HomeMy WebLinkAbout08-7423RODNEY E. LAUGHMAN, SR.
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action- Law
No. 09 - 'W3 016t L7i?L"
BONNIE LAUGHMAN,
Defendant
IN DIVORCE and CUSTODY
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree of divorce or annulment may be entered against you by the
court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may also lose money or property or other rights important to
you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle.
IF YOU SO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER 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, PA 17013
Phone: (717) 249-3166
(800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities 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.
1
RODNEY E. LAUGIRAAN, SR. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
No. o- 7 y a 3 Cc ?l L,
BONNIE LAUGHMAN,
Defendant
IN DIVORCE and CUSTODY
COMPLAINT UNDER SECTIONS 3301(c) or 3301(d)
OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, Rodney E. Laughman, Sr., by and through his
counsel, Michael J. Whare, Esquire and avers as follows:
1. Plaintiff is Rodney E. Laughman, Sr., an adult individual, who currently
resides at 31 Town Mills, Shippensburg, Cumberland County, Pennsylvania 17257.
2. Defendant is Bonnie Laughman, an adult individual, who currently resides at
265 Waynesboro Pike, Fairfield, Adams County, Pennsylvania 17320.
3. Plaintiff and Defendant have both been bona fide residents in the
Commonwealth for at least six months immediately previous to the filing of this
Complaint.
4. Plaintiff and Defendant were married on January 21, 2000, in Pleasant Hall,
Franklin County, Pennsylvania and separated on or about June 21 2006.
5. There have been no prior actions of divorce or annulment between the parties
hereto in this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available, and that Plaintiff may
have the right to request that the Court require the parties to participate in counseling.
8. Plaintiff requests the Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a
Decree in Divorce and such other Orders as may be just and appropriate.
COUNT 2 - CUSTODY
9. The previous paragraphs 1-8 are incorporated by reference.
10. Plaintiff seeks primary physical custody of the following children:
Name Present residence DOB
Rodney Laughman, Jr. 31 Town Mills 07/02/1992
Shippensburg, PA 17257
Alyssa Laughman 31 Town Mills 03/21/1998
Shippensburg, PA 17257
11. The children were not born out of wedlock.
12. The children are presently in the custody of Father, who resides a 31 Town
Mills, Shippensburg, Pennsylvania 17257.
13. During the past five years, the children have resided with the following
persons and at the following addresses:
List all Persons
Rodney Laughman and
Bonnie Laughman
Rodney Laughman
Rodney Laughman and
Jennifer Gravely
Bonnie Laughman
List All Addresses Dates
31 Town Mills 2003- June 2006
Shippensburg, PA 17257
31 Town Mills June 2006- November 2008
Shippensburg, PA 17257
31 Town Mills November 2008 - present
Shippensburg, PA 17257
265 Waynesboro Pike June 2006-present
Fairfield, PA 17320
14. The Mother of the children is Bonnie Laughman, who resides at 265
Waynesboro Pike, Fairfield, Adams County, Pennsylvania 17320.
She is married to the Plaintiff.
15. The Father of the children is Rodney E. Laughman, Sr., who resides at 31
Town Mills, Shippensburg, Cumberland County, Pennsylvania 17257.
He is married to the Defendant.
16. The relationship of plaintiff to children is that of Father.
The Father currently resides with the following persons:
Name
Relationship
Rodney Laughman, Jr. Son
Alyssa Laughman Daughter
Jennifer Gravely Girlfriend
17. The relationship of defendant to children is that of Mother.
The Mother currently resides with the following persons:
Name
Relationship
Alyssa Laughman Daughter
18. Plaintiff has not participated as a party or witness, or in another capacity, in
other litigation concerning the custody of the children in this or another court.
19. Plaintiff has no information of a custody proceeding concerning the children
pending in a court of this Commonwealth.
20. Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the children or claims to have custody or visitation rights with respect
to the children.
