HomeMy WebLinkAbout08-5548FRIDAY CHELLEY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 08- CIVIL TERM
CONNIE ROESLER, :CUSTODY
Defendant
COMPLAINT FOR CUSTODY
1. Plaintiff is Friday Chelley, (Father). Father resides at 2400 Market Street, Apartment
C83, Harrisburg, Dauphin County, Pennsylvania 17103.
2. Defendant is Connie Roesler, (Mother). Mother resides at 37 South Bedford Street,
Carlisle, Cumberland County, Pennsylvania, 17013..
3. Father seeks partial custody of the minor child:
Name Present Residence
Alvin Roesler 37 South Bedford Street
Carlisle, PA 17013
Alvin was born out of wedlock.
Alvin is currently in custody of mother.
4. Father lives alone.
5. Mother currently lives with the following persons
Name
Mr. & Mrs. Roesler
Relationship
Age
DOB: 7/23/08- age 7 weeks
Maternal Grandparents
6. Father has not participated as a party or witness, or in any other capacity, in other custody
litigation concerning the custody of Alvin in this or any other court.
7. Father has no knowledge of a custody proceeding concerning Alvin in a court of this
Commonwealth.
8. Father does not know of a person not a party to the proceedings who has physical custody
of Alvin or claims to have custody or visitation rights with respect to Alvin.
9. The best interest and permanent welfare of Alvin will be served by granting the relief
requested for reasons including, but not limited to the following:
a. Father has provided ample financial support for Mother, and continues to give
money to Mother to take care of Alvin when Mother allows it.
b. Despite the end of the relationship between Father and Mother, Father tried to
maintain contact with Alvin and develop a father/son relationship with him.
c. Father is willing and able to care for Alvin during periods of partial custody and
he is committed to establishing and nurturing a healthy father/son relationship
with him.
d. Father is willing to work with Mother to co-parent Alvin and will communicate
with Mother to best serve Alvin's interests.
10. Mother is not acting in Alvin's best interest in ways including but not limited to the
following:
a. Since Alvin's birth, Mother has repeatedly denied contact with Father and will not
allow Father to see Alvin.
b. Mother has moved without informing Father of the new address.
c. Mother has deliberately acted in a manner to interfere with, if not prohibit, Father
from establishing his relationship with Alvin.
11. Every person with rights to custody or having actual physical custody of Alvin has been
named as parties to this action.
WHEREFORE, Father requests this Court to grant him the following relief:
1. That the parties shall share legal custody of Alvin.
2. Grant the Mother primary physical custody of Alvin.
3. Grant the Father periods of partial custody with Alvin.
4. That the parties shall have an appropriate holiday schedule so that both parents can
spend time with Alvin during the various holidays.
5. Grant the non-custodial parent reasonable telephone contact with Alvin when he is in
the custody of the other parent.
6. Any other relief this Courts finds just and equitable.
Respectfully submitted,
' Alo, Esquire
i Legal Services
,outher Street
Carlisle, PA 17013
(717)243-9400
VERIFICATION
The above-named PLAINTIFF, Friday Chelley, 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 : S n---\?a/ Zy, 2 ox
Friday Chelleyo'
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FRIDAY CHELLEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 08- CIVIL TERM
CONNIE ROESLER
Defendant CUSTODY
CERTIFICATE OF SERVICE
I, Grace D'Alo, Esquire, of MidPenn Legal Services, attorney for the Plaintiff,
Friday Chelley, hereby certify that I have served a copy of the foregoing Custody
Complaint on the following date and in the manner indicated below:
U.S. First Class Mail, Postage Pre-Paid
Connie Roesler
37 S. Bedford St.
Carlisle, PA 17013
MidPenn Legal Services, Inc.
Date: s-
ace D'Alo, Esquire
idPenn Legal Services
401 E. Louther Street
Carlisle, PA 17013
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FRIDAY CHELLEY,
Plaintiff
V.
CONNIE ROESLER,
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO. 08- 5518
CUSTODY
CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
Kindly allow, Friday Chelley, Plaintiff, to proceed in forma au ris.
I, Grace E. D'Alo, attorney for the party proceeding in forma au eris, certify that
I believe the party is unable to pay the costs and that I am providing free legal services to
the party.
J? siica Diamondstone
C.Jffrey Biringer
Attorneys for Plaintiff
MidPenn Legal Services
401 E. Louther St.
Carlisle, PA 17013
(717) 243-9400
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FRIDAY CHELLEY IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
CONNIE ROESLER
DEFENDANT
2008-5548 CIVIL ACTION LAW
. IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, September 23, 2008 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 21, 2008 at 8:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. 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/ ac ueline M. Verne Es .
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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OCT 9 2 2008 q
FRIDAY CHELLEY,
Plaintiff
V.
CONNIE ROESLER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2008-5548
CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this 11?7ay of a4t..." , 2008, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
I . The Father, Friday Chelley and the Mother, Connie Roesler, shall have
shared legal custody of Kevin Matthew Roesler, born July 24, 2008. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the Child's general well-being including, but not limited
to, all decisions regarding his health, education and religion. Pursuant to the terms of 23
Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to
the child including, but not limited to medical, dental, religious or school records, the
residence address of the child and the other parent. To the extent one parent has
possession of any such records or information, that parent shall be. required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent. Both parents shall be
entitled to full participation in all educational and medical/treatment planning meetings
and evaluations with regard to the minor child. Each parent shall be entitled to full and
complete information from any physician, dentist, teacher or authority and copies of any
reports given to them as parents including, but not limited to: medical records, birth
certificates, school or educational attendance records or report cards. Additionally, each
parent shall be entitled to receive copies of any notices which come from school with
regard to school pictures, extracurricular activities, children's parties, musical
presentations, back-to-school nights, and the like.
2. Mother shall have primary physical custody of the child.
3. Father shall have periods of supervised visitation with the child every
Monday and Thursday from 10:30 a.m. to 1:30 p.m. The supervisor shall be the family
friend, Emily, and shall occur at Emily's home.
4. 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. Another
lJ " a
Custody Conciliation Conference is scheduled for Monday, November 24, 2008 at 10:30
a.m.
cc.' Christine Mathias, certified legal intern, Counsel for Father
grace D'Alo, Esquire, Mid Penn Legal Services,
?Connie Roesler, pro se
37 South Bedford Street
Carlisle, PA 17013
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FRIDAY CHELLEY,
Plaintiff
V.
CONNIE ROESLER,
Defendant
PRIOR JUDGE: None
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2008-5548 CIVIL ACTION - LAW
: IN CUSTODY
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
Kevin Matthew Roesler
DATE OF BIRTH CURRENTLY IN CUSTODY OF
July 24, 2008
Mother
2. A Conciliation Conference was held in this matter on October 21, 2008,
with the following in attendance: The Father, Friday Chelley, with his counsel, Christine
Mathias, certified legal intern and Grace D'Alo, Esquire, MidPenn Legal Services and
the Mother, Connie Roesler, pro se.
3. The parties agreed to an Order in the form as attached.
to-a?-off
Date acq line M. Verney, Esquire
Custody Conciliator
y
NOV 2 5 2008 C11
FRIDAY CHELLEY,
Plaintiff
V.
CONNIE ROESLER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2008-5548
CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this 74"- day of , 2008, upon - ji oot? consideration of the attached Custody Conciliation Report, it is or ered and directed as
follows:
The prior Order of Court shall remain in full force and effect except as
modified hereinafter.
2. Mother and Father shall share legal custody of the child, as outlined in
Paragraph One of the Order of Court dated October 24, 2008.
Mother shall have primary physical custody of the child.
4. Father shall have periods of partial physical custody of the child every
Saturday from 10:00 a.m. to 6:00 p.m. and Sunday from 12:00 p.m. to 6:00 p.m.
5. Mother shall provide breast milk and a change of clothing for the child
during Father's periods of partial custody. Father shall provide formula (currently Similac
Alimentum), diapers, blankets, and an approved car seat for transporting the child during
his periods of partial custody. If Father does not have a proper car seat for transportation
of the child, Father shall not remove the child from Mother's custody.
6. Father shall be responsible for all transportation.
7. Father's first weekend of partial custody shall take place at Father's
mother's home. Thereafter, Father may exercise his periods of partial custody at any
appropriate location of his choosing.
Mother and Father shall share custody of the child on holidays as mutually
agreed.
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9. Mother and Father shall keep each other informed of current contact
information including telephone numbers.
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10. Mother and Father shall notify each other of all medical care the child
receives while in the parent's care. Mother and Father shall notify the other immediately
of medical emergencies which arise while the child is in that parent's care.
11. Neither parent shall do anything which may estrange the child from the
other party, or injure the opinion of the child as to the other parent or which may hamper
the free and natural development of the child's love and respect for the other parent.
