Crockett, verifies
that the statements made in the above PETITION FOR SPECIAL
RELIEF are true and correct. Plaintiff understands that false
statements herein are made subject to the penalties of 18 Pa.
C.S. §4904, relating to unsworn falsification to authorities.
Date: 2) _aZ l _CA
Holly Mahe Crockett
HOLLY MARIE CROCKETT,
Plaintiff
vs.
KENNETH EDWARD BOHR,
Defendant
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-
CIVIL TERM
CUSTODY
AFFIDAVIT OF SERVICE BY MAIL
I, Jessica Holst, do hereby swear that I served Kenneth Bohr, with a Petition for Special
Relief on March 24, 2008 by certified mail, return receipt, restricted delivery, to the person and
address below:
Kenneth Bohr
1312 Berry Hill Street
Harrisburg, PA 17104
I, Jessica Holst, verify that the statements made in this Affidavit of Service are true and
correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904 relating to unsworn falsification to authorities.
Date: 3' aq' ()y Signature: 4t-
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HOLLY MARIE CROCKETT,
Plaintiff
VS.
KENNETH EDWARD BOHR,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08-1853 CIVIL
: CUSTODY
IN RE: PETITION FOR SPECIAL RELIEF
ORDER
AND NOW, this 2 S ` day of March, 2008, a rule is issued on the defendant to
show cause why the relief requested in the within petition for special relief ought not to be
granted. This rule returnable ten (10) days after service.
BY THE COURT,
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HOLLY MARIE CROCKETT
Plaintiff
V.
KENNETH EDWARD BOHR
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
NO. 08-1853
CIVIL ACTION -LAW
CUSTODY
ANSWER TO COMPLAINT FOR CUSTODY
AND NOW COMES, Kenneth Edward Bohr, through his attorneys, the Law Offices of Leslie D.
Jacobson, and avers the following:
1. Admitted.
2. Admitted.
3. Admitted, in part, and Denied in part. Denied that Elyssa is presently in the
custody of father as a result of refusal to return Elyssa to mother's custody. By
way of further response, Elyssa is presently in the custody of her father by
agreement of the parties and because of the inappropriate and unsafe living
conditions of mother. By way of further response the Defendant believes that the
parties lived at other residences from the child's birth until the child turned one.
5. Admitted.
6. Admitted.
7. Admitted.
8. Admitted.
9. Admitted.
10. Denied that Elyssa's best interests and permanent welfare will be served by
granting the relief requested. By way of further response as living arrangements
stand right now, Elyssa is much better off in the custody of her father and until
J.- 146
such time as mother resolves the inappropriate and unsafe living arrangements
with her boyfriend. At that time she should be granted temporary custody.
(sic) 10. Denied that Father has not acted in Elyssa's best interests. He has been
involved since Elyssa's birth and is currently acting as custodial parent pursuant
to an agreement between the parties due to the unsafe living conditions of mother
and her abusive boyfriend.
12. Admitted.
WHEREFORE, Father requests this Court to grant the following relief-
1 . That the parties shall share legal custody of Elyssa.
2. That Father shall have primary physical custody of Elyssa.
3. That Mother shall have appropriate periods of partial custody, especially
after she has resolved her unsafe living conditions.
4. That each parent shall have reasonable contact.
5. That the parties shall have an appropriate holiday schedule.
Respectfully submitted,
Dated: April 1, 2008 By:
*7.9. cobson, I.D# 52673
r Defendant
Street
PA 17111-5260
58
717.909.7788 [fax]
VERIFICATION
I, Kenneth Edward Bohr, being duly authorized to make this verification, do
hereby verify that the facts stated in the foregoing document are true and correct to the
best of my knowledge, information and belief. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to
authorities.
Date: Sib?
By: 91), ? ,7 _
Kenneth Edward Bohr
HOLLY MARIE CROCKETT
Plaintiff
V.
KENNETH EDWARD BOHR
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
: NO. 08-1853
CIVIL ACTION -LAW
CUSTODY
CERTIFICATE OF SERVICE
I, Jennifer L. Karr, Legal Assistant, with the Law Offices of Leslie David Jacobson,
hereby certify that I served a true and correct copy of the foregoing Answer To Complaint for
Custody by depositing the same in the U.S. Mail, First Class, postage prepaid to the following.
MidPenn Legal Services
Jessica Holst, Esquire
401 East Louther Street
Carlisle, PA 17013
Attorney for Plaintiff
LAW OFFICES OF LESLIE D. JACOBSON
Dated: April 1, 2008
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HOLLY MARIE CROCKETT
Plaintiff
V.
