The URL can be used to link to this page

Home My WebLink About04-2114 Jaime Lynn Leeper, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 04 -)./11..{ CIVIL TERM John Ivan Leeper, III, Defendant IN CUSTODY COMPLAINT FOR CUSTODY ]. The plaintiff is Jaime Lynn Leeper, residing at ] 05 Doub]ing Gap Road., Newville, Cumberland County, Pennsylvania] 7241. 2. The defendant is John Ivan Leeper, III, residing at 60 Renninger School Road, Middleburg, Snyder County, Pennsylvania 17842. 3. Plaintiff seeks custody of the following child: Name Zoe Ann Leeper Present Residence 105 Doubling Gap Newville P A 17241 DOB 3-16-01 Age 3 yrs, The child was not born out of wedlock 4, The child is presently in the custody of Jaime Lynn Leeper, residing at 105 Doubling Gap Road., Newville, Cumberland County, Pennsylvania] 724], During the past five years, the child has resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Jaime Leeper ] 05 Doubling Gap Rd. Newville, PA ]7241 2- 2004 to present John & Jaime Leeper 60 Renninger School Road Middleburg, PA 17842. birth to 2-2004 5. The mother of the child is Jaime Lynn Leeper, residing at 105 Doubling Gap Road., Newville, Cumberland County, Pennsylvania] 7241, She is married. The father of the child is John Ivan Leeper, III, residing at 60 Renninger School Road, Middleburg, Snyder County, Pennsylvania 17842. He is married, 6. The relationship of plaintiff to the child is that of mother, The plaintiff currently resides with the following persons, Name Nathan Edwards Relationship Boyfriend 7. The relationship of defendant to the child is that of father. The defendant currently resides with the following persons. Name Self Relationship 8. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 9. The best interest and permanent welfare of the child will be served by granting the relief requested because: Plaintiff has undertaken and performed the primary parental responsibilities for the child. Plaintiff is best able to provide the care and nurture which the child need for healthy development. A Court Order of custody and structured visitation is desired so that the Plaintiff and the child may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the child is not used in a manipulative fashion. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody subject to supervised visitation by the Defendant. Respectfully submitted, ROMINGER, BAYLEY & WHARE Date: {-/I~o'{ M(YjJ,~L ~JL . 155 S, Hanover Street Carlisle, PA 17013 (717) 24]-6070 Supreme Court J.D. # 89028 Attorney for Plaintiff VERIFICA nON I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. S 4904 relating to unsworn falsification to authorities. _ !ldm j ~ tflP-7 Ja~~ynn Leeplir, Plainti~ 1-~ ).J -- ~ ~~ ..0 ,/l.J 0' ~ "- "- ~ ~ Q0 r- ~ ~~ ~:; --I .-j. ., i~:~ ."-'!7! ".' \.~B ~ I~rl . (l < L) JAIME LYNN LEEPER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. 04-2114 CIVIL ACTION LAW JOHN NAN LEEPER, III DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, May 19, 2004 , 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 Conrthouse, Carlisle on Frid,.y, June 04, 2004 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. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 honrs prior to scheduled hearinjl. FOR THE COURT. By: Isl Hubert X. Gilroy. Esq. Custody Conciliator mhc 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 TIlE OFFICE SET FORTIl 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 - ~ ~~- '# .......... /";;:>iipzY LL-. , 27f" , -27 f!i"', ~ A r?- Iff'..y .~ JZ ~ ~k Ac?Or:':F ~ ~ ?~~ n ,A(/~,5' :,":':',':~,/ir'i8 AiM (i , ~s :2 \-1d 02 !,\,\\110UZ I""" :1' '1 dO ;.J\f\ (-'IN!~.'h.L'J(YJ _-In M "'''''-, ,', I 'r-(P 11-\ j.)i:,~.,-) .,-' ~ C' v ,llJI 0 8 2004 ~ JAIME LYNN LEEPER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLANlI> COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW JOHN IV AN LEEPER, III, Defendant NO. 2004 - 2114 IN CUSTODY COURT ORDER AND NOW, this \3ttdaY of July, 2004, UPOIli consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The mother, Jaime Lynn Leeper, shall enjoy primary legal and physical custody of Zoe Ann Leeper, born March 16, ;~001. 2. The father, John Ivan Leeper, III, shall enjoy periods of temporary physical custody with the minor child at such times aud under such circumstances as agreed upon by the parties. 