21. Each parent whose parental rights to the children have not been terminated
and the person who has physical custody of the children have been named as
parties to this action. All other persons, named below, who are known to have or
claim a right to custody or visitation of the children will be given notice of the
pendency of this action and the right to intervene:
Name(s) Address Basis of Claim
None
22. Reasons for granting relief:
A) A Court Order of custody and structured visitation is desired so that
Plaintiff and children may plan their schedules accordingly, and so that
misunderstandings and unmet expectations regarding custody and visitation can be
avoided, and also so that the child is not used in a manipulative fashion.
B) A Court ordered determination of custody is required to avoid continuing
conflict between the parties regarding parental responsibility for custody and support.
C) Plaintiff is best able to provide the care and nurture which the children
need for healthy development.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant his
petition for primary physical custody of the children.
Respectfully submitted,
Date: 'a - W"j /? ,, /7
Michael I Whar Esquire
37 East Pomfret Street
Carlisle, PA 17013
Supreme Ct. Id No. 89028
Attorney for Plaintiff
RODNEY E. LAUGHMAN, SR. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
No.
BONNIE LAUGHMAN,
Defendant
IN DIVORCE and CUSTODY
VERIFICATION
I verify that the statements made in this Complaint 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:.,,,..2 i 9jc) ,?" .K
Rodney Sr., Plaintiff
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RODNEY E. LAUGHMAN, SR. IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
2008-7423 CIVIL ACTION LAW
BONNIE LAUGHMAN IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Tuesday, December 30, 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 Thursday, January. 15, 2009 at 1:00 PM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinp..
FOR THE COURT.
By: /s/ _johnn Mangan, Jr., &9._
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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JAN a n 200 0
RODNEY E. LAUGHMAN, SR. : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
BONNIE LAUGHMAN
: No. 08-7423 Civil Term
Defendant : ACTION IN CUSTODY
COURT ORDER
AND NOW, this 2 s day of January 2009, upon consideration of the
attached Custody Conciliation Report, it is ordered and directed that:
This Order is entered pursuant to a Custody Conciliation Conference. A Custody
Hearing is hereby scheduled on the RU k day of , 2009 at
v ayYpm in Courtroom number / in the Cumberland County Court of
Common Pleas, Carlisle, PA 17013 at which time testimony will be taken in
regard to the physical custody for the subject Children. For purposes of this
hearing, the Father shall be deemed to be the moving party and shall proceed
initially with testimony. Counsel for each parry shall file with the Court and
opposing counsel a Memorandum setting forth each party's position on custody, a
list of witnesses who will be expected to testify at the hearing and a summary of
the anticipated testimony of each witness. These Memoranda shall be filed at
least five days prior to the hearing date.
2. Legal custody: The Mother, Bonnie Laughman, and the Father, Rodney
Laughman, Sr., shall have shared legal custody of Rodney Laughman, Jr., born
07/02/1992 and Alyssa Laughman, born 03/21/1998. The parties shall have an
equal right to make all major non-emergency decisions affecting the Children's
general well-being including, but not limited to, all decisions regarding their
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 Children
including, but not limited to, medical, dental, religious or school records, the
residence address of the Children and of the other parent. To the extent one
parent has possession of any such records or information, that parent shall be
required to share the same, or copies thereof, with the other parent within such
reasonable time as to make the records and information of reasonable use to the
other parent.
3. Physical Custody: Mother and Father shall share physical custody of the Children
as follows:
a. Commencing 01/16/09, Mother shall have physical custody of the
Children from after school on Friday until Wednesday morning
every other week. Father shall transport the Children to Mother's
residence on Friday at 5:30 pm. Mother is responsible for
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transporting the Child(ren) to school (or the baby-sitter prior to
school) Monday through Wednesday mornings.
b. Commencing 1/26/09, Mother shall have physical custody of the
Children from after school on Monday until Wednesday morning
every other week. Mother shall pick the Child(ren) up after school
on Monday. Mother is responsible for transporting the Child(ren)
to school (or the baby-sitter prior to school) Tuesday and
Wednesday mornings.
4. The non-custodial parent shall have liberal telephone contact with the Children on
a reasonable basis.
5. Holidays: The parents shall arrange a holiday schedule as mutually agreed.
6. The Children shall remain in their current school district absent mutual agreement
or further Order of Court.