12. 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. Another
Custody Conciliation Conference is scheduled for Tuesday, February 24, 2009 at 8:30
a.m.
BY
Edgar B.
URT,
cc: Grace D'Alo, Esquire, Mid Penn Legal Services, C
Nicole Berman, certified legal intern, Counsel for N
Anne MacDonald-Fox, Esquire, Family Law Clinic
P.J.
for Father ?
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FRIDAY CHELLEY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2008-5548 CIVIL ACTION - LAW
CONNIE ROESLER,
Defendant : IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley, P.J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Kevin Matthew Roesler July 24, 2008 Mother
2. A Conciliation Conference was held in this matter on November 24, 2008,
with the following in attendance: The Father, Friday Chelley, with his counsel, Grace
D'Alo, Esquire, MidPenn Legal Services and the Mother, Connie Roesler, with her
counsel Nicole Berman, certified legal intern and Anne MacDonald-Fox, Esquire, Family
Law Clinic.
3. The Honorable Edgar B. Bayley previously entered an Order of Court
dated October 24, 2008 providing for shared legal custody, Mother having primary
physical custody and Father having periods of supervised visitation.
4. The parties agreed to an Order in the form as attached.
Date acq line M. Verney, Esquire
Custody Conciliator
FEB 2 5 mm6
FRIDAY CHELLEY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2008-5548 CIVIL ACTION - LAW
CONNIE ROESLER,
Defendant : IN CUSTODY
ORDER OF COURT
AND NOW, this _7-V& day of , 2009, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Orders of Court dated October 24, 2008 and November 25, 2008
shall. remain in full force and effect except as modified hereinafter.
2. Father shall have periods of partial physical custody on alternating
weekends from Saturday at 10:00 a.m. to Sunday at 6:00 p.m. Said alternating weekends
shall begin immediately, provided Father give Mother a picture of the crib he has
available for the baby to sleep in. Father's alternating weekends shall be delayed until
the photo is provided to Mother.
3. Father shall have partial physical custody of the child on every
Wednesday from 2:30 p.m. to 5:30 p.m.
4. Father shall notify Mother if he must cancel any period of partial physical
custody at least 24 hours in advance.
5. Mother shall provide Father with a copy of the child's birth certificate and
social security card.
6. 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: -ace D'Alo, Esquire, Mid Penn Legal Services, Counsel for Father
aren Fernandez, certified legal intern, Counsel for Mother
Anne MacDonald-Fox, Esquire, Family Law Clinic
CO /at F.S mt. c l
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FRIDAY CHELLEY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2008-5548 CIVIL ACTION - LA 3V ,I, N-,,
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CONNIE ROESLER,
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Defendant : IN CUSTODY ??-
ORDER OF COURT
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AND NOW, this day of 2009, upon A
consideration of the -attached Custody Conciliation Report , it is ordered and directed as
follows:
I . The prior Orders of Court dated October 24, 2008, November 25, 2008
and March 2, 2009 shall remain in full force and effect except as modified hereinafter.
2. Father shall have periods of partial physical custody as follows:
A. On alternating weekends beginning June 24, 2011 from Friday at 2:00
p.m. to Monday at 2:00 p.m.
B. Every Wednesday from 11:00 a.m. to 2:30 p.m. provided he give 48
hour notice to the child's daycare provider that he intends to exercise said
period of custody.
3. Father shall pick up and return the child to daycare. However in the event
that Father misbehaves or causes problems at daycare, and the daycare provider validates
the instances of misbehavior in a letter, then Father forfeits his right to pick up the child
at daycare. In such an instance, Father shall then pick up and drop off the child at
Mother's residence at 5:00 p.m. Also, Father's right to periods of physical custody on
Wednesday shall be forfeited.
4. The parties shall only call the other party in an emergency.
5. Fattier shall assure that he uses appropriate language around the child, that
the child is bathed and has proper nutrition during his periods of physical custody.
6. 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,
Z? I-OIL
J.
cc: Marylou Matas, Esquire, Counsel for Father
Patrick Boyer, certified legal intern, Counsel for Mother j?
? Megan Riesmeyer, Esquire, Family Law Clinic ?l p?
FRIDAY CHELLEY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2008-5548 CIVIL ACTION - LAW
CONNIE ROESLER,
Defendant : IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley, P.J.
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
Kevin Matthew Roesler July 24, 2008 Mother
2. A Conciliation Conference was held in this matter on June 14, 2011, with
the following in attendance: The Father, Friday Chelley, with his counsel, Marylou
Matas, Esquire, and the Mother, Connie Roesler, with her counsel Patrick Boyer,
certified legal intern and Megan Riesmeyer, Esquire, Family Law Clinic.
3. The Honorable Edgar B. Bayley previously entered Orders of Court dated
October 24, 2008, November 25, 2008 and March 2, 2009 providing for shared legal
custody, Mother having primary physical custody and Father having periods of partial
physical custody.
4. The parties agreed to an Order in the form as attached.
6-' N- ??.
Date J ueline 'MV
ey, Esquir
Custody Conciliator
FRIDAY CHELLEY,
Plaintiff
V.
CONNIE ROESLER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.2008-5548
CIVIL ACTION -LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this ,.,3 day of ~~ ~~--~~- ,- upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Orders of Court dated June 16, 2011, October 24, 2008,
November 25, 2008 and March 2, 2009 are hereby vacated.
2. Father's Petition for Contempt is hereby withdrawn.
3. The Father, Friday Cheney and the Mother, Connie Roesler, shall have
shared legal custody of Kevin Matthew Roesler, born July 24, 2008. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the Child's general well-being including, but not limited
to, all decisions regarding his health, education and religion. Pursuant to the terms of 23
Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to
the child including, but not limited to medical, dental, religious or school records, the
residence address of the child and the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent. Both parents shall be
entitled to full participation in all educational and medical/treatment planning meetings
and evaluations with regard to the minor child. Each parent shall be entitled to full and
complete information from any physician, dentist, teacher or authority and copies of any
reports given to them as parents including, but not limited to: medical records, birth
certificates, school or educational attendance records or report cards. Additionally, each
parent shall be entitled to receive copies of any notices which come from school with
regard to school pictures, extracurricular activities, children's parties, musical
presentations, back-to-school nights, and the like.
4. During the school year:
A. Mother shall have primary physical custody of the child.
B. Beginning November 30, 2012, Father shall have periods of partial
physical custody three weekends in a row then Mother shall have one
weekend, then Father shall have three weekends in a row and continue
alternating thereafter. Father's periods of custody shall be from Friday at
1:30 p.m., when he shall pick up from daycare, until Monday at 9:00 a.m.
when Father shall deliver the child to daycare. Mother shall assure that
the child is in daycare on Father's weekends. If not in daycare, Mother
shall contact Father and advise him where he can pick up the child for his
weekend custody.
During the summer:
A. Father shall have primary physical custody of the child.
B. Mother shall have three weekends in a row, then Father shall have one
weekend, then Mother shall have three weekends and alternate thereafter
from Friday at 1:30 p.m. to Monday at 9:00 a.m.
6. Holidays:
A. Christmas shall be divided into two Blocks. Block A shall be from
December 24 at 1:30 p.m. to December 28 at 1:30 p.m. Block B shall be
from December 28 at 1:30 p.m. to January 2 at 9:00 a.m. Mother shall
have physical custody of the child for Block A in even numbered years
and Block B in odd numbered years. Father shall have physical custody of
the child for Block A in odd numbered hears and Block B in even
numbered years.
B. Thanksgiving shall be divided into two Blocks. Block A shall be from
Wednesday at 1:30 p.m. or after school to Friday at 5:00 p.m. Block B
shall be from Friday at 5:00 p.m. to Monday at 9:00 a.m. or the start of
school. Father shall have physical custody of the child for Block A in odd
numbered years and Block B in even numbered years. Mother shall have
physical custody of the child for Block A in even numbered years and
Block B in odd numbered years.
C. Memorial Day and Labor Day. In the event that these holidays
coincide with Father's weekend period of physical custody, his time shall
be extended to Tuesday at 9:00 a.m. or the start of school.
7. Transportation shall be such that during the school year, Father shall be
responsible for all transportation. During the summer, Mother shall be responsible for all
transportation.
8. Exchanges are generally to be made at daycare or school. If no daycare or
school, then the child shall be picked up or dropped off at maternal grandmother's home.
9. The parties shall have reasonable telephone contact with the child. In this
regard the parties shall keep the other apprised of each other's current telephone number.
The subject matter of the calls shall only be custody issues/exchanges or matters
pertaining to the child. If a phone message is left on voice mail the recipient parent shall
return the call within 30 minutes.
