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HomeMy WebLinkAbout08-3556 JANE E. JONES, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 0 8'.- 3 SSG GNP 1 + STEVEN R. JONES, Defendant CIVIL ACTION -LAW IN CUSTODY COMPLAINT FOR CUSTODY, PARTIAL CUSTODY, OR VISITATION AND NOW, comes the Plaintiff, Jane Jones, by and through his attorney, Bruce Foreman, Esquire, and seeks to obtain custody, partial custody, or visitation of her minor child and makes the following averments in support thereof: 1. Plaintiff is "Mother," an adult individual, who currently resides at 717 Colonial Court, Mechanicsburg, Cumberland County, and State of Pennsylvania. 2. Defendant is "Father," an adult individual, who currently resides at 3000 S. Chester Avenue, space 46, Bakersfield, and State of California 3. Plaintiff seeks custody of the following minor child: Name: Address: Age: Walter Thomas 717 Colonial Court, Mechanicsburg, PA 17050 7 4. The child was not born out of wedlock. 5. The child is presently in the custody of Mother, whose address is 717 Colonial Court, Mechanicsburg, Cumberland County, and State of Pennsylvania 6. During the past 7 years, the child has resided with the following persons at the following address: Persons: Address: Dates Mother Jane Jones, Father Steven Jones, and Cousins Robert R. Jones, Robert R. Jones Jr., and Daniel W. Jones. 5212 Orinda Ave., Las Vegas, NV 89120 -12/2/00 to 10/01/0 Mother Jane Jones, Father Steven Jones, Sister Alexzandra Jones, and nephew Christopher Jones. 2101 South Nellis Blvd., Las Vegas, NV 89121-10/01/02 to 11/16/2003 Mother Jane Jones, Father Steven Jones, Maternal Grandmother Susan Stock, and Maternal Grandfather Walter J. Stock Jr., 1217 Swan Dr., Patterson, CA 95363 -11/16/03 to 3/3/05 Mother Jane Jones, and Father Steven Jones, 3000 South Chester Ave. Sp #46, Bakersfield, CA 93304 - 3/3/05 to 6/19/2007 Mother Jane Jones, Maternal Grandmother Susan Stock and Maternal Grandfather Walter J. Stock Jr., 20 Orchard Ave, Carlisle PA 17015 - 6/19/07 to 9/14/07 Mother Jane Jones, 717 Colonial Ct., Mechanicsburg, PA 17050, 9/14/07 to Present 7. The Mother of the child is Jane Jones, who currently resides at 717 Colonial Court, Mechanicsburg, Cumberland County, and State of Pennsylvania. She is not married. 8. The Father of the child is Steven Jones, who currently resides at 3000 S. Chester Ave., space 46, Bakersfield, California, and State of California. He is not married. 9. The relationship of Defendant to the child is that of Father. Plaintiff currently resides alone. 10. The relationship of Plaintiff to the child is that of Mother. Defendant currently resides with the following people: Names: Walter Jones Relationship: Son 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 another court of this Commonwealth. 13. Plaintiff does not know of a person not a parry to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 14. The best interests and permanent welfare of the children will be served by granting the relief requested because the child should spend greater periods of custody with his mother. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order granting her custody, partial custody, or visitation of the child. Respectfully submitted, FOREMAN, FOREMAN & CARACIOLO, P.C. squire Bruce D. Forema?1193 Attorney ID No. 112 Market Street, 6"' Floor Harrisburg, PA 17101 717-236-9391- Telephone 717-236-6602- Facsimile brucegffclaw.net Attorney for Plaintiff v JANE E. JONES, Plaintiff, V. STEVEN R. JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. p $' - 3 S5 6 c M I -? um CIVIL ACTION - LAW IN CUSTODY VERIFICATION I, Jane Jones, verify that the statements made in this Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: Qwu t. JanJones I JANE E. JONES, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. No. 0?' 35-S-6 +-cr STEVEN R. JONES, CIVIL ACTION -LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Complaint for Custody upon the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, depositing a copy of the same with the United States Postal Service, certified mail, return receipt requested, prepaid, and addressed as follows: Steven R. Jones 3000 S. Chester Ave. Space 46 Bakersfield, California Date: OMPg 1 11 Respectfully submitted, FOREMAN, FOREMAN & CARACIOLO, P.C. - Az A?Z" / I& Bruce D. Foreman, squire Attorney ID No. 21193 112 Market Street, e Floor Harrisburg, PA 17101 717-236-9391- Telephone 717-236-6602- Facsimile bruce(a,ffclaw.net Attorney for Plaintiff n Gq, .rT'. r N a c:a w ZI: CC) 'GYP'S X47 rr1 -n I iS? JANE E. JONES IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-3556 CIVIL ACTION LAW STEVEN R. JONES IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, June 