7. Neither party may say or do anything nor permit a third party to do or say
anything that may estrange the Children from the other party, or injure the opinion
of the Children as to the other party, or may hamper the free and natural
development of the Children's love or affection for the other party. To the extent
possible, both parties shall not allow third parties to disparage the other parent in
the presence of the Children.
8. In the event of a medical emergency, the custodial party shall notify the other
party as soon as possible after the emergency is handled.
9. The parties may modify this Order by mutual agreement in writing. In the
absence of mutual consent, the terms of this Order shall control.
xDi tribution:
chael Whare, Esq.
Oa6ie Laughman, 265 Waynesboro Pike, Fairfield, PA 17320
t/J?ehn J. Mangan, Esq.
RODNEY E. LAUGHMAN, SR.
Plaintiff
V.
BONNIE LAUGHMAN
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: No. 08-7423 Civil Term
: ACTION IN CUSTODY
CONCILIATION CONFERENCE Si Mb URY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF
PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following
report:
1. The pertinent information pertaining to the children who are the subject of this
litigation is as follows:
Name Date of Birth Currently in the Custody of
Rodney Laughman, Jr. 07/02/1992 Mother and Father
Alyssa Laughman 03/21/1998 Mother and Father
2. A Conciliation Conference was held on January 15, 2009 with the following
individuals participating:
The Mother, Bonnie Laughman, pro se
The Father, Rodney Laughman, Sr., with his counsel, Michael Whare, Esq.
3. Mother's position on custody is as follows: Mother moved to Adams County
in the spring of 2008 and now Mother and Father live approximately fifty (50)
minutes apart. The Children have remained in their school district in
Cumberland County. Currently Mother and Father share physical custody
essentially equally. Mother has been transporting Alyssa to school (to a baby-
sitter prior to school starting). The parents have been flexible regarding
Mother's custodial time with Rodney, Jr. due to his age and work/school
commitments. Mother asserts that the status quo is working fine or in the
alternative, Mother requests that Alyssa change schools and that she would
have Alyssa for the school week. Mother has some concerns about the
Children and their academic performance.
4. Father's position on custody is as follows: Father asserts that the current
situation is not in Alyssa's best interest due to the travel time that Alyssa
spends from Mother's residence to school in the morning. Father would like
to have the Children for the school week (Monday through Friday) and would
be willing to expand Mother's weekend custodial time to three weekends per
month. Father is also willing to offset Mother's "loss" of custodial time by
expanding Mother's custodial time in the summer.
5. The Conciliator recommends an Order in the form as attached scheduling a
Hearing and entering an Order of Court regarding custody as outlined. It is
the Conciliator's belief that this would be in the Children's best interest. It is
expected that the Hearing will require one half day.
6. The proposed recommended Order may contain a requirement that the parties
file a pre-trial memorandum with the Judge to whom the matter has been
assigned.
Date: l 7 L,
RODNEY E. LAUGHMAN, SR.,
Plaintiff
v
BONNIE LAUGHMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
08-7423 CIVIL TERM
IN CUSTODY
IN RE: COMPLAINT FOR CUSTODY
ORDER OF COURT
AND NOW, this 20th day of April, 2009, upon
consideration of the Complaint for Custody filed in the
above-captioned matter, and pursuant to an agreement reached in
open court by the parties, with Plaintiff being represented by
Michael Whare, Esquire and Defendant representing herself, the
Order of Court dated January 21, 2009, with respect to custody of
the parties' children is hereby entered as a Final Order.
By the Court,
Michael Whare, Esquire
37 East Pomfret Street
Carlisle, PA 17013
For Plaintiff
/nnie Laughman
265 Waynesboro Pike
Fairfield, PA 17320
Defendant, pro se
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RODNEY E. LAUGHMAN, SR.
Plaintiff
V.
BONNIE LAUGHMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action- Law
No. 08-7423 Civil Term
IN DIVORCE
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Ps Form 3811, February 2004 Domestic Retum Receipt 102595-02-W1540
RODNEY E. LAUGHMAN, SR. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : Civil Action- Law
V)
:No. 08-7423 Civil Term -a3
BONNIE LAUGHMAN, Zrrnn ? rn--
Defendant M urn
IN DIVORCE el > X-
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WAIVER OF NOTICE OF INTENTION TO REQUEST ENT RVe
OF A DIVORCE DECREE UNDER SECTION 3301(d)
OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed
with the Prothonotary.
