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Home My WebLink About09-2388HARUN ALRISHID STANLEY, Plaintiff V. EMILEE JEAN HARTMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09- Z,3 Or CIVIL TERM CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Harun Alrishid Stanley, (Father). Father resides at 310 North Third Street, Harrisburg, Dauphin County, Pennsylvania 17101. 2. Defendant is Emilee Jean Hartman, (Mother). Mother resides at 2205 Cedar Run Drive - Apt E, Orchard Apartments, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Father seeks periods of partial custody of the minor child: Name Present Residence Age Sameer Stanley 2205 Cedar Run Drive - Apt. E 9.17.01 DOB, 7 yrs old Orchard Apartments Camp Hill, PA 17011 Sameer was born out of wedlock. Sameer is presently in the custody of Mother. During his lifetime, Sameer has resided with the following persons and at the following addresses: Name Address Date Harun Stanley Fayetteville, NC birth - 12/01 Emilee Hartman Emilee Hartman Myrtle Beach, SC 12/01-9/02 Harun Stanley Myrtle Beach, SC 9/02 - early 2003 Emilee Hartman Emilee Hartman unknown addresses in PA early 2003 -1/04 Harun Stanley New Cumberland, PA 1/04 - 4/04 Emilee Hartman Harun Stanley Camp Hill, PA 4/04 - 9/04 Emilee Hartman En-wee Hartman 2205 Cedar Run Dr. - Apt E 9/04 - present Orchard Apts Camp Hill, PA 17011 The parties are no longer in a relationship. 4. Mother resides with the following persons: Name Relationship Sameer Stanley Child with Harun Stanley 5. Father currently resides with the following persons: Name Relationship Anna Long Girlfriend Victor Alvarez Girlfriend's Father 6. Father has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of Sameer in this or another court. 7. Father has no information of a current custody proceeding concerning Sameer pending in a court of this Commonwealth. 8. Father does not know of a person not a party to the proceedings who has physical custody of Sameer or claims to have custody or visitation rights with respect to Sameer. 9. The best interest and permanent welfare of Sameer will be served by granting the relief requested for reasons including, but not limited to the following: a) Despite the end of the relationship between Father and Mother, Father has tried to maintain contact with Sameer and develop a father/son relationship with him. b) Father lives in a home that is a safe and nurturing environment in which to exercise periods of partial custody with Sameer. c) Father has all the necessary items to care for Sameer, during periods of partial custody. d) Father is willing and able to care for Sameer during periods of partial custody and he is committed to establishing and nurturing a healthy father/son relationship with him. e) Father has persistently pursued information on Mother's whereabouts on each occasion when she left with Sameer in order to develop and maintain a relationship with Sameer. f) Father is willing to work with Mother to co-parent Sameer and will communicate with Mother to best serve Sameer's interests. g) Mother is not acting in Sameer's best interest in ways including but not limited to the following: i) Mother is arbitrary in deciding when Father can visit with Sameer. ii) Mother has repeatedly left the area with Sameer and forces Father to search for them in order to maintain contact with Sameer. Mother has repeatedly reconciled with Father, allowing him to move into the home with her and Sameer and then leaves again, taking Sameer and interfering with the father/son relationship that Father has to keep re-establishing. iv) Mother has deliberately acted in a manner to interfere with, if not prohibit, Father from establishing a healthy father/son relationship with Sameer. 11. Every person with rights to custody or having actual physical custody of Sameer has been named as parties to this action. WHEREFORE, Father requests this Court to grant him the following relief: 1) Grant the parties shared legal custody of Sameer. 2) Grant Mother primary physical custody of Sameer. 3) Grant Father periods of partial custody with Sameer. 4) Establish a holiday schedule to ensure that both parents are able to celebrate with Sameer. 5) Any further relief that this Court finds to be just and proper. lessi a Holst, Esquire Mid Penn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 HARUN ALRISHID STANLEY, Plaintiff V. EMILEE JEAN HARTMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09- CIVIL TERM CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Jessica Holst, do hereby swear that I served Emilee Jean Hartman with a Complaint For Custody on ?' 1 _, 2009 by certified mail, return receipt, restricted delivery, to the person and addresses below: Emilee Jean Hartman 2205 Cedar Run Drive - Apt E Orchard Apartments Camp Hill, PA 17011 Date: --L??t V Signature: VERIFICATION The above-named PLAINTIFF, HARUN ALRISHID STANLEY, verifies that the statements made in the above COMPLAINT FOR CUSTODY are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: O v n 0 2 / 7- UN ALRI STANLE 1009 AP 1 6 A.;.1 C3 :. FP HARUN ALRISHID STANLEY, Plaintiff V. EMILEE JEAN HARTMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09- a 3 Rf CIVIL TERM CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Harun Alrishid Stanley, Plaintiff, to proceed in forma au eris. I, Jessica Holst, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am NRiding fryerlegal services to the party. yssi Holst, Esquire MidP n Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 2Q9 APR 18; 03 ??}}r HARUN ALRISHID STANLEY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-2388 CIVIL ACTION LAW EMILEE JEAN HARTMAN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, April 21, 2009 _,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, May 29, 2009 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Hubert X. GAro Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 OF THE MY 2009 APR 21 P 2. 14 Curd ,a ,' Ji E, HARUNI ALRISHID STANLEY, Plaintiff V. JEAN HARTMAN, Defendant, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No.: 2009-2388 Civil Term CIVIL ACTION - LAW IN CUSTODY TO THI. PROTHONOTARY OF CUMBERLAND COUNTY: ENTRY OF APPEARANCE 'lease enter the appearance of the undersigned counsel on behalf of Defendant, Jean Hartman, in the above captioned custody action. Respectfully submitted, Law Office of Joseph L. Hitchings oseph L. H chings, re Attorney Id No.: 65551 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 (717) 458-8123 (717) 790-6019 Fax Attorney for Defendant HARUN! ALRISHID STANLEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No.: 2009-2388 Civil Term EMIL JEAN HARTMAN, : CIVIL ACTION - LAW Defendant, : IN CUSTODY CERTIFICATE OF SERVICE , Joseph L. Hitchings, Esquire, hereby certify that the following service has been d in compliance with the Pennsylvania Rules of Civil Procedure: Via first class US mail postage pre-paid Jessica olst, Esquire Mid Pe n Legal Services 401 Eat Louther Street Carlisl . PA 17013 Hubert X. Gilroy, Esquire Martson Law Offices Ten East High Street Carlisle, PA 17013 Respectfully submitted, Law Office of Joseph L. Hitchings Joseph L. It ings, re Attorney Id No. 65551 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 (717) 458-8123 (717) 790-6019 Fax Attorney for Defendant OF THE P, 2009 hAY 2 JUN 0 4 20094 HARUN ALRISHID STANLEY, Plaintiff VS. EMILEE GENE HARTMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.2009-2388 IN CUSTODY COURT ORDER AND NOW, this I b{? day of June, 2009, upon consideration of the attached Custody Conciliation Report, the following TEMPORARY custody order is entered: 1. The mother, Emilee Gene Hartman, shall enjoy legal and physical custody of Sameer Stanley, born September 17, 2001. 2. The father, Harun Alrishid Stanley, shall enjoy periods of visitation of the minor child as follows: A. On Sunday afternoons starting at 1:00 p.m. and continuing until 4:00 p.m. Unless agreed otherwise between the parties, the visitation shall take place at City Island in Harrisburg. It is understood that the mother and her sister Melissa may be present during this visitation and, although not immediately supervising the visitation, shall be afforded the opportunity to always observe the father with the child during the visitation. 3. Father shall communicate with the mother's sister Melissa with respect to any communications that are necessary relative to the visitation set forth above and any changes that may be required. 4. The parties and their counsel shall meet for another custody conciliation conference on Friday, July 24, 2009, at 8:30 a.m. cc: ssica Holst, Esquire ZJseph L. Hitchings, Esquire Co. Oec ? ??/cam BY THE COURT, Judge 'le5r, HARUN ALRISHID STANLEY, Plaintiff VS. EMILEE GENE HARTMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.2009-2388 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Sameer Stanley, born September 17, 2001. 2. A Conciliation Conference was held on May 29, 2009, with the following individuals in attendance: The father, Harun Alrishid Stanley, who appeared with his counsel, Jessica Holst, Esquire, and the mother, Emilee Jean Hartman, with her counsel, Joselbh Hitchings, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. Date: 64-, 2009 Hubert X. Gilroy, E uire Custody Conciliat ALES , !GE OF THE I'#Y =1_!'Ir,rjTARY 2009 JUN 10 All 11: 17 C V M'+i' j L .;;. 1_ .)I 1 i`Y MAR ~~ 8 20100 HARUN ALRISHID STANLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. EMILEE GENE HARTMAN, Defendant PRIOR JUDGE: The Honorable M. L. Ebert CIVIL ACTION -LAW N0.2009-2388 n o IN CUSTODY ~-- .f~ O ~ T' ~ ...: - _ in COURT ORDER ~:_ .. .~ y AND NOW, this ~ 9~' day of March, 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: `~ rn~~y ..I -r~ ~~ A hearing is scheduled in Court Room No. 2 of the Cumberland County Courthouse on the a17'`-day of U-Q _, 2010 at ~. ~3D~.m. At this hearing, the father shall be the moving party amend shQall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending fixrther Order of this Court, this Court's prior Order of June 10, 2009, shall remain in place such that the mother shall continue to have legal and physical custody of the minor child, Sameer Stanley, born September 17, 2001. Additionally, it is ordered that the parties shall proceed with a program through the Harrisburg YWCA in order to arrange some type of supervised visitation for the father with the minor child. The parties shall cooperate with the Harrisburg YWCA by attending any orientation sessions or other requirements that may apply to their program. It is the intent of this provision that father be granted some supervised contact with the minor child under the supervision of the Harrisburg YWCA and subject to the conditions of their supervised visitation program. cc: "J ica Holst Es uire q Joseph L. Hitchings, Esquire ~ F..S' rn~ t,l£c~ 3 ~4/~a ~n'~ BY THE COURT, Judge M. L. Ebert HARUN ALRISHID STANLEY, Plaintiff vs. EMILEE GENE HARTMAN, Defendant PRIOR JUDGE: The Honorable M. L. Ebert : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2009-2388 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Sameer Stanley, born September 17, 2001. 2. A Conciliation Conference was held on March 12, 2010, with the following individuals in attendance: The father, Harun Alrishid Stanley, who appeared with his counsel, Jessica Holst, Esquire, and the mother, Emilee Jean Hartman, with her counsel, Joseph Hitchings, Esquire. 3. This case arose last June when father was seeking some periods of custody with the minor child. The parties agreed to limited custody where father was visiting with the child at City Island in Harrisburg for 3 hours on Sunday afternoons. The father was then incarcerated for a period of time and had no contact with the child for a number of months. 4. At the Conciliation Conference, the father appeared with his counselor. The father has been compliant with respect to terms of probation and has been involved in some intensive outpatient treatment. However, the father has serious medical issues with his eyes and has been undergoing operations that is delaying completion of his outpatient treatment. Father proposed merely limited supervised visitation through the Harrisburg YWCA. Mother would not agree, and demanded that father complete his outpatient treatment before she would agree to again initiating visitation. Mother demanded a hearing. 5. In light of the circumstances outlined above and consistent with a discussion the Conciliator had with Judge Ebert, the Conciliator recommends an Order in the form as attached. Date: ~ ~ ~ , 2010 Hubert X. Gi y, Esquire Custody C ciliator __ T M JUL 0 6 2010 HARUN ALRISHID STANLEY, Plaintiff v. EMILEE JEAN HARTMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.09-2388 CIVIL TERM CUSTODY ORDER OF COURT AND NOW, this «~ day of v , 2010, upon consideration of the attached Petition, the Defendant is Ordered to bring the minor child, Sameer Stanley, to the hearing scheduled for Tuesday, July 27, 2010, at 1:30 p.m. in Courtroom No. 2, Fourth Floor, Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, J. Distribution: ~ Jessica Holst, Esquire MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 ~ ~, 1,' V Joseph L. Hitchings, Esquire ~' "~ ;, - ~ ~: Rossmoyne Business Center .~ `r' °_ N ~ ).! -'' ~ 5000 Ritter Road, Suite 202 i ~ t. ~.:._ ra ; `~ ~, Mechanicsburg, PA 17055 -~, t= -"' `',= c ~, c~w> .. _,~. ~piGS rh.Oc~c~~ 7 //~/l ~ ~ti '{ ~~ o~ HARUN ALRISHID STANLEY, Plaintiff v. EMILEE JEAN HARTMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENN~YL~ANIQ C a -~-' NO.09-2388 CIVIL TERl~~' c : ~-„ 4.J J ':- ~: r N . • r~~ O CUSTODY ~ > ~ , ~. - j~' c.~. ~ :b ~ Petitioner, Harun Stanley, by and through his counsel, MidPenn Legal Services, states the following: 1. The above-captioned matter is scheduled for hearing on Tuesday, July 27, 2010, at 1:30 p.m. before Judge M. L. Ebert. 2. Petitioner believes that it is necessary for the Court to speak privately to the minor child involved in this custody matter in order to better ascertain the current situation. 