18, 2008 _,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at _4th Floor, Cumberland County Courthouse, Carlisle on Friday, July 25, 2008 at 1:30 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. FOR THE COURT. By: /s/ john J. Mangan, Jr., Esq Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,la(?? g0 b? 9 3Hi JANE E. JONES, Plaintiff V. STEVEN R. JONES, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3556 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY CUSTODY STIPULATION AND AGREEMENT 1. Plaintiff, Jane E. Jones, (hereinafter referred to as "Mother"), is an adult individual currently residing at 717 Colonial Court, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant, Steven R. Jones, (hereinafter referred to as "Father"), is an adult individual currently residing at 3000 South Chester Avenue, Space 46, Bakersfield, State of California. 3. The parties agree to share legal custody of their minor child. All decisions effecting the child's growth and development including, but not limited to: medical and dental treatment; psychiatric or psychological therapy or like treatment; decisions relating to actual or potential litigation involving the child, directly or as a beneficiary, other than custody and litigation; education, both secular and religious; choice of camp, if any; athletic pursuits and extra curricular activities shall be considered major decisions and shall be made by parties jointly, after discussion and consultation with each other and a view toward obtaining and following harmonious policy in the child's best interest. The parties shall endeavor to speak with one another before making any decisions affecting the schedule of the child. The parties further agree that neither shall unilaterally make decisions regarding the child's time that would affect the custodial time of the other parent. 4. Primary physical custody of the child shall be with Mother, subject to a period of physical custody with Father during the minor child's summer recess from school. Said period of physical custody shall be any thirty (30) day period during the minor child's summer recess, with the thirty (30) day period not to fall on the first week of the minor child's summer recess nor the last week of summer recess before the start of school. Father shall notify Mother of when the thirty (30) day period of physical custody is to begin at least sixty (60) days in advance. 5. Transportation shall be the sole responsibility of the party receiving the minor child, including escorting the minor child during any air travel. 6. The parties may modify the schedule as set forth above as they may agree to be in the best interest of the minor child, and the parties are encouraged to be flexible in accommodating reasonable requests for scheduled changes. 7. Liberal visitation of the minor child shall be allowed and encouraged upon the agreement of the parties. 8. Neither Father nor Mother shall use any controlled substances in the presence of the child nor shall they consume alcohol to the point of intoxication in the presence of the child during any period of visitation. 9. The non-custodial parent at any given time shall have reasonable ongoing telephone access to the minor child, and the minor child should not be precluded from telephoning the non-custodial parent at reasonable times. Should the minor child be unavailable to receive a telephone call from the parent, the custodial parent shall be responsible for having the child return the telephone call. 10. Each party shall keep the other advised of a current address and telephone number. 11. The parties shall communicate directly with each other regarding the minor child, and shall not allow any interference from any third persons. The minor child shall not be used as an intermediary. All contact between the parties, whether in person or by telephone, shall be polite, civil, and respectful. 12. The parties shall not conduct or permit arguments or heated conversations in the presence or hearing of the minor child. 13. Neither Father nor Mother shall do anything to estrange the child from the other parent, and both shall encourage the child's relationship with the other parent. Specifically, neither parent shall make or permit any other person in the household to make any remarks or do anything which in anyway could be construed as derogatory or uncomplimentary to the other parent. It shall be the one express duty of each parent to uphold the other as one whom the child shall respect and love. Additionally, neither parent shall make any derogatory or uncomplimentary remarks about the friends, companions and relatives of the other parent in the presence of the child. 