KENNETH EDWARD BOHR
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
NO. 08-1853
CIVIL ACTION -LAW
CUSTODY
ANSWER TO PETITION FOR SPECIAL RELIEF
AND NOW cows, Kenneth Edward Bohr, through his attorneys, the Law Offices of
Leslie D. Jacobson, and avers the following:
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Denied. On March 1, 2008, Plaintiff requested that the Defendant take Elyssa
into his home because her live-in boyfriend was drunk and abusive and she felt
that the child, herself and her other son were in danger. By way of further
response Elyssa, Plaintiff, and Plaintiffs son Dominick were permitted to stay at
the Defendant's home from March 1, 2008 through March 5, 2008 because of the
abusive situation in Plaintiffs home.
6. Admitted. Defendant has removed Elyssa from Fishing Creek Elementary School
and transferred her into the Harrisburg City School District.
Denied that Plaintiff did not learn of this until advised by Fishing Creek
Elementary School. By way of further response on Thursday March 6, 2008 after
discussion between the parties and after being informed by Elyssa that she was
afraid to go to Plaintiff s home because of this abusive boyfriend, it was agreed
between the parties that Defendant would retain Custody of Elyssa and would
change school districts. At all times Plaintiff was aware of this decision and the
change in schools.
7. Denied that the Defendant is not acting is Elyssa's best interest and specifically:
a. Denied.
b. Denied.
c. Denied. Mother has been permitted complete access to the child.
d. Denied. For same reasons as enumerated in paragraph 6.
e. Admitted in part.
Denied that Defendant's residence is in an unsafe area of Harrisburg.
f. Denied.
g. Denied. At all times Defendant provides appropriate transportation for
his child and his step-children.
h. Denied.
8. Denied for the reasons enumerated in paragraph 6. Mother currently lives in a
situation with an abusive boyfriend which is inappropriate and not in Elyssa's
best interest, and further Elyssa has expressed fear and reluctance to return to
mother's residence.
9. Denied. At all times father has been, and is willing to provide appropriate contact
with the child by mother and at such time as mother has straightened out her
current inappropriate living arrangements she would be permitted physical
custody with the child.
WHEREFORE, Father respectfully requests that this Court deny the request for Special
Relief, and any for other Relief deemed appropriate.
Dated: April 1, 2008 By:
Jacobson, I.D# 52673
for Defendant
l5RD6rry Street
Harrisburg, PA 17111-5260
717.909.5858
717.909.7788 [fax]
VERIFICATION
I, Kenneth Edward Bohr, being duly authorized to make this verification, do
hereby verify that the facts stated in the foregoing document are true and correct to the
best of my knowledge, information and belief. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to
authorities.
Date: -3/31 p By: £
Kenneth Edward Bohr
HOLLY MARIE CROCKETT
Plaintiff
V.
KENNETH EDWARD BOHR
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
NO. 08-1853
CIVIL ACTION -LAW
CUSTODY
CERTIFICATE OF SERVICE
I, Jennifer L. Karr, Legal Assistant, with the Law Offices of Leslie David Jacobson,
hereby certify that I served a true and correct copy of the foregoing Answer To Petition for
Special Relief by depositing the same in the U.S. Mail, First Class, postage prepaid to the
following.
MidPenn Legal Services
Jessica Holst, Esquire
401 East Louther Street
Carlisle, PA 17013
Attorney for Plaintiff
LAW OFFICES OF LESLIE D. JACOBSON
Dated: April 1, 2008
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HOLLY MARIE CROCKETT IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
KENNETH EDWARD BOHR
DEFENDANT
2008-1853 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, March 28, 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 Wednesday, April 23, 2008 at 10:00 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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fAPR 2 5 2008
HOLLY MARIE CROCKETT IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 2008-1853 CIVIL ACTION LAW
KENNETH EDWARD BOHR
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this z 17` day of g22 '/ , 2008, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The Mother, Holly Marie Crockett, and the Father, Kenneth Edward Bohr, shall have shared
legal custody of Elyssa Bohr, born January 29, 1999. 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.
2. The parties shall have physical custody of the Child in accordance with the following
schedule:
A. During the remainder of the 2007-2008 school year, the Father shall have primary
physical custody of the Child and the Mother shall have partial physical custody on alternating
weekends from Friday at a time to be arranged by agreement between the parties through Sunday at
6:00 p.m. The alternating weekend schedule shall begin with the Mother having custody of the Child
on Friday, May 2, 2008.