I verify that the statements made in this Affidavit 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.
?- ?
Rodney ghm ,Plaintiff
RODNEY E. LAUGHMAN, SR.,: IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v.
BONNIE LAUGHMAN,
Defendant
CIVIL ACTION - LAW
NO. 08-7423 CIVIL TERM
ORDER OF COURT
AND NOW, this 10'h day of February, 2011, upon consideration of Plaintiff s
Praecipe To Transmit Record [erroneously indicated as filed on behalf of Defendant], and
it not being clear that Plaintiff's Affidavit under Section 3301(d) of the Divorce Code
was accompanied by the Notice To Defendant required by Pa. R.C.P. 1920.72(d), a
divorce decree will not be entered at this time, without prejudice to the parties' rights to
correct the deficiency and file a new praecipe to transmit.
'Michael J. Whare, Esq.
37 East Pomfret Street
Carlisle, PA 17013
Attorney for Plaintiff
Bonnie Laughman
265 Waynesboro Pike
Fairfield, PA 17320
Defendant, pro Se
BY THE COURT,
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2911 FEB 14 AM 41: F
'CUMBERLAND COU'14'?*`PENNSYM*111'?
RODNEY E. LAUGHMAN, SR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. Civil Action- Law
No. 08-7423 Civil Term
BONNIE LAUGHMAN,
Defendant
: IN DIVORCE
AMENDED PRAECIPE TO TRANSMIT THE RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of
a divorce decree:
1. Grounds for divorce: Irretrievable breakdown under §3301(d) of the Divorce Code.
2. Date and manner of service of the Complaint: Filed on December 22, 2008 and was
served on the Defendant by certified mail, endorsed restricted delivery-return receipt
requested and signed by the Defendant on December 27, 2008.
3. (b)(1) Date of Execution of the affidavit required under §3301(d) of the Divorce Code:
December 19, 2008. (2) Date of filing and service of defendant's affidavit upon the
respondent: Filed December 22, 2008 and served on the Defendant with the Complaint on
December 23, 2008 and again served on Defendant on July 6, 2009 along with the Notice to
Request Entry of Divorce . (See undersigned counsel's Certificate of Service attached to
Notice to Request Entry of Section 3301(d) Divorce Decree that was filed on February 3,
2011)
4. Related Claims pending: None.
5. (b) Date Plaintiff's Waiver of Notice under §3301(d) of the Divorce Code was filed with
the Prothonotary : January 24, 2011.
Date Defendant's Waiver of Notice under §3301(d) of the Divorce Code was filed with
the Prothonotary :
Respectfully submitted,
Date: 2-1q -a MMichael J. Wh , Esquire
37 East Pomfret Street
Carlisle, PA 17013
(717) 243-3561
Supreme Court ID #89028
Attorney for Plaintiff
Rodney E. Laughman, Sr.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 08-7423 Civil Term
DIVORCE DECREE
AND NOW, p? l ( , it is ordered and decreed that
Bonnie Laughman
Rodney E. Laughman, Sr.
Bonnie Laughman
bonds of matrimony.
plaintiff, and
defendant, are divorced from the
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (If no
claims remain indicate "None.")
None.
By the Court,
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RODNEY E. LAUGHMAN, SR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
BONNIE LAUGHMAN, NO. 08-7423 CIVIL TERM
Defendant IN CUSTODY
PETITION FOR MODIFICATION OF CUSTODY
AND NOW, comes Petitioner, Rodney E. Laughman, Sr., the Plaintiff in the above
captioned matter, by and through his counsel, Hannah Herman-Snyder, Esquire, and the law firm
of Griffie &Associates, P.C. and avers as follows:
1. Your Petitioner is the above-named Plaintiff, Rodney E. Laughman, Sr., hereinafter
"Father," an adult individual currently residing at 11 Koser Lane, Shippensburg,
Cumberland County, Pennsylvania.