14. Each parent shall keep the other advised on an ongoing basis of the schedule of all curricular and extra curricular activities and events in which the minor child is engaged. Both parents shall have the right to attend these activities and events and participate in them to the extent parents are normally allowed or encouraged to do so. During scheduled periods of custody, both parents shall be responsible for the child's attendance at regularly scheduled activities and special events. 15. Both parents shall fully share information including oral and written reports, regarding the minor child concerning all aspects of her life, including, inter alia, religion, summer activities, and friends. Both parents shall take part in all major decisions concerning the minor child; and both parents agree to cooperate to the fullest possible extent in the minor child's upbringing to the end that her relationship with both parents shall be as harmonious as possible. 16. Each party shall advise the other promptly of any illness suffered or injury sustained by the minor child. 17. With regard to any emergency decision which must be made, the parent with whom the child is physically residing at the time shall be permitted to make the decision necessitated by the emergency without consulting the other parent in advance, However, the parent shall inform the other parent of the emergency and consult with him or her as soon as possible. Date: 0A AAA Jones A:.,_ el- Date: o?? n2 Steven R. Jones r? ?? .`.» ??? ?' ? ,; -,,. ? ?x ~ `yr ? i .?:a R? :;? ..? x:162901, , f JANE E. JONES, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-3556 STEVEN R. JONES, CIVIL ACTION -LAW Defendant : IN CUSTODY ORDER OF COURT vla AND NOW, this U day of 2008, upon consideration of the attached Stipulation of the parties in the above captioned matter, consisting of 3 pages and bearing the written consent of the parties, AND upon direction of this Court that the parties need not be present before this Court in order to incorporate their Stipulation into a Consent Order, it is ORDERED that said Stipulation is incorporated herein by reference as if set forth in full and approved as a Consent Order pursuant to Pa.R.C.P. 1915.7. BY THE COURT: \? -4, ?XA ? , J. pro j` 's - JVQ -"sip 90frr/k VINNA iASINIIN:?! d ALN'rl, r' 10 ! Z :6 wv ZZ inn Boot A M%0? l d 3HI 3G ORIGINAL i? e. ED curs L STEVEN R. JONES T? Ii 'i1C 1170OT,wt it 3601 E. Wyoming Ave #24 2,111 APR -4 PH 3: '52 Las Vegas, NV 89104 (661) 599-5562 CUMBERLAND COUNT Defendant in Proper Person P E N N S Y L V A N I A JANE E. JONES, IN THE COURT OF COMMON PLEAS Plaintiff, ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) CIVIL ACTION - LAW STEVEN R. JONES, ) NO. 08-3556 CIVIL TERM Defendant, ) IN CUSTODY PETITION TO HOLD PLAINTIFF IN CONTEMPT OF COURT FOR FAILURE TO PROVIDE COURT ORDERED VISITATION; FOR MODIFICATION OF VISITATION, UNMONITORED TELEPHONIC VISITATION, AWARD OF FEES AND COSTS, AND RELATED RELIEF (**VIA TELEPHONIC VISITATION**) COMES NOW, STEVEN R. JONES, in Proper Person, and files this petition to hold Plaintiff in contempt of court for interfering with court ordered visitation, and request to modify and enforce visitation, and unmonitored telephonic visitation, stating the following: 1. Petitioner herein referred t as Father, resides at 3601 Wyoming Ave #24, Las Vegas, NV 89104. 2. Respondent, hereinafter referred to as Mother, resides at 717 Colonia Court, Mechanicsburg, PA 17050. 3. The above-named parents of Walter James Jones (DOB: 12/2/00) (hereinafter "the Child.") 4. The current Order and Custody Stipulation and Agreement (hereinafter "Agreement" dated July 22, 2008, is attached as Exhibit "A" and incorporated herein by reference (hereinafter "Order")- 5. The parties currently share legal custody of the child. 6. Per paragraph 4 of the Agreement, Mother has primary physical custody of the child. 7. Custody was agreed upon since at the time that the Order was entered father lived in California. Father has since relocated, first back East, where Mother denied Father visitation, and presently to Nevada. 8. Mother has denied Father summer visitation in 2008, 2009 and 2010. When Father was in Pennsylvania, Mother allowed Father supervised visitation only, for one week, at the home of his sister. Mother invited herself and was present the entire week. 9. Judge Ebert has entered all related Orders. 