B. Beginning in the 2008-2009 school year and continuing thereafter, the Mother shall
have primary physical custody of the Child with the Father having partial physical custody on
alternating weekends from Friday at a time to be arranged by agreement between the parties through
Sunday at 6:00 p.m. and during additional times as arranged by agreement between the parties.
C. During the summer school break, the parties shall share having physical custody of
the Child on an alternating weekly basis, with the exchange to take place every Sunday at a time to be
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arranged by agreement. The summer custody schedule shall begin with the Father having custody on
the first weekend after the end of the school year. The summer custody schedule shall end on the last
Sunday before the first day of school.
3. For the remainder of the 2007-2008 school year, the Child shall continue to attend school in
the Harrisburg School District. Beginning in the 2008-2009 school year, the Child shall resume her
enrollment in the Mechanicsburg Area School District.
4. The parties shall share. or alternate having custody of the Child on holidays as follows:
A. Christmas: The Christmas holiday shall be divided into Segment A, which shall run
from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B, which shall
run from Christmas Day at 12:00 noon through December 26 at 12:00 noon. In even-numbered years,
the Mother shall have custody of the Child during Segment A and the Father shall have custody during
Segment B. In odd-numbered years, the Father shall have custody of the Child during Segment A and
the Mother shall have custody during Segment B.
B. Thanksgiving: The Thanksgiving holiday shall run from the Wednesday evening
before Thanksgiving through the Friday evening following Thanksgiving. The Father shall have
custody of the Child for Thanksgiving in even-numbered years and the Mother shall have custody in
odd-numbered years.
C. Easter: The parties shall alternate having custody of the Child on Easter as arranged
by agreement.
D. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule.
E. In the event a holiday period of custody falls immediately preceding or following an
alternating weekend period of custody, the holiday and regular periods of custody shall run
continuously without interruption.
5. Unless otherwise agreed between the parties, the parent receiving custody of the Child shall
be responsible to provide transportation for the exchange of custody.
6. Neither party shall do. or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
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.
cc:
ZZ 3essica Holst, Esquire - Counsel for Mother
/Allen D. Moyer, Esquire = Counsel for Father
x11291,08
BY THE COURT, I
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1.?,.,
HOLLY MARIE CROCKETT IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 2008-1853 CIVIL ACTION LAW
KENNETH EDWARD BOHR
Defendant 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
Elyssa Bohr January 29, 1999 Father
2. A custody conciliation conference was held on April 24, 2008, with the following
individuals in attendance: the Mother, Holly Marie Crockett, with her counsel, Jessica Holst, Esquire,
and the Father, Kenneth Edward Bohr, with his counsel, Allen D. Moyer, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
C;1 Y'
Date Dawn S. Sunday, Esquire
Custody Conciliator
HOLLY MARIE CROCKETT, IN THE COURT OF COMMON PLEAS
Plaintiff/Respondent : CUMBERLAND COUNTY
: PENNSYLVANIA, `C-r
V. =rn
KENNETH EDWARD BOHR, <> C D Q
Defendant/Petitioner : No. FC 2008-1853 .CCU ss
: IN CUSTODY -cam :z c a
t,a
r
EMERGENCY CUSTODY PETITION FOR SPECIAL RELIEF PURSUANT TO
RULE 1915.13
OF THE PENNSYLVANIA RULES OF CIVIL PROCEDURE
TO THE HONORABLE JUDGES OF SAID COURT:
AND NOW,comes the Petitioner,Kenneth E. Bohr,by and through his attorney,
Benjamin R. Yoffee, Esquire,who respectfully represents as follows:
1. Petitioner/Father,Kenneth E. Bohr, is an adult individual currently residing at
311 S. 4t' Street,Newport,Perry County,Pennsylvania, for 1 year.
2. Respondent/Mother,Holly M. Crocket, is an adult individual currently
residing at 634 Cumberland Point,Mechanicsburg, Cumberland County,
Pennsylvania for 1 years.
3. The Winor child in qugtion is Elyssa M. Bohr age 14 years (D.O.B.
01/29/99).
4. The current custody order in general gives Father shared legal custody and
physical custody every other weekend and shared physical custody in summer
on week on week off basis.
f g'3,a0 a aY�
5. On or about March 19,2012 at approximately 9:O0p.m.the Petitioner was
contacted by minor child and was told that the cell phone Petitioner had
provided daughter for emergencies was missing from her bedroom.
6. During said conversation, Petitioner heard his daughter and a roommate of
mother yelling;when minor child returned to the phone she told Petitioner that
she had been pushed into a mirror by mother's roommate Shardae Strickland
and had hurt her wrist.