3. Petitioner does not believe that Respondent will bring the children without a Court Order requiring that she do so. 4. Petitioner has attempted to contact Respondent's Counsel via phone and letter but has received no response. It is assumed that Respondent is opposed to the relief sought. WHEREFORE, Petitioner respectfully requests that this Court enter an Order requiring that Respondent bring the child to the July 27, 2010, custody hearing. submitted, Mid~~nri Legal Services 401 ast Louther Street Carlisle, PA 17013 (717) 243-9400 HARUN ALRISHID STANLEY, Plaintiff v. EMILEE JEAN HARTMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-2388 CIVIL TERM CUSTODY CERTIFICATE OF SERVICE I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for Plaintiff, Harun Stanley, hereby certify that I have served a copy of the forgoing Petition to Request Attendance of Minor Children on the following date and in the manner indicated below: U.S. First Class Mail, Postase Pre-Paid Joseph L Hitchings, Attorney for Defendant Rossymoyne Business Center 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Date: ~ ' ~D' ~'~ Jes a ~Iol~t, Esquire Mi nn Legal Services 401 ast Lowther Street Carlisle, PA 17013 (717)243-9400 ,~ HARUN ALRISHID STANLEY : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA ~ Plaintiff ~ ~ C C ';a v. N0.09-2388 CIVIL TERM -.,~;- ~~ • ~ =r-~ EMILEE JEAN HARTMAN :CIVIL ACTION -LAW = -- ,~ IN CUSTODY __ ~ ; Defendant ~~ "~-- 'c ~~. ~{ -r,. ~ ~ _ DEFENDANT'S PRE-TRIAL MEMORANDUM I. Factual and Procedural Background Plaintiff/Father Harun Alrishid Stanley and Defendant/Mother Emilee Jean Hartman are the parents of one (1) minor child: Sameer (Ricky) Stanley born September 17, 2001, age 8 years, 10 months. The child was born out of wedlock. The parties had previously lived together however they have not been together for the past several years. Since September 2004, Sameer has resided with his Mother at 2205 Cedar Run Drive, Apt. E, Camp Hill, PA 17011. During this same period Father has had multiple residences, and it is believed at some points was homeless. Father has a history of drug abuse and violence against the Defendant, including choking her to unconsciousness which resulted in Protective Orders in North Carolina. Prior to filing the instant Custody Complaint, Father had sporadic contact with Sameer. On April 16, 2009, Father filed his Custody Complaint, seeking shared legal custody and periods of partial physical custody. On May 29, 2009, a conciliation conference was held before Custody Conciliator, Hubert X. Gilroy. The parties were able to reach an agreement, and a Court Order was entered dated June 10, 2009, whereby Mother would have legal custody and primary physical custody of Sameer, and Father would have periods of observed visits with Sameer at City Island, Harrisburg on Sundays from 1:00 to 4:00 p.m. Subsequently the parties agreed to alternative meeting sites for Father's visitation. Mother's sister, Melissa Albright, transported Sameer for the visits and observed his interaction with his Father. Ms. Albright became increasingly concerned as a result of Father's bizarre conduct during the visitations. As a result, she was no longer comfortable bringing Sameer to the visits or having contact with Father. Defendant's counsel advised both opposing counsel and the conciliator of the issues with the visits and they were stopped. On or about July 2, 2009, Father was charged with multiple drug related charges including possession of marijuana, possession of controlled substances, possession of drug paraphernalia, and disorderly conduct. Those charges were filed at Cumberland County Court Docket No. CP- 22-CR-3597-2009. As a result of the criminal charges, Father was incarcerated in the Cumberland County Prison. Father ultimately plead guilty to all charges on November 9, 2009, and was sentenced to 6 months probation, fines, costs and attend CMU. In January 2010, counsel for Father wrote undersigned counsel and the Conciliator, and requested a resumption of Father's supervised visits. A conciliation conference was held before Mr. Gilroy on March 12, 2010. This was the first opportunity for Mother to get specifics from Father concerning the criminal charges, the terms of his probation, his drug use and his drug treatment. Father requested supervised visits at the Harrisburg YWCA. Mother was opposed and requested he complete his intensive outpatient drug treatment before visits were resumed. Father would not agree so Mother requested a hearing. Following the conciliation conference a temporary Order dated March 19, 2010, was entered, continuing the terms of the prior Court Order and granting Father periods of supervised visits through the Harrisburg YWCA. Father has had supervised visits at the YWCA on an every other week basis, since entry of the temporary Order to present. Sameer was initially very upset about resuming visits with his Father, but has participated in the visits as required. Mother does notice negative changes in Sameer's behavior following his visits with his Father. II. Statement of Issues to Arise During Trial: Whether it is in the child's best interest to grant Father more extensive periods of visitation with Sameer. III. Admissions From Pleadings to be Made Part of Record: None. IV. Stipulations of the parties: None at this time. V. Witnesses to be Called: A) Mother, Emilee Jean Hartman, 2205 Cedar Run Drive, Apt E, Camp Hill, PA 17011 She will testify to her parenting abilities, relationship with her son, relationship with the Plaintiff and the history of violence and drug use, and her concerns with granting Plaintiff more extensive visitation with Sameer. B) Melissa Albright (Mother's sister) She will testify to Mother's parenting abilities, Mother's relationship with her son, structure within the home, her interactions with the Plaintiff, safety concerns for Sameer, and issues with the prior visitations with Plaintiff. Mother reserves the right to call additional witnesses in rebuttal to any witnesses called by Defendant, and upon notice to the Court and opposing party. VI. Status of Expert Witnesses, Reports, Evaluations and Studies: None requested. VII. Statement of Obiections or Unusual Evidentiary Problems Expected to Arise at Trial• None anticipated. VIII. Special Requests, Uncompleted Matter: If Father is seeking unsupervised visits, Mother will need to know where Father is residing, and to have the opportunity to see the residence to insure it is a safe place for a minor child. IX. Settlement Offer: Mother is willing to continue the supervised visits, and is willing to increase the frequency to a weekly schedule. X. Estimated Length of Trial One half day. Respectfully submitted, Office of Joseph L. Hitchings ~y6seph L. Hitchings, squire Attorney ID No.: 655 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone: (717) 458-8123 Fax: (717) 790-6019 Attorney for Defendant HARUN ALRISHID STANLEY : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. N0.09-2388 CIVIL TERM EMILEE JEAN HARTMAN :CIVIL ACTION -LAW IN CUSTODY Defendant CERTIFICATE OF SERVICE I, Joseph L. Hitchings, Esquire, hereby certify that the following service has been completed in compliance with the Pennsylvania Rules of Civil Procedure: Via first class US mail postage pre-paid Jessica Holst, Esquire 401 East Louther Street Suite 103 Carlisle, PA 17013 ~~-h Date Respectfully submitted, Law Offtce of Joseph L. Hitchings yoseph L. Mitbhin qui Attorney Id No.: 655 5000 Ritter Road, Suite 2 Mechanicsburg, PA 17055 (717)458-8123 (717) 790-6019 Fax Attorney for Defendant HARUN ALRISHID STANLEY, Petitioner Vs. EMILEE JEAN HARTMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-2388 CIVIL TERM CUSTODYNISITATION C= . m _.. p .. , rn -- Z c -a rn r r r o0 --+ca z rC?= a CD-n Z ? F3 C > --4 PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Harun Stanley, Petitioner, to proceed in forma au eris. I, Jessica Holst, attorney for the party proceeding in forma papperis, certify that I believe the party is unable to pay the costs and that I am providi fre legal services to the party. Fessica 1st, Es re Legal Services st Louther Street Carlisle, PA 17013 (717) 243-9400 HARUN ALRISHID STANLEY, IN THE COURT OF COMMON PLEAS OF Petitioner CUMBERLAND COUNTY, PENNSYLVANIA cam ; -ri vs. NO. 2009-2388 CIVIL TERM -n3 z ° "a EMILEE JEAN HARTMAN, v c m a c3 Respondent CUSTODY i0-x =Q E5 ' PETITION FOR EMERGENCY RELIEF -< -" Petitioner, Harun Alrishid Stanley, by and through his counsel, MidPenn Legal Services, states the following: 1. Petitioner, hereinafter referred to as Father, resides at 1842 Market Street, Apartment 4, Harrisburg, Dauphin County, Pennsylvania 17103. 2. Respondent, hereinafter referred to as Mother, previously resided at 2205 Cedar Run Drive, Apartment E, Camp Hill, Cumberland County, Pennsylvania 17011. Mother has recently moved and changed her telephone number and has refused to provide her new contact information to Father. 3. The parties are the parents of the minor child, Sameer Stanley, born September 17, 2001. Sameer is ten (10) years old. 4. A custody order was entered on July 27, 2010 by The Honorable M. L. Ebert, Jr. In pertinent part, the order grants the parties shared legal custody. Mother has primary physical custody and Father had periods of supervised visitation at the YWCA until his completion of an outpatient drug and alcohol treatment program at which time he would have unsupervised partial custody every Sunday for six (6) hours. 5. Despite completing his program and providing paperwork to both Mother and her counsel in Spring '2011, Mother refused to allow Father to exercise his Sunday visits until mid- September 2011 and at that time, only permitted visits on alternating Sundays, despite an order granting every Sunday. 6. In early October 2011, Sameer was taken to the hospital for an evaluation following a suicidal gesture made at school when he wrapped a shoe string around his neck and said that he wanted to die. 7. At that time, Mother agreed with Father to participate in family counseling if Father coordinated the process. Father scheduled an appointment with T.W. Ponessa and provided the appointment information to Mother who then failed to appear or participate. 8. On October 22, 2011, when Father was preparing to return Sameer to Mother's custody, Sameer again threatened suicide and Father took Sameer to Pinnacle Health at the Harrisburg Campus for crisis intervention. 9. In an attempt to respect as much of Sameer's privacy as possible, this petition will quote portions of the hospital reports provided by Father to counsel rather than attach them as an exhibit. The complete report will be made available to the court for in camera review upon request. 10. According to the hospital reports, Sameer reported with suicidal ideations and homicidal ideations towards Mother. Sameer reported "that he often has thoughts of hurting self when @ mothers and no thoughts of hurting w/ father." [sic]. Sameer further stated that "my mom slaps me when she doesn't want me to talk and pinches me and digs nails in skin" and that "about a month ago [mother] ashed on leg w/ cig." And that "he doesn't feel safe @ mothers." [sic] 11. The hospital reports note that Sameer mentioned the conflict between his parents with the ongoing custody case and that his condition is exacerbated by family stress but also that Sameer's condition appears to be "relieved by Being with father calms patient." [sic]. 12. Hospital reports further note that "without other individuals present, that the reason he [Sameer] wants to die is because he doen't want to be around his mother who allegedly abuses him verbally and physically." [sic]. 13. In the hospital reports, Sameer was committed to the hospital upon Mother signing a 201 "at out insistence." [sic]. Father asserts that Mother only agreed to allow Sameer to be admitted after the doctor threatened an involuntary commitment. 14. Father believes that in light of Sameer's current issues and as a result of the ongoing conflict brought about by this custody action, that Sameer would be best served by the appointment of a guardian ad litem. 15. Mother is not acting in Sameer's best interests because: a. Mother had unilaterally limited Father's opportunity to exercise his visits with Sameer. Due to limited availability Father had to continue with one (1) hour rather than two (2) hour visits at the YWCA. However, when a two (2) hour slot was available, Mother would not accommodate that change despite the July 27, 2010 order. b. 136spite Mother's knowledge in June 2011 that Father had completed his outpatient drug and alcohol program, she did not allow Father to exercise his unsupervised custody with Sameer until September 2011. c. Mother has since unilaterally decided that Father's visits will only be on alternating Sundays rather than every Sunday as provided by the July 27, 2010 Order. d. Recently, Mother advised Father that Sameer attempted suicide and agreed to attend family counseling if Father handled the scheduling. Father followed through on this and coordinated counseling through T.W. Ponessa and Mother has refused to participate. e. According to the July 27, 2010 Order, Father is permitted to provide Sameer with a cellular telephone, at Father's cost, in order to maintain contact with Sameer. It is believed that Mother has confiscated the phone in order to prevent Sameer's ongoing contact with Father. It is also believed that Mother has confiscated other items given to Sameer by Father. f. Upon Sameer's release from hospitalization, Mother is believed to have moved and has changed her telephone number without providing any contact information for Father. Consequently, Father does not know where Sameer is, Father cannot reach Sameer to check on his current condition and Father was not given his period of partial custody on Sunday, October 30th g. Mother has refused to work cooperatively with Father to ensure an ongoing father/son relationship. h. Mother's behavior suggests an on-going desire to estrange Sameer from Father and to interfere with the father/son relationship Father is trying to nurture with Sameer. 16. Father is the parent who can currently best provide for Sameer for reasons including, but not limited to, the following: a. Father has demonstrated a commitment to maintaining a relationship with Sameer and being proactively involved in his life. b. Father is willing and able to provide for Sameer's mental, physical and emotional well-being. c. Father is willing to and capable of caring for Sameer on a primary basis. d. Father is willing to coordinate counseling to address Sameer's mental and emotional health and will closely monitor Sameer to ensure that any future concerns are addressed immediately. e. Father is willing to communicate with and work cooperatively with Mother to co- parent Sameer and will help Mother to maintain her mother/son relationship with Sameer. 17. Father has contacted Highland Elementary School and has confirmed that as of October 31 ", he was still enrolled there but the school would not provide Father with an address for Sameer. Father resides in Dauphin County and is in the Harrisburg School District. If he were to obtain custody of Sameer, he would transfer him immediately to Roland Elementary School to ensure that he did not fall behind in his education. 