10. Neither party may expose the child to adult movies.
11. RELOCATION: 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.
12. 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: /Marylou Matas, Esquire, Counsel for Father t:-~
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FRIDAY CHELLEY,
Plaintiff
V.
CONNIE ROESLER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.2008-5548 CIVIL ACTION -LAW
IN CUSTODY
PRIOR JUDGE: Kevin A. Hess, P.J.
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
Kevin Matthew Roesler July 24, 2008
Mother
2. A Conciliation Conference was held in this matter on November 28, 2012,
with the following in attendance: The Father, Friday Cheney, with his counsel, Marylou
Matas, Esquire, and the Mother, Connie Roesler, with her counsel Ria Periera, certified
legal intern and Megan Riesmeyer, Esquire, Community Law Clinic.
3. The Honorable Kevin A. Hess previously entered Orders of Court dated
June 16, 2011, October 24, 2008, November 25, 2008 and March 2, 2009 providing for
shared legal custody, Mother having primary physical custody and Father having periods
of partial physical custody on alternating weekends Friday to Monday and every
Wednesday afternoon.
4. The parties agreed to an Order in the form as attached.
Date
/1/(, , /,~ . ,~ ~~
acq line M. Verney, Esquire
Custody Conciliator
FRIDAY CHELLEY,
IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v.
CONNIE ROESLER,
Defendant
To the Prothonotary:
CIVIL ACTION — LAW
NO. 2008 -5548 CIVIL ACTION LAW
n�co
zr
PRAECIPE TO PROCEED IN FORMA PAUPERIS>c
> ry
IN CUSTODY
J. MASLAND
Kindly allow, Friday Chelley, Plaintiff in the above action, to proceed in forma pauperis.
I, Marylou Matas, Esquire, attorney for the party proceeding in forma pauperis, certify
that I believe the party is unable to pay the costs and that I am providing free legal services to
the party.
Date:
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
Zr.
Respectfully submitted,
SAIDIS, SULLIVAN & ROGERS
1
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Mar M as Es u�e
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Attorney Id. 4919
26 West High Street
Carlisle, PA 17013
(717) 243 -6222
Counsel for Plaintiff
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
FRIDAY CHELLEY,'
Plaintiff :•
t
I s y L
CONNIE ROESLER,
Defendant
L.)
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION — LAW
NO. 2008-5548 CIVIL ACTION LAW
IN CUSTODY
J. MASLAND
PETITION FOR CONTEMPT AND MODIFICATION OF CUSTODY
NOW COMES FRIDAY CHELLEY, by and through his counsel, Marylou Matas,
Esquire, Saidis, Sullivan & Rogers, and petitions this Honorable Court as follows:
1. Petitioner (hereinafter referred to as "Father") is Friday Chelley, who resides
at 2400 Market Street, Apt. C83, Harrisburg, Dauphin County, Pennsylvania 170103.
2. Respondent (hereinafter referred to as "Mother") is Connie Roesler, whose
last known address is 37 South Bedford Street, Carlisle, PA 17013, and who is represented
by the Children's Advocacy Clinic.
3. The parties are the parents of one child, Kevin Matthew Chelley, born July
24, 2008, age 4.
4. On December 3, 2012, this Honorable Court entered an Order with regard to
custody of the child. A copy of the Court's Order is attached hereto as Exhibit "A".
5. Pursuant to the Court's Order, the parents exercise shared legal custody; the
child resides primarily with Mother during the school year; the child resides primarily with
Father during the summer.
6. The parties agreed to enroll the child at the Milton Hershey School, in
Hershey, Pennsylvania; he was accepted for enrollment beginning January 27, 2014. This
Agreement was documented through correspondence from Mother's counsel, dated
January 31, 2014, a copy of which is attached hereto and incorporated herein as Exhibit
"B."
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
7. According the visitation policy provided to the parents prior to enrollment, the
parties were made aware prior to the enrollment that the child would have limited access to
his parents, through visitation or otherwise, for the first several months.
8. As documented in Exhibit B, Mother felt it important to strictly follow school
rules and desired to communicate the importance of rules to Father.
9. As documented in Exhibit B, Mother expressed her clear interest and desire
in exercising the limited visitation with the child after consultation with Father.
COUNT I — MODIFICATION OF CUSTODY
10. Paragraphs 1 -9 are incorporated herein as if repeated in full.
11. The child was scheduled for spring /Easter break from the Milton Hershey
School, from April 18 -April 27, 2014.
12. Prior to the break, the parties, without the assistance of counsel, agreed that
they would divide the break between themselves, so that Mother would pick up the child
from school on April 18. Father was to retrieve the child from Mother's home in Carlisle on
Monday, April 21, 2014, through Thursday, April 24, 2014. Mother would exercise custody
again from Friday through Sunday, at which time she would return the child to school.
13. On Monday, April 18, when Father arrived at Mother's home in Carlisle, she
refused to allow Father access to the child for his period of visitation.
14. Father was denied contact with the child for the limited period of time the
child with have the ability to spend with his Father during the spring.
15. Because Father was denied contact with his child during this spring break,
Father is concerned that he will be unable to see his child until the summer begins.
16. The child has additional breaks from school during the school year; the
parties do not have a firm agreement with regard to how these breaks will be divided
between them.
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
WHEREFORE, Father requests your Honorable Court to modify the Custody
Agreement to provide for a visitation schedule for the school year when the child attends
Milton Hershey School.
COUNT II — CONTEMPT
17. Paragraphs 1 -16 are incorporated herein as if restated in full.
18. The parties, pursuant to the Order of Court dated December 3, 2012, shared
legal custody of the child.
19. Mother has threatened to refuse to return the child to the Milton Hershey
School where he is enrolled as a full time student.
20. Father disagrees, vehemently, with that decision.
21. Pursuant to paragraph 2 of their Order, December 3, 2012:
Each parent shall have an equal right, to be exercised jointly with the other
parent, to make all major non - emergency decision affecting the Child's general well -being
including, but not limited to, all decisions regarding his health, education and religion.
Both parent[s] shall be entitled to full participation in all educational and
medical /treatment planning meetings and evaluations with regard to the minor child.
22. Father firmly believes it is in the child's best interest to attend this school, for
his educational well- being, for his moral well -being and for his general health and welfare.
23. Father does not agree with Mother's decision to change the child's
educational provider.
24. Father would request that the Court direct that the child continue on with his
education at this facility.
25. Father is concerned that Mother is not an appropriate decision maker and
would request, additionally, that with regard to education, he be the child's educational
decision maker.
26. In the past, Mother has failed and refused to ensure that the child attended
his daycare and preschool facility on a regular basis.
27. On numerous occasions, Mother has told Father that she does not believe
the child should be in school until he is seven (7) years old.
28. A copy of this Petition has been forwarded to Mother's attorney of record, the
Family Law Clinic, and they DO NOT concur with the relief requested.
WHEREFORE, Father requests that this Court hold Mother in contempt for her
failure to share legal custody.
Respectfully submitted,
SAIDIS, SULLIVAN & ROGERS
I (4,7 £ A.. 7 \
Marylo'G Mats, Esquir
Attorney Id. 84919
26 West High Street
Carlisle, PA 17013
(717) 243 -6222
Counsel for Plaintiff
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
FRIDAY CHELLEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. CIVIL ACTION — LAW
NO. 2008 -5548 CIVIL ACTION LAW
CONNIE ROESLER,
Defendant IN CUSTODY
VERIFICATION
I verify that the statements made in the foregoing document are true and
correct. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities.
5- /5--- /U
Date
FRIDAY CHELLEY
FRIDAY CHELLEY, ' :IN THE COURT OF ciiiviiON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. ; NO. 2008'-5548 CIVIL ACTION - LAW
CONNIE ROESLER,
Defendant : IN CUSTODY
ORDER OF COURT
re A
AND N 3 '
OW, this c? day of /14,. ,e,e6e44.txted
• 4-01
, 019; upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Orders of Court dated June 16, 2011, October 24, 2008,
November 25, 2008 and March 2, 2009 are hereby vacated.
2. Father's Petition for Contempt is hereby withdrawn,
3. The Father, Friday Chelley and the Mother, Connie Roesler, shall have •
shared legal custody of Kevin Matthew Roesler, born July 24, 2008.„ Each parent-shall
have an equal right, to be exercised jointly with the oilier parent,:tb,iriake all inalor'.non- •
_
emergency decisions affecting the Child's genetal Well-being inCluding; but not liniited
to,.all decisions regarding his health, education and religion. Pursuant to the terms of 23
Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to
the child including, but not limited to medical, dental, religious or school records, the
residence address of the child and the other parent. To the extent one parent has
possession of any such records or information, that parent shall be required to share the
same, or copies thereof, with the other parent within such reasonable time as to make the
records and information of reasonable use to the other parent. Both parents shall be
entitled to full participation in all educational and medical/treatment planning meetings
and evaluations with regard to the minor child. Each parent shall be entitled to full and
complete information from any physician, dentist, teacher or authority and copies of any
reports given to them as parents including, but not limited to: medical records, birth
certificates, school or educational attendance records or report cards. Additionally, each
parent shall be entitled to receive copies of any notices which come from school with
regard to school pictures, extracurricular- activities, children's parties, musical
presentations, back-to-school nights; and the like.