7. Mother resides in Section 8 housing and is not to have roommates; however,
Petitioner was informed by Upper Allen Police that Shardae Strickland and
Jennifer Grossman are subletting the townhouse and they could be removed
lawfully.
8. Upper Allen Township Police were contacted and Petitioner drove from his
residence in Newport to Mechanicsburg;police had left the scene prior
Petitioner's arrival.
9. Upon arrival father was confronted by Shardae Strickland who denied that
she had done anything to minor child.
10. Father took daughter to the emergency room at Holy Spirit Hospital where it
is suspected that minor child has an occult fracture and was provided with a
sling and splint and further instruction to be seen at OIP.
11. Minor child is to see an orthopedic specialist in Camp Hill on March 20, 2013
for further diagnosis and treatment.
12. OlP Associates diagnosed the child's arm as being broken at the growth plate
and the child is currently in an arm cast as a result.
13. Cumberland County Children and Youth Services are investigating the
matter.
14. Mother has had previous referrals to Cumberland County Children and
Youth Services for other allegations of abuse and there are services already in
place at the home while these allegations are being investigated.
15. There is an immediate threat to the health, safety, and welfare of Elyssa Bohr
while under the care of Respondent.
16. Petitioner requests the court grant him exclusive emergency custody pending
abuse investigation.
WHEREFORE,the Petitioner requests this Honorable Court enter a temporary,
emergency Order vesting sole legal and physical custody of the subject child, Elyssa M.
Bohr(D.O.B 01/29/99) in Petitioner until such time as a hearing on this matter can be
scheduled.
Respectfully su ed,
Benjamin R. Yoffee, Esquire
Attorney I.D.No. 208504
15 East Main Street
P.O. Box 605
New Bloomfield,Pa 17068
(717)582-0122
Date: d1
1 2013 Attorney for Petitioner
*R 25 r�
2Q0
HOLLY MARIE CROCKETT IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA
vs. : 2808-1853 CIVIL ACTION LAW
KENNETH EDWARD BOHR
Defendant IN CUSTODY
a
ORDER OF COURT
AND NOW, this day of I 2008, upon
._ .consideration of the attached Custody Conciliation Re 44s erdered and--diaected as-€ol --- _---, °-
1. The Mother, Holly Marie Crockett,and the Father,Kenneth Edward Bohr,shall have shared
legal custody of Elyssa Bohr, barn January 29, 1999. Major decisions concerning the Chil4 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,8s4)Pssible. 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.
2. The parties shall have physical custody of the Child in accordance with the following
schedule:
A. During the remainder of the 2007-2008 school year, the Father shall have primary
physical custody of the Child and the Mother shall have partial physical custody I on alternating
weekends from Friday at a time to be arranged by agreement between the parties through Sunday at
6:00 p.m. The alternating weekend schedule shall begin with the Mother having custody of the Child
on Friday,May 2, 2008.
B. Beginning in the 2008-2009 school year and continuing thereafter, the Mother shall
have primary physical custody of the Child with the Father having partial physical custody on
alternating weekends from Friday at a time to be arranged by agreement between the parties through
Sunday at 6:00 p.m. and during additional times as arranged by agreement between the parties.
C. During the summer school break, the parties shall share having physical"custody of
the Child on an alternating weekly basis, with the exchange to take place every Sunday at a time to be
arranged by agreement. The summer custody schedule shall begin with the Father having custody on
the first weekend after the end of the school year. The summer custody schedule shall end on the last
Sunday before the first day of school.
3. For the remainder of the 2007-2008 school year,the Child shall continue to laftAd school in
the Harrisburg School District. Beginning in the 2008-2009 school year, the Child shall resume her
enrollment in the Mechanicsburg Area School District.
4. The parties shall share•or alternate having custody of the Child on holidays as follows:
A. Christmas: The Christmas holiday shall be divided into Segment A,which shall run
from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B, which shall
run from Christmas Day at 12:00 noon through December 26 at 12:00 noon. In even numbered years,
the Mother shall have custody of the Child during Segment A and the Father shall have custody during
Father odd numbered years, the Fath' ill have custody of the Child during Segment A and
the Mother shall have custody during Segment B.
B. Thanksgiving: The Thanksgiving holiday shall run from the Wednesday evening
before Thanksgiving through the Friday evening following Thanksgiving. The Father shall have
,custody of the Child for Thanksgiving in even-numbered years and the Mother shall custody in
odd-numbered years.
C. Easter: The parties shall alternate having custody of the Child on Easter as arranged
by agreement.
D. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule.
E. In the event a holiday period of custody falls immediately preceding or f6llowing an
alternating weekend period of custody, the holiday and regular periods of custody, shall run
continuously without interruption.
