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Home My WebLink About04-1868 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEFFERY L. HAULMAN, Plaintiff v. CNIL ACTION - LAW IN CUSTODY NO. ()l.l- tft.!' CLDl",~~ BARBARA Z. MOHR, Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty(20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without furthernotice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER 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 2 Liberty Avenue Carlisle,PA 17013 (717) 249-3166 NOTICIA Le han demandado a usted en la corte. Si usted qui ere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, 1a corte tomaramedidas ypuede entrar una orden contra usted sin previo aviso o notificacion yporcualguier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiendades 0 otros derechos importantes para usted. LLEVE ESTADEMANDAA UN ABOGADO IMMEDIATAMENTE. SINO nENE ABOGADO o SINOTIENEELDINERO SOFICIENTEDE PAGAR TALSERVICO, V AY AENPERSONAL o LLAME POR TELEFONO A LA OFICINA CUY A DlRECCION SE ENCUENTRA ESCRlT A ABAJO PARA A VERlGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 HANFT & KNIGHT, P.C. ~ -~~ J\1lchael J. Hanft, squire Attomey ill No. 57976 Sean M. Shultz, Esquire Attorney ill No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, P A 17013-9142 (717) 249-5373 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEFFERY L. HAULMAN, Plaintiff v. CIVIl. ACTION - LAW IN CUSTODY .-,- NO. 0<;- /'i(,f CV;J /.v-- BARBARA Z. MOHR, Defendant COMPLAINT FOR PRIMARY CUSTODY AND NOW, this 1-'1"" day of April, 2004, comes Plaintiff, Jeffery L. Haulman, by and through his attorneys, Hanft & Knight, P. c., and files the following Complaint for Primary Custody in support thereof avers as follows: 1. The Plaintiffis Jeffery L. Hauhnan, an adult individual residing at 229 WestDauphin Street, Eno1a, Pennsylvania 17025. 2. The Defendant is Barbara Z. Mohr, an adult individual residing at 101 Howard Street, Enola, Pennsylvania 17025. 3. The Plaintiff seeks primary custody and visitation of the following child: Name Megan Rose Haulman Present Residence Age 101 Howard Street 6 Enola, Pennsylvania 17025 D/O/B February 2, 1998 The child was born out of wedlock. The child is presently in the physical custody of Barbara Z. Mohr. In addition to the child's present address, during the past five years, the child has resided with Defendant at the following addresses: 101 Howard Street, Enola, Pennsylvania 17025. The mother ofthe child is the Defendant who resides at 10 1 Howard Street, Enola, Pennsylvania 17025. The father of the child is the Plaintiffwho resides at 229 West Dauphin Street, Enola, Pennsylvania 17025. 4. The relationship ofP1aintiffto the child is that of natural father. The Plaintiff currently resides with his son, Justin B. Hau1man, who is umelated to De~endant. 5. The relationship of the Defendant to the child is that of natural mother. The Defendant currently resides with the child and Defendant' s other daughter, Chelsea Mohr, who is wrrelated to Plaintiff. 6. Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation conceming the custody of the child in this or another court. The Plaintiffhas no information of a custody proceeding concerning the custody of the child in this or any other court. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interests and permanent welfare ofthe child will be served best by granting the relief requested because: a) TheP1aintiffhas had shared physical and legal custody of the child since the child's birth; b) The Plaintiff provides the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; c) The Plaintiff is, and has always been, willing to accept custody of the child; and d) The Plaintiff continues to exercise parental duties and responsibilities and enjoys the love and affection of the child; and e) The Plaintiff provides a more stable home environment. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. There are no other persons who are known to have or claim a right to custody or visitation of the child. 9. Defendant has not allowed Plaintiffto see the child fi)fmore than one month. Therefore, Plaintiff respectfully requests that a conciliation be scheduled as soon as possible. WHEREFORE, Plaintiff respectfully requests Your Honorable Court grant PlaintiffJ effery L. Haulman primary custody of Megan Rose Hau1man, while providing Defendant with partial custody. Respectfully submitted, HANF Michael J. Hanft, Esquire Attomey ill No. 57976 Sean M. Shultz, Esquire Attorney ill No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, P A 17013-9142 (717) 249-5373 Attorneys for Plaintiff 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 of18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. jAl~ ~[aulman ~ ~ (") ..... rJ c <=> ~ <=> Ii < ..c- ~ - ~f~ :r- ~:n p, -0 .....1 ::0 ~'>r" ~~ ~ <./) .:~. N - ~;;,: -.J {>S & ~ ~""'j ~~ ~:C) -0 f! .ocO :x W t ::t=,.C: -7 ~ Om ...} ~- -'" ~ :t ........ N -< $ JEFFERY L. HAULMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION .. LAW : IN CUSTODY BARBARA Z. MOHR, Defendant : NO. 04-1868 CIVIL TERM TO THE PROTHONOTARY: ENTRY OF APPEARANCE Please enter the appearance of the undersigned counsel fbr the Defendant, Barbara Mohr, in the above captioned matter. Respectfully Submitted, (/)/70 ~)m Certified Le '~~ ! /" (7!:::-~ -L=~)~kZ o M. PLACE ROBER E. RAINS LUCY JOHNBTON-WALSH ANNE MACDONALD-FOX Supervising Attomey FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 () c s: -On! Q;j -'-.".' ,~ ~~;., c:= ~~j ~ "> = = J:- ::;: ;p. -< I Q) o -n -< :C-r, nlF~:;; .r)fT"l :6<:., S1c, t5JJ ."'t...... ~::5 (fl ---1 );:,. '"r; =< "'" :!