10. That the last custody order was modified in 2008, when the child was 8 years old. The child is presently 10 years old at this time. 11. Defendant attempted to obtain the concurrence of Plaintiff's original attorney but Defendant was advised that said counsel no longer represents the Plaintiff. Given Plaintiff's status as a pro se litigant, Defendant is unable to request concurrence for the relief requested in this Petition. WHEREFORE, Father respectfully requests the following: 1. This matter be scheduled for a Custody Conciliation to modify the terms of the current custody order; 2. That the court hold Mother in contempt of court and award father compensatory visitation for one week in 2008; 2009 and 2010, in addition to summer visitation for a period of six weeks from 2011 forward. 3. That the parties continue to share joint legal custody of the minor child. 4. That specified UNMONITORED telephonic visitation be provided to Father, and that Mother be assigned specified consequences if she violates either the in person or telephonic visitation. 5. That Father be awarded any other relief that is deemed proper in this matter. Dated this day of 32011. STEVEN R. JONES 3601 E. Wyoming Ave #24 Las Vegas, NV 89104 (661) 599-5562 In Proper Person _3 EXHIBIT A JANE E. JONES, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-3556 CIVIL TERM STEVEN R. JONES, CIVIL ACTION - LAW Defendant IN CUSTODY n J CUSTODY STIPULATION AND AGREEMENT 7 fr 1. Plaintiff, Jane E. Jones, (hereinafter referred to as "Mother"), is an adult,?nEJividu% 4- ate, currently residing at 717 Colonial Court, Mechanicsburg, Cumberland Goz ty ai r Pennsylvania. c 2. Defendant, Steven R. Jones, (hereinafter referred to as "Father"), is an adult individual currently residing at 3000 South Chester Avenue, Space 46, Bakersfield, State of California. The parties agree to share legal custody of their minor child. All decisions effecting the child's growth and development including, but not limited to: medical and dental treatment; psychiatric or psychological therapy or like treatment; decisions relating to actual or potential litigation involving the child, directly or as a beneficiary, other than custody and litigation; education, both secular and religious; choice of camp, if any; athletic pursuits and extra curricular activities shall be considered major decisions and shall be made by parties jointly, after discussion and consultation with each other and a view toward obtaining and following harmonious policy in the child's best interest. The parties shall endeavor to speak with one another before making any decisions affecting the schedule of the child. The parties further agree that neither shall unilaterally make decisions regarding the child's time that would affect the custodial time of the other parent. 4. Primary physical custody of the child shall be with Mother, subject to a period of physical custody with Father during the minor child's summer recess from school. Said period of physical custody shall be any thirty (30) day period during the minor child's summer recess, with the thirty (30) day period not to fall on the first week of the minor child's summer recess nor the last week of summer recess before the start of school. Father shall notify Mother of when the thirty (30) day period of physical custody is to begin at least sixty (60) days in advance. 5. Transportation shall be the sole responsibility of the party receiving the minor child, including escorting the minor child during any air travel. 6. The parties may modify the schedule as set forth above as they may agree to be in the best interest of the minor child, and the parties are encouraged to be flexible in accommodating reasonable requests for scheduled changes. 7. Liberal visitation of the minor child shall be allowed and encouraged upon the agreement of the parties. 8. Neither Father nor Mother shall use any controlled substances in the presence of the child nor shall they consume alcohol to the point of intoxication in the presence of the child during any period of visitation. 9. The non-custodial parent at any given time shall have reasonable ongoing telephone access to the minor child, and the minor child should not be precluded from telephoning the non-custodial parent at reasonable times. Should the minor child be unavailable to receive a telephone call from the parent, the custodial parent shall be responsible for having the child return the telephone call. 10. Each party shall keep the other advised of a current address and telephone number. 11. The parties shall communicate directly with each other regarding the minor child, and shall not allow any interference from any third persons. The minor child shall not be used as an intermediary. All contact between the parties, whether in person or by telephone, shall be polite, civil, and respectful. 12. The parties shall not conduct or permit arguments or heated conversations in the presence or hearing of the minor child. 