4. During the school year:
A. Mother shall have primary physical custody of the child.
B. Beginning November 30, 2012, Father shall have periods of partial
physical custody three weekends in a row then Mother shall have one
weekend, then Father shall have three weekends in a row and continue
alternating thereafter. Father's periods of custody shall be from Friday at
1:30 p.m., when he shall pick up from daycare, until Monday at 9:00 a.m.
when Father shall deliver the child to daycare. Mother shall assure that
the. child is in daycare on Father's weekends. If not in daycare, Mother
shall contact Father and advise him where he can pick up the child for his
weekend custody.
5. During the summer:
A. Father shall have primary physical custody of the child.
B. Mother shall have three weekends in a row, then Father shall have one
weekend, then Mother shall have three weekends and alternate thereafter
from Friday at 1:30 p.m. to Monday at 9:00 a.m.
6. Holidays: .
A. Christmas shall be divided into two Blocks. Block A shall be from
December 24 at 1:30 p.m. to December 28 at 1:30 p.m. Block B shall be
from December 28 at 1:30 p.m. to January 2 at 9:00 a.m. Mother shall
have physical custody of the child for Block A in even numbered years
and Block B in 'odd numbered years. Father shall have physical custody of
the child for Block A in odd numbered hears and Block B in even
numbered years.
B. Thanksgiving shall be divided into two Blocks. Block A shall be from
Wednesday at 1:30 p.m. or after school to Friday at 5:00 p.m. Block B
shall be from Friday at 5:00 p.m. to Monday at 9:00 a.m. or the start of
school. Father shall have physical custody of the child for Block A in odd
numbered years and Block B in even numbered years. Mother shall have
physical' custody of the child for Block A in even numbered years and
Block B in odd numbered years.
C. Memorial Day and Labor Day. In the event that these holidays
coincide with Father's weekend period of physical custody, his time shall
be extended to Tuesday at 9:00 a.m. or the start of school.
7. Transportation shall be such that during the school year, Father shall be
responsible for all transportation. During the summer, Mother shall be responsible for all
transportation.
8. Exchanges are generally to be made at daycare or school. If no daycare or
school, then the child shall be picked up or dropped off at maternal grandmother's home.
9. The parties shall have reasonable telephone contac.t with the child. In this
regard the parties shall keep the other apprised of each other's current telephone number.
The subject matter of the calls shall only be custody. issues/exchanges or matters
pertaining to the child. If a phone message is left on voice mail the recipient parent shall
return the call within 30 minutes.
10. Neither party may expose the child to adult movies.
11, RELOCATION: 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.
12. 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,
74, A1444d
J.
cc: Marylou Matas, Esquire, Counsel for Father
Ria Periera, certified legal intern, Counsel for Mother
Megan Riesmeyer, Esquire, Family Law Clinic
C)
w
c-)
TRUE :COOY, FROM RECORO )2. -7.-
CrP
In Testimony whereof, I tiereTtInta- Set MY hand ---1
and the seal of said C put at.gatifsle2Pa, -
This 3 day of ,• •
-n
•
—1
.-n
r11
rn
7:1CD
C:)
—IC)
CD -1-1
T-,-1
—4
FRIDAY CHELLEY,
Plaintiff
V.
CONNIE ROESLER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2008-5548 CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: Kevin A. Hess, P.J.
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
Kevin Matthew Roesler July 24, 2008 Mother
2. A Conciliation Conference was held in this matter on November 28, 2012,
with the following in attendance: The Father, Friday,Chelley, with his counsel, Marylou
Matas, Esquire, and the Mother, Connie Roesler, with her counsel Ria Periera, certified
legal intern and Megan Riesmeyer, Esquire, Community Law Clinic.
3. The Honorable Kevin A. Hess previously. entered Orders of Court dated
June 16, 2011, October 24, 2008, November. 25, 2008 and March 2, 2009 providing for
shared legal custody, Mother having primary physical custody and Father having periods
of partial physical custody on alternating weekends Friday to Monday and every
Wednesday afternoon.
Date
4. The parties agreed to an Order in the form as attached.
acq line M. Verney, Esquire
Custody Conciliator
01130/2114 2:5 7172433G3q
PE NN STATE
The Dickinson
School of Law
$
Community Law Clinic
371 West South Street
Carlisle, PA 17013
Fox Number 717-241-3!;)0fi
Phone Number 717-243-29613
1 Al,.1 LI IN11. PACT E1/01
1 nrinumitylkrov
A ..-rvieeto the .7clffirriltnity by aludeol!:
from '11.a Vickli S(1001 Of 41W
p,,,,mylvar)
• State 1 ).1i,,opalry
We! Soufh Stt.cftt
7 '7;1 hei1.77 . VA I 7013
717 24 2968
1 m :159(1
To Ms rylou Mita, Lsq. HIM,: M. NICL)I(.:' A/deist/It
rgix: 717-241-3596 Pager: 8
Phone:: 717-243-2966
Re: Chet ley v. Roesler
0 Urgent
• Cnmmorits :
001-0= ?C;14
X For Devilew 1-1 Plea.se Connnient ,,.; Recycle
WE ARE 'TRANSMITTING FROM OUR TEL IF OUR COPY Is la AurFedliait 0:=4.1k1 INCOMPLETE,
PLEASE CALL LIS IMMEDIATELY AT 717443-2968.
THE INFORMATION CONTAINED IN THIS TRANSMISSION IS CONFIDENTIAL AND
INTENDED ONLY FOR THE USE OP THE INDIVIDUAL OR ENTITY i'0 WHOM 15
ADDRESSED_ IF YOU HAVE RECEIVED THIS TRANSIIIIISSION IPJ ERROR PLEASE
NOTIFY US IMMEDIATELY AND MAIL THE ORIGINAL. TRANSMISSION
0Y/ 30/ 2014 20: 50 7172433[39
PENNSTATE
The Dickinson
School of Law
Marylou Matas, Esq.
Saidis, Sullivan and Rogers
26 West High Street.
Carlisle, PA 17013
VIA FACSIMILE ONLY
Re: Chelley v. Roeslei
Dear Ms. 1Vlotas:
AW CA rusts.
Community Lan ('6nie
.January 31, 2014
A u11 air•;• to the Ornrn I ity Fty 'itucrent,
hom 1'11:- Dick■mron Schnn! r.t 1.uw .rr
I r'vnrriyrvaain Starr lirttvcmory
I am the new student attorney fin Ms. Connie Roesler in Pto
with Mr. Friday Chelley T recently met Ms. Roesler and she
enrollment at the Milton Hershey School (MHS) on January
that this change was made in agreement with Mr. ('hellcy.
Due to the unique nature of the MI IS's vim
wants to elriphasize to Mr. Chcllcy the i•npot'tancc of sit it 11, t,, ??
Roesler said that Mr. Clrelley should he i eeeiving an iuthrmatst;ri
information, but in the meantime it 'L ila,portarit for M, 'hell= '
more detailed Visitation Policy emi knmre).
PAGF 02/0c1
171 Wcm Snurh Sircel
auksI . PA I 70 1
' trrit.e: 7I7-24 294A
1596
usiudy and support issues
of Kevin's recent.
I. Ms. Roesler informed me
icics my client
Ni::, t1,e• :;c;hool rules. Ms
kr i irom M1 1S with all this
iii' the tiollownlg (please see
MT -IS has a 4 -week adjustment plan that ,,r +th /7it.; newly
visitation from family-or friends ;ends Felt nary 24.
Kevin can receive phone calls from amity and friends altr•
T1 or on the
ving (Nt,
weekends_
MI-IS told Ms. Roesler that Fridays are tht' hest days to reat.:11 audc;nls
As a newly enrolled student, Kcvm can have three ot'ereigftl lrrrrde this s >rrng.
re Starting next school year, Kevin ,.'an have five r)ve1'!1r4rh1 rt' <'i'!t:'rtri,t front I.abcn' day to
Memorial day weekend.