\: UI (7) JEFFERY L. HAULMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN CUSTODY BARBARA Z. MOHR, Defendant : NO. 04-1868 CIVIL TERM CERTIFICATE OF SERVICE I, Mary Claycomb Kulp, hereby certifY that I served a tme and correct copy of the Entry of Appearance on Jeffery Haulman through his attorney, Sean M. Shultz, at 19 Brookwood Avenue, Suite 106, Carlisle, PA 17013, by First Class U.S. mail. May 6, 2004 ~~~~ Certified LI~gal Intem o ~~, ;-'?t.;';; 2",:. -:Zl. '~2.':; s;::::<- ~~;~ ~ r-> g .r ::l'C ,,,, -" I U' o -n ~~ \l1p -orn -OC) 9h :2~..3:3 ~~~- f?\ C) ~ ":0 ~-< ;:::- ::>:: - - U1 -l JEFFERY L. HAULMAN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 04-1868 CIVIL ACTION LAW BARBARA Z. MOHR DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, May 11, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June 03, 2004 , the conciliator, 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. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin!!. FOR THE COURT. By: Isl Hubert X. Gilroy, Esq. Custody Conciliator mhc The Court of Common Pleas of Cumberland County is rcquired 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 .~~# ~~~ 40-//5 . lIP ~ """-p',,:,v ~tL, Ac?//. > .~~~ ~'~ ~./W ~!?//> \!l!,.J;/IilAS'!\!fJ:!d 1 'Nflr" f" ..," '-'-'''(1''\ Ai.. '1\./..' .,;;.)~'r :'.J:<Un, IV LO:'1 !../d II ),VIHOOZ AH'vl0NOi{J.OCid 3H1 :10 301:!:I0-G3ll:l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA JEFFREY L. HAULMAN, Plaintiff v. CNIL ACTION - LAW NO. 04-1868 BARBARA Z. MOHR, Defendant IN CUSTODY CERTIFICATE OF SERVIC]~ AND NOW, this -t.1"'-day of May, 2004, I, Sean M. Shultz, Esquire, hereby certifY that the following person was served with a True and Correct copy of the Complaint in Custody filed in the above-referenced matter. The Complaint in Custody was maikd on April 28, 2004, but actual service took place on April 29, 2004, by Defendant signing for a copy ofthe Complaint in Custody which was mailed in the United States Mail, Certified Mail--Retum Receipt Requested, Restricted Delivery, Postage Prepaid, addressed as follows: Barbara Z. Mohr 101 Howard Street Eno1a, Pennsylvania 17025 A copy of the signed Domestic Retum Receipt is attached hereto as Exhibit "A" and by reference incorporated herein and made a part hereof. Respectfully submitted, C/7_~ ~ltz, Esquir Attorney ill No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 F:\User Folder\Firm Docs\Gendocs2004\3408_1ceT,ser.wpd Attorneys for Plaintiff ._ Co'mplete fte~~'1 r2:/ari9_~_._,JVsi?'-~_mpje~~_?~1~~~ Rem 4 if RestriclEid DeIiV5/)' Is desIred. " ; ';::;X; ,:' II 'Print your name:_~~cf add~son' theJ~vl~_i'Sey",;:~:i:.t-y;t\: so that we"c;an returnthecarti to YOlJ.{-<;,3~,t~;;,~~t~ . Attach this card to the back of the mellplece, ,co', ,"0, ;', or, <<:>" _ th~.frl?!:l~ _If~pac~ 'permits.;,' :_(~{2t,'!.;~~t;:,,~:'#~!:' :{_~:;) 1. Article AddreSsed'to:'", _ ,'-, ::?~'~<;'::ki ;/ ,,' _ __:'>,_:_,_i)>,;:'<:-:<:;</~__;-_:_:: :'/'~/__<:';_<'-' .__\_,:<,,-'):;_.,_~f!};i .:',: 'Bar bat,r]ifMok.y:~" J 6d~ lo~{Jt;~:~;;:g;~~4 ~ . ,An rv~YLA ~" ,... 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HAULMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW BARBARA Z. MOHR, Defendant NO. 2004 - 1868 IN CUSTODY COURT ORDER , AND NOW, this ~ day of June, 2004, upon considleration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The mother, Barbara Z. Mohr, and the father, Jeffery L. Haulman, shall enjoy shared legal custody of Megan Rose Haulrnan, born February 2, 1998. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy periods of temporary physiical custody of the minor child as follows: a. On alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m. b. At such other times as agreed upon by the paliies. 4. Neither party should consume alcohol when they have custody of the minor child. Additionally, neither party shall cousume illegal drugs when they have custody of the minor child. Furthermore, neither party shalll disparage the other parent or the other parent's family to the minor child or in the presence of the minor child. 5. When the father has custody of the minor child, he shall eusure that overnight accommodations are made such that she has a separate bed that she may sleep in alone. Additionally, father shall not leave the minor child unsupervised in the custody of his son Justin or his nephew Jason. 6. Legal counsel for the parties shall conduct a telephone conciliation conference call on Thursday, August 26, 2004 at 8:30 a.m. The conference call will be initiated by the Custody Conciliator. At that time, the Conciliator will review the status of the case to determine if the case requires that a hearinl~ before the Court be scheduled. V}N/':l},S:-l~ ,FJd Aj)~(-'(>''': "., r::~V";i18 92:\ lid 01 NnnUDZ ,,\b\/lC,~<iJHj.c){id 3Hl :10 :';:j,:.j~O"{iJll:j 7. Father's weekend of alternate custody shall start on June 11, 2004 but shall also include the weekend of June 18, 2004. The weekend of June 25, 2004 shall be the mother's weekend with the parties alternating thereafter. 8. Both parties shall enjoy reasonable telephone contact with the minor child when the child is in the custody of the other parent. BY THE COURT, cc: Abigail Salawage Sean Shultz, Esquire ~~ &._!o.tJ'f' C;~ dUN 0 8 2004 ( JEFFERY L. HAULMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW BARBARA Z. MOHR, Defendant NO. 2004 - 1868 IN CUSTODY CONCILIATION CONFERENCE SUMMARY 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 child who is the subject of this litigation is as follows: Megan Rose HauIman, born February 2, 1998. 