2. Your Respondent is the above-named Defendant, Bonnie Laughman, hereinafter
"Mother," an adult individual currently residing at 45 Ortanna Road, PO Box 38,
Cashtown, Adams County, Pennsylvania.
3. The parties are the natural parents of one minor child, namely Alyssa Laughman, born
March 21, 1998. 483-00 PA A"
Ca b&
4. The parties are subject to an Order of Court entered on January 21, 2009, a copy of
which is attached hereto and incorporated herein by reference as Exhibit "A."
5. Since the entry of the aforementioned Order of Court, dated January 21, 2009, the
parties only followed that Order of Court for a very short period of time and since, at
least, 2011,the child has resided with Father on a primary basis.
6. Mother requests modifications to the custody schedule on a regular basis, and Father
has always complied; however, the changes in the schedule have always allowed that
Father is exercising primary physical custody.
7. Mother's requests for modifications to the custody schedule have been to
accommodate her personal life and the changes are disruptive to the child's schedule
and routine.
8. The child is having issues in school in regards to her grades, such that it does not
benefit the child to have any midweek visits with Mother as Mother's only input into
the school situation is that if the child wants to fail, that is her own problem.
9. Mother has had no involvement in the child's educational needs and issues, and all
communication regarding the child's issues have been between Father and the school.
10. The child is not completing school work and is missing school or arriving late for
school on days she is in Mother's custody.
11. A routine schedule, eliminating midweek visits with Mother, will benefit the child
and will allow Father to work with the child on improving her school performance.
10. The Honorable Wesley Oler, Jr., signed the initial Custody Order in this matter.
11. Defendant, Bonnie Laughman, is being provided with a notice of the filing of this
Petition for Modification of Custody at her address of 45 Ortanna Road, PO Box 38,
Cashtown, Adams County, Pennsylvania 17810.
WHEREFORE, Petitioner requests your Honorable Court modify the current Order so as
to grant Petitioner primary physical custody of the child and Respondent periods of partial
physical custody such that Respondent's periods of partial physical custody do not take place
during the school week.
Respectfully submitted,
Hannah Herman-Snyder, Eskuire
Attorney for Plaintiff/Petitioner
Supreme Court ID No. 91537
GRIFFIE& ASSOCIATES, P.C.
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
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f. JAN 2 n 20096,
RODNEY E.LAUGHMAN, SR : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V.
No. 08-7423 Civil Term
BONNIE LAUGHMAN
Defendant :ACTION IN CUSTODY
COURT ORDER
AND NOW,this I— day of January 2009,upon consideration of the
attached Custody Conciliation Report, it is ordered and directed that:
1. This Order is entered pursuant to a Custod Conciliation—Conference. A Custody
Hearing is hereby scheduled on the. L day o4er]ai 2009 at
am/pm in Courtroom number in the County Court of
Common Pleas, Carlisle,PA 17013 at which time testimony will be taken in
regard to the physical custody for the subject Children. For purposes of this
hearing,the Father shall be deemed to be the moving party and shall proceed
initially with testimony. Counsel for each party shall file with the Court and
opposing counsel a Memorandum setting forth each party's position on custody,a
list of witnesses who will be expected to testify at the bearing and a summary of
the anticipated testimony of each witness. These Memoranda shall be filed at
least five days prior to the hearing date.
2. Legal custody: The Mother,Bonnie Laughman,and the Father,Rodney
Loughman,Sr.,shall have shared legal custody of Rodney Laughman, Jr.,born
07/02/1992 and Alyssa Laughman,born 03/21/1998. The parties shall have an
equal right to make all major non-emergency decisions affecting the Children's
general well-being including,but not limited to,all decisions regarding their
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 Children
including,but not limited to,medical;dental,religious or school records,the
residence-address of the Children and of the other parent~ To the extent one
parent has possession of any such records or information,that parent shall be
required to share the same, or copies thereof,with the other parent within such
reasonable time as'to make the records and information of reasonable use to the
other parent.