5. Unless otherwise agreed between the parties,the parent receiving custody of the Child shall
be responsible to provide transportation for the exchange of custody.
6. Neither party shall do.or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent,or hamper the free and naun-al developinent of the
Child's love and respect for the other parent. Both,parties shall en
.en.dug that third
comply --parties having contact— ,
With 6 Child co ly with this provision.
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,
J.
cc: Jessica Holst,Esquire—Counsel for Mother TRUE CORY i=Rom kla,CORO
Allen D. Moyer,Esquire ;. Counsel for Father In T"fln- my w1wW.I h"unto yet my hand
VW No Sod of said 0"S W40 Pa
HOLLY MARIE CROCKETT
• IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
VS. a
2008-18$3 CIVIL ACTION LAW
KENNETH EDWARD BOHR. ,
Defendant : IN CUSTODY
CUSTODY COIYCILIATIUN SUMI Y 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:
N- AME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Elyssa Bohr January 29, 1999 Father
2. A custody conciliation conference was held on April 24, 2048, with the following
individuals in attendance: the Mother, Holly Marie Crockett, with her counsel, Jessica Holst, Esquire,
and the Father,Kenneth Edward Bohr,with his counsel, Allen D. Moyer, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date
Dawn S. Sunday,Esquire
Custody Conciliator
r
JOHN R. DIM EMERMNCY CENTER DISCHARGE INSTR RECORD
HOLY SPIRIT HOORTAL (717) M-43M'
Mr exam Mon,and umaomeot you nave received is the Emergency Cermer have bey modeaed on an emery baste only,and are act intended to be a aabathWe for or'an effort to provide
medical cam.if you develop new pmbkma or comprlicaum comma you physclan or ties Emergency Center.
FOLLOW THE INSTRUCTIONS CHECKED BELOW:
WOUND CARE VEIMATIONB
( }May gently wash over wound in 24 hours with soap and water or { )Conanuu mow.
f
{ }Change drsesing—times daily.Redress with BacitrecinlNeosporin { )else ( Tylenol ee needed for peen,fever
and sterile dressing or Heave it open if advised, instructions for age and wtil�ht,ero.
{ )Keep wound dean,dry t }covered t )uncovored { I Use the t ftwkV medics according to package lhstruedons:
1:
04 Aft STRAINS,AR RES
{ the irycured pest feu reduce swsliMg. 3:
( peaks for to reduce swelling. { }T AM NJ
( } for for—days. DO NOT OWM ON OPM*MI ACHNW Y Vft"TAKING:
{ "ft taupaptoratq t N� ).for
t )use : ( )A's needed,weW tokrratsd. The P may reduce swIffectiveness
( )At all times.NO WEIGHT BEARING , of medication You we otrremtly taking.Check pacloega kralrruatlons
or consult with Pharmacist.
NECKISA er FOLLOW-UP This le our for fellwm-up.B your
RwL{ )Wear avoid i ndh for support for days. ; Ineurance(�) s pitpaiofaa ralrleeSi.=for spaeieikly corweu ltedon,
( }
Apply moss tee heat liftlrhg,strenuous aotivriY kx Imes . IT IS YOUR REWONIl� J I Y Tel f>aMIN'TIM1 f Y;APPOOVAL
{ )Apply moist heat for rrufrnutss—Imes daily
beginning in hours. { )Fallow-con with: { }Urgi CsnW ( )Om HutalthJCoeipeny Doctor
ADDITIONAL INSTRUCTIONS { )Family Dodo or
in days for: ( )1;01101001,u
{ )Encourage kid Intake { )Suture removal
( liquid diet.Advance to u as ( }The following teat was performeed: t r 4 4
( Off to work on to � ( )CSC { )CMP ( )EKG ( )X-RAY( )CT ( )US ( )OTHER
{ }L,klm Duty until; IF YOU DO NOT HAVE A FAMILY PHYSICIAN CALL 763-29M
FOR PHYSICIAN REFERRAL.
( }No gyrMaports urtlN ( )Can as soon as possible for appointment
t )Fallow kvdnrcdwm on Workman's CaKr�ensation Form. ( )Pick up your X-Rays from the Radiology DepaRment prior to
( )Wear eye patch for hors. your follm-up appointment.Cali 708-21Ig6 lo have One ready.
( }If nose bleed recurs,pinch nose firmly for 5 minutes ( )See your physician or specialist If not Improved in days.
continuously,return N bleeding not controlled. ( )Return to Emergency Center 9 you feel your call*Jm Is worsening,
t )The interpretation of Your X-Rays are preliminary reading.