13. Neither Father nor Mother shall do anything to estrange the child from the other parent, and both shall encourage the child's relationship with the other parent. Specifically, neither parent shall make or permit any other person in the household to make any remarks or do anything which in anyway could be construed as derogatory or uncomplimentary to the other parent. It shall be the one express duty of each parent to uphold the other as one whom the child shall respect and love. Additionally, neither parent shall make any derogatory or uncomplimentary remarks about the friends, companions and relatives of the other parent in the presence of the child. 14. Each parent shall keep the other advised on an ongoing basis of the schedule of all curricular and extra curricular activities and events in which the minor child is engaged. Both parents shall have the right to attend these activities and events and participate in them to the extent parents are normally allowed or encouraged to do so. During scheduled periods of custody, both parents shall be responsible for the child's attendance at regularly scheduled activities and special events. 15. Both parents shall fully share information including oral and written reports, regarding the minor child concerning all aspects of her life, including, inter alia, religion, summer activities, and friends. Both parents shall take part in all major decisions concerning the minor child; and both parents agree to cooperate to the fullest possible extent in the minor child's upbringing to the end that her relationship with both parents shall be as harmonious as possible. 16. Each party shall advise the other promptly of any illness suffered or injury sustained by the minor child. 17. With regard to any emergency decision which must be made, the parent with whom the child is physically residing at the time shall be permitted to make the decision necessitated by the emergency without consulting the other parent in advance, However, the parent shall inform the other parent of the emergency and consult with him or her as soon as possible. Date: 0`110'"1 t0Q Ja E. Jones Date: Steven R. Jones Aj-- STEVEN R. JONES 3601 E. Wyoming Ave #24 Las Vegas, NV 89104 (661) 599-5562 Defendant in Proper Person JANE E. JONES, ORIGINAL Fiver 0 _ FICL ,IF 1 HE PROTHONOTARY 2011 APR -4 PSI 3: 52 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS Plaintiff, ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) CIVIL ACTION - LAW STEVEN R. JONES, ) NO. 08-3556 CIVIL TERM Defendant, ) IN CUSTODY CERTIFICATE OF SERVICE I, 5 ?G?CJL h? , Jo IV&5, hereby certify that I am on this day serving a copy of the Petition for Contempt and Modification upon the person and in the manner indicated below: Service by First-Class Mail, postage prepaid, and addressed as follows: Jane E. Jones 717 Colonia Court Mechanicsburg, PA 17050 Dated this .3 t day of &- , 2011. Person Serving JANE E. JONES, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA c V. STEVEN R. JONES, DEFENDANT NO. 08-3556 CIVIL C-) ORDER OF COURT == c ?: -°4' AND NOW, this 27th da y of April, 2011, upon consideration of Steven R. Jones' Pro Se Petition to Hold Plaintiff in Contempt of Court; IT IS HEREBY ORDERED AND DIRECTED that: 1. Mother, Jane Jones, shall file an Answer to the Petition on or before May 19, 2011. 2. The Court Administrator shall schedule this matter to be heard before a custody conciliator. Father will be authorized to participate in the conciliation hearing by telephone. By the Court, M. L. Ebert, Jr., ? Jane Jones 711 Colonia Court Mechanicsburg, PA 17050 Steven Jones 3601 E. Wyoming Avenue, #24 Las Vegas, NV 89104 Court Administrator P'??lC ? )), bas / Copies Mo?d 4' a7/tl okh J. t r' GrFtvC. Foreman & Caraciolo, P.C. i t (a a Try t Y, Bruce D. Foreman, Esquire Attorney ID No. 21193 112 Market Street, 6'h Floor „„ _ t 4 i t I 231 1 Net. I 1 Y Harrisburg, PA 17101 (717) 236-9391 CUMBERLAND COUNTY Fax 02 PENNSYLVANIA bruce@ffclaw.net Attorney for Plaintiff JANE E. JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. STEVEN R. JONES, Defendant : NO. 08-3556 CIVIL TERM CIVIL ACTION-LAW IN CUSTODY RESPONSE OF PLAINTIFF TO DEFENDANT'S PETITION TO HOLD PLAINTIFF IN CONTEMPT OF COURT AND NOW, comes the Plaintiff, Jane E. Jones, and in response to a Petition to Hold Plaintiff in Contempt of Court filed by Defendant, Steven R. Jones, replies, as follows: 1. Plaintiff is unaware of Petitioner's current residence and, accordingly, has insufficient information to respond to the truth or falsity of Paragraph 1 of Petitioner's Complaint. 