3. Physical Custody: Mother and Father shall share physical custody of the Children
as follows:
a. Commencing 01/16/09,.Mother shall have physical custody of the
Children from after school on Friday until Wednesday morning
every other week. Father shalll transport the Children to Mother's
residence an Friday at 5:30 pm. Mother is responsible for
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transporting the Children)to school (or the baby-sitter prior to
school)Monday through Wednesday mornings.
b. Commencing 1/26/09,Mother shall have physical custody of the
Children from after school on Monday until Wednesday morning
every other week. Mother shall pick the Children)up after school
on Monday. Mother is responsible for transporting the Children)
to school(or the baby-sitter prior to school)Tuesday and
Wednesday mornings.
4. The non-custodial parent shall have liberal telephone contact with the Children on
a reasonable basis.
5. Holidays: The parents shall arrange a holiday-schedule as mutually agreed.
6. The Children shall remain in their current school district absent mutual agreement
or further Order of Court.
7. Neither party may say or do anything nor permit a third party to do or say
anything that may estrange the Children from the other party,or injure the opinion,
of the Children as to the other party,or may hamper the free and natural
development of the Children's love or affection for the other party. To the extent
possible,both parties shall not allow third parties to disparage the other parent in
the presence of the Children.
8. In the event of a medical emergency,the custodial party shall notify the other
party as soon as possible after the emergency is handled.
9. The parties may modify this Order by mutual agreement in writing. In the
absence of mutual consent,the terms of this Order shall control.
BY TBE CO ,
I'S Lei ,
J.
Distribution:
Michael Whare,Esq.
Bonnie Laughman,265 Waynesboro Pike,Fairfield,PA 17320
John J.Mangan,Esq.
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VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unsworn falsifications to authorities.
DATE: 3
Rodney a r., Plaintiff/Petitioner
RODNEY E. LAUGHMAN, SR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION- LAW
BONNIE LAUGHMAN, NO. 08-7423 CIVIL TERM
Defendant IN CUSTODY
CERTIFICATE OF SERVICE
I, Hannah Herman-Snyder, Esquire, hereby certify that I did, the ff' day of March,
2013, cause a copy of Plaintiff's Petition for Modification of Custody to be served upon
Defendant by serving her by first-class mail,postage prepaid at the following address:
Bonnie Laughman
PO Box 38
Cashtown, PA 17810
DATE: N-b jm a r,
Hannah Herman-Snyder, Esq 're
Attorney for Plaintiff/Petitioner
Supreme Court ID No. 91537
GRIFFIE &ASSOCIATES, P.C.
200 North Hanover Street
Carlisle, PA 17013
(717)243-5551
(800)347-5552
RODNEY E. LAUGHMAN, SR. IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANa
MCC i
V. 2008-7423 CIVIL ACTION LAW Cn! '
BONNIE LAUGHMAN
IN CUSTODY =C
DEFENDANT '
ORDER OF COURT
AND NOW, Tuesday,April 02,2013 , 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 Tuesday,May 07,2013 9:00 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders,and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: /s/ john 1.Mangan,jr. 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
�13�3
RODNEY E. LAUGHMAN, SR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - LAW
NO. 08-7423 CIVIL
BONNIE LAUGHMAN,
Defendant
ORDER
AND NOW, this /1' day of May, 2013, the above-captioned case is assigned to
the Honorable J. Wesley Oler, Jr., Senior Judge.
BY THE COURT,
Kev' A. Hess, P. J.
'The J. Wesley Oler, Jr.
Court Administrator
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RODNEY E. LAUGHMAN, SR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2008-7423 CIVIL ACTION - LAW;,,, r
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• -v= a:
BONNIE LAUGHMAN, �Co
Defendant : IN CUSTODY •'
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ORDER OF COURT <
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AND NOW,this fly day of M.> ti , 2013, upon `; ,
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows: ry
1. A Hearing is scheduled in Court Room No. , of the Cumberland
County Court House, on the l`b day of ':r"I q , 2013, at q'
o'clock,A. M., at which time testimony will be taken. For purposes of this Hearing,
Father shall be deemed to be the moving party and shall proceed initially with testimony.
Counsel for each party shall file with the Court and opposing counsel a Memorandum
setting forth each party's position on custody, a list of witnesses who will be expected to
testify at the Hearing and a summary of the anticipated testimony of each witness. These
Memoranda shall be filed at least five days prior to the Hearing date.