Your flkns will be reviewed by a radiologist.You or you Il!'it
will be contacted if there is a change in the diagnosis.
PROCEDURES
{ }None .
{ }Laceration Repair { )Your blood pressure was elevated.Check with your physician.
{ I WD
( }Removal of Foreirn Body
( I Procedure!Seddon
{ ) of Dislocation A/ l
( )Other i/
I hereby acknowledge receipt of these loans and Cure Informaton.
I understand that i have had emergency b eau nu#gl*and that I may
be released before all of my medical problems are fmoern or treated.
f will arrange far id>ibvr-up car
4^1 have been Instructed.It is eery
resporbaibHitY of this visit.
SGNATURE: pmer
( )PATIENT/RB a PELiZI�S AKIIIMti
SIGNATURE:
Law Office of Ben a�min Yoffee, P.C.
15 East Main Street
P.O. Box 605
New Bloomfield, PA 17068
(717)582-0122
FAX
TO: Jessica Hoist, Esquire FROM: Benjamin Yoffee, Esquire
COMPANY: DATE: March 21, 2013
FAX NUMBER: 717-243-8026 TOTAL NO. OF PAGES: 5, including
cover
PHONE NUMBER: RE: Crockett v. Bohr
❑ Urgent ❑ For Review ❑ Please Comment oPlease Reply
Notes/Comments:
Following is a Petition far Special Relief that I will be filing this morning in Cumberland County. Please
contact me N you wish to discuss this matter.
HOLLY MARIE CROCKETT,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS
V. OF THE NINTH JUDICIAL DISTRICT
2008-01853 CIVIL TERM
KENNETH EDWARD BOHR,
Defendant/Petitioner IN CUSTODY
IN RE: EMERGENCY CUSTODY PETITION FOR SPECIAL RELIEF PURSUANT TO
RULE 1915.13 OF THE PENNSYLVANIA RULES OF CIVIL PROCEDURE
ORDER OF COURT
AND NOW, this 21st day of March 2013, upon consideration of the Emergency
Custody Petition for Special Relief Pursuant to Rulf 1915.13 of the Pennsylvania Rules
of Civil Procedure, a HEARING is scheduled for 25 March 2013, at 10:30 a.m. in
{ Courtroom Number Six of the Cumberland County Courthouse, 1 Courthouse Square,
Carlisle, Pennsylvania 17013.
PETITIONER shall effectuate service of this Order of Court upon Respondent.
Proof of service shall be filed prior to the time of the hearing.
The sole issue to be addressed at the hearing is the current and immediate
health and well-being of the minor child, Elyssa M. Bohr. The fourteen year-old child
shall not be present at the Courthouse without prior authorization from the court. All
other custody issues shall be referred to a Custody Conciliator.
• No further relief is granted at this time.
f-nm 3C Fn
COURT, �„r'- " ��,
c�
-<l' -�+c
—
C C. ?
Thomas A. Placey C.P.J` C) -'=z
Distribution:
Benjamin Yoffee,Esq.
✓ Jessica Holst,Esq.
�es ,'( -d 31-24�13
HOLLY MARIE CROCKETT, IN THE COURT OF COMMON PLEAS
iffl'Respondent .
CUMBERLAND COUNTY
PENNSYLVANIA
v.
FAMILY DIVISION
KENNETH EDWARD BOER,
'/Pedtione NO.2008-01853 CIVIL TERM
PROOF OF SERVICE
I hemby oettify that I am this clay serving upon the peaons and in the maot indicaW
below. The mesmer of service satisfies the requiranen s of Pa.RCP 400.
Service by Facsimile @ 717-243-8026
Also
r'^s
Service by first class United States Mail,addressed as follows: - 3 w
'Worn a ter=
Jessica Holst,Esquire zr i
lvlid Penn Legal Services
401 E.Louther Street,Suite 103 E
Carlisle,PA 17013 °-''
=C� ter.
Dated: IaQ 2013 Mee--
Be4unin Yolfm Esquire
Attorney ID No.208504
HOLLY MARIE CROCKETT, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS NO. 2008-1853 CIVIL TERM
KENNETH EDWARD BOHR,
Defendant IN CUSTODY
IN RE: EMERGENCY CUSTODY PETITION FOR SPECIAL RELIEF
PURSUANT TO RULE 1915. 13 OF THE PENNSYLVANIA RULES OF CIVIL
PROCEDURE
ORDER OF COURT
AND NOW, this 25th day of March, 2013, upon
consideration of the Emergency Custody Petition for Special
Relief Pursuant to Rule 1915. 3, following a conference with
the parties, the following amendments to the 29 April 2008
custody order are to be included with that order:
1 . The parties shall not permit any contact,
direct or indirect, with their minor child by Ms . Strickland
or Ms . Grossman.