3. This order is entered with the understanding that the father was not in attendance at the Custody Conciliation Conference. In the event the father desires to modify this order, he may fIle a petition with the Court to have this matter again referred back to the Custody Conciliator. BY THE COURT, cc: Michael J. Whare, Esquire John Ivan Leeper, III ~ ~ 7_/,/,0'/ (+, V;N\//\~l/.S,\jN~~jd I r I. '......-,,~. '-, '~';"""'~J r J~: I I: , i ,,! ;,...' ",", ".: , ;'''...''1...._.-.., ". .'._',_1.1 O~ :IIHIt 'JllnnaU2 tU-jvlONOi'{108d 3Hl :10 :J8i.i!(}-03lij JAIME LYNN LEEPER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v JOHN IV AN LEEPER, III, Defendant NO. 2004 - 2114 IN CUSTODY IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody COIIlciliator submits the following report: CONCILIATION CONFERENCE SUMMARY REPORT 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Zoe Ann Leeper, born March 16, 2001. 2. A Conciliation Conference was held on July 1, 2004" with the following individuals in attendance: Attorney Michael J. Whare, Esquire, attorney for the mother, Jaime Lynn Leeper. 3. Attorney Whare indicated that he had served the father with the petition and the father had recently been incarcerated. He also indicated that mother has custody of the child. 4. Based upon the above, the Custody Conciliator recommends and order in the form as attached. 7(;1 of! H{!;1~- Custody C ciiliator DATE JAIME LYNN LEEPER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04 - 02114 Civil Term JOHN NAN LEEPER, III, Defendant : ACTION IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW, comes Petitioner, John I. Leeper, III, by and through his counsel, John Mangan, Esquire, and petitions the Court as follows: 1. Jaime Lynn Leeper, (hereinafter referred to as "Respondent"), is the above-named Plaintiff, and is an adult individual currently residing at 648 Alexander Spring Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. John Ivan Leeper, III, (hereinafter referred to as "Petitioner") is currently residing at 302 Vermont Avenue, Burnham, Mifflin County, Pennsylvania 17009. 3. The parties are the natural parents of one child, namely, Zoe Ann Leeper, born March 16,2001. 4. The parties are subject to an Order of Court dated July 13, 2004, a copy of which shall be furnished to the conciliator at least 48 hour prior to the scheduled conciliation. 5. The current custody order provides that Respondent shall enjoy primary legal and physical custody of the child, Petitioner shall enjoy periods of temporary physical custody at such times and under such circumstances as agreed by the parties and that because the order was entered with the understanding that Petitioner did not attend the prior conciliation conference, Petitioner has the right to have this matter again referred to a custody conciliator for review. 6. The current custody order does not specify any specific schedule as to Petitioner's right of visitation with his child; Petitioner is requesting an order which would specifically set up a visitation schedule with his child so that the Parties may plan their schedules accordingly, so that misunderstandings and unmet expectations regarding custody can be avoided, and also so that the child is not used in a manipulative fashion. 7. The best interest and permanent welfare of the child will be served by granting the relief requested. 8. It is believed and averred that the best interest and permanent welfare of the child will be promoted by changes proposed in this custody petition. WHEREFORE, Petitioner requests the court to set a conciliation date to examine issues regarding custody of the child. Respectfully submitted, Date: S("Z P {tV(; Jo I. . No. 7000 35 E. High Street Carlisle, Pa. 17013 (717) 241-2446 Attorney For Petitioner .. Attornev Verifieation I, John J. Mangan, hereby verify that the facts contained within the foregoing documents associated with the petition for modification of custody order are true and correct to the best of my knowledge, information and belief and are made pursuant to 18 Pa.C.S. ~ 4904. relating to unsworn falsification to authorities. Date: 42y[erc. . Mangan rney for Petitioner . . .. CERTIFICATE OF SERVICE I, John J. Mangan, Esquire, attorney for Petitioner, do hereby certify that I this day served a copy of the Petition to Modify Custody Order upon the attorney of record for Respondent via hand delivery as follows: Date: s72t; ~ Michael Whare, Esquire 155 South Hanover