18. Without this Court's intervention, Sameer is at risk of emotional harm both by Mother's apparent refusal to actively see to Sameer's mental and emotional health and by Mother's denial of contact between Father and Sameer. 19. Counsel for Father has confirmed that Attorney Joseph Hitchings continues to represent Mother and further understands that Mother has or intends to file her own Special Relief Petition to prevent Father from having unsupervised contact with Sameer. Consequently, it is believed that there is not concurrence with the relief requested in this Petition. WHEREFORE, Father respectfully requests that the Court order the following: a. Respondent shall transfer custody of the minor child, Sameer Stanley, born September 17, 2001, to Petitioner. b. Until further order of court, the parties shall share legal custody of Sameer. c. This matter shall be scheduled for an expedited custody conciliation to determine a more specific custody order regarding Sameer. d. Until the conciliation conference, Petitioner shall have primary physical custody of Sameer. e. Until the conciliation conference, Respondent shall have periods of custody as agreed upon by the parties. f. is hereby appointed as guardian ad litem for the minor child. Both parents shall sign all necessary releases to provide the guardian ad litem access to information including, but not limited to, educational, mental health, medical dental and counseling records. Both parents shall cooperate with the guardian ad litem in scheduling appointments for interviews and other matters necessary for the guardian ad litem to carry out his/her duties. g. The local police or other appropriate law enforcement agency shall assist Petitioner in obtaining custody of Sameer from Respondent or other adult who may have custody of Sameer. h. Any other relief this Court finds just and equitable. Jessi 1st, squire p eg Services 401 E uther Street Carlis e, PA 17013 VERIFICATION The above-named PETITIONER, Harun Alrishid Stanley, verifies that the statements made in the above PETITION FOR EMERGENCY RELIEF are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. M ?`" l l Date: on Alrish anley HARUN ALRISHID STANLEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2009-2388 CIVIL TERM EMILEE JEAN HARTMAN, CUSTODY Defendant ORDER OF CUSTODY AND NOW, this _. rNay of 2010, the custody of the minor child, Sameer Stanley, born.September 17, 2001, shall be set forth as follows: 1. Legal Custody: The parties will share joint legal custody of Sameer Stanley, born September 17, 2001, age 8 years old. The parties agree that major decisions concerning Sameer, including, but not necessarily limited to, Sameer's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in Sameer's best interest. Each party agrees not to impair the other party's rights to shared legal custody of Sameer. Each party agrees not to attempt to alienate the affections of Sameer from the other party. Each party shall notify the other of any activity or circumstance concerning Sameer that could reasonably be expected to be of concern to the other. Day-to-day decisions shall be the responsibility of the parent then having physical custody. With regard to any IFX V" a F ft emergency decisions which must be made, the parent having physical custody of Sameer at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent authorized by statute. Mutual agreement should be made, in advance, regarding the following matters: enrollment or termination in a particular school or school program, advancing or holding Sameer back in school, authorizing enrollment in college, authorizing Sameer's driver's license or purchase of an automobile, authorizing employment, authorizing Sameer's marriage or enlistment in the armed forces, approving a petition for emancipation, authorizing foreign travel, passport application or exchange student status. The parent with physical custody during any given period of time shall communicate in a prompt fashion with the other parent concerning the well-being of Sameer, and shall appropriately notify the other parent of any changes in health or educational progress. Each parent shall execute any and all legal authorizations so that the other parent may obtain information from Sameer's schools, physicians, psychologists, or other individuals concerning their progress and welfare. 2. Physical Custody shall be as follows: a. From the date this order is granted: i. Mother shall have primary physical custody of Sameer. ii. Father shall have partial physical custody of Sameer: 1. Father will have supervised visitation with Sameer at the YWCA in Harrisburg Pennsylvania once each week for a period of two (2) hours. b. Six (6) months from the date of this order, and, upon Father's presentation of documentation establishing completion of an outpatient drug and alcohol treatment program to Mother's Counsel: i. Mother shall have primary physical custody of Sameer. ii. Father shall have partial physical custody of Sameer: 1. Every Sunday for a six (6) hour period as agreed upon by the parties. 2. Prior to each unsupervised visit, Father will inform Mother of the activities planned and locations where they will take place. 3. Mother reserves the right to conduct a home study of Father's residence, at her own expense. c. Holidays: i. Mother's Day: 1. Sameer will spend Mother's Day with Mother. The holiday shall be from 9:00 a.m. until 6:00 p.m. ii. Father's Day: 1. Sameer will spend Father's Day with Father. The holiday shall be from 9:00 a.m. until 6:00 p.m. iii. The holiday schedule will always take precedence over the regular custody schedule. iv. The holiday schedule will begin upon Father's presentation of documentation establishing completion of an outpatient drug and alcohol treatment program as indicated in paragraph 2(b). 3. Once Father's visits are no longer at the YWCA, the parties shall exchange custody of Sameer at either: a. Strawberry Square, 11 North 3rd Street, Harrisburg, PA, in front of Bagel Lover's Caf6; or, b. City Island, Harrisburg, PA, in front of the Metro Bank Park Entrance. 4. Mother and Father shall permit and support Sameer's access to all family relationships. Special family events such as weddings, family reunions, family gatherings, funerals, graduations, etc., shall be accommodated by both parties with routine visitations resuming immediately thereafter. Each parent shall have the option of proposing time and date variations to the other parent when special recreational options or other unexpected opportunities arise but such proposals shall be made with 30 days notice to the other party. Each parent must confer with the other parent before arranging regularly occurring extracurricular activities for Sameer which might interfere with regular visitation. 5. Each parent should be promptly and politely responsive to the other parent's telephone calls. Initially, Mother and Father will communicate via text messages. Mother shall obtain and maintain a separate phone for this purpose and will provide Father with the number of that phone. Contact between Mother and Father shall pertain to custody matters only. 6. During any period of custody or visitation, the parties to this Order shall not possess or use any controlled substance, nor shall they consume alcoholic beverages to the point of intoxication, nor smoke cigarettes inside the residence or vehicle. The parties shell likewise assure, to the extent possible, that other household members and/or houseguests comply with this prohibition. 7. Telephone contact: Each parent shall be entitled to reasonable telephone contact with Sameer. Father is permitted to give Sameer a cellular phone. Father will pay all costs associated with the phone provided to Sameer. Mother will be permitted to exercise reasonable control over Sameer's use of the phone, but shall not be unreasonable in allowing Sameer access to or use of such phone. Mother shall not unreasonably interfere with contact from Sameer's extended family on Father's side. 8. Neither party shall relocate with Sameer without written agreement by the other parent or a court order. 9. Neither party shall do anything which may estrange Sameer from the other parent, or injure the opinion of Sameer as to the other parent or which may hamper the free and natural development of Sameer's love or respect for the other parent. Both parties shall provide Sameer with a "safety zone" by discouraging third parties from making negative remarks about either parent when Sameer is within earshot. 10. The parties shall be entitled to custodial time outside the parameters of this Order so long as the parents agree to such changes or additions to the regular custody schedule. The parties also recognize that by agreement, they may make any changes, alterations or additions to any portion of this Order. In the case of a disagreement regarding such changes, the parties shall follow the custody schedule as outlined in this Order. BY THE COURT: L. ert, Judge TRUE COPY FROM RECORD M Testimony where&, I here unto set my hand and the seal said Cali! ffi arlisle, Pa. Thk pf 20 Prothhonotarr HARUN ALRISHID STANLEY, IN THE COURT OF COMMON PLEAS OF Petitioner CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2009-2388 CIVIL TERM EMILEE JEAN HARTMAN, : Respondent CUSTODY AFFIDAVIT OF SERVICE BY MAIL I, Jessica Holst, do hereby swear that I served Joseph L. Hitchings, Esquire, with a Petition for Emergency Relief by USPS I" Class Mail, electronic receipt requested, at the address below: Joseph L. Hitchings, Esquire Rossmoyne Business Center 5000 Ritter Road Suite 202 Mechanicsburg, PA 17055 I, Jessica Holst, verify that the statements made in this Affidavit of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: J/. y' / / Signature: HARUN A. STANLEY, Plaintiff V. EMILEE J. HARTMAN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-2388 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY HONORABLE M.L. EBERT EMERGENCY PETITION FOR SPECIAL RELIEF .., .. -; c _1 AND NOW this ?jdaY of November, 2011, comes the Defendant/Petitioner, Emilee A ?. J. Hartman, by and through her undersigned attorney, Joseph L. Hitchings, Esquire, and avers in support of her Petition for Special Relief as follows: 1. The Petitioner is Emilee J. Hartman (hereinafter sometimes referred to as "Mother"), the natural mother of the subject child, Sameer (Ricky) Stanley, born September 17, 2001. The child is 10 years old. 2. Respondent is Harun A. Stanley (hereinafter sometimes referred to as "Father"), the natural father of the Sameer Stanley. 3. Pursuant to an Order of Court dated July 27, 2010, and based on agreement of the parties, Mother has primary physical custody of the child with Father having periods of supervised visitation at the YWCA in Harrisburg, leading to 6 hour periods of unsupervised visitation. A true and correct copy of the current custody Order is attached hereto as Exhibit "A". 0 loco to 13s`f 4. Unsupervised visitation with Father has been occurring for the past several months. During this time, the child has had a drastic decline in his mood and behavior, resulting in him talking about suicide and making an attempt by tying a shoelace around his neck and tightening it during school. 5. As a result of the school incident, Mother was contacted by the school, and she took the child for a mental health evaluation. 6. The child was likewise taken for a mental health evaluation during the most recent unsupervised visit with his Father on October 22, 2011. The child was admitted to the psychiatric floor or Harrisburg Hospital and remained there until being discharged on October 27, 2011. 7. The child frequently states that he is anxious and apprehensive about his visits with his Father, and he lacks a feeling of safety with his Father. It is believed and therefore averred that this stems from the child having witnessed Father physically assaulting Mother while the parties were together, as well as knowing the Father's history of drug use and subsequent incarceration. 8. Recently, Father's girlfriend stated in the front of the child that if Mother "showed up at their house, she would throw her down the steps". This has exacerbated the child's feelings of anxiousness and insecurity around his Father. 9. For the past year, the child has been receiving counseling from Mary Tarbell, M.Ed., I.PC of the Mynd Works Children's Services in Harrisburg. 10. Ms. Tarbell has been the child's therapist both when the supervised visits were being held, as well as when the unsupervised visits started. 11. She has reported a significant decline in the child's mood and behavior since the unsupervised visits have started, and has opined that unsupervised visits are detrimental to the child's sense of security and emotional well being. A true and correct copy of Ms. Tarbell's report is incorporated herein and attached hereto as Exhibit "B". 12. It is believed that it is in the child's best interest to suspend the contact with his Father to enable him to work on his emotional issues. Alternatively it is requested that Father's visits be supervised and be held in a therapeutic setting. WHEREFORE, Defendant/Petitioner, Emilee J. Hartman, respectfully requests that This Honorable Court enter an Order, suspending Father's visitation, or in the alternative, directing the visitation be supervised in a therapeutic setting. Date:--[I - 3 - I Respectfully Submitted, LAW OFFICE OF JOSEPH L. HITCHINGS By: J seph L. H' c ngs, E uire Attorney for Plaintiff/Pet Toner Attorney ID# 65551 5000 Ritter Road, Suite 202 Mechanicsburg, Pennsylvania 17055 Telephone: (717) 458-8123 Fax: (717) 790-6019 VERIFICATION I, Emilee J. Hartman, verify that the statements made in this Petition are true and correct to the best of my knowledge. 