2 . Mother is directed to work with Children
and Youth services and comply with all recommendations
including counseling.
3 . The minor child shall have contact with
the noncustodial parent at least once a day by telephone.
4 . The remaining issues of the petition are
referred to Dawn Sunday, Esquire, for a custody conference.
5 . The minor child is to be returned to
school and is to attend school regularly absent lawful
excuse.
The 29 April 2008 Custody order otherwise
remains in full force and effect until modified by agreement
of the parties or further order of this court .
By the Court,
Thomas A. P1 ey, C. P. J.
t/ Holly Marie Crockett, Pro Se
634 Cumberland Pointe Circle
Mechanicsburg, PA 17055
Benjamin Yoffee, Esquire "rev nc rn;:�
For the Defendant rn 'PP -0 t
CO --Ac:l
Dawn Sunday, Esquire -All
Custody Conciliator
:mlc
Ap f e'-S ilk /"2-/ '-'z
lG
HOLLY MARIE CROCKETT IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
ZZ
V. XM UJ 7-- --2008-1853 CIVIL ACTION LAW M --�
;r 770 -ca r-
KENNETH EDWARD BOHR
D IN CUSTODY
DEFENDANT
r
ORDER OF COURT
AND NOW, Friday,April 05,2013 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,April 19,2013 10:00 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/ Danw S. Sunday,Esq.Ve-11
Custody Conciliator r
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
P/1q Telephone (717)249-3166
5
LL,
H° i "-, ' FF r
HOLLY MARIE CROCKETi2'I3 PR 1 8 PH1 1 3�u al� I ,
Plaintiff CUMBERLAND CO c U 11 i .;�%J1ff"s�mi�M l
1
�
R
PENHSYLVANI Sri`, +,
v. IN THE COURT OF COMMON PLEAS
OF THE NINTH JUDICIAL DISTRICT
2008-1853 CIVIL TERM
KENNETH EDWARD BOHR,
Defendant IN CUSTODY
IN RE: PETITION FOR APPOINTMENT OF GUARDIAN AD LITEM
ORDER OF COURT
AND NOW this 18th day of April 2013, pursuant to 23 Pa.C.S. Section 5334, the
court appoints the Children's Advocacy Clinic of the Penn State Dickinson School of
Law as Guardian Ad Litem for Elyssa M. Bohr, born 29 January 1999, Pursuant to 23
Pa.C.S. Section 5334 (b), the Guardian Ad Litem shall be charged with representing the
legal and best interests of the child during the proceedings and shall do all of the
following:
1. Meet with the child as soon as possible following the appointment, and as
appropriate thereafter.
2. On a timely basis, be given access to relevant court records, reports of
examination of the parents and other custody of the child and medical,
psychological, and school records.
3. Participate in all proceedings.
4. Conduct such further investigation necessary to ascertain relevant facts for
presentation to the court.
5. Interview potential witnesses, including the child's parents and caretakers, if any.
The guardian ad litem may examine and cross-examine witnesses and present
witnesses and evidence necessary to protect the best interests of the child.
6. Make specific recommendations in a written report to the court relating to the
best interests of the child including any services necessary to address the child's
needs and safety. The court shall make the written report part of the record so
that it may be reviewed by the parties. The parties may file with the court written
comments regarding the content of the report. The comments filed by the parties
shall also become part of the record.
7. Explain the proceedings to the child to the extent appropriate given the child's
age, mental condition and emotional condition.
8. Advise the court of the child's wishes to the extent that they can be ascertained
and present to the court whatever evidence exists to support the child's wishes.
When appropriate because of the age or mental and emotional condition of the
child, determine to the fullest extent possible the wishes of the child and
communicate this information to the court.
- - BURT,
A
a
Tho !s A. Placey C.P.J.
Distribution:
molly Marie Crockett, pro se
/B/enjamin Yoffee, Esq.
./Lucy Johnston-Walsh
Children Advocacy Clinic
rs- 112vilscL
eipa
HOLLY MARIE CROCKETT IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. 2008-1853 CIVIL ACTION LAW
KENNETH EDWARD BOHR
Defendant IN CUSTODY
ORDER OF QOURT
AND NOW, this day of UA4 2013, upon
consideration of the attached Custody Conciliation leport, it is brdered and directed as follows:
1. The prior Order of this Court dated April 29, 2008 is vacated and replaced with this Order.
The prior Order of this Court dated March 25, 2013 shall continue in effect.