• During the overnight weekend visit!, it is critical that the parent taking Kevin home for the
weekend gives Lr/ least two days notice to Kevin' r Itouscpareite:-
please feel free to call me to dismiss this matter. I nut current Iv working with Ms. Rocsler to
draft a proposed custody agreement that would address these new visitation restrictions. Since
the total overnight visits for this spring; semester between hotly 1Y..1feitt.l i-i only three weekends we
urge both parties not to exercise their visitatio a tights without , :onsultirrg the other party, We
appreciate your assistance in passing on this irlessage. to Mr i_hc•lIcy.
Very RespectLull;
4:.
Nicole Ni.: \nt�t,attr
Certified I c:h,xl latest:
01/30/2014 20:50 71 /2433639
PENNSTATE
Ott.
The Dickinson
Scboo] of Law
I AW ra INlr:
Grmmunity U V / (link .1 / 1 Wcsi, South Strcul
uriiulr, PA 17011
A S•tilrr 10 the community by •uiudrui .
liar Ti, : Dic:hitc.on School t.f I,.tv ..•.,
Enclosure: NITS Visitation Policy {lih � (rFy)vania Stnln ['nivs:rnity
cc: Connie Roesler
:1114:c 717- 241-2968
i•:)x • 71'f 741 11)96
PAGE 03/0`]
'0113 2 _4 20:50 71 72433639
PAGE- 01/0,1
MILS 4-WEEK ADJUSTMENT PLAIN
Summary and Purpo,y!
The purpose of the MISS 4-Week Adjustment Plan for newly enrolled students is to provide a
specific time period in which new students become acclimated and connected to their Student
Homes and the MI-IS community.
Details
Definition
During the first 4-weeks of the student's enrollment, visitait: privileges with family and friends
are prohibited. Phone contact and letter writing with encourni;crriem lbr the new student is
highly recommended, A communication plan dui :'yisting form is required in order to
establish the best time for parent/sponsors to call and speak with their newly enrolled student
Exceptions
Due to the School's rolling enrollments, defined bre:at periods, and Family Weekends there will -
be exceptions to the 4-Weck Adjustment Plan as followi-
Family Weekends -- should the calendar dictate a Fain i Weekend during the first 4-weeks
of enrollment, students may participate in visitation foi day visit only on Saturday of the
Family Weekend.
Break Periods -- during the defined break,: Cilmi.,ksgiving,„ Christmas, and Easter)
students may participate in visitation and/or go home lo, [hen break period.
Departme nt Responsible H-If onw Life
19[Page
02/30/201.1 2e: 50 7172433639
Summary and Purpose
I (1W r :l I N T' : PN3[ 05/09
VISITATION POLICY
It is the policy of MSS to promote active, ongoing visitation. arul Pon-tact between MiJS students
and their parents /sponsors,. families and other authorized visitors through properly pre - arranged
weekend visitations_ Therefore the students are permitted to take five (5) weekend visits during
the course of the school year.
Details
Authorized Visitors
• Visitors must be authorized by the parent/sponsor..
• Authorized Visitors must he at least 21 year old. Siblings (may not he M CS student) with a
valid driver's license under the age: of 21 must have r4ortre rift 11/4 din irlistrativc Approval.
• Natural. parents Or adoptive parents have %ill I visitation rights rt,deys restricted by a court
order.
• Parents /sponsors will not be approved visitors of other stoder:tt . rhaf are (TUt related to them
unless otherwise approved by the t tome i.it Director.
• No more than 5 authorized. visitors on the visitation roster al a time unless otherwise
approved by the Home Life Director (changes to authorized vkit-ors, may be made at the
request of a parent or sponsor).
• U,ousepare .its wilt review the student visitation rosters on a yearly basis with
parents /sponsors and update accordingly to include accurate contact information, etc.
Steps for Visitor Authorization
• Parent/sponsor completes the Visitor Authorization .Form
• Parent/sponsor returns the Visitor .Authorization form to ay: rle , � eparcrlts.
• .T.- T-ouseparents review the form for r`omplete.71ess and t'r }rwarri I•' iii" Hrirrlr !,11C Ad1),linlstralor.
• Authorization of visitors will be based on present knowteclg: ;,r's;:.i iitfrnrrnation provided by
the parent or sponsor at the time of the request_
The. Home Life Administrator will send a verification lotto +! -:r)provid iegiiest, with a,
Visiting Policy brochure, to the authorized isi tor and rhoirf itic ltl.,f niv
13'Page
01/30/2014 20.50 71/243363'1
LAW i'.I 1Mii: PA(-I- 16/09
• lIouseparents add the authorized visitor" came to the Visiting Roster
• I-Iouseparents may make adjustments to Tice original Visit int. Roster as changes occur.
• Individuals recommended for authorization by the parent/sponsor will be approved unless, in
the School's judgment, the visitor may place a student's or staff's well being at risk.
• Any authorized visitor may be removed from the visitation roster by the School if they place
a student's or staff's well -being at risk or fail to adhere to thr uk" of the policy.
• Only authorized visitors are permitted to pickup and return students_ The authorized visitor
assumes fill responsibility for the students, with accountability ultimately being with the
parent/sponsor.
Weekend Day Visitation
• All visitors need to be scusitiv<- to :;:tudcnl home sehredntc , . visitors are strongly
encouraged to notify housepaieaits igf the Li irisrlatrerii jio;ialii cif 2 days in ad.vanc:..:
• Tf visits take place without an appropriate request the visii .cnrnsiderecl an um:xi-used
absence and may result in the loss of an overnight weekend
• Students most be in good standing in order to visit with app other than their
parent /sponsor. Any student responsibilities to the student l . me. health services, scholastic,
extra- curricular, etc. must he met bclore visitation bep,in <.
Visitation while on Level 3 or Level 4 Detentions
Should a student be serving Level 3 or I,evci 4 detentions detentions di)ralt he time nf'a requested
visitation or break period by an authorized visitor (including parents /sponsors), the student's
visitation privilege will not he approved. In the event that a student dot's not comply with the
visitation policy during this time, the .'Vit.endtnice Policy r7oI4`r•ileaei's will he activated.
Special Circumstances
• if the Z)etention Period the stmierii. is to :.c ivO abiiiG 3i"ac ,,,;,i�.sgivn g ee Laster Break period,
the student will serve the Detention Period by particip,at.0 ii in the Behavioral Intercession
Program during that specified break Participation will Ela" 1,00erartsaiitr , and, once completed,
the student will have satisfactoiih serve,' the l)ctertiifro
14I t''age
01/30/2014 20: 50 7172433E19
UV (I mit:
Students issued Detentions abutting the Summer Break period will serve all of their days
satisfactorily prior to being dismissed, In addition, students serving a I )etention Period
abutting the Summer Break will need to be enrolled in an appropriate YEE program .for the
duration of their stay.
Exceptions
PAGE 07/y
• Christmas Break will qualify as an exception. from detentions During Christmas Break,
for those students on detentions approaching Christmas Break., they may complete detentions
upon conclusion of the Christmas Break period.
• Students may be released from detention pes iods early only with the approval of the assigned
Home Life Administrator due to extcnuatinv, circumstances.
Suniday Chapel Atteodariee
Parents/sponsors and authorized visitors arc encouraged lo atik,,c1A-1 Sunday Chapel and sit with
their child and the student home thrnily.
Visitation may begin once the visitor returns to the student hot to.. 1.6 •iign and document the
Visitation Register.
Overnight Weekend Visitation
Students are permitted five overnight eekend visits during the year between the
weekend after Labor Day and Memorial Day; ,:wernight visitaiiou is not permitted on the Labor
Day weekend.
*Note — students who enroll after Augusi will receive a reduced ilurnber of overnight weekends
as indicated:
Students enrolling (Vier October 1st will he allowed 4 weekends
Students enrolling after December lst will be allowed
Students enrolling alter ildarell• 1st will he allowed 7 wcek;?nds
Students enrolling after May 1st will Ile allowed I weekend
Parent/sponsors must authoriz Jl Clvernight weekend visik
Only individuals on the Visiting Rosii ,. arc cngiblc to ovoLo4en: ,;-.4■1non with a student,
.15IPage
"9
01/30/2014 20:50 7172433E39
l AW 11 TNT,. PA(;F 09/03
Students will be able to leave campus for overnight weekend visits beginning at 4:00 p.nl. on
Friday afternoon (provided all student responsibilities have been :attended to). On those long
weekends where Monday is a holiday, students are expected ft, rniiarn in their student home by
5:00 p.m. Monday evening.
Steps for Overnight Weekend Visiting
• Parent/sponsor completes the Request for Overnight Weekend Visitation form that is located
in the back of the MH'S Community Calendar.
• Parent/sponsor returns the Request for Overnight Weekend Visitation form to the
housepnrents no later than 5 working days prior to the planned weekend overnight visit
If the overnight visit takes place without an appropriate. et ;uiat; 9. tine overnight will be
considered an unexcuscd absence and may result in the loss of an overnight weekend.