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 Emilee J. II man EXHIBIT "A" HARUN ALRISHID STANLEY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2009-2388 CIVIL TERM EMILEE JEAN HARTMAN, CUSTODY Defendant ORDER OF CUSTODY AND NOW, this .2 7A4ay of 2010, the custody of the minor child, Sameer Stanley, born September 17, 2001, shall be set forth as follows: 1. Legal Custody: The parties will share joint legal custody of Sameer Stanley, born September 17, 2001, age 8 years old. The parties agree that major decisions concerning Sameer, including, but not necessarily limited to, Sameer's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in Sameer's best interest. Each party agrees not to impair the other party's rights to shared legal custody of Sameer. Each party agrees not to attempt to alienate the affections of Sameer from the other party. Each party shall notify the other of any activity or circumstance concerning Sameer that could reasonably be expected to be of concern to the other. Day-to-day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of Sameer at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent authorized by statute. Mutual agreement should be made, in advance, regarding the following matters: enrollment or termination in a particular school or school program, advancing or holding Sameer back in school, authorizing enrollment in college, authorizing Sameer's driver's license or purchase of an automobile, authorizing employment, authorizing Sameer's marriage or enlistment in the armed forces, approving a petition for emancipation, authorizing foreign travel, passport application or exchange student status. The parent with physical custody during any given period of time shall communicate in a prompt fashion with the other parent concerning the well-being of Sameer, and shall appropriately notify the other parent of any changes in health or educational progress. Each parent shall execute any and all legal authorizations so that the other parent may obtain information from Sameer's schools, physicians, psychologists, or other individuals concerning their progress and welfare. 2. Physical Custody shall be as follows: a. From the date this order is granted: i. Mother shall have primary physical custody of Sameer. ii. Father shall have partial physical custody of Sameer: 1. Father will have supervised visitation with Sameer at the YWCA in Harrisburg Pennsylvania once each week for a period of two (2) hours. b. Six (6) months from the date of this order, and, upon Father's presentation of documentation establishing completion of an outpatient drug and alcohol treatment program to Mother's Counsel: i. Mother shall have primary physical custody of Sameer. ii. Father shall have partial physical custody of Sameer: 1. Every Sunday for a six (6) hour period as agreed upon by the parties. 2. Prior to each unsupervised visit, Father will inform Mother of the activities planned and locations where they will take place. 3. Mother reserves the right to conduct a home study of Father's residence, at her own expense. c. Holidays: i. Mother's Day: 1. Sameer will spend Mother's Day with Mother. The holiday shall be from 9:00 a.m. until 6:00 p.m. ii. Father's Day: 1. Sameer will spend Father's Day with Father. The holiday shall be from 9:00 a.m. until 6:00 p.m. iii. The holiday schedule will always take precedence over the regular custody schedule. iv. The holiday schedule will begin upon Father's presentation of documentation establishing completion of an outpatient drug and alcohol treatment program as indicated in paragraph 2(b). 3. Once Father's visits are no longer at the YWCA, the parties shall exchange custody of Sameer at either: a. Strawberry Square, 11 North 3rd Street, Harrisburg, PA, in front of Bagel Lover's Cafe; or, b. City Island, Harrisburg, PA, in front of the Metro Bank Park Entrance. 4. Mother and Father shall permit and support Sameer's access to all family relationships. Special family events such as weddings, family reunions, family gatherings, funerals, graduations, etc., shall be accommodated by both parties with routine visitations resuming immediately thereafter. Each parent shall have the option of proposing time and date variations to the other parent when special recreational options or other unexpected opportunities arise but such proposals shall be made with 30 days notice to the other parry. Each parent must confer with the other parent before arranging regularly occurring extracurricular activities for Sameer which might interfere with regular visitation. 5. Each parent should be promptly and politely responsive to the other parent's telephone calls. Initially, Mother and Father will communicate via text messages. Mother shall obtain and maintain a separate phone for this purpose and will provide Father with the number of that phone. Contact between Mother and Father shall pertain to custody matters only. 6. During any period of custody or visitation, the parties to this Order shall not possess or use any controlled substance, nor shall they consume alcoholic beverages to the point of intoxication, nor smoke cigarettes inside the residence or vehicle. The parties shall likewise assure, to the extent possible, that other household members and/or houseguests comply with this prohibition. 7. Telephone contact: Each parent shall be entitled to reasonable telephone contact with Sameer. Father is permitted to give Sameer a cellular phone. Father will pay all costs associated with the phone provided to Sameer. Mother will be permitted to exercise reasonable control over Sameer's use of the phone, but shall not be unreasonable in allowing Sameer access to or use of such phone. Mother shall not unreasonably interfere with contact from Sameer's extended family on Father's side. 8. Neither party shall relocate with Sameer without written agreement by the other parent or a court order. 9. Neither party shall do anything which may estrange Sameer from the other parent, or injure the opinion of Sameer as to the other parent or which may hamper the free and natural development of Sameer's love or respect for the other parent. Both parties shall provide Sameer with a "safety zone" by discouraging third parties from making negative remarks about either parent when Sameer is within earshot. 10. The parties shall be entitled to custodial time outside the parameters of this Order so long as the parents agree to such changes or additions to the regular custody schedule. The parties also recognize that by agreement, they may make any changes, alterations or additions to any portion of this Order. In the case of a disagreement regarding such changes, the parties shall follow the custody schedule as outlined in this Order. BY THE COURT: /V/ cm--,v, ec-,L,2 J-11, 14. L. E ert, Judge 7- TRUE COPY FROMf=ORD In Testimony whereof, I hers unto set my hand and the said C urt a C , arlisle Pa. ThlsIM of 20 Prothonota EXHIBIT "B" U1 71 y f r L ?±bL?b -? .? ~ c,cV L1 010 ? L r-OLEO 3333 North Front St., Harrisburg, PA 11!310. 717.233.1681 a 717.234.8258 fax • www.jfsofhbg.org A PROGRAM OF JEWISHFAMLYSERVICEOF GREATER HARRISBURG I NC. October 27, 2011 Joseph Hitchings, Esq. Joseph Hitchings Law Offices 5ooo Ritter Rd, Suite 2ol Mechanicsburg, PA 17055 Dear Mr. Hitchings: I am writing this letter on behalf of Ricky Hartman (aka Sameer Stanley). The purpose of this letter is to provide you with my perspective as a mental health professional regarding the best interests of Ricky. Based on my office-based counseling sessions with Ricky, I respectfully offer the following: t. Ricky's mother, Emilee Hartman, has been consistent in bringing Ricky to appointments at our agency since January 2011. She has been engaged in Ricky's counseling, open to hearing the therapist's perspective, and willing to consider suggestions based on Ricky's best interest. 2. Ms. Hartman consistently expresses that her paramount concern is Ricky's safety, given the history of domestic violence that she experienced with his father. Ricky reportedly witnessed some of this abuse, and as a result he is also a victim of the trauma. 3. When Ricky was having supervised visitation with his father at the YWCA, he seemed to be progressing in developing his relationship with his father and getting to know him. Ricky has shown a distinct decline in mood and behavior since the change to unsupervised visits, and has indicated in sessions that he is apprehensive and anxious about the new arrangements. It is my opinion that unsupervised visitation at this time is detrimental to Ricky's sense of security and emotional well-being. Supervised visitation allows him to experience the father-son connection in an environment in which he feels safe. 4. It is extremely important that Ricky be shielded from the acrimony that exists between his mother and father. This would include arguments or discussions that he can overhear, any negative statements made directly to him by either parent about the other, or any attempts to question him about the private life of the other parent. I hope these recommendations assist in the decision-making process for Ricky. If you need further information, please call me at (7.17) 233-1681. Sincerely, Mary Tarbe , M.Ed., LPC Therapist HARUN ALRISHID STANLEY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVAN12 a `j a, -? V. -.M 2009-2388 CIVIL ACTION LAW i,nr- :a rv " ca EMILEE JEAN HARTMAN C .Y IN CUSTODY ::?.? -" r DEFENDANT y A r - ORDER OF COURT AND NOW, _ Tuesday, November 22, 2011 , upon consideration of the attached. Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on _ Thursday, December 08, 2011 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Es q. c?- 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 ess(Cp'Z J?v`ar- FS?. os e?v?l L /? -XC l ?pr? X 0/?foy, egjI&S ?L3??J AUTHORITY TO PAY COURT APPOINTED COUNSEL -r 1 0 9(111 1. COURT e common ? District Justice C? Common Pleas ? Appellate ? Other N? 3. FOR (D.J., C.P., APPELLATE) C / 4. TA 5. BUDGET CODE 0 . pi rM A l I CASE OF 6 T RGE/OFFENS (P RDON CITATION) 8. ? PETTY . '. ENSE . ? FELONY ? MISDEMEANOR vs 1 9. PROCEEDINGS (De cribe briefly) 11. PERSON REPRESENTED VI OCKET NO. l 1 C 1 O Defendant - Adult nn '' I M 2 ? Defendant - Juvenile y / _ ¦ L /?l? g ? Appellant 4 O Appellee 13. CRIMINAL DOCKET NO. 1 ` 5 ? Habeas Petitioner 6 ? Material witness 10. PERSON REPRESENTED (Full Name) 7 ? Paroles Charged With Violation a ? Probation ?sgee violation 14. APPEALS DOCKET NO. LJ I Cj 9 ? Otne 16. NAME OF ATTORNEY/PAYEE AND ?t 1601616 V l Aopt Date MAILING ADDRESS 1--A 'cfI ?? vi Ol?. Sari ?( /? rvI' v Iz1 ?, ?? \ I 1 I J+?T ?0 IV NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE IrJ,,`P( )10 13 7. T O VA 1 W'Off 12- I 8. SOO N 0 0 CLAIM FOR SERVICES OR EXPENSES - 1 9. SERVICE HOURS DATES U CLA Nft a. Arraignment and/or Plea Mu toMa prrllourt!'teo total ho in "In C' Vt kMcom- b. Preliminary Hearing ry pen* EnIA"otal WaR c. Motions and Request s _ ?,-Lj?j«. d Bail Hearings ?y,C fV ---1m O a. Sentence Hearings Z CJt U 2 I. Trial ?.! g. Revocation Hearings h. Juvenile Hearings i. Appeals Court 19A. TOTAL IN COURT COMP. 4 Other (Specify on additional sheets) TOTAL HOURS / f X $55 PER HOUR a $ 1-7, 00/ 20. a. Interviews and conferences Multiply rate per hour times total Enter total "Out of Court" h ours. U b. Obtaining and reviewing records compensation below. . O M C Legal research and brief writing 3 O d. Investigative and other work (Specify on additional sheets) 20A. TOTAL OUT OF COURT 00 COMP. TOTAL HOURS = U , X $45 PER HOUR ' $ 1 g ? / 21. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM Mileage $ per mile x w Please contact Court Administrator for current mileage rate = 21 A. TOTAL ITEMIZED EX P. O =S 22. CERTIFICATION OF ATTORNEY/PAYEE 23. GRAND TOTAL CLAIM Has compensation and/or reimbursement for work In this case previously been applied for? ? YES "0 = $ 2 5j - . If yes, were you paid? ? YES "0 If yes, by whom were you paid? How much? 24. DEDUCT. PRIOR PYMTS. Has the person represented paid any money to you, or to your knowle"nyone else, In connection with the matter for = S ou were appointed to provide representation? ? YES 0" NO If yes, give details on additional sheets which y I'L 11 S.! t 'NET AMO NT CLAD 25 I swear or affirm the truth or correctness of the above statements Signature orney/Payee Date . -S 26.APP11uvt a cuu r P J Signature of , fl Dale: d 27. AMT. AFFPR VED $ Ar aE rvt u ge Copy 1 - Mail to Court Administrator at completion of service ?,pw OFFI??, OF SEAN M. SHULTZ,,. 4 Irvine Row Carlisle, PA 17013 Phone (717) 701-8412 Fax (717) 701-8416 billing@ShultzLawOffice.com www.ShultzLawOffice.com Invoice submitted to: Sameer Stanley December 14, 2011 In Re: GAL Invoice #13229 Professional Services Hre/Rate Amount 11/10/2011 Telephone conference with Attorney Hitchings' staff; Voicemail to Attorney 0.10 4.50 Hitching 45.00/hr 11/14/2011 Telephone conference with Attorney Hitchings; Voicemail to Emilee Hartman; 0.20 9.00 Office conference with SMS 45.00/hr Telephone conference with Emilee Hartman 0.10 4.50 45.00/hr 11/15/2011 Telephone conference with Judge Ebert's staff 0.10 4.50 45.00/hr Telephone conferences with Emilee Hartman, Court Administrator's Office and 0.20 9.00 Attorney Gilroy's staff 45.00/hr Email to Attorney Gilroy's staff 0.10 4.50 45.00/hr 11/17/2011 Telephone conference with Judge Ebert's staff 0.10 4.50 45.00/hr 11/18/2011 Office conference with Stanley Sameer 0.80 36.00 45.00/hr 12/2/2011 Telephone conference with Emily Hartman; Office conference with SMS; Email 0.20 9.00 to Shelly Brooks; Email from Shelly Brooks 45.00/hr Sameer Stanley Page 2 Hrs/Rate Amount 12/4/2011 Draft Memorandum 1.00 45.00 45.00/hr 12/6/2011 Revise Memorandum 0.30 13.50 45.00/hr Format and review Memorandum 0.40 18.00 45.00/hr Fax Memorandum to attorneys 0.10 4.50 45.00/hr 12/7/2011 Telephone conference with Attorney Hoist; Email to Attorney Hoist 0.10 4.50 45.00/hr Telephone conference with Attorney Hitchings; Email to Attorney Hitchings 0.10 4.50 45.00/hr Fax Memorandum to Attorney Gilroy 0.10 4.50 45.00/hr 12/8/2011 Court Appearance for Conciliation ? 1.40 77.00 55.00/hr For professional services rendered 5.40 $257.00 Balance due $257.00 AUTHORITY TO PAY COURT APPOINTED COUNSEL f"L`/ JAN 19 2012 ? 1. COURT ? Di i t t J i 2. VOUCHER N0 14271 r s ust c ce [) Common Pleas ? Appellate ? Other 3. FOR (D.J.. C.P., APPEL TE 4. AT ( ITY/S ATE) 5. BUDGET CODE 6. THE CASE OF 7. CHARGE/OFFENSE ( UROON CITATION) 8. ? PETTY OFFENSE A 1A vs ? FELONY ? MISDEMEANOR 9. PROCEEDINGS Describe briefly) 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. L 1 ? Defendant - Adult 2 ? Detendant Juvenile /tt ?7 O vll G U A A 3 ? Appellant 13. CRIMINAL DOCKET NO 4 ? Appellee 5 ? Habeas Petitioner 6 ? Material Witness i i Wi l 10. PERSON REPRESENTED (Full Name) on 7 ? Parolee Charged th V o at g ? Probationer Charged With Violation 14. APPEALS DOCKET NO. (/? ?' V 9 16 Other ! tl/' rY11 / 16. NAME OF ATTORNEY/PAYEE AND Aopt Date ( I MAILING ADDRESS I In't g M. Uf L T(10 C ZAP ?, 1 f1 0? NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE O ov) ? ? i4_ 17. 2 ON N,9. L - 11 zm_ 18. SOCiALZS?GUf?{TY 0 Ip NO ?'IT U CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES AMOUNTS CLAIMED a. Arraignment and/or Plea Multiply rate per h9w times total ?" " " b. Preliminary Hearing b. hourfs )o oWeIn IRTourt com- below. diRpr total c. Motions and ROQU6ata , -p3 tV CO °i f n 1- d Bail Hearings M. :3 O s. Sentence Hearings F Ujr N 7 L) Z I. Trial CD r- g. Revocation Hearings <C-1 h. Juvenile Hearings a' C}: b i. Appeals Court 19 AWM CO A`rCOMP. I. Other (Specify on additional sheets) TOTAL HOURS = X $55 PER HOUR - $ 20. a. Interviews and conferences Multiply rate per hour limes total U. ~ b. Obtaining and reviewing records hours. Enter total "Out of Court" compensation below. O ¢ c. Legal research and brief writing O O d. Investigative and other work (Specify on additional sheets) 20A. TOTAL OUT OF COURT COMP. TOTAL HOURS = X $45 PER HOUR $ G 21. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM Mileage $ per mile x w Please contact Court Administrator for current mileage rate 21A. TOTAL ITEMIZED EXP. O a 22. CERTIFICATION OF ATTORNEY/PAYEE Has compensation and/or reimbursement for work in this case previous p?e/n/ap`ppllied for? (5 YES ? NO If ?27 ? 'YES H ? it 23. GRAND TOTAL CLAIMED = $ yes, were you paid ow much ? NO If yes, by whom were you paid?- ? - Has the person represented paid any money to you, or to your knowledge anyone els , In connection with the matter for 24. DEDUCT. PRIOR PYMTS. which you were appointed to provide representation? ? YES "0 If yes, give details on additional sheets a S I swear or affirm the truth or correctness -S'-14A 1 I& / 12 25: NET AM U T CLAIMED of the above statements Signature o Attomey/Pe a Date 26n`'P'vuvEO cull Signature of `? `^ 1wMENt Jud / D e ? NNW V1 27. AMT. APPROVED = s v ' g ale: . ,_ '7 ,_T Copy 1 - Mail to Court Administrator at completion of service Law Offices of SAIDIS, SULLIVAN & ROGERS A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: attorney@ssr-attorneys.com www.ssr-attomeys.com Invoice submitted to: Sameer Stanley Make checks payable to Saidis, Sullivan & Rogers. January 13, 2012 In Re: GAL Invoice #13421 Professional Services Hrs/Rate Amount 12/14/2011 Receive and review Order 0.10 4.50 45.00/hr For professional services rendered 0.10 $4.50 Previous balance $257.00 Accounts receivable transactions 1/3/2011 Payment - Thank You No. 834341 ($257.00) Total payments and adjustments ($257.00) Balance due $4.50 z HARUN ALRISHID STANLEY, Plaintiff vs. EMILEE JEAN HARTMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009-2388 IN CUSTODY COURT ORDER S? AND NOW, this I. day of February, 2012, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's prior Order of December 12, 2011, shall remain in place subject to the following modifications: 1. Father's periods of temporary custody shall be modified as follows: A. Father's custody on Saturday February 18, shall be consistent with paragraph 1(A) of the December 12, 2011, Order. B. Starting February 25, father's periods of partial custody shall be every weekend from Saturday at 9:00 a.m. until Sunday at 6:00 p.m. C. Starting the weekend of Friday, March 16, father's periods of custody shall be alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m. 2. The above Order shall be TEMPORARY in nature pending a telephone conference the Custody Conciliator shall conduct with counsel for the parties and the GAL on Monday, April 19, 2012, at 8:00 a.m. At the time of the telephone conference and in the event matters are proceeding smoothly as far as custody, the Conciliator may recommend a more permanent Order to the Court. Counsel for the parties are directed to exchange proposals prior to the mentioned telephone conference relative to a proposed holiday schedule and any vacation schedule that may apply in this matter. 3. Prior to the father having overnights with the minor child, father shall afford the mother an opportunity to inspect father's home with a proviso that father shall insure that his girlfriend is not at the home at the time of the inspection BY THE COURT: 4k-?W M.L. Ebert, Jr., Judge cc: ?Jess:ica Holst, Esquire ? Joseph Hitchings, Esquire M lP - n -, v Sean M. Shultz, Esquire n = s r -am ? '?e5 rna:Irq? abiba ? ? -n te4ze G x® 77' _ G7 ° :'i ra `n CD M x ?, HARUN ALRISHID STANLEY, Plaintiff vs. EMILEE JEAN HARTMAN, Defendant Prior Judge: The Honorable M.L. Ebert, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009-2388 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The Conciliator met with the Attorneys for the parties and the GAL on February 10, 2012. This about the third or fourth Custody Conciliation and the parties reached an agreement in the nature of an Order in the form as attached. Date: February , 2012 Hubert X. Gilro , Esquire Custody Conc' iator AUTHORITY TO PAY COURT APPOINTED COUNSEL ? MAR 2 3 2012 1. COURT 2. VOUCHER ? ? District Justice C-Com?mon Pleas ? Appellate ? Other N- 14563 3. FOR (D.J., C.P., APPE TE? 4. A CITY/ TATE1 5. BUDGET CODE 6 THE CA E OF 7. CHARGE/OFFENSE PURDON CITATION) 8. ? PETTY OFFENSE vs An I vq 1A U ? FELONY O MISDEMEANOR 9. PROCEEDINGS ( escribe briefly) 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. 1 ? Defendant - Adult - 2 O Defendant-Juvenile ` l0l 39 ;z_ e (,TAL 3 ? Appeuant 13. CRIMINAL DOCKET NO. 4 ? Appellee 5 ? Habeas Petitioner 6 ? Material Witness i 10. PERSON REPRESENTED (Full Name) on 7 ? Parolee Charged With Violat 8 ? Probationer Charged With Violation 14. APPEALS DOCKET NO. ? 9 X Other. S(anp'/'r ('4a-nLem 16. NAME OF ATTORNEY/PAYEE AND Appt Date MAILING ADDRESS IM ' L l? fqt NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE ? "` ??)ils?, ? ? J? X13 17.T E)P E o.^/ 16. SOCIAL SECURITY NO OR EINNO CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES A U ` CLAIMED a. Arraignment and/or Plea Mulupy3lte ptltiriour es total - h l b b. Prelimina Heart ry Hearing taOC n com ou CM pen 611111 EntW*otal below. c. Motions and Requests d. Bail Hearings O a. Sentence Hearings a ""- Z I. Trial n C _ g- Revocation Hearings rQ h. Juvenile Hearings :7 c-n I. Appeals Court 19A. TOTAk IN COURT COMP. j. Other (Specify on additional sheets) TOTAL HOURS X $55 PER HOUR - 5 20. a. Interviews and conferences Multiply rate per hour times total f C t t t l "O t rt" h E ours. n er u o ou o a b. Obtaining and reviewing records compensation below. O M I c. Legal research and brief writing ? O d. Investigative and other work (Specify on additional sheets) 20A. TOTAL OUT OF COURT OU . COMP. /39.!;b l TOTAL HOURS = - I X $45 PER HOUR j?'j = $ „ 0 j j v 21. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM Mileage $ per mile x 4 Ld" 4 Please contact Court Administrator for current mileage rate a e = 21 A. TOTAL ITEMIZED EXP. O =$ 22. CERTIFICATION OF ATTORNEY/PAYEE ? l d f ? c YES NO 23. GRAND T TAL CLAIMED or e r Q Has compensation and/or1simbursement for work in this case previous en a = i If yes, were you paid? B YES O NO If yes by whom were you pal;? How much? 24. DEDUCT. PRIOR PYMTS. Has the person represented paid any money to you, or to your knowle anyone else, n connection with the matter for = S give details on additional sheets ti 7 OYES O If yes id t , e represen a which you were appointed to prov 3 f 17Z jL 1 swear or affirm the truth or correctness T 25: NET AMOUNT CLAIMED Date of the above statements Signature of %Mkirney/Payee = s 9--+ ,?fl ? 26.^r' PU°i E U Signature of ?Date: 3 Z/1 27. AMT. APPROVED = C? 1 $ ( q 0/ r•AYMENT Judge ? J Copy 1 - Mail to Court Admini` rator at completion of service LEMOYNE OFFICE 635 NORTH 121H STREET SUITE 400 LEMOYNE, PA 17043 TELEPHONE: (717) 612-5800 FACSIMILE: (717) 612-5805 Law Offices of Saidis, Sullivan & Rogers A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 1701.3 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: attorney@ssr-attorneys.com WW ssr-attorneys.com REPLY TO CARLISLE March 2, 2012 Sameer Stanley x RE: GAL Payments received since last invoice Accounts receivable balance carried forward DATE DESCRIPTION 02/01/2012 Voicemail to Emilee Hartman 02/03/2012 Review file; Office conference with Ricky Stanley 02/06/2012 Telephone conference with Attorney Holst; Memo to file 02/08/2012 Telephone conference with Mary Tarbell, counselor for Ricky Stanley 02/10/2012 Review file prior to Conciliation 02/10/2012 Attend Conciliation 02/22/2012 Receive and review Order of Court TOTALS Our file# 81068 S880088 Invoice# 5872 EIN: 27-2700453 $0.00 $0.00 HOURS LAWYER 0.10 DMH 0.80 SMS 0.20 DMH 0.40 SMS 0.20 SMS 1.20 SMS 0.20 SMS 3.10 $140 SN89089 GAL Billing Summary Total professional services Total of new charges for this invoice Total balance now due ** Trust account remaining balance is $0.00 Invoice4 5872 Page 2 $146.00 $146.00 $146.00 PRIVACY POLICY: During this firms representation of you, we may receive nonpublic, personal information from you or from sources about you. It is our policy and practice that our attorneys and staff do not at any time reveal information relating to our representation of you unless you consent after consultation, except for disclosures that are impliedly authorized to carry out the representation, and except for disclosures required or authorized by the Pennsylvania Rules of Professional Conduct. Interest at 1 1/2% per month on unpaid balance after 30 days. AND NOW, this day of March, 2012, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that the prior Custody Orders issued in this case are modified as follows: HARUN ALRISHID STANLEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW EMILEE JEAN HARTMAN, NO. 2009-2388 r T Defendant _ IN CUSTODY y-- _.., COURT ORDER 1. Father's overnight periods of partial custody with the minor child are suspended. Father's periods of partial custody shall be on every Saturday from 9:00 a.m. until 7:00 p.m. Transportation for exchange of custody shall be consistent with the December 12, 2011, Order. 2. Legal counsel for the parties shall conduct another telephone conference with the Custody Conciliator and the GAL on Thursday, April 19, 2012, at 8:00 a.m. BY THE COURT: M.L. Ebert, Jr., Judge cc: Jessica Holst, Esquire Joseph Hitchings, Esquire d Sean M. Shultz, Esquire l r d S// /ice c ?iCL HARUN ALRISHID STANLEY, Plaintiff vs. EMILEE JEAN HARTMAN, Defendant Prior Judge: The Honorable M.L. Ebert, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009-2388 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT' IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. This case comes before the Conciliator on an emergency request from mother's counsel. The minor child has recently been expelled from school for carrying a knife to school. When confronted at school with the knife, he indicated that his father gave the knife to him "for protection." This version was confirmed in a session the minor child had with his counselor. Since that time, the child is suggesting that he found the knife. 2. Mother has serious concerns because the child is now expelled from school and these type of discipline problems have arisen with the child since the father has come back in to the picture. The history has been that the father just started seeing the child one day a weekend and we have recently expanded that visitation to overnights. 3. Included in the telephone conferences were Sean Shultz, Esquire, who is the GAL appointed for the child. In these discussions, the Conciliator was inclined to terminate father's overnight visitation with the child on a temporary basis, and the GAL concurred in that recommendation. 4. The Conciliator conducted two telephone conferences with legal counsel for the parties. Based upon those conference calls, the Conciliator recommends an Order in the form as attached. Date: March v? , 2012 Hubert X. 991roy, Esquire Custody; onciliator ,, AUTHORITY TO PAY COURT APPOINTED COUNSEL 1?/APR 11 2012 1. COURT ? i i 2. VOUCHER 4 5 6 4 0 1 str ? D (; ct Justice 0Ommon Pleas ? Appellate ? Other , N- 3. FOR (D.J.. C.P., APPE TE) 4. AT ( ITY/ST TE) 5. BUDGET CODE 01WID/0-6 o op 631 THE C SE OF 7. CHARGE/OFFENSE ( UROON CITATION) 8. ? PETTY OFFENSE (,' vs ) hvlw" ? FELONY ? MISDEMEANOR 9. PROCEEDING (Describe briefly) 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. 1 ? Defendant - Adult 2 ? Defendant - Juvenile *1 u -.7 1 A L 111 3 ? Appellant 4 ? Appellee 13. CRIMINAL DOCKET NO 5 ? Habeas Petitioner 6 ? Material Witness 10. PERSON REPRESENTED (Full Name) 7 ? Parolee Charged With Violation 8 ? Probationer Charged With Violation 14. APPEALS DOCKET NO. ?l 9 ;X Other. ,Id 16. NAME OF ATTORNEY/PAYEE AND Appt Date MAILING ADDRESS S r ?? t`'S S Gt 11 i yffA 4? kvq eor's NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE J 17. TELEPHONE No. 18. SOCIAL SECURITY NO OR E IN NO 2 LP 2 z2- '7 D12 Q -Z-7 53 CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES AMOUNTS CLAIMED a. Arraignment and/or Plea Multiplf rite pwfturjjmes total b. Preliminary Hearing hours I115:?)btaW-Oln Court" com- pen"Fold. Entfaq'total-below. a Motions and Request s . -` ? d Bail Hearings ; :) O a. Sentence Hearings r_n -- V Trial I 2 . g. Revocation Hearings a -. h. Juvenile Hearings a.- I. Appeals Court 19A: Q'F'AL IN'COURr COMP. I. Other (Specify on additional sheets) J TOTAL HOURS X $55 PER HOUR - $ 20. a. Interviews and conferences Multiply rate per hour times total b. Obtaining and reviewing records " hours. Enter total "Out of Court compensation below. O M f- :) c, Legal research and brief writing O O d. Investigative and other work (Specify on additional sheets) 20A. TOTAL OUT OF COURT COMP. TOTAL HOURS = X $45 PER HOUR 3 $ O (/ 21. ITEMIZATION OF REIMBURSABLE EXPENSES AMT. PER ITEM Mileage $ per mile X w Please contact Court Administrator for current mileage rate 21 A. TOTAL ITEMIZED EXP. O _$ 22. CERTIFICATION OF ATTORNEY/PAYEE 23. GRAND ,OT L CLAIMED Has compensation and/or reimbursement for work In this case previous been a lied for? f?ES ? MO 2 J [1 1 Z = $ - 4P 11 yes, were you paid? YES C3 NO If yea bywhOm were you paid? How much?- On connection with the matter for Has the erson re resented aid an mon one else t u or t r kn e an l d p p p , y . y ey o yo o you ow e g which you were appointed to provide representatign? ? YES WNO If yes, give details on ad itional sheets $ s 1 swear or affirm the truth or correctness s 6=1a._ y 25: NET AMO CLAIMED of the above statements Signature of A omey/Payee Date : $ 26.-Pr10vFO F Signature of 27. AMT. APPROVED AVME MENi n Judge Judge ? 'Dale; Copy 1 - Mail to Court Administrator at completion of service LEMOYNE OFFICE 635 NORTH 12711 STREET SUITE 400 LIMOYNE, PA 17043 TELEPHONE: (717) 612-5800 FACSIMILE: (717) 612-5805 Law Offices of Saidis, Sullivan & Rogers A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 1701.3 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: attorneyCssr-attorneys.com w ww ssr-attornevs. com REPLY TO CARLISLE April 2, 2012 Sameer Stanley x RE: GAL Our file# 81068 S880088 Invoice# 6137 EIN: 27-2700453 Balance forward as of invoice dated March 2, 2012 $146.00 Payments received since last invoice $0.00 Accounts receivable balance carried forward $146.00 DATE DESCRIPTION HOURS LAWYER 03/02/2012 Email to Shelly Brooks 0.10 DMH 03/02/2012 Receive letter from Shelly Brooks 0.10 SMS 03/20/2012 Emails to and from counsel to set up conference call 0.20 DMH 03/26/2012 Attend conference call 0.40 SMS 03/27/2012 Review letter from client's therapist 0.20 SMS 03/27/2012 Telephone conference with Emilee Hartman and 0.60 SMS client; Notes to file 03/28/2012 Telephone conference with Conciliator and other 0.60 SMS counsel TOTALS 2.20 $99.00 ? 