2. A Conciliation Conference was held on June 3, 2004, with the following individuals in attendance: The father, Jeffery L. Haulman, with his counsel, Sean Shultz, Esquire, and the mother Barbara Z. Mohr, with her couusel, Abigail Salawage, of the Dickinson School of Law, Family Law Clinic. 3. Based upon the recommendation of the Conciliator, the parties agree to the entry of an order in the form as attached. L< I ~( () If DATE CJII---K) Hubert X. Gilroy" Es Custody Conciliator JEFFERY L. HAULMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY BARBARA Z. MOHR, Defendant : NO. 04-1868 CIVIL TERM PETITION FOR LEAVE TO WITlLORAW Petitioner, The Family Law Clinic, hereby petitions for leave to withdraw from further representation of Barbara Z. Mohr, pursuant to Pa.R.P.C. 1.l6(a) and Pa.R.C.P. 1012(b), and in support therefore avers the following: 1. The Family Law Clinic entered an appearance in the above captioned matter on behalf of Barbara Z. Mohr on May 6, 2004. 2. On June 3, 2004, the Family Law Clinic attended a custody conciliation representing Ms. Mohr. 3. An Order of Court was issued on June 9, 2004, granting Ms. Mohr shared legal and primary physical custody of her daughter. A custody conciliation teleconference is scheduled for August 26, 2004. 4. On June 30, 2004, the undersigned certified legal intem and Lucy Johnston-Walsh, supervising attorney at the Family Law Clinic, spoke to Ms. Mohr on the telephone and Ms. Mohr indicated that she wanted to hire another attorney. 5. On July 20,2004, Ms. Mohr discharged the Family Law Clinic, in writing, from representing her in this matter. A copy of the Discharge is appended hereto as Petitioner's Exhibit A and is incorporated herein by reference. 6. Pursuant to C.C.R.P. 206(2), the Family Law Clinic sought concurrence from opposing counsel to this petition; opposing counsel concurred. 7. Pursuant to PaRC.P. 1012(d): the Plaintiff's address is 101 Howard Street, Enola, P A, 17025; this petition was served on Plaintiff by mailing a copy to the aforementioned address. A copy of this petition was mailed to opposing counsel, Sean Shultz, Esq. WHEREFORE, pursuant to Pa.R.P.C. 1.16(a), termination is mandatory upon discharge oflawyer, and the Family Law Clinic respectfully requests leave to withdraw from this action. Respectfully Submitted, Date: % :2BJ clCL"'t-/ ~ :::t~ ~ :IPLACE /. uJ~ ROBE E.RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Sup"rvising Attorneys F AMIL Y LAW CLINIC 45 1\:orth Pitt Street Carlisle, P A 17013 717-243-2968 JEFFERY L. HAULMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY BARBARA Z. MOHR, Defendant : NO. 04-1868 CIVIL TERM DISCHARGE I, Barbara Z. Mohr, discharge the Family Law Clinic from representing me as my attorney in this case. Date: 7-,)0 - eCI i~J,~: 1 /!l~l Barbara Z. M/ohr EXHIBIT I A JEFFERY L. HAULMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN CUSTODY BARBARA Z. MOHR, Defendant : NO. 04-1868 CIVIL TERM CERTIFICATE OF SERVICe I, Abigail J.W. Sa1awage, hereby certifY that I served a true and correct copy of the Petition for Leave to Withdraw by depositing a copy of the same in the United States first class mail, postage prepaid on July 28, 2004 to the following people at the following addresses: Barbara Z. Mohr 101 Howard Street Enola, P A 17025 Sean Shultz, Esq. Hanft & Knight, PC 19 Brookwood Ave, Suite 106 Carlisle, P A 17013 Date: July 28, 2004 F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A I 70 13 717-243-2968 0 ....., c: = 0 = ."O~ .r:- ...., rn ffi '- 5!:n ~p::! c::: r- n1r- 0,) N :g~ ...<.:;",< 0) ~C) ~ );:c:; -0 25:11 4::. (-~ :::c: ;i>~ 60 ~ . -m :=; ~-l -< W s5 Cl -< v -- JUL 2 9 2004 f JEFFERY L. HAULMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA - v. : CIVIL ACTION - LAW : IN CUSTODY BARBARA Z. MOHR, Defendant : NO. 04-1868 CIVIL TERM ORDER OF COURT AND NOW, this ---1.5.l- day Of-4..u-~u..~.r , 2004 upon consideration of the attached petition, it is hereby ordered that the Family Law Clinic is granted leave to withdraw from further representation of Barbara Z. Mohr. BY THE COURT: . JUL 29 lOf)4 f JEFFERY L. HAULMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LA W : IN CUSTODY BARBARA Z. MOHR, Defendant : NO. 04-1868 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Barbara Z. Mohr, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date~rJ ~~ ~.p~fll-u4~ ROBER E. RAINS ANNE MACDONALD_FOX LUCY JOHNSTON_ WALSH Supervising Attorneys F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle, P A 17013 717/243-2968 (") ~ 0 r:: = " ...... ~ <- '-1 "'U ''J..~ :J.::n rr"!r:", c:: "'r- -~. ...., ,- 2{ N ::am r~";!j= CD 01' ~t: "~~ "'. ""0 Sr':I >-;,:-. :Jc - C') ~:-'-l .~m >c;' ~ :::j z '". ~ N :.1-..1 w -< JEFFREY L. HAULMAN, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION .. LAW BARBARA Z. MOHR, Defendant : No. 2004-1868 : IN CUSTODY PETITION TO WITHDRAW AS COVNSEL AND NOW, comes Jeanne B. Costopoulos, Esquire, attorney of record for Defendant, Barbara Z. Mohr, and respectfully represents the following in support of this petition: 1. Petitioner is undersigned counsel, Jeanne B. Costopoulos, Esquire, attomey of record for Defendant, Barbara Z. Mohr, in the above captioned custody case. 2. Defendant has expressed to Petitioner that she is no longer in need of her services and that she plans retain other counsel. WHEREFORE, Petitioner Jeanne B. Costopoulos, Esquire, respectfully requests this Honorable Court to permit her to withdraw as counsel from Defenclant's case. DATED: '1/'1/1) Rd~Ubmitted by: ~stoPoUlOS' E~e -.. PA S.Ct. LD. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, P A 17055 Phone: (717) 790-9546 JEFFREY L. HAULMAN, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW BARBARA Z. MOHR, Defendant : No. 2004-1868 : IN CUSTODY VERIFICATION I, Jeanne B. Costopoulos, hereby verifY that the statements made in the foregoing document are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. !} 4904, relating to unsworn falsification to authorities. Date: 1 !r~/()s- Signature: ---- Jeanne B. Costopoulos, Esquire JEFFREY L. HAULMAN, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW BARBARA Z. MOHR, Defendant : 1'10.2004-1868 : IN CUSTODY CERTIFICATE OF SERVICE I, Jeanne B. Costopoulos, Esquire, hereby certify that this day I served a copy of the foregoing document upon the person, and in the manner, indicated below, which service satisfies the requirements of the P A Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Mechanicsburg, Pennsylvania, through first class mail, prepaid, and addressed as follows: Barbara Z. Mohr 101 Howard Street Enola, P A 17025 Sean M. Schultz, Esquire 11 Roadway Drive, Suite B Carlisle, PA 17013 BY: e"""IO' F~olre P A Supreme Court ID No. 68735 5000 Ritter Road, Suite 202 Mechanicsbul'g, PA 17055 Telephone: (717) 790-9546 DATED: {If ,IOJ' o c: r-> <= = <f' <- c: r o -n :::tl..,., nlp -ofTl ,.)0 ;::)r~) .-~-r'-, ~,~~'~ ~"..,.. r11 S:2, ~l>' ~ .::- ~ ~ U1 .::- :"~ECEIVED JUL 15 ZOllS Jy JEFFREY L. HAULMAN, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIl. ACTION - LAW BARBARA Z. MOHR, Defendant : No. 2004-1868 : IN CUSTODY ORDER OF COURT 3"\'-'\ \ parties to show cause why the attached Petition to Withdraw as Counsel should not be granted. AND NOW this ~daY of , 2005, a rule is hereby issued on both Rule returnable J.o days from service. BY THE COURT: d[ co >: (-.....I IT, ....1.. .:.;... l;::::. .... , , W.-y ~ ~2 (~5 c: !i::I~_ c t) 0"\ CD: LLJ 0- ~lLl U-iE !L- a "~i .:..~ ool)i ~, t t, fJ~ ~L J ~~ , '- ~: :,:) -'-) _I => """') U'> = = "" JEFFREY L. HAULMAN, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 2004-1868 BARBARA Z. MOHR, Defendant : CIVIl. ACTION - AT LAW : CUSTODY TO THE HONORABLE J. WESLEY OLER, JR., JUDGE OF SAlD COURT: MOTION TO M A KF, RllT ,F, A HSOI ,TTTF, AND NOW, the Petitioner, Jeanne B. Costopoulos, Esquire, makes the following Motion to Make Rule Absolute: 1. Petitioner, Jeanne B. Costopoulos, Esquire, filed a Petition to Withdraw as Counsel on July 14,2005. 2. On July 19, 2005, a rule was issued on both parties to show cause why the Petition should not be granted. The Rule was returnable 20 days from service. 3. Petitioner served both the Petition and Rule on Defendant, Barbara Z. Mohr, on July 27, 2005. (See attached Exhibit A - Affidavit of Service). 4. Petitioner served both the Petition and Rule on Plaintiffs counsel, Sean M. Schultz, Esquire, on July 25,2005. (See attached Exhibit B - Affidavit of Service) 5. Neither party has filed an answer to the undersigned's Petition to Withdraw as Counsel and more than 20 days have elapsed since service of the Petition and Rule upon both parties. WHEREFORE, the undersigned respectfully requests this Honorable Court to grant her leave to withdraw as counsel for Defendant, Barbara Z. Mohr. Respectfully submitted, ~ --- ""- Jeanne B. Costopoulos, Esquire 5000 Ritter Road, Suite 202 Mechanicsburg, P A 17055 Telephone: (717) 790-9547 P A Supreme Ct. 10 No. 68735 t'lz;/z Cfr/;.r Date: JEFFREY L. HAULMAN, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 2004-1868 BARBARA Z. MOHR, Defendant : CIVIL ACTION - AT LAW : CUSTODY rFRTTFTr'ATF OF SFRVTr'F I, Jeanne B. Costopoulos, Esquire, hereby certify that I am this day serving a copy of the foregoing document upon the persons, and in the manner, indicated below, which service satisfies the requirements of the P A Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Mechanicsburg, Pennsylvania, first class mail, prepaid, and addressed as follows: Sean M. Schultz, Esquire 11 Roadway Drive, Suite B Carlisle, PA 17013 Barbara Z. Mohr 403 S. 2nd Street Lykens, P A 17048 BY: Jeanne B. Costopoulos, Esquire 5000 Ritter Road, Suite 202 Mechanicsburg, P A 17055 Telephone: (717) 790-9547 P A Supreme Ct. ID No. 68735 Date: 't!(Z)(ZQdF AFFIDAVIT OF SERVICE TO THE PROTHONOTARY: I, Jeanne B. Costopoulos, Esquire, verifY that the Petition to Withdraw as Counsel and Rule to Show Cause was served upon the Defendant, Barbara A. Mohr, on July 27, 2005 by first class, Certified, Restricted Delivery Mail No. 7000 15300001 60020933, postage prepaid, return receipt requested, restricted delivery, pursuant to the requirements of Pa.R.C.P.91930.4. Dated: ?/?r/Zoctr BY: Je~OUlOs, ESqUir:- 5000 Ritter Road, Suite 202 Mechanicsburg, Pennsylvania 17055 PA Supreme Court ID No. 68735 Telephone: (717) 790-9546 S[ Nfl! n 1" I,d I r ('-, . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: . Date~f Delivery ~ ~2:'I-b~ . s delivery address different from item 1? Yes If YES, enter delivery address below: No Lf03,s.dn.dJ ft L'j/<.e~ ~ I >df( ~p r ~ Z. (YLo Y\r 10 ( J{ DiP'*'" sirfld gItO(fA.( IA- /702-5' 3. ~jce Type .e ~ertified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) ~ 2. Article Number (r,.nsfe'~oms.",ic.lab.l) ,tJOO 1t)?O {)()O( ~ 002 Oc(?3 PS Form 3811, August 2001 Domestic Return Receipt 102595-01-M-2509 EXHIBIT A AFFIDAVIT OF SERVICE TO THE PROTHONOTARY: I, Jeanne B. Costopoulos, Esquire, verifY that the Petition to Withdraw as Counsel and Rule to Show Cause was served upon counsel for Plaintiff, Sean M. Schultz, on July 25,2005 by first class, Certified, Restricted Delivery Mail No. 7000 1530000160020940, postage prepaid, return receipt requested, restricted delivery, pursuant to the requirements of Pa.R.C.P. ~1930.4. BY: Dated: 6(2d2~ e B. Costopoulos, Esquire 5000 Ritter Road, Suite 202 Mechanicsburg, Pennsylvania 17055 PA Supreme Court ID No. 68735 Telephone: (717) 790-9546 . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: rea" f}1, 5'c.AIAI+z, B(_ ~U.~o~r~ ~flV~ COf!e( PfJ- 170(3 3. Service Type ...!!!fCertified Mail o Registered o Insured Mail D Express Mail D Return Receipt for Merchandise Dc.o.o. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (rransferlromservicBlabell '1 000 l~,D DoC l (POO2- DC( C/o PS Form 3811, August 2001 Domestic Return Receipt 102595.01-M-2509 EXHIBIT B ;y RECEI'/ED AUG 25m ~ JEFFREY L. HAULMAN, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 2004-1868 BARBARA Z. MOHR, Defendant : CIVIL ACTION - AT LAW : CUSTODY ORnF,R OF COllRT AND NOW, this ~~y of J . 0 ,2005, upon consideration of Jeanne B. Costopoulos' Petition to Withdraw as Counsel and Petition to Make Rule Absolute, it is hereby Ordered that Jeanne B. Costopoulos Esquire, is granted leave to withdraw as counsel for Defendant, Barbara Z. Mohr. BY THE COURT: J. J . ;!:;: tn E; ~ en :=:~ co. (J lU;;f: :'::.:; '\ QcS o.:.~,,- tl::~~ 9(;, O(,J- l.U 0_ dlLl u.:r: l- ~ "" N U, -"') :;:<r '-'" = = "" ~i ~ ~> ::::J (,) ftl "" ", \ t- ~ i\~l SJ ;s ~ JEFFREY L. HAULMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW BARBARA Z. MOHR, Defendant : No. 2004-1868 : IN CUSTODY PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance ofNichole M. Staley O'Gorman, Esquire in the above- captioned matter. - Date: q- fh:J6 CERTIFICATE OF SERVICE I, JENNIE R. KELLEY, an employee of the law firm of Purcell, Krug & Haller, counsel for Plaintiff, hereby certify that the foregoing PRAECIPE TO ENTER APPEARANCE, was made upon the following by Certified Mail, Return Receipt Requested, Postage Prepaid, on q Is / D5 f I Sean M. Shultz, Esquire HANFT & KNIGHT, P.C. 19 Brookwood Avenue Suite 106 Carlisle, PA 17013-9142 ~ l-,~ ,--;Y ~/(/ ennie R. Kelley . 0 ~> 0 c....-:> C <::-;::1 -n C.fl (j) ref, -0 I ~ -,"\ C...) '~.:'t CJ "';::., .r ::< JEFFREY L. HAULMAN, Plaintiff J~ 11 r ~ ZOO5 IN THE COURT OF COMMON PLEA~ OF CUMBERLAND COUNTY, PENNSYLVANIA !Iv v CIVIL ACTION - LAW BARBARA Z. MOHR, Defendant NO. 04-1868 IN CUSTODY COURT ORDER AND NOW, this ~ day of September, 2005, upon consideration of the attached Custody Conciliation report, it is ordered and directed that this Court's prior Order of June 9, 2004 shall remain in effect subject to the following additions or modifications: 1. Transportation for exchange of custody shall be handled with the parties meeting at a halfway point for exchange, with the halfway point being at the Sheetz Store in Halifax on Route 225. 2. The father shall always have custody of the minor child on Father's Day and the mother shall always have custody of the minor child on Mother's Day. In the event those days do not correspond with the father or mother's scheduled weekend, they shall have that entire weekend on Mother's day or Father's Day, with this adjustment not to interfere with the alternating weekend schedule. 3. The parties shall alternate holidays to include Memorial Day, July 4th, Labor Day, Thanksgiving and New Years Day. For July 4th, Thanksgiving and New Years, the time frame shall be from 9:00 a.m. until 7:00 p.m. For Memorial Day and Labor Day, on the alternating holiday schedule the person having the holiday shall also have that weekend. Under this arrangement, the parent getting the weekend for the holiday shall not disrupt the standard alternating weekend schedule. 4. For the Christmas Holiday, mother shall have custody of the minor child on Christmas Eve from 6:00 p.m. until Christmas Day at 6:00 p.m. and father shall have custody from 6:00 p.m. on Christmas Day until 6:00 p.m. on December 26"'. '" \ ,', ..7, :.) J .\; 1 ';ODL 5. Each party shall enjoy reasonable telephone contact with the minor child when the child is in the custody of the other parent. Additionally, the parties shall have the ability to contact each other by phone to communicate solely on issues regarding custody of the minor child. There shall be no telephone contact concerning any other issues. 6. Both parties shall keep the other parent advised with respect to where they are when they have custody of the minor child and shall advise the other parent with respect to a telephone number as to where they can be located in the event of an emergency when they have custody. 7. Neither parent shall engage in viewing any type of inappropriate e-mail or films when they have custody of the minor child. 8. When father has custody of the minor child, the minor child shall not sleep over at anybody else's home where father is not present anymore than approximately one evening per month. 9. The parties shall exchange e-mail addresses so that they can communicate with each other with respect to scheduling visitation and other matters relating to the child. They shall not communicate via e-mail or otherwise on any other issues except for the minor child. 10. In all other respects, the prior the Order of Court shall remain in effect. BY THE COURT, / ., cc: Sean M. Shultz, Esquire Nicole Staley O'Gorrnan, Esquire (!~--ru:: ~~ q- (cIoS JEFFREY L. HAULMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW BARBARA Z. MOHR, Defendant NO. 04-1868 IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY 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 child who is the subject of this litigation is as follows: Megan Rose Haulman, born February 2, 1998. 