2. In the copy of the Petition recently forwarded by Petitioner to Plaintiff, Plaintiff's address is listed as 717 Colonia Court, Mechanicsburg, PA 17050; Respondent's actual address is 717 Colonial Court, Mechanicsburg, PA 17050. 3. Admitted in part and denied in part; the parties are the parents of a child born December 2, 2000 but Petitioner apparently does not know his son's middle name which is Thomas and not James as asserted by Petitioner. 4. Admitted. 5. Admitted. 6. Admitted. 7. Denied as stated; to the contrary, Plaintiff is unaware of Petitioner's address as, despite the mandate to do so in their current Custody Order, Petitioner does not provide his current location to Plaintiff and frequently does not respond to phone calls or messages from Plaintiff and will not participate in co-parenting with Plaintiff. Plaintiff is not aware of where Petitioner relocated at various times but has always been amenable to visitation for Petitioner with his child when Petitioner, in advance, makes arrangements, as required by the existing Custody Order. 8. Denied as stated; Plaintiff has always been willing to provide visitation to Petitioner over any summer pursuant to the agreed upon Custody Order which states that Father may designate a thirty (30) day period during the child's summer recess, which period shall not fall on the first week of the child's summer recess from school nor the last week of the summer recess from school but which period will require Father to notify Mother at least sixty days in advance. At no time since the Custody Order has been in effect has Petitioner provided Plaintiff with sixty days advance notice of any request for visitation. By way of further response, it is noted that the minor child of the parties hereto will commence a summer vacation period from school in approximately thirty days but Petitioner has still not provided Plaintiff with notice of a specific thirty day period or any lesser period during which he wishes to have the child. By way of further response, due to learning disability problems, as Petitioner is aware, the child, Walter Jones, participates in a summer school program in the Cumberland Valley School District so as to not fall behind which further complicates visitation over the summer and, in the best interest of the child, should not be disrupted. Nonetheless, Petitioner will not discuss a summer visitation schedule which could accommodate both notice and summer school requirements for the said minor child. 9. Admitted. 10. Admitted. 11. Denied; Petitioner is required to request concurrence from counsel and, it is asserted, that Petitioner is aware that Plaintiff's current counsel is the undersigned. By way of further response, if Petitioner did not know how to contact Plaintiff's attorney, it would be the responsibility of Petitioner to contact Plaintiff and attempt to get concurrence which he did not do. Plaintiff has been and remains willing to provide a period of custody over the summer pursuant to the Court Order with sixty days notice or, in the best interest of the child, a lesser period with less than sixty days notice but which would not interfere with the child's summer school schedule pursuant to a joint agreement authorized under the existing Custody Stipulation and Agreement. WHEREFORE, Plaintiff respectfully requests that Petitioner's Petition be dismissed with costs taxed against Petitioner. NEW MATTER 12. Plaintiff incorporates the answers to Paragraph 1 through 11 of Petitioner's Petition herein as fully as if set forth. 13. Paragraph 5 of the existing Custody Order requires that the party receiving the custody of Child be responsible for and escort the Child during any travel. Despite Plaintiff's inquiring of Petitioner about travel plans, Petitioner has never paid for nor been responsible for travel arrangements for the child either in coming to or returning from Petitioner nor offered to be responsible for the same; Plaintiff requests that, to the extent that visitation is arranged for Petitioner, Petitioner abide by Paragraph 5 of the existing Order requiring that he transport and be responsible for escorting the child in transit to him. Plaintiff believes and therefore avers that Petitioner does not have a valid driver's license. 14. Paragraph 10 of the said Custody Order requires that each party keep the other party advised of a current address and telephone number. Petitioner has refused and failed to provide the same and continues to refuse and fails to do so; Plaintiff requests, before any visitation be considered, that Petitioner provide the same to Plaintiff. 