6880098 GAL Billing Summary Total professional services Total of new charges for this invoice Plus net balance forward Invoice# 6137 Page 2 $99.00 $99.00 $146.00 Total balance now due $245.00 ** Trust account remaining balance is $0.00 PRIVACY POLICY: During this firms representation of you, we may receive nonpublic, personal information from you or from sources about you. It is our policy and practice that our attorneys and staff do not at any time reveal information relating to our representation of you unless you consent after consultation, except for disclosures that are impliedly authorized to carry out the representation, and except for disclosures required or authorized by the Pennsylvania Rules of Professional Conduct. Interest at 1 1/2% per month on unpaid balance after 30 days. ONL- MAY 11 2012 AUTHORITY TO PAY COURT APPOIN'ru) COUNSEL t ?- CHER 1. COURT ?? ' ? Other ll ? A t NO 14512 Common Pleas ? District Justice B ppe a e 3. FOR (D.J., C.P., APPELLATE) 4. A CITY/ tTE1 5. BUDGET CODE 11HE CAS OF 7. CHARGE/OFFENS (PURDON CI rATION) 6. ? PETTY OFFE SE ? FELONY O MISDEMEANOR M EEDINGS ( ascribe briefly) 11. PERSON REPRESEN,rE3 . CIVIL DOCKET NO. 12 . t O 2 O Defendant - Adul Defendant - Juvenile ? P ; e 3 O Appellant 13. CRIMINAL DOCKET NO. ?AL 4 ? Appellee 5 ? Habeas Petitioner 6 ? Material Witness 7 O Parolee Chargeci With violation APPEALS DOCKET NO 4 PERSON REPRESENTED (Full Name) 10. 6 O Probationer Charged With violation . . 1 // 6 ho d, Apol Date NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE 16. NAME: OF ATTORNEY/PAYEE AND MAILING ADDRESS s d i(s) ,Sul ? ? ages Ca,() rsi-e, PA 17. EPHO ENO 16. SOCIAL SECURITY NO OR EIN NO CLAIM FOR 9. 1 a. Arraignment and/or Plea b. Preliminary Hearing c. Motions and Requests d Bail Hearihills s. Sentence Hearings O U I. Trial Z g. Revocation Hearings It. Juvenile Hearings I. Appeals Court 4 Other (Specify on additional sheets) TOTAL HOURS a 20. a. Interviews and conferences 0. Obtaining and reviewing records LL O ¢ c. Legal research and brief writing d. Invesdgadve and other work (Speci fy on additional sheets) Out TOTAL HOURS - 21 X $55 PER HOUR =S Multiply rate per hour times total hours. Enter total "Out of Court" compensation below. 20A. TOTAL OUT OF COURT COMP. 2 X $45 PER HOUR S y j 5 J• ?? w Please contact Court Administrator for current mileage rate 1 A. TOTAL ITEMIZED EXP. F O =$ _ 23. GRAND TOTAL CLAIMED 22. CERTIFICATION OF ATTORNEY/PAYEE Has compensation and/or I bumement for work in this case previously appii for? C3' YES ? NO = S ) "06 m How much??1 24. DEDUCT. PRIOR PYMTS. If yes, were you paid? YES ? NO If yes by whom vlrsrs you paid? Has the person represented paid any money to you, or to your knowle yon. else, t connection with the matter for = S which you were appointed to provide represents on? YES NO If yes, give details on additional 25: NET AMOUNT CLAIMED 1 swear or affirm the truth or correctness Signature of Attorney/P so Date of the above statements 27. AMT. APPROVED 28.nI•vnuv[oI Signature of = S r 53 06 F C)64 , ? Date. ?AYMENt Judge ICES OR EXPENSES O f-D C:i 19A. TOTAL IN COURT COMP. Copy 1 - Mail to Court Administrate} at completion of service Law Offices of Saidis, Sullivan & Rogers A PROFESSIONAL CORPORATION LEMOYNE OFFICE 635 NORTH 12TH STREET SUITE 400 LEMOYNE, PA 17043 TELEPHONE: (717) 612-5800 FACSIMILE: (717) 612-5805 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 1.701.3 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: attorney@ssr-attorneys.com www.ssr-attorneys.com REPLY TO CARLISLE May 2, 2012 Sameer Stanley x RE: Emilee Hartman and Harun Stanley Our file# 81068 S880088 Invoice# 6595 EIN: 27-2700453 Balance forward as of invoice dated April 2, 2012 $245.00 Payments received since last invoice $238.50 Accounts receivable balance carried forward $6.50 DATE DESCRIPTION HOURS LAWYER 04/03/2012 Receive and review Order 0.20 SMS SMS 04/09/2012 Adjustment on March invoice 0.00 60 0 SMS 04/18/2012 Telephone conference with Holy Spirit Case . 04/19/2012 Manager, Amy Patterson Telephone conference with Conciliator and counsel 0.30 SMS 04/24/2012 Receive and review letter from Sameer Stanley; 0.40 SMS Telephone conference with Sameer SMS 04/25/2012 Receive and review email and 2 letters from 0.40 Attorney Holst 40 1 SMS 04/27/2012 Office conference with client . 10 0 SMS 04/27/2012 Receive and review voicemail from Mary Tarbell . TOTALS 3.40 $146.50 .S890088 GAL Billing Summary Total professional services Total of new charges for this invoice Plus net balance forward Total balance now due ** Trust account remaining balance is $0.00 Invoice# 6595 Page 2 $146.50 $146.50 $6.50 $153.00 PRIVACY POLICY: During this firms representation of you, we may receive nonpublic, personal information from you or from sources about you. It is our policy and practice that our attorneys and staff do not at any time reveal information relating to our representation of you unless you consent after consultation, except for disclosures that are impliedly authorized to carry out the representation, and except for disclosures required or authorized by the Pennsylvania Rules of Professional Conduct. Interest at 1 1/2% per month on unpaid balance after 30 days. c, AUTHORITY TO PAY COURT APPOINTED COUNSEL 1. COURT - / 2. VOUCHER N 0 14' 575 Pleas ? Appellate ? Other ? District Justice C7GOmmon _ 3. FOR (D.J., C.P., APPELLA 4. CITY/ T T) 5. BUDGET CODE ? p i , 6. HE CA E OF 7. CHARGE/OFFENS (PURDON CITATION) 8. ? PETTY O F NSE ? FELONY ? MISDEMEANOR VS 9. PROCEEDINGS (describe briefly) 11. PERSON REPRESENTED 12. CIVIL DOCKET NO. 1 O Defendant. Adult /9 n fendant •Juvenile 2 O De X11 GAL 3 ? ADDellant 13. CRIMINAL DOCKET NO. 4 ? Appellee 5 ? Habeas Petitioner 6 O Material Witness 10. PERSON REPRESENTED (Full Name) 7 ? Parolee Charged With Violation 8 O Probation rCharged ith Violation 9 (YOtner. 14. APPEALS DOCKET NO. (' 16. NAME OF ATTORNEY/PAYEE AND Appt Date MAILING ADDRESS 2J,4 V) ED TO CASE NAME OF COMMON PLEAS JUDGE ASSIGN 0 /3 17. TE E? O E No. ?Z 18. SO?ALSEC?aiTY O O i EIN NO "? Z "/T f CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES AMOUNTS CLAIMED a. Arraignment and/or Plea Multiply rate per hour times total r to obtain "In Court" com- ho b. Preliminary Hearing u s pensation. Enter total below. c. Motions and Requests t- d Sail Hearings } O s. Sentence Hearings t i Tom' C U Z f. Trial _ rrt g. Revocation Hearings _ tt t 3 h. Juvenile Hearings CO i. Appeals Court 19111[t?SAL IN CO MP. 4 Other (Specify on additional sheets) C _ TOTAL HOURS = X $55 PER HOUR - 20. a interviews and conferences Multiply rate"-pier hour times total f Co t l "O t rt" h E t t 0. Obtaining and reviewing records ours. n er u o u o a compensation below. O M Q Legal research and brief writing U d. Investigative and other work (Specify on additional sheets) 20A. TOTAL OUT OF COURT O COMP. TOTAL HOURS = L X $45 PER HOUR $ __42 op r P , 21. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM Mileage $ per mile x W Please contact Court Administrator for current mileage rate v 21 A. TOTAL ITEMIZED EXP. O :_ 22. CERTIFICATION OF ATTORNEY/PAYEE I d O 'or? YES 23. GRAND TOTAL CLAIMED s dIV Has compensation and/orr imbumement for work In this case prmrlous VIRA If yes, were you paid? <J YES O NO If yes, by whom were you pald7 How much? PRIOR PYMTS. 24 DEDUCT Has the person represented paid any money to you, or to your knowle anyone else, in connaction with the matter for . . _ S give details on additio al sheets pointed to provide representat ? El YES NO If yes were a hi h o . p w c y u s- 2- ff h h t 25: NET AMOy NT CLAIMED or correc nes irm t e trut I swear or a naturo Attomey/Psye Date tatements Si h b f _$ P e a ove s g t o /.. _ 26.nrwnuvtu R)14 Signature of , Date: li, & -t '? 27. AMT. APPROVED DD PAvr?ENr Judge V Copy 1 - Mail to Court Administrator at completion of service Law Offices of Saidis, Sullivan & Rogers A PROFESSIONAL CORPORATION LEMOYNE OFFICE 635 NORTH 12TH STREET SUITE 400 LEMOYNE, PA 17043 TELEPHONE: (717) 612-5800 FACSIMILE: (717) 612-5805 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 1.7013 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: attorney@ssr-attorneys_com www.ssr-attorneys.com REPLY TO CARLISLE June 4, 2012 Sameer Stanley X RE: Emilee Hartman and Harun Stanley Balance forward as of invoice dated May 2, 2012 Payments received since last invoice Accounts receivable balance carried forward DATE DESCRIPTION 05/04/2012 Receive and review email from Attorney Hitchings 05/11/2012 Receive and review email and letter from Attorney Holst 05/15/2012 Review file; Leave message for Harun Stanley regarding need for him to call his attorney if he needs advice 05/15/2012 Review letter from Mary Tarbell 05/22/2012 Telephone conference with Emilie Hartman 05/23/2012 Receive and review email from Attorney Holst regarding trouble with custodial arrangements TOTALS Our file# 81068 S880088 Invoice# 7099 EIN: 27-2700453 $153.00 $0.00 $153.00 HOURS 0.20 0.40 0.20 0.20 0.40 0.20 1.60 LAWYER SMS SMS SMS SMS SMS SMS $72.00 •5880088 GAL Invoice# 7099 Page 2 Billins Summ Total professional services $72.00 Total of new charges for this invoice $72.00 Plus net balance forward $153.00 Total balance now due $225.00 ** Trust account remaining balance is $0.00 PRIVACY POLICY: During this firms representation of you, we may receive nonpublic, personal information from you or from sources about you. It is our policy and practice that our attorneys and staff do not at any time reveal information relating to our representation of you unless you consent after consultation, except for disclosures that are impliedly authorized to carry out the representation, and except for disclosures required or authorized by the Pennsylvania Rules of Professional Conduct. Interest at 1 1/2% per month on unpaid balance after 30 days. Because your opinion is important to us, we invite you to participate in our Client Survey. Use this link to complete the Survey: http://www.ssr-attorneys.com/client-survey.html Thank you for your time. At Saidis, Sullivan & Rogers we understand "Trust Matters." HARUN ALRISHID STANLEY, Plaintiff vs. EMILEE JEAN HARTMAN, Defendant Prior Judge: The Honorable M.L. Ebert, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2009-2388 IN CUSTODY COURT ORDER AND NOW, this alp t%-- day of June, 2012, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No. 2 of the Cumberland County Courthouse , 2012 at 'qtb-A.m. At this hearing, the father shall on the A ' _ -day o be the moving party an shall proceed initially with testimony. Counsel for the al* parties shall file with the Court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. The GAL may file a separate memorandum in advance of the hearing setting forth his thoughts with respect to the matter. 2. In the event mother is prepared to pay the costs for a home evaluation, father shall cooperate in such an evaluation conditioned upon the evaluator doing an evaluation of both the mother and father's home and including the results of both evaluations in any report. 3. Pending further Order of this Court, this Court's March 30, 2012, Order which incorporated the December 12, 2011, Order of Court, shall remain in effect. It is noted that the father is afforded every Saturday for custody with the minor child. If Saturday is not a convenient time because of the child's baseball schedule or otherwise, father's custody shall be on Sunday from 9:00 a.m. until 7:00 p.m. However, mother is directed to abide by the existing Order to insure father has at least one day a week with the child on days that are not the same days where father has class at Harrisburg Area Community College. cc: Jessica Holst, Esquire Joseph Hitchings, Esquire V Sean M. Shultz, Esquire 4'1e,5 Ma, led Ajo?? BY THE COURT: M.L. Ebert, Jr., Judge ? 2p Z? 3? _ HARUN ALRISHID STANLEY, Plaintiff vs. EMILEE JEAN HARTMAN, Defendant Prior Judge: The Honorable M.L. Ebert, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009-2388 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. A conciliation conference was held on June 22, 2012. Present were the mother, Emilee Jean Hartman, with her counsel, Joe Hitchings, Esquire. The father was unable to attend because of transportation issues, but his counsel, Jessica Holst, Esquire, was in attendance. The GAL, Sean M. Shultz, Esquire, was unable to attend but sent a lengthy email to the conciliator and both attorneys in advance. 2. This a very problematic case. The parents are at odds and the child is experiencing a great deal of difficulty on a variety of fronts. The prior order provided father with alternating weekends, but a recent order of March 30, 2012, eliminated overnights and just gave father one evening per week. 3. There are issues because the mother unilaterally removed the child from the counselor that the child had been seeing for quite some time. There is an issue on transportation requirements in that the father is legally blind and lives in Harrisburg while the mother lives in New Cumberland. 4. Father is only seeking alternating weekend custody and some time for a vacation. Mother is still resistant to this suggestion and indicates father has numerous problems. She is seeking a home study of father's situation. After approximately four conciliations, this case is ripe for a hearing and the conciliator recommends an Order in the form as attached. Date: June ':? , 2012 Hubert X. Gilroy, Esq Custody Conciliator IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HARUN ALRISHID STANLEY, Plaintiff No. 09-2388 c CIVIL ACTION - LAW' r- cn < The Honorable M.L. EbZTr . N a ru t.. V. EMILEE JEAN HARTMAN, Defendant MOTION FOR CONTINUANCE _1 _? r -Tt C) 9401 And now, this Z_ - _ day of July, comes Sean M. Shultz, Esquire, as Guardian ad Litem for Sameer Stanley, and respectfully represents the following: 1. A Custody Hearing is scheduled for August 24, 2012, at 9:00 a.m., in the above-referenced matter. 2. Guardian ad Litem will be on vacation and unable to attend the hearing. 3. Jessica Holst, Esquire, attorney for the Plaintiff, and Joseph Hitchings, attorney for the Defendant, concur with the request for the continuance. 4. The Honorable M.L. Ebert, Jr. has been assigned to this matter. WHEREFORE, Guardian ad Litem respectfully requests this Honorable Court continue the Custody Hearing scheduled for August 24, 2012, at 9:00 a.m. Respectfully submitted, SAIDIS, SULLIVAN & ROGERS Sean M. Shultz, Esquire ?