If tim stud.ertt is taking an overnight weekend with someone ether than the parent /sponsor, the
host must submit a written invitation to he received by tater than 5 days prior
to the visitation Horisepare is >.zzrd approve thr nwmi to4 The form will then
be placed in the student home file:•;
On. Family Weekends, student visitation beg,iris on Sail] I'd a. . =r .0 :a Pareu1y /sponsors
and /or their designated approved v!siterr;s (w1th sponsor :Ipin ! lal., ak+ then student For
overnight visitation witbont one of the five evemight visits tweet if the following steps
occur:
✓ Students who are out visiting overnight on Saturday right r•it!e1 attend Chapel on Sunday
morning and be seated at lea,s9 9.0 minutes prior to the ioi ' t >Ut e service-
* If your student does not return tot Chapel Service, i'his weuL +. nd wit I be counted. as one of'
their five long weekends. Also he /she will lose an additions! weekend, according to
Home Life Policy.
* If your student arrives late and /or is dressed inappropriate t ; tot t:lnspcl tic /she, will lose
one of their five weekend visit:.
• Student visitation can c;on9:i:fue On Snindaa y following C.Im t trial
1 fi I f a i:)
'Or/30/2014 28: 50 71'12433639
iilePrt.v1r,,- • '••••:,1,-.1t.tr...' • ': 1,...11..--•
,, 06 i'.,1 L., ,i, '
, , r
NEW STUDENT ADJUSTMENT
FLAN IN PAC.
NO (
RETURNING STUDENTS
No C
;-,..L' ..
..1- „SetttemfivIR,"11-3
LADOR DAY WEEKEND .
8/30 - 912
NO C
HOMECOMING WEEKEND
0/27 - 9/29
Owl-MIGHT ONLY
FALL rAMILY WEEKEND
11/1 - 11/3
NO mil
-.SITurietriftil
, ... ,.
ALIOVirrt
.,.;-;:. r.1•, .•,,,.. ,
—..,..._.
-, -,,,,,i•twotv.„.-", :,„,-:_,... ..
st.tibt•TaitTNI
MARTIN LUTHER KING, R.
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FRIDAY CHELLEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. CIVIL ACTION — LAW
NO. 2008-5548 CIVIL ACTION LAW
CONNIE ROESLER,
Defendant
IN CUSTODY
J. MASLAND
CERTIFICATE OF SERVICE
I hereby certify that on this 4. day of i ft it C , 2014, a true and correct
copy of the foregoing document was served upon the party listed below, via First Class
Mail, postage prepaid, addressed as follows:
Certified Legal Intern
45 North Pitt Street
Carlisle, PA 17013
SAIDIS, SULLIVAN & ROGERS
)1(6(
Maryl s, Esquire
Supreme Cotirt ID No. 84919
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Counsel for Plaintiff
- 7?
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
FRIDAY CHELLY..
Plaintiff
—2 Hi 2:
v. •
t3s S SYl:D1l P' i
CONNIE ROESLE
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION — LAW
NO. 2008 -5548 CIVIL ACTION LAW
IN CUSTODY
J. MASLAND
CRIMINAL RECORD /ABUSE HISTORY VERIFICATION
I, Friday Chelley, hereby swear or affirm, subject to penalties of law including 18
Pa.C.S.§ 4904 relating to unsworn falsification to authorities that:
1. Unless indicated by my checking the box next to a crime below, neither I nor any other
member of my household have been convicted or pled guilty or pled no contest or was
adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act 42
Pa.C.S. § 6307 to an of the following crimes in Pennsylvania or a substantially equivalent crime
in any other jurisdiction, including pending charges:
Check Crime
all that
apply
Self Other
household
member
❑ 18 Pa.C.S. Ch.25 ❑ ❑
(relating to criminal
homicide)
❑ 18 Pa.C.S. §2702 ❑ ❑
(relating to aggravated
assault)
❑ 18 Pa.C.S. §2706 ❑ ❑
(relating to terroristic
threats
❑ 18 Pa.C.S. §2709.1 ❑ ❑
(relating to stalking)
❑ 18 Pa.C.S. §2901 ❑
(relating to kidnapping)
Date of
conviction,
guilty plea, no
contest plea or
pending charges
Sentence
LI
18 Pa.C.S. §2902 D
(relating to unlawful
restrant)
18 Pa.C.S. §2903 E El
(relating to false
imprisonment)
18 Pa.C.S. §2910 El El
(relating to luring a
child into a motor
vehicle or structure)
18 Pa.C.S. §3121 LI
(relating to rape)
18 Pa.C.S. §3122.1 Lil
(relating to statutory
sexual assault)
18 Pa.C.S. §3123 E El
(relating to involuntary
deviate sexual
Intercourse)
El 18 Pa.C.S. §3124.1
(relating to sexual
assault)
18 Pa.C.S. §3125 El El
(relating to aggravated
indecent assault)
18 Pa.C.S. §3126 El
(relating to indecent
assault)
18 Pa.C.S. §3127
(relating to indecent
exposure)
❑ 18 Pa.C.S. §3129 ❑ ❑
(relating to sexual
intercourse with animals)
❑ 18 Pa.C.S. §3130 ❑ ❑
(relating to conduct
relating to sex
offenders)
❑ 18 Pa.C.S. §3301 ❑ ❑
(relating to arson and
related offenses)
❑ 18 Pa.C.S. §4302 ❑ ❑
(relating to incest)
❑ 18 Pa.C.S. §4303 ❑ ❑
(relating to concealing
death of child)
❑ 18 Pa.C.S. §4304 ❑ ❑
(relating to endangering
welfare of children)
❑ 18 Pa.C.S. §4305 ❑ ❑
(relating to dealing
in infant children)
❑ 18 Pa.C.S. §5902(b) ❑ ❑
(relating to prostitution
and related offenses)
❑ 18 Pa.C.S. §5903 ❑ ❑
(c) or (d)
(relating to obscene
and other sexual materials
and performances)
❑ 18 Pa.C.S. §6301 ❑ ❑
(relating to corruption
of minors)
❑ 18 Pa.C.S. §6312 ❑ ❑
(relating to sexual
abuse of children)
❑ 18 Pa.C.S. §6318 ❑ ❑
(relating to unlawful
contact with minor)
❑ 18 Pa.C.S. §6320 ❑ ❑
(relating to sexual
exploitation of children)
❑ 23 Pa.C.S. §6114 ❑ ❑
(relating to contempt for
violation of Protection
order or agreement)
❑ Driving under the ❑ ❑ 2010 guilty plea
influence of drugs
or alcohol
❑ Manufacture, sales ❑ ❑
delivery, holding,
offering for sale or
possession of any
controlled substance or
other drug or device
2. Unless indicated by my checking the box next to an item below, neither I nor any other
member of my household have history of violent or abusive conduct including the following:
Check Self Other Date
all that household
apply member
❑ A finding of abuse by Children & Youth ❑ ❑
Agency or similar agency in Pennsylvania
Or similar statute in another jurisdiction
❑ Abusive conduct as defined under the ❑ ❑
Protection from Abuse Act in
Pennsylvania or similar statute in
another jurisdiction
❑ Other: ❑ ❑
3. Please list any evaluation, counseling or other treatment received following conviction or
finding of abuse:
4. If any conviction above applies to a household member, not a party, state that person's
name, date of birth and relationship to the child:
5. If you are aware that the other party or members of the party's household has or have a
criminal /abuse history, please explain:
I verify that the information above is true and correct to the best of my knowledge
information or 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:
Signature of Friday Chelley
Printed Name
FRIDAY CHELLEY IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
V.
CONNIE ROESLER
DEFENDANT
CUMBERLAND COUNTY, PENNSYLVANIA
2008-5548 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, June 06, 2014 , upon consideration of the attached Complaint, it is
hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, July 01, 2014 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.
You must file with the Court a verification regarding any criminal record or abuse history regarding you and
anyone living in your household on or before the initial in-person contact with the court (including, but not limited to,
a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition.
No party may make a change in the residence of any child which significantly impairs the ability of the other party
to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and
Pa.R.C.P. No. 1915.17 regarding relocation.
FOR THE COURT,
By: /s/ Jacqueline M. Verney, 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.
Copies irtie
A+17 02
A44.y' J _ VE/2_,Jel
calt-M
147)
c7 �, c =
Cumberland County Bar Association
3' -c-- —/
32 South Bedford Street nip L _
Z rrl
Carlisle, Pennsylvania 17013 � —'j.;
Telephone (717) 249-3166z rn p; c
..c r..3 _.) .'-)
---I c...) .._
BAYLEY & MANGAN
Mark F. Bayley, Esquire
Attorney I.D. #: 87663
17 West South Street
Carlisle, PA 17013
(717) 241-2446
FRIDAY CHELLEY,
Plaintiff
vs.