2. Pending the hearing, the prior Order of Court of the Honorable J. Wesley
Oler, Jr. dated January 21, 2009 shall remain in full force and effect with the following
modification.
3. The parties shall cooperate with continued counseling for the child. The
parties shall share the cost of any unreimbursed cost for counseling.
4. 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,
S. J.
cc nnah Herman-Snyder, Esquire, Counsel for Father
Jane Adams, Esquire, Counsel for Mother
Ca ,'mss << .
RODNEY E. LAUGHMAN, SR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2008-7423 CIVIL ACTION - LAW
BONNIE LAUGHMAN,
Defendant : IN CUSTODY
PRIOR JUDGE: J. Wesley Oler,Jr., 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
Alyssa Laughman March 21, 1998 disputed
2. A Conciliation Conference was held in this matter on May 8, 2013, with
the following in attendance: The Father, Rodney E. Laughman, Sr., with his counsel,
Hannah Herman-Snyder, Esquire, and the Mother, Bonnie Laughman, with her counsel,
Jane Adams, Esquire.
3. The Honorable J. Wesley Oler previously entered an Order of Court dated
January 21, 2009 providing for shared legal custody, and shared physical custody on a
5/2 rotating schedule. Father filed a Petition to Modify.
4. Father's position on custody is as follows: Father seeks shared legal
custody and primary physical custody, with Mother having alternating weekends during
the school year and shared physical custody during the summer. Father asserts that
shortly after the current Order was put into place, the parties mutually agreed to change it
so that Father has primary physical custody. Father maintains that Mother does not
encourage the child in her school work and delivers her to school tardy frequently.
Father also asserts that there is domestic violence in Mother's home that is detrimental to
the child. Lastly, Father indicates that once when the child did not return home after
school he contacted the police who later indicated that Mother knew where the child was
which was with her boyfriend at a cabin alone all weekend.
5. Mother's position on custody is as follows: Mother seeks shared legal
custody and primary physical custody during the school year with Father having
alternating weekends and 50150 physical custody in the summer. Mother asserts that the
child is afraid of Father,that Father drinks alcohol and drives with the child in the car.
Mother maintains that she has had 50150 physical custody of the child, and that she
delivers the child to school in a timely fashion.
6. The Conciliator recommends an Order in the form as attached scheduling
a Hearing, and maintaining the status quo with the addition of counseling for the child. It
is expected that the Hearing will require one day.
5-- g- / 3
Date Jac eline M. Verney, Esquire
Custody Conciliator
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2CE3 JUL -9 PM 12: 54
CUMBERLAND COUNTY
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RODNEY E. LAUGHMAN, SR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : No. 08-7423
BONNIE LAUGHMAN, : The Honorable J. Wesley Oler
Defendant : IN CUSTODY
CUSTODY STIPULATION AND AGREEMENT
THIS STIPULATION AND AGREEMENT entered into the day and year hereinafter set
forth, by and between Rodney E. Laughman, Sr., hereinafter referred to as "Father", who
currently resides at 11 Koser Lane, Shippensburg, Cumberland County, Pennsylvania, and
Bonnie Laughman, hereinafter referred to as "Mother," who currently resides at 45 Ortanna
Road, Cashtown,Adams County, Pennsylvania.
WHEREAS, the parties are the natural parents of one minor Child, namely and Alyssa
Laughman, born March 21, 1998, hereinafter referred to as "Child;"
WHEREAS, the parties live separate and apart, and wish to enter into a comprehensive
stipulation and agreement relative to physical and legal custody of their child.
NOW THEREFORE, in consideration of mutual covenants, promises and agreements as
hereinafter set forth, the parties stipulate and agree as follows:
1. Legal Custody: The Mother, Bonnie Laughman, and the Father, Rodney E. Laughman,
Sr., shall have shared legal custody of Alyssa Laughman, born March 21, 1998. The
parties shall have an equal right to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions regarding their
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.