-- Attorney ID No. 90946 26 W. High Street Carlisle, Pennsylvania 17013 (717) 243-6222 Guardian ad Litem IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HARUN ALRISHID STANLEY, No. 09-2388 Plaintiff CIVIL ACTION - LAW V. EMILEE JEAN HARTMAN, The Honorable M.L. Ebert, Jr. Defendant VERIFICATION I VERIFY that the statements set forth in the attached Motion 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: July Z , 2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HARUN ALRISHID STANLEY, No. 09-2388 Plaintiff V. CIVIL ACTION - LAW EMILEE JEAN HARTMAN, The Honorable M.L. Ebert, Jr. Defendant CERTIFICATE OF SERVICE AND NOW, this Z-4day of July, 2012, I, Sean M. Shultz, Esquire, hereby certify that I have this day served the following person with a copy of the foregoing Motion for Continuance by first class, United States Mail, postage pre-paid, addressed as follows: Jessica Holst, Esquire MidPenn Legal Services 401 E. Louther Street Carlisle, Pennsylvania 17013 Attorney for Plaintiff Joseph L. Hitchings, Esquire Rossmoyne Business Center 5000 Ritter Road, Suite 202 Mechanicsburg, Pennsylvania 17055 Attorney for Defendant Respectfully submitted, SAIDIS, SULLIVAN & ROGERS Sen a'''M. Shultz, Esquire Attorney ID No. 90946 26 W. High Street Carlisle, Pennsylvania 17013 (717) 243-6222 Guardian ad Litem IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HARUN ALRISHID STANLEY, No. 09-2388 Plaintiff CIVIL ACTION - LAW V. EMILEE JEAN HARTMAN, The Honorable M.L. Ebert, Jr. Defendant ORDER AND NOW, this 104*_clay of , 2012, upon consideration of the within Motion, it is hereby ORDERED and DECREED that the Hearing scheduled in the above- captioned matter for August 24, 2012, at 9:00 a.m. is continued to 4W . S , 2012, at .m., in Courtroom No. c;?- of the Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, J. C-) G r .' rv i f rry Esquire cc: Jessica Holst =M ?`- C r - e i- ^' , , Joseph Hitchings, Esquire r E o Ic ? Sean M. Shultz, Esquire c ; d e 1 s /na. ,e AUTHORITY TO PAY COURT APPOINTED COUNSEL Q? JUL 0 6 012 to 1. COURT '// i ? Di t t J i 2. VOUCHER N- 1 4630 r s c ust ce V Common Pleas ? Appellate ? Other , 3. FOR (D.J., C.P., AP LL E) 4. (CITY SIAT) n 5. BUDGET COD OF 6. 1?HE AS 7. CHARGE/OFFENS (PUROON CITATION) 8. ? PETTY OFF ENSE ? LIU ( -1J- vs ha ? FELONY ? MIS DEMEANOR 9. PROCEEDINGS (D scribe briefly) 11. PERSON REPRESENTED 12. CIVIL DOCKE NO. 1 O Defendant - Adult n 2 O Defendant - Juvenile - G &AL 3 ? Appellant 13. CRIMINAL DO CKET NO. 4 ? Appellee 5 ? Habeas Petitioner 6 ? Material Witness With Vi ti h l P l 10. PERSON REPRESENTED (Full Name) arged on aro o a 7 ? ee C 8 ? Probationer Charged With Violation 14. APPEALS DO CKET NO. er Sid- ew 9 Other /1 r_ eld 1 16. NA OF ATTORNEY/PAYEE AND App, Date / MAILING ADDRESS R 7 e S??lwavl's ens L h -e Y4 2 LO Pi NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE . A ) -79 13 17. TE PHONE No. 2LI3- 10 ii-7- 18. SOCIAI.SECURITV 1-7-2:76 O EINNO CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES A U -T L ED a. Arraignment and/or Plea Multiply?e pfi5o r ti es total b. Preliminary Hearing hour tai4Mjp pens ntELr tpt C om I - c. Motions and Requests ?rn c ?r i- d tail Hearings Nt-- ,?= 7 :3 0 e. Sentence Hearings .-<3> 'J Z p -.4 -^ Z U f. Trial CD, » C ? ' t O g. Revocation Hearings y n Z J Ca T h. Juvenile Hearings i. Appeals Court 19A. TOT N RT$CMP. 4 Other (Specify on additional sheets) TOTAL HOURS X $55 PER HOUR - $ 20. a. Interviews and conferences Multiply rate per ho ur times total U. .- b. Obtaining and reviewing records hours. Enter total " compensation belo Out of Court" w. O ? c. Legal research and brief writing 33 0 d. Investigative and other work (Specify on additional sheets) 20A. TOTAL OUT F COURT COMP. TOTAL HOURS = I X $45 PER HOUR 3 $ S 5 21. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM Mileage $ per mile x w Please contact Court Administrator for current mileage rate 0 21 A TOTAL ITEMI ED EXP. a 22. CERTIFICATION OF ATTORNEY/PAYEE Has compensation and/orr imburaement for work In this case previously, een ap Ila fob? L9?YES 23. GRAND TOTA -s CLAI,LNED GV` `//) If id? Q YES ? NO If ? H h? h ? L yes, were you pa ow muc yes, byw om were you paid Has the person represented paid any money to you, or to your knowle W nyone else, In connection with the matter for 24. DEDUCT. PRIO R PYMTS. which you were appointed to provide representatlon ? YES NO It yes, give details on additional heets 3 $ 1 swear or affirm the truth or correctness- _ f Z -- 25: NET AMO NT LAIMED of the above statements Signature nomey/Payee Date m = 26.nI an 14 a rIO PAVMEN/ Signature of 0Date: 7 Judge \0, % 't ?? a 1 27. AMT. Al QV LjQ a $ D v COPY 1 - Mail to Court Administrator at completion of service Law Offices of Saidis, Sullivan & Rogers A PROFESSIONAL CORPORATION 26 WEST HIGH STREET LEMOYNE OFFICE CARLISLE, PENNSYLVANIA 1701.3 635 NORTH 12"111 STREET TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 SUITE 400 EMAIL: attorney@ssr-attorneys.com LEMOYNE, PA 17043 wwwssr-attorneys.com TELEPHONE: (717) 612-5800 FACSIMILE: (717) 612-5805 July 2, 2012 Sameer Stanley Our file# 81068 5880 x Invoice# 7556 EIN: 27-2700453 RE: Emilee Hartman and Harun Stanley Balance forward as of invoice dated June 4, 2012 Payments received since last invoice Accounts receivable balance carried forward DATE DESCRIPTION $225.00 $225.00 $0.00 06/08/2012 Receive and review letter from Attorney Hitchings 06/12/2012 Emails to and from Shelley of Attorney Gilroy's office; Office consultation with SMS 06/14/2012 Email from Shelley of Attorney Gilroy's office 06/14/2012 Receive and review letter from Attorney Gilroy's office 06/21/2012 Review file; Email to Conciliator Gilroy and Attorneys Holst and Hitchings 06/28/2012 Office conference with SMS:Telephone conference with Judge Ebert's staff, Voicemails to Attorneys Holst and Hitchings 06/28/2012 Receive and review Order TOTALS HOURS 0.20 0.30 0.20 0.20 0.60 0.20 0.20 1.90 $85.50 ,WYER MS MH MH MS MS SU0088 , GAL Billing Summary Total professional services Total of new charges for this invoice Total balance now due * * Trust account remaining balance is $0.00 Invoice# 7556 Page 2 $85.50 $85.50 $85.50 PRIVACY POLICY: During this firms representation of you, we may receive nonpublic, personal information from from sources about you. It is our policy and practice that our attorneys and staff do not at any time reveal informatio to our representation of you unless you consent after consultation, except for disclosures that are impliedly authorize out the representation, and except for disclosures required or authorized by the Pennsylvania Rules of Professional C you or relating to carry Interest at 1 1/2% per month on unpaid balance after 30 days. 0 7 2012 AUTHORITY TO PAY COURT APPOINTED COUNSEL 1. COURT i 1< 2. VOJCHER i?j _ 14631 ? Distr ct Justice 9 ommon Pleas ? Appellate ? Other 3. FOR (D.J - DELLATE) 4. A CITY FATE) N BUDGET CODE 6. IN E CASE OF 7. CHARGE/OFFENSE ( URDON CITATION) 8. C PETTY OFFENSE vs Lfk r O FELONY O MISDEMEANOR 9. PROCEEDINGS (D scribe briefly) 11. PERSON REPRESENTED t 11(1 DOCKET NO. 1 ? Defendant - Adult / -7 Q 1/{ / • S / I 2 ? Defendant - Juvenile G -? J U ?AL 3 ? Appellant 13. CRIMINAL DOCKET NO 4 ? Appellee 5 ? Habeas Petitioner 6 ? Material Witness 10. PERSON REPRESENTED (Full Name) 1 ? Parolee Charged With Violation 9 ? Probationer Charged With Violation 14. APPEALS DOCKET NO. MOM ?S?Mleq 9 K Other ? hil' _/ ' 16. NAME OF ATTORNEY/PAYEE AND Appt Date MAILING ADDRESS A( i-SI S 1"Van if wogef-3 2. w? H-` h Si - NAME OF COMMON PL AS JUDGE ASSIGNED TO CASE 11013 17. T PHON No - Z22 18. SOCIAL SECURITY NO OR Ew NO Z-7 - Z CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES AMOUNTS CLAIMED a. Arraignment and/or Plea Multiply rate per hour times total h i " C "i b. Preliminary Hearing com- ours to obta n ourt n pensadbll. EV totaTbelow, c. Motions and Requests r- , N il- d Bail Hearings r .. ?, f.y..lt r3 :3 e. Sentence Hearings I ? ? c:7 2 n z f. Trial 01 A CD g. Revocation Hearings -fir" = 1 h. Juvenile Hearings C5 "O C:)? :3r, 4. I. Appeals Court 19A. 7W IN ?QUR II P. 2 C •, N Other (Specify on additional sheets) J;7- - $ C3 r TOTAL HOURS = X $55 PER HOUR 20. a. Interviews and conferences Multiply rate per hour times total " " b. Obtaining and reviewing records hours. Enter total Out of Court compensation below. O 2 0 c. Legal research and brief writing H O 0 d. Investigative and other work (Specify on additional sheets) 201. TOTAL OUT OF COURT COMP. TOTAL HOURS = 1 1 X $45 PER HOUR = $ V V (VV/ 21. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM Mileage $ per mile x 6 W Please contact Court Administrator for current mileage rate ? F 21A. TOTAL ITEMIZED EXP. O a $ 22. CERTIFICATION OF ATTORNEY/PAYEE /' Has compensation and/orimbureement for work in this case previous an ap led for? (311ES ? NO -72 t 23. GRAND TOTAL CLAIMED =$ r If yes, were you paid? B YES ? NO If yes, by How much? • whom were you paid? - 24• DEDUCT. PRIOR PYMTS. Has the person represented paid any money to you, or to your knowledge anyone elseArt connection with the matter for a $ which you were appointed to provide representation? ? YES "0 If yes, give details on additional sheets 1 swear or affirm the truth or correctness 25: NET AMOUNT CLAIMED above statemen ts of, he Signature of A sy/Pay Date O " L nuvt a )1 ME ( ature of S gn J d Date: 27. AMT. APPROVED $ N u ge Copy 1 - Mail to Court Admihist4tor at completion of service . / , ? . Law Offices of Saidis, Sullivan & Rogers A PROFESSIONAL CORPORATION LEMOYNE OFFICE 635 NORTH 12-I'll STREET SUITE 400 LEMOYNE, PA 17043 TELEPHONE. (717) 612-5800 FACSIMILE: (717) 612-5805 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 1701.3 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: attorne)T@ssr-attorneys.com www.ssr-attorneys.com August 2, 2012 Sameer Stanley x RE: Emilee Hartman and Harun Stanley Balance forward as of invoice dated July 2, 2012 Payments received since last invoice Accounts receivable balance carried forward DATE DESCRIPTION REPLY TO CARLISLE Our file# 81068 5880088 Invoice# 8035 EIN: 27-2700453 $85.50 $85.50 $0.00 06/29/2012 Voicemail from Attorney Hitchings; Telephone conference with Attorney Holst 07/02/2012 Prepare Motion to Continue 07/11/2012 Review Order of Court 07/16/2012 Receive and review letter from Attorney Holst TOTALS HOURS LAWYER 0.20 DMH 0.50 DMH 0.10 SMS 0.10 SMS 0.90 $40.50 •S88WR8 GAL Invoice4 8035 Page 2 Billine Summarv Total professional services $40.50 Total of new charges for this invoice $40.50 Total balance now due $40.50 * * Trust account remaining balance is $0.00 PRIVACY POLICY: During this firms representation of you, we may receive nonpublic, personal information from you or from sources about you. It is our policy and practice that our attorneys and staff do not at any time reveal information relating to our representation of you unless you consent after consultation, except for disclosures that are impliedly authorized to carry out the representation, and except for disclosures required or authorized by the Pennsylvania Rules of Professional Conduct. Interest at 1 1/2% per month on unpaid balance after 30 days. HARUN ALRISHID STANLEY, : IN THE COURT OF COMMON PLEAS Pla~iatlff : CUMBERLAND COUNTY, PENNSYLVAr v. :CIVIL ACTION -LAW n • ~ ..... EMILEE JEAN HARTMAN, : N0.2009-2388 ~, Defendant : IN CUSTODY ~r~ r ..~ Z Q PRAECIPE TO WITHDRAW APP~AR~NCE ~~ -,- TO THE PROTHONOTARY: -~'~ ~' Please withdraw the appearance of Joseph Hitchings, Esquire as a representative for Defendant, Emilee Jean Hartman. Dater jp -! ~, oseph itchings, Attorney ID #65551 5000 Ritter Road, STE 202 Rossmoyne Business Center Mechanicsburg, PA 17055 PRAECIPE TQ ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Melanie L. Erb, Esquire in the above referenced matter the Defendant, Emilee Jean Hartman, per her request. Date: / 02 Respectfully Submitted, ani i rb Attorney ID # 84445 2132 Market Street Camp Hill, PA 17011 (717}975-9446 -~-~ Melanie L. Erb, Esquire 2132 Market Street Camp Hill, PA 17011 717-975-9446 Merb(a~dpl lag„w.net HARUN ALRISIIIID STANLEY, Ptalnnff vs. EMILEE JEAN HARTMAN Defendant ?O~z ~~~ ~ ~~ rAk ~ 5 aM 11: s~ CU .: ~~~ ~~ 1'~V,~~li,~ . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, FL~NNSYLV. CIVIL ACTION -LAW N0.2A09-2388 IN CUSTODY CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date, a true a correct copy of the Order was served by first class mail upon the following: Sean M. Shultz, Esquire 4 Irvine Row Carlisle, PA 17013 GAL Date: / a- e b Melanie L. Erb, Esquire 2132 Mazket Street Camp Hill, PA 17011 717-975-9446 Merb( dplglaw.net HARUN ALRISHID STANLEY, Plaintiff vs. EMILEE JEAN HARTMAN Det'cndsnt f =~' ~~ rr~~ ~~or~to~ro ~- . ~F~ r zol~ auc ~ s an ~~: 56 LVA~t1A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV. CIVIL ACTION -LAW N0.2~09-2388 IN CUSTODY CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date, a true a correct copy of the Order was served by first class mail upon the following: Jessica Holst, Esquire 401 East Louther Street, Suite # 103 Cazlisle, PA 17013 Attorney for Plaintiff Date: ~~~~ . r HARUN ALRISHID STANLEY, Petitioner` vs. EMILEE JEAN HARTMAN, Defendant _ _ _ ~ __ _ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-2388 CIVIL TERM I . CUSTODY/VISITATION ANSWER TO DEFENDANT'S MOTION FOR CONTINUANCE Harun Stanley, (hereinafter, Father) by acid through his counsel, MidPenn states the following: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. ~~ N ~' C ~ ~ C!h N ~~ ~ .C~ s„ ~' c~ 3 zc,~ ~. ~ o ~~ -~ -~ --c 5. Admitted. Father's counsel received a Praecipe to Enter Appearance on or about August 15, 2012. 6. Father is without sufficient information to either admit or deny this allegation. l i 7. Fathet~ is without sufficient information to either admit or deny this allegation. 