CONNIE ROESLER,
Defendant
L ED -OFFICE
Lt THE PRO { HONOT1AR
7014 JUN 12 PM 3: j L4
CUMBERLAND COUNTY
PENNSYLVANIA
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2008-5548
: CIVIL ACTION - LAW
: IN CUSTODY
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Defendant, Connie Roesler, in the above -
captioned matter.
Date:
Mark F. Bayley, Es IP Tire
Bayley & Mangan
17 West South Street
Carlisle, PA 17013
(717) 241-2446
Supreme Court I.D. # 87663
FRIDAY CHELLEY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 2008-5548
CONNIE ROESLER, : CIVIL ACTION - LAW
Defendant : IN CUSTODY
CERTIFICATE OF SERVICE
I, Mark F. Bayley, Esquire, do hereby certify that I this day served a copy of the foregoing
document upon the following by First Class U.S. Mail:
Dated:
Saidis, Sullivan & Rogers
Attn: Marylou Matas, Esquire
2.6 West High Street
Carlisle, PA 17013
ark F. Bayley, E •uire
FRIDAY CHELLEY,
Plaintiff
V.
CONNIE ROESLER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2008-5548 CIVIL ACTION - L 4 W r
m
-�
: IN CUSTODY
ORDER OF COURT
w
C
CJ
AND NOW, this day of , 2014, upon
consideration of the attached Custody Conciltion Report, it is ordered and directed as
follows:
1. The prior Order of Court dated December 3, 2012 shall remain in full
force and effect with the following modifications.
2. The child shall continue to attend Milton Hershey School unless the
parties agree otherwise or further Order of Court.
3. The parties shall share physical custody of the child as follows:
A. Father shall have physical custody of the child from June 27 to July 2,
2014. Mother shall pick up the child at a time and location near Father's home on July 2,
2014. Mother shall have physical custody of the child from July 2 to July 6, 2014.
Father shall have physical custody of the child from July 6 to July 13, 2014 provided he
can have him excused from summer school.
B. During the school year, the child has five weekends off of campus. The
parties shall alternate these weekends with Mother having the first weekend.
C. During the school year, the child has vacations for the following
holidays: Columbus Day, Thanksgiving, President's Day, Easter, Memorial Day. The
parties shall alternate these holidays with Mother having Columbus Day in 2014.
D. Christmas shall be divided equally and alternated by the parties with
Mother having the first part of Christmas in 2014 -December 19-27 and Father having
December 27 -January 4, 2015. In 2015, Father shall have the earlier time. It is
understood that depending on the school calendar, these dates may change. The parties
shall divide the holiday time regardless of the actual dates of the recess.
E. The parties shall share equally the summer holiday if the child does not
attend summer school.
1
F. If the child attends summer school, the parties shall alternate the
weekends. Each parent shall be entitled to one full week in the summer and shall notify
the other party 30 days in advance of the week they select.
4. Except as otherwise indicated herein, custody exchanges when necessary
to be made between the parties shall occur at the time the bus arrives in Carlisle or 1:00
p.m. and shall occur at the bus stop at the Carlisle Square.
5. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY THE COURT,
cc: " arY lou Matas, Esquire, Counsel for Father
Mark F. Bayley, Esquire, Counsel for Mother
20111
FRIDAY CHELLEY,
Plaintiff
V.
CONNIE ROESLER,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2008-5548 CIVIL ACTION - LAW
Defendant : IN CUSTODY
PRIOR JUDGE: Albert H. Masland, J.
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: 1/
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Kevin Matthew Roesler July 24, 2008 Mother
:0
2. A Conciliation Conference was held in this matter on June 25, 2014, vvith
the following in attendance: The Father, Friday Chelley, by telephone, with his counsel;
Marylou Matas, Esquire, and the Mother, Connie Roesler, with her counsel, Mark F.
Bayley, Esquire.
4�+
3. The Honorable Albert H. Masland previously entered an Order of Court
dated December 3, 2012 providing for shared legal custody, Mother having primary
physical custody during the school year and Father having primary physical custody
during the summer. Since the entry of that Order of Court, the parties enrolled the child
in Milton Hershey School.
4. The parties agreed to an Order in the form as attached.
Date
Jacc{ieline M. Verney, Esquire
Custody Conciliator
SEP 30 PH 2: 'n
L} ti
CUMBERLAND COUNTY
PENNSYLVANIA
FRIDAY CHELLEY,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
: 2008-5548 CIVIL ACTION LAW
CONNIE ROESLER, : IN CUSTODY
Defendant
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance with regard to the above captioned matter.
My address of record shall be 1370 Grandview Court, Carlisle, Pennsylvania 17013.
Respectfully submitted,
Connie Roesler, Pro se
Appec,r(vict
*Le._ Ppol-Ctoktcyl-c.ry
P k ser wk y c * eG rc. H ce. v) i 1'--•
reeic—r e -o CCc)J e w� �. •4- �.
V"` 4,-1)2 R
FRIDAY CHELLEY,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
: 2008-5548 CIVIL ACTION LAW
CONNIE ROESLER, : IN CUSTODY
Defendant
CERTIFICATE OF SERVICE
I, Connie Roesler, do hereby certify that I this day served a copy of the foregoing
document upon the following by First Class Mail on the below date:
Saidis, Sullivan & Rogers
Attn: Marylou Matas, Esquire
26 West Pomfret Street
Carlisle, PA 17013
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
FRIDAY CHELLEY,
v.
CONNIE ROESLER,
Child's Name
Plaintiff
: IN THE COURT OF COMMON PLEAS -0=
: CUMBERLAND COUNTY, PENNSYL
: No. 2008-5548 CIVIL TERM
: CIVIL ACTION — LAW
Defendant : IN CUSTODY
Prior Judge: Albert H. Masland
NOTICE OF PROPOSED RELOCATION
Kevin Matthew Roesler
Age
6
Jr"
Currently residing at:
Milton Hershey School, Hershey, PA
during the school year, shared
custody during the summer
1. Defendant proposes to relocate to: 613 Mulberry Avenue, Apt. A, Muscatine, Iowa,
52761.
2. The mailing address for the proposed new residence is: same as address of proposed
new residence.
3. The names and ages of the individuals who will reside in the new residence or who intend
to live in the new residence are:
Name
Friday Chelley
Jonason Chelley
Minnie Chelley
Esther Cheney
Esther Chelley
(father's brother)
(father's sister-in-law)
(father's niece)
(father's mother)
Age
50
14
4. The telephone number of the proposed new residence is:
(retaining cellular telephone number and not installing land line at this time.)
5. The name of the new school district and school (s) that the child will attend is:
Father desires for the child to continue to attend the Milton Hershey Academy, Hershey,
PA, during the school year.
6. The date of the proposed relocation is: October 30, 2014.
7. The reasons for the proposed relocation are:
Father's family has moved to Iowa. Father has no additional support system in the local
area and prefers to reside near his family.
8. Father proposes that the custody schedule be revised as follows, if he is permitted to
relocate:
a. Mother shall maintain primary custody of the child during the school year.
b. Father shall have custody of the child from one (1) week after the end of the
school year until one (1) week before the beginning of the next school year.
c. Mother shall be entitled to exercise custody of the child for the weekends and
school breaks during the school year.
d. Father shall be responsible for transportation for his summer periods of custody,
for himself and for the child.
e. Each parent shall be entitled to phone calls and Skype communications with the
child while he is in the custody of the other parent.
f. The parents shall maintain legal custody of the child.
g. The child shall remain enrolled in the Milton Hershey Academy.
9. A Counter -Affidavit is attached, which can be used by any other party to object to the
proposed relocation and the modification of the existing Custody Order.
WARNING: If a non -relocating party does not file an objection with the Court to
the relocation within thirty (30) days after receipt of this Notice, the party may not
object to the relocation.
Date: ()CI 1019"
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
Respectfully submitted,
SAIDIS, SULLIVAN & ROGERS
Marylou M. s, Esq.
Attorney ID
26 West High Street
Carlisle, PA 17013
Phone: (717) 243-6222
Fax: (717) 243-6486
Email: mmatas@ssr-attorneys.com
Attorney for Petitioner
FRIDAY CHELLEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. : No. 2008-5548 CIVIL TERM
CONNIE ROESLER,
: CIVIL ACTION — LAW
Defendant : IN CUSTODY
Prior Judge: Albert H. Masland
VERIFICATION
I verify that the statements made in this notice are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. § 4908, relating to
unsworn falsification to authorities.