15. In Paragraph 8 of Petitioner's Petition, he suggests that there was no summer visitation in 2008 under the existing Court Order but Plaintiff notes that said Court Order was not in existence at that time. WHEREFORE, Plaintiff respectfully requests that Petitioner's Petition be dismissed with costs taxed against Petitioner. Respectfully submitted, FOREMAN & CARACIOLO, P.C. 1-/? Q?? Date: - ?I-Bruce D. Fore Esquire Attorney ID No. 2 193 112 Market Street, 6`h Floor Harrisburg, PA 17101 (717) 236-9391 Attorney for Plaintiff Foreman & Caraciolo, P.C. Bruce D. Foreman, Esquire Attorney ID No. 21193 112 Market Street, 60' Floor Harrisburg, PA 17101 (717) 236-9391 Fax (717) 236-6602 bruce@ffclaw.net Attorney for Plaintiff JANE E. JONES, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-3556 CIVIL TERM STEVEN R. JONES, CIVIL ACTION-LAW Defendant IN CUSTODY VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. To the extent that any of the averments are based upon an understanding or application of law, I have relied upon counsel in making this Verification. 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 dd i .. ?n. C' hf=n-- J E. JONES Foreman & Caraciolo, P.C. Bruce D. Foreman, Esquire Attorney ID No. 21193 112 Market Street, 6 h Floor Harrisburg, PA 17101 (717) 236-9391 Fax (717) 236-6602 bruce@ffclaw.net Attorney for Plaintiff JANE E. JONES, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-3556 CIVIL TERM STEVEN R. JONES, CIVIL ACTION-LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Response to Defendant's Petition and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by First Class Mail addressed to the following person: Steven R. Jones 3601 E. Wyoming Ave. #24 Las Vegas, NV 89104 Date: Respectfully submitted, FOREMAN & CARACIOLO, Bruce D. Foreman, E4Auire Attorney ID No. 21193 112 Market Street, 6tn Floor Harrisburg, PA 17101 (717) 236-9391 Attorney for Plaintiff JANE E. JONES PLAINTIFF . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-3556 CIVIL ACTION LAW C= STEVEN R. JONES = -a° IN CUSTODY 2,M! DEFENDANT Cdr fir-, ORDER OF COURT C: r ?..? AND NOW, Thursday, May 05,...2011 , upon consideration of the attached #Co"I aik it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at___ 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, June 07, 2011 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR. THE COURT. By: /s/ ohn I. Man-an, r. 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. -?Ieven P, T,, e, Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 /e ('Op; es is .)ed 5??/i? JANE E. JONES, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA G? V. / STEVEN R. JONES, DEFENDANT NO. 08-3556 CIVIL ORDER OF COURT AND NOW, this 27th day of April, 2011, upon consideration of Steven R. Jones' Pro Se Petition to Hold Plaintiff in Contempt of Court; IT IS HEREBY ORDERED AND DIRECTED that: 1. Mother, Jane Jones, shall file an Answer to the Petition on or before May 19, 2011. 2. The Court Administrator shall schedule this matter to be heard before a .4m stody conciliator. Father will be authorized to participate in the conciliation hearing by telephone i,\1u.$1`t Jane Jones 711 Colonia Court Mechanicsburg, PA 17050 Steven Jones 3601 E. Wyoming Avenue, #24 Las Vegas, NV 89104 bas l By the Court, M. L. Ebert, Jr., J. se- /7? C) 211, JANE E. JONES, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-3556 CIVIL ACTION LAW STEVEN R. JONES, IN CUSTODY Defendant Prior Judge: M.L. Ebert, Jr., J. ORDER OF COURT AND NOW this 101h day of October 2011, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. The prior Order of Court entered July 22, 2008 shall be in full force and effect pending further Order of Court or agreement of the parties. 2. In light of the fact that Mother did not participate in the conference, either party may contact the assigned conciliator to reschedule the custody conference. The parties are directed to provide verification to the assigned conciliator that the other party was properly notified. 3. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, 9.istribution: "/? even Jones, 3601 E. Wyoming Ave, #24, Las Vegas, NV 89104 J Jones, 717 Colonial Crt, Mechanicsburg, PA 17050 John J. Mangan, Esquire Co ?'e?s .rte ? P .? ....eY c aa? JANE E. JONES, Plaintiff V. STEVEN R. JONES, Defendant Prior Judge: M.L. Ebert, Jr., J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08-3556 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Walter J. Jones 12/02/2000 Primary Mother 2. A stipulated Order of Court and agreement dated 07/22/2008 was issued. A Conciliation Conference was supposed to be held 06/07/2011, Father did appear by phone, but Mother was unable to be reached. There may have been an issue of notice to the parties. 3. The undersigned recommends the entry of an Order in the form as attached. Date John J. an, Esquire Custody Conciliator