2. A Conciliation Conference was held on September 8, 2005, with the following individuals in attendance: The father, Jeffrey L. Haulman, with his couusel, Sean M. Shultz, Esquire, and the mother, Barbara Z. Mohr, with her counsel, Nicole Staley O'Gorman, Esquire. 3. The Conciliator recommends an Order in the form as attached. {-f-OS DATE JEFFREY L. HAULMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BARBARA Z. MOHR, Defendant No. 2004-1868 IN CUSTODY EMERGENCY PETITION TO SUSPEND PHYSICAL CUSTODY AND NOW, comes Petitioner, Barbara Z. Mohr, by and through her attorneys, Purcell, Krug and Haller, and files the following Emergency Petition to Suspend Physical Custody: 1. Petitioner is Barbara Z. Mohr, Defendant in the above captioned custody action and mother of the minor child Megan Rose Haulman (born 2/2/98) . 2. Respondent is Jeffrey L. Haulman, Plaintiff in the above captioned custody action and father of the aforementioned minor child. 3. Pursuant to orders of court dated June 9, 2004 and September 13, 2005, the parties share legal custody and Mother has primary physical custody of the minor. A true and correct copy of these orders is attached hereto as Exhibits ~A" and ~B". 4. Father has periods of physical custody on alternating weekends from Friday at 6:00 p.m. to Sunday at 6:00 p.m. and designated holidays. 5. On or about January 11, 2006, Mother's older daughter to a prior marriage, Chelsea Mohr (age 13), provided her with a letter addressed to her pediatrician, Dr. Naresh Maingi. The letter details a history of sexual abuse perpetrated by Mr. Haulman when Mother and the children resided with Mr. Haulman. A true and correct copy of said letter is attached hereto and made part hereof as Exhibit "C". 6. Mother immediately contacted Children and Youth Services who in turn referred the matter to the East pennsboro Township Police Department. An investigation is now ongoing. 7. The undersigned counsel for Mother has been advised by Audra Henessey, representative of Children and Youth Services, that a safety plan has been put in place which requires Mother to prohibit all contact between Mr. Haulman and Megan until further notice. 8. Neither Mother nor governmental authorities are able to rule out sexual abuse of the Megan at this time. 9. Mr. Haulman has a history of viewing pornography on his computer, while naked, in front of minor children. The most recent custody order prohibits him from viewing any pornography in view of past events. 10. The June, 2004 order also requires Mr. Haulman to establish separate sleeping quarters for Megan, as he previously required her to sleep with him. 11. It is believed and averred that Mr. Haulman has and may continue to require Megan to shower with him. 12. Prior to Ms. Mohr and Mr. Haulman's separation. Mr. Haulman was found in bed rubbing lotion on the naked body of Chelsea Mohr. 13. Pursuant to the existing Court Order, Mr. Haulman's next scheduled period of physical custody should occur on January 27, 2006. WHEREFORE, Petitioner, Barbara Z. Mohr, respectfully requests this Honorable Court to suspend all physical custody of Jeffrey Haulman. PURCELL, KRUG & HALLER Esquire Date: I r 70 Ou tjichole . tD #7986 1719 North Front Street Harrisburg, PA 17102 717 234-4178 Attorney for Petitioner, Barbara Z. Mohr CX'r-;\'lt A ~ SEP U ~ 2005 JEFFREY L. HAULMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW BARBARA Z. MOHR, Defendant NO. 04-1868 IN CUSTODY COURT ORDER AND NOW, this (31v day of September, 2005, upon consideration of the attached Custody Conciliation report, it is ordered and directed that this Court's prior Order of June 9,2004 shall remain in effect subject to the following additions or modifications: 1. Transportation for exchange of custody shall be handled with the parties meeting at a halfway point for exchange, with the halfway point being at the Sheetz Store in Halifax on Route 225. 2. The father shall always have custody of the minor child on Father's Day and the mother shall always have custody of the minor child on Mother's Day. In the event those days do not correspond with the father or mother's scheduled weekend, they shall have that entire weekend on Mother's day or Father's Day, with this adjustment not to interfere with the alternating weekend schedule. 3. The parties shall alternate holidays to include Memorial Day, July 4th, Labor Day, Thanksgiving and New Years Day. For July 4th, Thanksgiving and New Years, the time frame shall be from 9:00 a.m. until 7:00 p.m. For Memorial Day and Labor Day, on the alternating holiday schedule the person having the holiday shall also have that weekend. Under this arrangement, the parent getting the weekend for the holiday shall not disrupt the standard alternating weekend schedule. 4. For the Christmas Holiday, mother shall have custody of the minor child on Christmas Eve from 6:00 p.m. until Christmas Day at 6:00 p.m. and father shall have custody from 6:00 p.m. on Christmas Day until 6:00 p.m. on December 26"'. 5. Each party shall enjoy reasonable telephone contact with the minor child when the child is in the custody of the other parent. Additionally, the parties shall have the ability to contact each other by phone to communicate solely on issues regarding custody of the minor child. There shall be no telephone contact concerning any other issues. 6. Both parties shall keep the other parent advised with respect to where they are when they have custody of the minor child and shall advise the other parent with respect to a telephone number as to where they can be located in the event of an emergency when they have custody. 