2. Physical Custody: Mother and Father shall share physical custody of the Child on an
equal basis such that Father shall exercise physical custody of the Child at all times not
specifically set forth herein: Mother shall exercise custody every Tuesday at 5:00 p.m.
until Wednesday morning, when she shall either drop the child off at school, or if school
is not in session, to Father at 7:00 a.m.; every Wednesday at 5:00 p.m. until Thursday
morning, when she shall either drop the Child off to school, or if school is not in session,
to Father at 7:00 a.m.; and every other weekend from Friday at 5:00 p.m. until Monday
morning, when she shall either drop the Child off to school, or if school is not in session,
to Father at 7:00 a.m.
3. Transportation: Transportation shall be shared as follows:
A. For the Tuesday and Wednesday custody exchanges, Mother shall pick up the
Child from Father's residence, and for the Friday custody exchange, Father shall
drop the Child off to Mother's residence.
B. For all custody exchanges that are taking place in the morning, said custody
exchanges shall be Mother's responsibility.
C. All transportation, in regards to holidays and vacation, shall be shared equally by
the parties.
4. Laundry: Mother shall ensure that the Child's laundry is taken care of during her long
weekend with the Child such that Mother returns clean clothes to Father on the Monday
following her long weekend of custody.
5. Holidays: The parents shall arrange a holiday schedule as mutually agreed.
6. School District: The Child shall remain in her current school district absent mutual
agreement or further Order of Court.
7. Vacation: Each party shall be entitled to one week of summer vacation, with thirty (30)
days notice to the other party, with said notice including contact information and the
vacation destination. Said period of time shall not be attached to any regularly scheduled
period of custody, but rather than include any regularly scheduled period of custody.
8. Interference: Neither party may say or do anything nor permit a third party to do or say
anything that may estrange the Child from the other party, or injure the opinion of the
Child as to the other party, or may hamper the free and natural development of the
Child's love or affection for the other party. To the extent possible, both parties shall not
allow third parties to disparage the other parent in the presence of the Child.
9. Emergency: In the event of a medical emergency, the custodial party shall notify the
other party as soon as possible after the emergency is handled.
10. Modifications: The parties may modify this Order by agreement in writing. In the
absence of mutual consent, the terms of this Order shall control.
11. Relocation: No party shall be permitted to relocate the residence of the Child to significantly
impair the ability of another person to exercise custody UNLESS every individual who has
custody rights to the Child consents to the proposed relocation OR the Court approves the
proposed relocation. A person proposing to relocate MUST comply with the notice
requirements pursuant to 23 Pa. C.S.A. Section 5337(c).
12. Counseling: While the Child recently completed counseling with Amy Whorley of Pathways
Counseling in Chambersburg, the parties agree that if either one of them believes, in the
future, that counseling is necessary for the Child, they shall make best efforts to ensure that
Amy Whorley is the counselor. The costs of the counseling not covered by insurance shall
be shared equally by the parties.
13 Prior Orders and Hearing: All prior Orders in this matter are vacated, and the hearing
scheduled for July 22, 2013 at 9:00 a.m. is cancelled.
14. Acknowledgment: The parties acknowledge that they have read and understand the
provisions of this Agreement. Each party acknowledges that the Agreement is fair and
equitable and that it is not the result of any duress or undue influence.
15. Stipulation: The parties stipulate that in making this Agreement, there has been no fraud,
concealment, overreaching, coercion, or other unfair dealing on the part of the other
party.
IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms
hereof, set forth their hands and seals the day and year hereinafter mentioned.
WITNESSETH:
`+� Date ROD► e ' • , HMA 'I, SR.g.
01 ' i . . 4._ 1 I A 466/3 g/hvt.f...4.-
41 Date BONNIE LAUGHMAN
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RODNEY E. LAUGHMAN, SR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
No. 08-7423
BONNIE LAUGHMAN, The Honorable J. Wesley Oler
Defendant IN CUSTODY
ORDER OF COURT
AND NOW this j day of v 2013, the attached Custody Stipulation
and Agreement is hereby made an Order of Court, and, specifically, all prior Orders in this
matter are vacated, and the hearing scheduled for July 22, 2013 at 9:30 a.m. is cancelled.
BY THE COURT,
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cc: 'Alannah Herman-Snyder, Esquire
Attorney for Plaintiff MM }
V/Jane Adams, Esquire J
Attorney for Defendant
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