2. The Mother, Holly Marie Crockett, and the Father, Kenneth Edward Bohr, shall have shared
legal custody of Elyssa Bohr, age 14. 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. §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.
3. The parties shall have physical custody of the Child in accordance with the following
schedule:
A. During the remainder of the 2012-2013 school year, the Mother shall have primary
physical custody of the Child and the Father shall have partial physical custody on alternating
weekends from Friday at a time to be arranged by agreement between the parties through Sunday at
6:00 p.m.
B. Beginning in the 2013-2014 school year, the Child shall reside primarily with the
Father and shall be enrolled in the Newport School District. During the school year, the Mother shall
have custody of the Child on alternating weekends from Friday between 5:00 p.m. and 6:00 p.m.
through Sunday at 5:00 p.m. and during additional times as arranged by agreement between the parties.
C. During the summer school breaks, the parties shall have custody of the Child on an
alternating weekly basis. In 2013, the summer custody schedule shall begin with the Father having
custody on the first weekend after the end of the school year. Beginning in 2014 and continuing
thereafter, the summer custody schedule shall begin with the Mother having custody on the first
weekend after the end of the school year. The summer custody schedule shall end one full week
before the beginning of the new school year.
4. For the remainder of the 2012-2013 school year, the Child shall continue to attend school in
the Mechanicsburg School District. Beginning in the 2013-2014 school year, the Child shall be
enrolled in the Newport School District.
5. The parties shall share or alternate having custody of the Child on holidays as follows:
A. Christmas: The Christmas holiday shall be divided into Segment A, which shall run
from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B, which shall
run from Christmas Day at 12:00 noon through December 26 at 12:00 noon. In even numbered years,
the Mother shall have custody of the Child during Segment A and the Father shall have custody during
Segment B. In odd numbered years, the Father shall have custody of the Child during Segment A and
the Mother shall have custody during Segment B.
B. Thanksgiving: The Thanksgiving holiday shall run from the Wednesday evening
before Thanksgiving through the Friday evening following Thanksgiving. The Father shall have
custody of the Child for Thanksgiving in even numbered years and the Mother shall have custody in
odd numbered years.
C. Easter: The parties shall alternate having custody of the Child on Easter as arranged
by agreement.
D. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule.
E. In the event a holiday period of custody falls immediately preceding or following an
alternating weekend period of custody, the holiday and regular periods of custody shall run
continuously without interruption.
6. Unless otherwise agreed between the parties, the parent receiving custody of the Child shall
be responsible to provide transportation for the exchange of custody.
7. The Father shall contact the Mother by telephone on or before November 1 to arrange for a
parenting meeting between the parties to review the custodial and school arrangements as a result of
the Child's experience during the first semester in the Newport School District. If the parties are
unable to agree as to whether to continue or change the custodial arrangements at that time, either party
may file a Petition to have an additional custody conciliation conference scheduled. In the event the
Mother is the parent who desires the scheduling of an additional conciliation conference and she is not
able to obtain legal services, the Father agrees to file the Petition at the Mother's request.
8. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
9. 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.
10. 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.
Y THE COURT,
Thomas Y I lacey J.
cc: Xenjamin Yoffee Esquire —Counsel for Father
Molly Marie Crockett—Mother
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HOLLY MARIE CROCKETT IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 2008-1853 CIVIL ACTION LAW
KENNETH EDWARD BOHR
Defendant IN CUSTODY
Prior Judge: Thomas A. Placey
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 AGE CURRENTLY IN CUSTODY OF
Elyssa Bohr 14 Mother
2. A custody conciliation conference was held on April 19, 2013, with the following
individuals in attendance: the Father, Kenneth Edward Bohr, with his counsel, Benjamin Yoffee
Esquire, and the Mother, Holly Marie Crockett, who was not represented by counsel in this matter.
3. This Court previously entered an Order on March 25, 2013 on the Father's Emergency
Petition prohibiting contact between the Mother's roommates and the Child, requiring the Mother to
comply with the recommendations of Children& Youth Services and requiring the Child to have
contact with the non-custodial parent on a daily basis. The remaining issues were referred to
conciliation. At the conciliation conference, the parties discussed the very serious issues related to the
Child including her problems in school both academically and socially, her truancy issues in school
and the other issues which were heard by the Court in the Special Relief Hearing. The parties made
the difficult decision to change the primary custody arrangement in an attempt to give the Child a fresh
start in a new school and to address some of the other issues which have arisen.
4. The parties agreed to entry of an Order in the form as attached.
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Date Dawn S. Sunday, Esquire
Custody Conciliator