8. Deniefd as stated. Father does not disagree that the child should continue in counseling and other appropriate treatment but a primary concern for Father is that Mother elected to change the child's counseling program and move the child to a program in Lancaster which effectively prohibited Father from the active involveme he had while the child was getting counseling and treatment in Harrisburg. A furthe delay in this hearing will continue to negatively impact Father's role in the child's treatment and counseling. '-'~ "~ 'tam ~~ C7 --n c, ~'r-; ...K b _ __ _ _ _ 9. As this is a statement of request, Father has no response other than to note that at nd~ time has Father's counsel been contacted regarding this request for a continuance aid in light of the situation and the ongoing concern for the child's well-being, Father unable to agree to continue this matter. WHEREFORE, Father respectfully requests that this Court deny Defendant's Motion for Continuance and allow this matter to proceed on September 5, 2012 at 1:30 p.m. Respec submitted, ess' olst, Esquire Mid enn Legal Services 401 East Louther Street Carlisle, PA 17013 (717)243-9400 _ _ ,_ HARUN ALRISHID STANLEY, Petitioner vs. EMILEE JEAN HARTMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-2388 CIVIL TERM CUSTODY/VISITATION CERTIFICATE OF SERVICE I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for Petitioner, Harun Stanley, hereby certify that I have served a copy of the forgoing Petition for Contempt and Modifical by: LISPS First Class Mail. Certified Mail. Electronic Receipt Reauested• Melanie Erb, Esquire 2132 Market Street Camp Hill, PA 17011 Sean Shultz, Esquire 26 West High Street Carlisle, PA 17013 Date: ~~2~~11-- Jessica o st, Esquire MidPe Legal Services 401 East Louther Street Carlisle, PA 17013 (717)243-9400 HARUN ALRISHiD STANLEY, '~ Plaintiff v. EMILEE JEAN HARTMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2009-2388 IN CUSTODY ORDER AND NOW, this _ ~ ~~~ day of , 2012, based upon the Motion of Defendant, Emilee Jean Hartman, the hearing presently scheduled for September 5, 2012 is hereby continued to the ~1 ~ day of .~C('r~~ , 2012 at ~: ~s ~M. in Courtroom Number a-- BY THE COURT: ~~ --t -C J. c c ~~i7' ~;Z r v x .i N -~ 3 C«J c -,; Distribution: / Melanie L. Erb, Esquire, 2132 Market Street, Camp Hill, PA 17011b~ / Jessica Holst, Esquire, 401 East Louther Street, Suite #103, Carlisle, PA 17013 ~' Sean M. Shultz, Esquire, 26 West High Street, Carlisle, PA 17013 o~t- ~' ~~ cs h~a.` I ~d R/.~~~ ~ ~L "-~ ~ '"a'! n'! ~,~; ~; j'T i .~i -+c~ -~ ~' -°' C"'7 ~, -~ ~,-, AUTHORITY TO PAY COURT APPOINTED COUNSEL ld~V Q 9 ~n» 1. COURT ~~ ~~ ^ Di t i t J ti t 2. VOUCHER N~ 4 6 5 ~ r s c us ce YCommon Pleas ^ Appellate ^ Other 3. FOR (D.J., C.P., APP LA ) 4. (CITY/ jAT 5. BUDGET CODE r ~` '~ 0~ 6. I T E CASE OF t 7. CHARGE/OFFENS (PURDON CITATION) 8. ^ PETTY OFFENSE vs Tom' Irnl.- ^ FELONY ^ MISDEMEANOR 9. PROCEEDINGS (D tribe briefly) 1 1. PERSON REPRESENTED 12. CIVIL DOCKET NO. t ^ Dslsndant-Adult ',t t/ ~ 2 O Defendant-Juvenile -~ ~ J y ~ ~ ^ Appellant 13. C~INAL~DO~EET NO ' ` a ^ gppellee 5 ^ NaDeas Petitioner ~ r,,,-y 6 ^ Material Wdness l ti P l h With Vi ~,~y ~- ~`' _°' ~ 10. PERSON REPRESENTED (Full Name) r ~ /~ ~ s~ on arged aro o a 7 ^ ee C e ^ Probationer Charged ith violation 9 ~ Other. ~~i ~ ~ i (J 14 AL9~DOCAO. N~ O .r31YJ ~-~ ~ ,. V IM i ~ ~. `) ~ O (/ I I1 16. NAME OF ATTORNEY/PAYEE AND ~%" ("'; ~ -+~- -- ~7;' G M (LING ADDRESS ' C Appl Oate ~~ ~ ~ .~ r I NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE Ca l~", Jas ~ ~~- j`J 13 , r V 17. TE1,E~ ~ ~NE o. ~~ ~, "1 '' 18. sOC~'~s~C~u'aITV NO OF EiN NO L ~ CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES AMOUNTS CLAIMED a. Ar-signment and/or Plee Multiply rate per hour times total b. Preliminary Healing penaation~Entler totaCberto~com- a Motions and RsVuests a. , t- d Bail Hearings c 'O e. Sentence Hearings -~- --. ~~ ~ j ; ~" "' 1 C Z f. Trial g. Revocation Hesrinpa = ~ - ~Ti h. Juvenile Hearings ?° ' -~- - -_ i. Appeals CouR 19 ~`_1'AL 1 C T COMP,r i 4 Other (Specify on additional sheets) !"? . ~ r~~~ ~, z N TOTAL HOURS a X $55 PER HOUR ~ . W `~ ~ 20. a. Interviews and conferences Multipy rate par hour times total " " b- Obtaining and reviewing records hours. Enter total Out of CouR compensation below. ~ ¢ 7 G Legat research and txiet writing H ~ ~ d. Investigatlve and other work (Specify on additional sheets) 200. TOTAL OUT OF COURT COMP. TOTAL HOURS = X $45 PER HOUR § ' / /1~ ~~ lX 2t. ITEMIZATION OF REIMBURSABLE EX PENSES AMT. PER ITEM Miles $ er mile x w Please contact Court Administrator for current mileage rate ~ 210. TOTAL ITEMIZED EXP. O a s 22. CERTIFICATION OF ATTORNEY/PAYEE 23. GRAND TOTAL CLAIMED Has compensation and/or~r imburasment for work In this ease provlou sn ap Iled fot? t3~ES ` ~ C ~ = s How muchl__ Ifyes.wereyoupaid? i~YES ^ NO Ifyes,bywhomwereyoupsid? L 1..L_tJ.(/ 24 DEDUCT. PRIOR PYMTS. Has the person represented paid any money to you, or to your knowle~ anyone else, n connection with the matter for S a which you were aDDOinted to provide representatlon7 ^ YES ~tVO If yes, give details on additional sheets I swear or affirm the truth or correctness ~-+/~w 4~l' 1/ 1 ~ ~ ~~ ~- 25: NET AMO N7 Ct.A1MED of the above statements Slgnaturo of A ntsy/Pays Oata = s 26.nr•vr~uvtu FUrr Signature of 27. AMT. APPROV , ~' ~ ( r'AVMENr Judge - Date: m s Copy 1 -Mail to Court Administrator at completion of service ' ,~1 r LEMOYNE OFFICE 635 NORTH 12~~+ STREET SUITE 400 LEMOYNE, PA 17043 TELEPI-IONS: (717) 612-5800 FACSIMILE: (717) 612-5805 Law Offices of Saidis, Sullivan & Rogers A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-6222 -FACSIMILE: (717) 243-6486 EMAIL: attorney@ssr-attorneys.com ww~cssr-attorneys. com REPLY TO CARLISLE November 2, 2012 Sameer Stanley X RE: Emilee Hartman and Harun Stanley Our file# 81068 5880088 Invoice# 9334 EIN: 27-2700453 Balance forward as of invoice dated September 4, 2012 $45.00 Payments received since last invoice $45.00 Accounts receivable balance carried forward $0.00 DATE DESCRIPTION HOURS 09/07/2012 Receive and review Order rescheduling Hearing 0.20 09/11/2012 Receive and review letter from Attorney Holst 0.20 10/19/2012 Telephone conference with Todd Johnson of PA 0.40 Counseling TOTALS 0.80 AMOUNT LAWYER $9.00 SMS $9.00 SMS $18.00 SMS $36.00 ~S88rJ088 GAL Invoice# 9334 Page 2 Billing Summary Total professional services Total of new charges for this invoice Total balance now due ** Trust account remaining balance is $0.00 $36.00 $36.00 $36.00 PRIVACY POLICY: During this firms representation of you, we may receive nonpublic, personal information from you or from sources about you. It is our policy and practice that our attorneys and staff do not at any time reveal information relating to our representation of you unless you consent after consultation, except for disclosures that are impliedly authorized to carry out the representation, and except for disclosures required or authorized by the Pennsylvania Rules of Professional Conduct. Interest at 1 112% per month on unpaid balance after 30 days. V HARUN ALRISHID STANLEY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-2388 CIVIL TERM EMILEE JEAN HARTMAN, Defendant :CUSTODY nR DF.R AND NOW, this day of, 2013, upon consideration of the attached STIPULATION FOR ENTRY OF CUSTODY ORDER, it is hereby ordered that the terms and conditions of the stipulation are hereby made an order of this Court. By the Court, M.L. Ebert, Jr., Judge G Distribution: Jessica Holst, Esquire, MidPenn Legal Services, 401 East Louther Street, Suite 103, Carlisle, PA 17013 Melanie L. Erb, Esquire, 2132 Market Street, Camp Hill, PA 17011 - ?? - -I r Sean M. Shultz, Esquire, 26 West High Street, Carlisle, PA 17013~r ?rv k'? c: ' _ AUTHORITY TO PAY COURT APPOINTED COUNSEL 4 A2R n gftp 1.COURT 2.VOUCHER 0 District Justice Wo'Common Pleas 0 Appellate 0 Other �10 14874 3.FOR(D.J.,C.P.APPELLATE) 4.AT�ITY/STtTE) 5.BUDGET CODE � - P . — '� )'e. =-/SIC)-/0-4&-wey 6.IN"CASE OF T.CHARGE/OFFENSE(PUROON CITATION) S. 0 PETTY OFFENSE 9.PROCEEDINGS(Detcribe briefly) 11.PERSON REPRESENTED 12.CIVIL DOCKET NO. 6rAL 4 0 Appellee 13.CRIMINAL DOCKET NO, 5 0 Habeas petitioner 6 (3 material witness 7 0 Parolee Charged With Violation 10.PERSON REPRESENTED(Full Name) 8 0 Probationer Charged With Violation 14.APPEALS DOCKET NO. 6 16.NAME OF ATTORNEY/PAYEE AND Apol Date MAILING ADDRESS LIM S vo I-M 'e NAME OF COMMON PLE JUDGE ASSIGNED TO CASE 00)T60S 17.T L PHONE No. 18. SOCIALSECURIT CLAIM FOR SERVICES OR EXPENSES 19. StRVICE HOURS DATES _.AMQ1JNTS1CLAIMED a. Arraignment and/or Islas Mu refoor hour times total vr b. Preliminary Hearing ;ft,com A -Tow. c. Motions and Riliqueaft =M -0 r— CD 0. Sentence meetings g, Revocation Hearings C) h. Juvenile Hearings L Appeals Court 19A.14TALCM CCOT COMP. Other(Specify on additional shoots) TOTAL HOURS X$55 PER HOUR $ 20. & Interviews and conference* Multiply rate per hour times total hours.Enter total"Out of Court" U. b. Obtaining and reviewing records compensation below. 0 c. Legal research and brief writing 0 d.Invissitgadve 6-4 other work(Specify an additional shoots) 20A. TOTAL OUT OF COURT TOTAL X$45 PER HOUR $ HOURS T It, fD mile x Plows contact Court Administrator for current mileage rate 21 A. TOTAL ITEMIZED EXP. 22.CERTIFICATION OF ATTORNEY/PAYEE 23. GRANDIALC E 0 If yes.were you paid? erYES ONO Ityssbywhoo"weroyoupe How much? - - A — W '� 2 .DIEDUCT.PRIOR PYIIIITS. Has the person represented paid any money to yotk or to your knowl fluryonal elm In connection with the matter for $ which you were appointed to provide hipresentatfq�? 0 YES,;NO If yes.=91ve details on addilionall to I swear or affirm the truth or correctness 25,-MET AIAO)Jgf CLAIIIIIIIED of the above statements signature of%homay/payse, Date $ PA 00 Date: 26.APPROVt is of Copy 1 -Mail to Court Administrator at completion of service Law Offices of Saidis, Sullivan & Rogers A PROFESSIONAL CORPORATION 26 WEST HIGH STREET LEMOYNE OFFICE CARLISLE,PENNSYLVANIA 17013 635 NORTH 12TH STREET TELEPHONE: (717) 243-6222-FACSIMILE: (717) 243-6486 SUITE 400 EMAIL: attorney@ssr-attorneys.com LEMOYNE,PA 17043 WNVW.ssr-attorneys.com TELEPHONE: (717)612-5800 FACSIMILE: (717) 612-5805 REPLY TO CARLL5U March 4,2013 Sameer Stanley Our file# 81068 S880088 x Invoice# 11184 EIN: 27-2700453 RE: Emilee Hartman and Harun Stanley Balance forward as of invoice dated January 4,2013 $108.00 Payments received since last invoice $108.00 Accounts receivable balance carried forward $0.00 DATE DESCRIPTION HOURS AMOUNT LAWYER 01/11/2013 Email exchange with Attorney Hoist regarding 0.20 $9.00 SMS status of agreement and order 02/11/2013 Letter to Attorney Hoist 0.20 $9.00 DMH TOTALS 0.40 $18.00, Billing Summary Total professional services $18.00 Total of new charges for this invoice $18.00 Total balance now due $18.00 ** Trust account remaining balance is $0.00 PRIVACY POLICY: During this firms representation of you,we may receive nonpublic,personal information from you or from sources about you. It is our policy and practice that our attorneys and staff do not at any time reveal information relating to our representation of you unless you consent after consultation,except for disclosures that are impliedly authorized to carry out the representation,and except for disclosures required or authorized by the Pennsylvania Rules of Professional Conduct. Interest at 1 1/2%per month on unpaid balance after 30 days. AUTHORITY TO PAY COURT APPOINTED COUNSEL MAY 13 2W 1.COURT 2.VOUCHER 14872 ❑ District Justice &-common Pleas 0 Appellate 0 Other N2 3.FOR(D.J.,C.P.,APPEL TE)p 4.AT( ITY/ST TE 5.BUDGET CODE Pa & THE C E OF 7.CHARGE/OFFENSE`(PURDON CITATION) 8. ❑ PETTY OFFENSE vs 11MAY 4 ❑ FELONY❑MISDEMEANOR 9.PROCEEDING (Describe briefly) 11.PERSON REPRESENTED 12.CIVIL DOCKET NO. ❑ Defendant-Adult ❑ Defendant-Juvenile di— Z579 A L 3 0 Appellant 13.CRIMINAL DOCKET NO. 4 ❑ Appellee 5 0 Habeas Petitioner 6 ❑ Material Witness 7 ❑ Parolee Charged With Violation 10,PERSON REPRESENTED(Full Name) a ❑ Probationer Charged With Violation 14.APPEALS DOCKET NO. IMP& &W64 9 4 Other. NIrjd 0 16.NAME OF ATTORNEY/PAYEE AND Aoot Date ,V ))81 MAILING ADDRESS K I L. E"b,—r4 �,Tr/ I Qi-obs 's V(114 VaA Ter6 NAME OF COMMON PLEA JUDGE ASSIGNED TO CASE o w,s vlt� 1-703 17,TELEPHON E No. 18. SOCIAL SECURITY NQ PA E IN NO CLAIM FOR SERVICES OR EXPENSES 19. SERVICE HOURS DATES i4MO(INTS CUAIMED a. Arraignment and/or Pies !M0 P rate�r h(W times total o o=n "I d'o"" corn. t ow. b. Preliminary Hearing on.Smer t0l Pot c. Motions and Requests r -a r1 t I.- d. Sail Hearings r.) CD M :) le. Sentence Hearings 0 Zf. Trial g. Revocation Hearings C: to h. Juvenile Hearings ;;I_, -4 Ir-n i.Appeals Court 19A3OTAf TN COURT COMP. Other(Specify on additional sheets) TOTAL HOURS X$55 PER HOUR 20. a Interviews and conferences Multiply rate per hour times total hours. Enter total"Out of Court" LL 1b.Obtaining and reviewing records compensation below. 0 c. Legal research and brief writing �-M D 0 d.Investigative and other work(Specify on additional sheets) 20A. TOTAL OUT OF COURT 0 U COMP. TOTAL HOURS= f L4 X$45 PER HOUR =S 21. ITEMIZATION OF REIMBURSABLE EXPENSES AMT PER ITEM Mileage$ per mile x w Please contact Court Administrator for current mileage rate z 1- 21A TOTAL ITEMIZED EXP. 0 =$ 22.CERTIFICATION OF ATTORNEY/PAYEE 23. GRAND TOTAL CLAIMED 6, OV Has compensation and/0 for work In this case previciusyheel ap lied for? 0 YES ❑ NO $ It yes,were you paid?and/or ❑ NO Ifyea.by whom were you paid? Howmuch? I IM Has the person represented paid any money to you,or to your knowled els in connection with the matter for 24.DEDUCT.PRIOR PYMTS- go anyone which you were appointed to provide representation? ❑ YES 001NO If yes.give details on additional sheets I swear or affirm the truth or correctness -7/if-K 25.'NETAMO NT CLAIMED of the above statements Signature of Attorney/Payee Date S 7f. ('I Signature 27.AMT.APPROVED PAYMENT I Judge Iii Date: 21�1 14113 $ I 8-,9-P 26.APPROVE r6 got Copy 1 -Mail to Court AdministAtor at completion of service Law Offices of Saidis, Sullivan & Rogers A PROFESSIONAL CORPORATION 26 WEST HIGH STREET LEMOYNE OFFICE CARLISLE, PENNSYLVANIA 17013 635 NORTH 12114 STREET TELEPHONE: (717) 243-6222- FACSIMILE: (717) 243-6486 SUITE 400 EMAIL: attorney@ssr-attorneys.com LEMOYNE,PA 17043 www.ssr-attorneys.coin TELEPHONE: (717)612-5800 FACSIMILE: (717) 612-5805 REPLY TO CARLISLE May 2,2013 Sameer Stanley Our file# 81068 S880088 X Invoice# 11810 EIN: 27-2700453 RE: Emilee Hartman and Harun Stanley Balance forward as of invoice dated March 4, 2013 $18.00 Payments received since last invoice $18.00 Accounts receivable balance carried forward $0.00 DATE DESCRIPTION HOURS AMOUNT LAWYER 03/26/2013 Leave voicemail for Emily Hartman 0.20 $9.00 DMH 03/26/2013 Receive and review message from Harun Stanley; 0.20 $9.00 SMS Leave message for Attorney Holst TOTALS 0.40 $18.00 Billing Summary Total professional services $18.00 Total of new charges for this invoice $18.00 Total balance now due $18.00 Trust account remaining balance is $0.00 PRIVACY POLICY: During this firms representation of you,we may receive nonpublic,personal information from you or from sources about you. it is our policy and practice that our attorneys and staff do not at any time reveal information relating to our representation of you unless you consent after consultation,except for disclosures that are impliedly authorized to carry out the representation,and except for disclosures required or authorized by the Pennsylvania Rules of Professional Conduct. Interest at 1 1/2%per month on unpaid balance after 30 days.