7. Neither parent shall engage in viewing any type of inappropriate e-mail or fIlms when they have custody of the minor child. 8. When father has custody of the minor child, the minor child shall not sleep over at anybody else's home where father is not present anymore than approximately one evening per month. 9. The parties shall exchange e-mail addresses so that they can communicate with each other with respect to scheduling visitation and other matters relating to the child. They shall not communicate via e-mail or otherwise on any other issues except for the minor child. 10. In all other respects, the prior the Order of Court shall remain in effect. BY THE COURT, ~ cc: Sean M. Shultz, Esquire Nicole Staley O'G<lrman, Esquire PY FROfu ,ECOHD !~") T~.~sz~m[Hli "{flf;1}feof. i hems U 110 set my haRd :"J tl1a S!>(l! oj s.aid Coo t Ca1Sl8, Pa. . ~ I 0,. ..LhflJ ---- ~XVb\~ 8 ~ '83/88/2885 18:18 71 72498457 KtHGHT & ASSOCIATES I-'Abt.. tl'-:/tJ'I JUN 0 B 20D4f v IN THE COURT OF COl\1MON PLEAS qF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW JEFFERY L. HAULMAN, Plaintiff BARBARA. Z. MOHR, Defendant NO. 2004 - 1868 IN CUSTODY COURT ORDER AND NOW, this q ~ day of June, 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: L The mother, Barbara Z. Mohr, and the father, Jeffery L. Haulman, shall enjoy shared legal custody of Megan Rose Haulman, born February 2, 1998. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy periods of temporary physical custody of the minor child as follows: a. On alternating weekends from Friday at 6:00 p.rn. until Sunday at 6:00p.m. b. At such other times as agreed upon by the parties. 4. Neither party should consume alcohol when they have custody of the minor child. Additionally, neither party shall conswne illegal drugs when they have custody of the minor child. Furthermore, neither party shall disparage the other parent or the other parent's family to the minor child or in the presence of the minor child. 5. When the father bas custody {If the minor child, he shall ensure that overnight accommodations are made such that she has a separate bed tbat she may sleep in alone. Additionally, father shall not leave the minor c.hild unsupervised in the cusrody of his son Justin or his nephew Jason. 6. Legal counsel for the parties sball conduct a telephone conciliation conference call on Thursday, August 26, 2004 at 8:30 a.m. The conference call will be initiated by the Custody Conciliator. At that time, the Conciliator will review the status of the case to determine if the case requires that a hearing before the Court be scheduled. ~9/B8/2905 10:18 71 72490457 KrHGHT & ASSOCIATES PAGE 1j,j/lj4 7_ Father's weekend of alternate custody shall start on June 11, 2004 but shall also include the weekend of June 18, 2004. The weekend of June 25, 2004 shall be the mother's weekend with the parties alternating thereafter. 8. Both parties shall enjoy reasonable telephone contact with the minor child when the child is in the custody of the other parent BY THE COURT, yffle Cd, UJ~ (Q a,~ ~ cc: Abigail Salawage Sean Shultz, Esquire TRUE COPY FROM RECORa In T 6:rtimooy w1Jeroof. I hare IlnW SSlmy h<ll'lt1 an~ tile 521 cA said ~ at Catllsle. Pel. fillS /'2 ~~)' tl ~; ;2M'I " J j;',=. Aff j , Protl111nO!3l\l f )(h,b+ t 06 12: 18p p.2 dc-1€:\- \l-O& _..._ ..C~~Cu -- _.-.-__.-D.f';_\')Q~og;, ---- _=-_.~~.0~~f'___(h.d_-~-~_--lli-ln8-~-+o . \~e ~('e __~bC\.D~D0~~Ih.:e~CS:'9':s()n.. _~ f'10i^1 So.~d-u -----"n.~-.t'n:R-'-OR_?0-S:>j-'~--~ml4~ s_peScausE. X _ '-_.._.. __feme l_v_e..~___o:-l~_....Q"ns:L__vYJC:o Y':1-Podc...b (" . --.- ._~bou~~Q,.\'6l~.__Q-.\J00_n't~Jb<->*\"\CJVJ . _.nn __.J:-h6-&' ~'S~~Q_\.)\d_h.Ccppen +0 \'J~c"''' ._ ___C\.('-~___ :::C__~Pf\'J-_.n.wc,.1\~_~\* ~ ,_ S0.l..._~___ _~~~~ A~*._.::L_..\\.~e,cl_.~o ~... J +- 1l0'-.l.._ '"};~(eci .-Vf::-,\[lf_U-el('J., 0cL~O...f'\Q +N~ bl€ ,6c,#:n< 0J-' _,*\-.J~ bv\. ...~~~ ~ e..~ -t=' ~:DLJ ld CA.<s,~-.M.:f'..--j-o-.8P.- ups*-c..'lrs L.-)\.\-h "'-I"" CA. 'f\ncl. _ o..s~e,,_d. ._i0l e!}o.A n.n..d 0U ~ +1 r1... ..+G _ _ 6.}C'-E- - _.<i0~.,.tn6-\-&"t(0, c\.c.\L-'C.-dh~ +0 IJ -\-"'~ J^-.()_cl _ ~ Cavr:Sf'. +he...~ l'l&l--eJ1ed. V~R..-0,n __wf'.-wer-E;. Up Jh.-((f h~ ~C>\.~ V'cQ.. ....k 4.c~~,e o.\!~ 0lj Cl~-€SMd ~,€. +CQ~ D~_f'\-"-lS. HE;... -+ouch-ed Me. ev~';J;k ~\N"'Z~ O-.('\~ Vu~ f'\~ "'O,0<:\S O\) '^\'C<\ J-3 08 12: 18p p.3 .\n ',{6 ~ rlVo..~. ",-<,{' "-S. 3: ~\. ~ ~ c-",d, <i"lel, n\.\._~j OS\J-fufl.J:' Io.ff! hincJ (!J:{: _S~..~a,^,-e<\.lht'..,s.'t\~ *0\...'C.\., e.d. CS\~ . ~~1~__i'1(' _OS'lcLch.d. o~ +k;Y1,JLs._-. J~S~_3:.___~(\~<L _.-teet rj' t...<h T ~eeJ ... 0Jd__~_<5f_ro..~T 4o~~+ (1)(J1+.)0 ... ..s.:y_ '^!?/j_tb:~ct. . else .... becc:.t,se x. e"., ve;;X U(1c.o~('~c.bie.Cl[r~c..~. 60+ in r"1Sf . . 0' 'J ~~ :1zc.n.0:'1d ~~~ \-\ .. f-p_lnion _. e:.. __.:l,s ~ , . E:.1S . c.'9uS\'{€. Ve.0~/ri:,~S7c-~ c.nd SeKL'~)y "-u"'s _X. d.on'-\-__uQ.{)-I- f'-.:Ji '\.-1. J-o 5!-6 ~f"0~'-1. . 0-C1.d... ~ n~S. ' W ~...L Cu.'" W('(+;~. +hi:5, S LV1Cef<>~/ __ ~~~ -t ~. .-) .'') ) ) VERIFICATION I, ~~(\,b(i\(' ",Ai G \,,,-- , Plaintiff in the within action, hereby verify that the facts contained in the foregoing Emergency Petition to Suspend ?hysiclal are true and correct to the best of my Custody knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Fa. C.S. Section 4904, relating to unsworn falsification to authori ties. x ) i J\,~~~,- ? / /11(~'L DATE: January 23, 2G06 CERTIFICATE OF SERVICE I, CA THI LEIGH MCADAMS, an employee ofthe law firm of Purcell, Krug & Haller, counsel for Plaintiff, hereby certifY that the foregoing Emerl!ency Petition to Suspend Physical Custody and Proposed Order were served upon the following via first-class, postage prepaid mail and by facsimile on January 24,2006 on: Sean M. Shultz, Esquire KNIGHT & ASSOCIATES, P.C. 11 Roadway Drive, Suite B Carlisle, P A 17013 ~~ /0:dA: ,"Wl'~ Cathi Leigh Mc ams " ., , ,\ ,~, "'" ~...'