Date:
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
FRIDAY CHELLEY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : No. 2008-5548 CIVIL TERM
CONNIE ROESLER,
: CIVIL ACTION — LAW
Defendant : IN CUSTODY
Prior Judge: Albert H. Masland
CERTIFICATE OF SERVICE
1-k
I hereby certify that on this day of Odakh. , 2014, a true and correct copy
of the Notice of Proposed Relocation and Counter -Affidavit was served upon the party listed
below, via First Class Mail, postage prepaid, addressed as follows:
Connie Roesler, pro se
1370 Grandview Court
Carlisle, PA 17013
SAIDIS, SULLIVAN & ROGERS
04/LA
Marylou M a , Esq.
Attorney ID
26 West High Street
Carlisle, PA 17013
Phone: (717) 243-6222
Fax: (717) 243-6486
Email: mmatas@ssr-attorneys.com
Attorney for Petitioner
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
FRIDAY CHELLEY , IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. 2008-5548 CIVIL TERM
CONNIE ROESLER ,
Defendant
CIVIL ACTION — LAW
IN CUSTODY
Prior Judge: Albert H. Masland
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of the Defendant, Connie Roesler,
with regard to the above matter.
Respectfully submitted,
C")
\
Paul. Primrose, Esquire
ID No. 315016
325 South Hanover Street
Carlisle, PA 17013
717-623-3104
Attorney for Defendant
FRIDAY CHELLEY , IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. 2008-5548 CIVIL TERM
CONNIE ROESLER ,
Defendant
CIVIL ACTION LAW
IN CUSTODY
Prior Judge: Albert H. Masland
CERTIFICATE OF SERVICE
AND NOW, this 6th day of November, 2014, I, Paul Primrose, Esquire, hereby certify
that I did hand deliver a copy of the foregoing, upon the Plaintiff by hand delivery to the
following:
Saidis, Sullivan & Rogers
attn: Marylou Matas, Esquire
26 West High Street
Carlisle, PA 17013
Respectfully submitted,
h
Paul Primrose, Esquire
ID No. 315016
325 South Hanover Street
Carlisle, PA 17013
717-623-3104
Attorneyfor Defendant
FRIDAY CHELLEY, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : No. 2008-5548 CML TERM
CONNIE ROESLER, : CIVIL ACTION—LAW a
Defendant : IN CUSTODY z�u
Prior Judge: Albert H. Masland U)r—
z
C�
>
COUNTER AFFIDAVIT REGARDING RELOCATION x '
This proposal of relocation involves the following child: ' =
Child's Name Age Currently residing at.
Kevin Matthew Roesler 6 Milton Hershey School, Hershey, PA
I have received a notice of proposed relocation and
1. I do not object to the relocation and I do not object to the modification of
the Custody Order consistent with the proposal for revised custody schedule as attached
to the Notice.
2. 1 do not object to the relocation, but I do object to modification of the
Custody Order, and 1 request that a hearing be scheduled:
a. Prior to allowing the child to relocate.
b. After-the child relocates.
3. 1 do ,object to the relocation and I do object to the modification of.the
Custody Order, and I further request that a hearing be held on both matters prior to the
relocation taking place.
1 understand that in addition to checking (2) or(3) above, I must.also file this Notice with
the Court in writing and serve it on the other party by certified mail, return receipt requested.
If I fail to do so within 30 days of my receipt of the proposed relocation notice, I shall be
Law Ogicw of foreclosed from.objecting to the relocation.
3adis I verifythat the statements made in this Counter-Affidavit are true and correct. I
suluyem understand that false statements .herein are made subject to the penalties of 18 Pa.C.S.
k Rogers
6 WWt 1&street §4904(relating to unsworn falsification to authorities).
adsle,PA 17013 ,
Date: F `r c^ c:
Paul Primrose, Esquire
on behalf of Connie Roesler
FRIDAY CHELLEY , IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2008-5548 CIVIL TERM
CONNIE ROESLER , CIVIL ACTION—LAW
Defendant IN CUSTODY
Prior Judge: Albert H. Masland
CERTIFICATE OF SERVICE
AND NOW,this 6th day of November, 2014, I, Paul Primrose,Esquire, hereby certify
that I did hand deliver a copy of the foregoing, upon the Plaintiff by hand delivery to the
following:
Saidis, Sullivan&Rogers
attn: Marylou Matas,Esquire
26 West High Street
Carlisle, PA 17013
Respectfully submitted,
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I
Paul Primrose,Esquire
ID No. 315016
325 South Hanover Street
Carlisle, PA 17013
717-623-3104
Attorney for Defendant
FRIDAY CHELLEY,
PLAINTIFF
V.
CONNIE ROESLER,
DEFENDANT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: 08-5548 CIVIL TERM
ORDER OF COURT
AND NOW, this /27 day of November, 2014, a hearing on Plaintiffs
Notice of Proposed Relocation and Defendant's Counter Affidavit Regarding
Relocation is scheduled for Thursday, December 18, 2014, at 2:30 p.m., in
Courtroom Number 1, Cumberland County Courthouse, Carlisle, Pennsylvania.
✓Marylou Matas, Esquire
26 West High Street
Carlisle, PA 17013
ul Primrose, Esquire
325 South Hanover Street
Carlisle, PA 17013
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Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
FRIDAY CHELLEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. CIVIL ACTION — LAW
NO. 2008-5548 CIVIL ACTION LAW
CONNIE ROESLER,
Defendant
IN CUSTODY
J. MASLAND
PETITION FOR CONTINUANCE
NOW COMES Petitioner, Marylou Matas, Esquire, and Petitions this Court as
follows:
1. Your Petitioner is Marylou Matas, Esquire, attorney for Plaintiff, Friday Chelley.
2. Respondent is Connie Roesler, represented in this matter by Paul Primrose,
Esquire.
3. Plaintiff filed a Notice or Relocation and Counter Affidavit.
4. Defendant filed a Counter Affidavit regarding the proposed relocation.
5. This Court scheduled a hearing on the proposed relocation matter. The hearing is
scheduled for December 18, 2014, at 2:30 p.m.
6. The parties are attempting to reach an agreement regarding the outstanding matters
raised in Plaintiff's proposed relocation and respectfully request that the hearing be
continued to allow them additional time to negotiate an acceptable agreement.
7. Petitioner has forwarded a copy of this to Paul Primrose, Esquire, attorney of record
for Defendant. Counsel concurs in this request for continuance.
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WHEREFORE, Petitioner requests Your Honorable Court to continue the hearing
scheduled for December 18, 2014, at 2:30 p.m. to a later date and time.
Respectfully submitted,
Date: 1 /(S �7
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
SAIDIS, SULLIVAN & ROGERS
-111(a-AuvettL
Marylou Mat'4,, Esquire
Attorney Id. 84919
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Counsel for Plaintiff
FRIDAY CHELLEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. CIVIL ACTION — LAW
NO. 2008-5548 CIVIL ACTION LAW
CONNIE ROESLER,
Defendant
IN CUSTODY
J. MASLAND
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
§4904, relating to unsworn falsifications to authorities.
Date:
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
7/1(dag
Mar , Esqui
FRIDAY CHELLEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. CIVIL ACTION — LAW
NO. 2008-5548 CIVIL ACTION LAW
CONNIE ROESLER,
Defendant
IN CUSTODY
J. MASLAND
CERTIFICATE OF SERVICE
I hereby certify that on this day of , 2014, a true and correct
copy of the foregoing document was served upon the party listed below, via First Class
Mail, postage prepaid, addressed as follows:
Paul Primrose, Esquire
325 South Hanover Street
Carlisle, PA 17013
SAIDIS, SULLIVAN & ROGERS
Mar)ieti'Ma :s, Esqui
Supreme &ou ID No. 84919
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Counsel for Plaintiff
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
FRIDAY CHELLEY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. CIVIL ACTION — LAW
NO. 2008-5548 CIVIL ACTION LAW
CONNIE ROESLER,
Defendant
IN CUSTODY
J. MASLAND
ORDER OF COURT
AND NOW, this G (9 ' day of December, 2014 the hearing previously
scheduled for December 18, 2014, at 2:30 p.m. in Courtroom Number 1 of the Cumberland
County Courthouse, is rescheduled to the 64-" day of ti , 20/5, at
130
o'clock i .M., in Courtroom Number / of the Cumberland County
Courthouse, Carlisle, Pennsylvania.
Marylou Matas, Esquire
Counsel for Plaintiff
Law Offices of
Saidis
Sullivan
& Rogers
26 West High Street
Carlisle, PA 17013
Paul Primrose, Esquire
Counsel for Defendant
COO �, s /11 22-1 LL
BY THE COURT
Albert H. Masland, Judge