. 70 (') ~ ~ ~ \-.; <> - 0 ...-'. .;;;- ----"" ..0 --'=- ~ 'C.) <:.i:> '0- C> ~ ,_:' .-0 0' ~ 0. -, \ - ,,---- , ~ o ,I,L\N 2 <1, 2006 p~ JEFFREY L. HAULMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BARBARA Z. MOHR, Defendant No. 2004-1868 IN CUSTODY ORDER AND NOW, this :J..srt. day of .J" .D7u>> 1 , 2006, upon consideration of Petitioner'S Emergency Petition to Suspend Physical Custody, it is hereby ordered that all physical custody of Respondent, Jeffrey L. Haulman, pursuant to the Jun~ 9, 2004 and September 13, 2005 ie,....IfI><Uou..l) A f>l'''lM~t l,~=r..~o~ 1L.~ Court qrq:=.rs is hereby ..suspended.\il'J.ti1 ~nqh ti~l< ilS E t, .J" (.'''''It\I7,-,~ll,,j)' .J' tt(~. lH J.c.r <-<>;11 l..c. L.c.lJ. up Or') '4ot!Q.)) 4iJ ~eC:~;C:ff. 'J'",.mohi p Pol i C'P rmn r'hildrgl'J. ~I'J.Q. Ye~LL l':eL v';'c,=s COtl.rlll~P- rnl=>;r in"'ITe'c:d~ji)ilti'JB :J.F19 Qli'tii'rmiflc tLo.t ~L ~b betIc: f03: the Rllnj.ord- rn;nr"lr t-...... roc:o"Tl'"l'i' 'ln9'b1PQr-.rif:'88. Col..tact yvitL. rtr. IIatllr"aR un~or t~9 ochcd~l~ ~~~vi6tl~ly ~oLaLliafi~d. BY THE COURT: ). tVC4 Pa of L J. Distribution: Nichole M. Staley O'Gorman, Esquire Counsel for Petitioner Sean M. Shultz, Esquire ~'LA Counsel for Respondent r- - ~ /-.7i5'-0(.- ~. '1\,"'0, :"\ J",I./ ,.,.,-, ..' \ ' ' ~ -,\,\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEFFREY L. HAULMAN, Plaintiff No. 2004-1868 v. IN DIVORCE BARBARA Z. MOHR, Defendant Y\.~ MOTION FOR HEARING AND NOW, this 2l :;;;;.;'day of June, 2006, comes the Plaintiff, Jeffrey L. Haulman, by and through his attorneys, Knight & Associates, P .C., and files the following Motion for Hearing and in support thereof avers as follows: 1. The parties are the natural parents of Megan Rose Haulman, born February 2, 1998. 2. On January 25, 2006, upon consideration of Defendant's Emergency Petition to Suspend Physical Custody, the Honorable J. Wesley Oler ordered that all physical custody of Jeffrey L. Haulman pursuant to the June 9, 2004 and September 13, 2005 Court Orders is temporarily suspended. 3. The January 25,2006 Order also stated that a prompt hearing on the continuation of the Order would be held upon motion of Plaintiff, Jeffrey L. Haulman. 4. Plaintiff would like to have supervised contact with his daughter, Megan Rose Haulman. 5. Plaintiff believes and therefore avers that due to his request being limited to supervised contact, a conciliation conference may be sufficient in this matter. 7. Plaintiff is aware that Hubert X. Gilroy, Esquire is available for a Conciliation in this matter on the afternoon of July 11, 2006. Plaintiffs counsel has confirmed that counsel for Defendant is available on the aforementioned date for a Conciliation Conference. WHEREFORE, Movant, Jeffrey L. Haulman, respectfully requests that this Court enter an Order scheduling a Conference before the Conciliator or a hearing before the Court in this matter. Respectfully submitted, ~~ Sean M. Shultz, Esquire Attorney ill No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Plaintiff VERIFICATION I verify that the statements made in the foregoing Motion are true and correct to the best of my knowledge, information and belief. This Verification is made by Plaintiffs counsel based upon information provided by Plaintiff to Plaintiff s counsel regarding the factual averments contained herein. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. J ~ '2- 'Z., z.."'c)~ F:IUser FolderlFinn DocslGendocs2006\3408-1motion.hearing.wpd ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEFFREY L. HAULMAN, Plaintiff No. 2004-1868 v. IN DIVORCE BARBARA Z. MOHR, Defendant CERTIFICATE OF SERVICE AND NOW, this 21 ~ay of June, 2006, I, Sean M. Shultz, Esquire, hereby certify that I have this day served the following with a copy of the foregoing Motion for Hearing by first class, United States Mail, postage pre-paid, addressed as follows: Nichole M. Staley O'Gorman, Esquire 1719 North Front Street Harrisburg, Pennsylvania 17102 Attorney for Defendant Respectfully submitted, KNIGHT & ASSOCIATES, P.C. ~!f!3- Attorney LD. No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorney for Plaintiff ~~~ \',~-~,::.)c C.--. t" ., c' (,,) '~.,.l) _L'..J " ~ JIy RECEIVED JUN 27 21m Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEFFREY L. HAULMAN, Plaintiff No. 2004-1868 v. IN DNORCE BARBARA Z. MOHR, Defendant ORDER OF COURT AND NOW, this ~ day of J' W)( ,2006, upon consideration of the foregoing Motion for Hearing, a Custody Conciliation is scheduled for JU1Y~, 2006, at&': 0 0 -t-.M. on the 4th Floor ofthe Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. FOR THE COURT, By: Distribution: Sean M. Shultz, Esquire "- Counsel for Plaintiff '\ Nichole M. Staley O'Gorman, Esquire 1 ~5--rJ~ ~ i~t4 Counsel for Defendant / Hubert X. Gilroy, Esquire Conciliator ~ JI6' 1'~,\,\\\.Jr\ ~!S:Z Vd OC l' :-" S~jJZ I\L ~r":l .1:1 JUL 2 5 2006 rr' JEFFREY L. HAULMAN, Plaintift' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. NO.2004-1868 CIVIL ACTION - LAW BARBARA Z. MOHR, Defendant IN CUSTODY ORDER ~ AND NOW, this ;J l{ day of July, 2006, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. ~~~ 'j "7 r' c;:, _1 r f ~ 92: [Ii ^d\/L,.~