Street Carlisle, P A 17013 JOM. g A ey, or Petitioner A me J.D. #87000 35 East High Street Suite 204 Carlisle, P A. 17013 717-241-2446 - ~ ~ () ~ = 0 ~ c <= ., -0;: c:r-- , ::r. :r" ~ ~ ;:;.. -< rn r= N -0 IT: ~qy () G'\ ~~$; \ u ~ " ~,... :~?) ... L.,> ;.:'5 n ---I ~ f:1> U1 ,:0 f'v -< I, ... JAIME LYNN LEEPER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 04-2114 CIVIL ACTION LAW JOHN IV AN LEEPER, III DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, June 02, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June 22, 2006 , the conciliator, at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearin2. FOR THE COURT. By: /s/ Hubert X Gilrov. Esq. Custody Conciliator f11l 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 HA VE 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 '" . rf ~ -II- --. ~ 4; f?JO. e/l ~("1 p .$ ~ ~v, 1cl,e.1 ~.4w ~~ ~ ~~ ~<7,.-e-? ~" ," '-"--,'Iln'" . 1'1"..,',...:........ ,. "'.-. i ,.1"",'::"-;"\ V l\..I.J"',\ ~!,: ' " " ".' i' ~ 20 :8~!d 2- tH\f 90al I u\'41'u"h::"i-i' \'".:,.\ 3111.:\0 ^O v. i \\...11 U... j....,..l~ , 381~i;:1()-03ll:l , RECEIVED JUN a ~1"1f)1 JAIME LYNN LEEPER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 04-2114 CIVIL ACTION - LAW JOHN IV AN LEEPER, III, Defendant : IN CUSTODY COURT ORDER AND NOW, this L day of J v--. c- , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's Order of July 13, 2004 is vacated and replaced with the following Order: 1. The Mother, Jaime Lynn Leeper, and the Father, John Ivan Leeper, III, shall enjoy shared legal custody of Zoe Ann Leeper, born March 16,2001. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy periods of temporary physical custody of the minor child as follows: A. On alternating weekends from Friday until Sunday the times for exchange to be agreed upon by the parties. B. At such other times as agreed. 4. Each party shall enjoy at least one week of vacation time during the summer months with the minor child subject to the party giving the other parent at least two weeks' notice. 5. The holidays shall be handled as follows: A. For Christmas, the Mother shall always have custody from Christmas Eve at noon until Christmas Day at noon, and the Father shall have custody of the minor child from Christmas Day at noon until December 26tb at noon. B. For Thanksgiving, the Father shall have custody during the day on Thanksgiving and return the child at approximately 5:00 p.m. to the Mother. C. Other major holidays shall be shared or alternated between the parties as they agree. BY THE COURT, Cc: John Mangan, Esquire "- Michael J. Whare, Esquire / (, -go -0& C6 i (.t>J .~ CPtf . n .-~ .~! . I j .):.: :(J ~", CS ;:::',,:~ SCOl . ~. ",:: .. ht)i..:..,I,), i1 =lU , JAIME LYNN LEEPER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 04-2114 CIVIL ACTION - LAW JOHN IVAN LEEPER, III, Defendant IN CUSTODY Prior Judge: The Honorable J. Wesley Oler, Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CML RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Zoe Ann Leeper, born March 16,2001 2. A Conciliation Conference was held on June 22, 2006 with the following individuals in attendance: The Mother, Jaime Lynn Leeper, with her counsel Michael J. Whare, Esquire Legal Counsel for the Father, John Mangan, Esquire The Father, John Ivan Leeper, III, did not appear 3. The parties agreed to the entry of an Order in the form as attached. Date: June ~ '1 , 2006 v JAIME LYNN LEEPER (n/k/a STALKER), : IN THE COURT OF COMMON PLEAS OF Respondent : : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2004-2114 CIVIL TERM • JOHN IVAN LEEPER, III, Petitioner : CUSTODY can4, - t 1 PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: - - Kindly allow John Leeper, III, Petitioner, to proceed in forma pauperis. I, Jessica Holst, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Jessie Tolst, Esquire MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 JAIME LYNN LEEPER (n/k/a STALKER), : IN THE COURT OF COMMON PLEAS OF Respondent : : CUMBERLAND COUNTY, PENNSYLVANIA C3 vs. : NO. 2004-2114 CIVIL TERM -n " eca ;.Y, •, rr! C) Pi --1 JOHN IVAN LEEPER, III, --r _ 1 Petitioner : CUSTODY ` . ,p PETITION FOR CONTEMPT Petitioner, John Leeper, by and through his counsel, MidPenn Legal Services, states the following: 1. Petitioner, hereinafter referred to as Father, resides at 504 East Freedom Avenue, Burnham, Mifflin County, Pennsylvania 17009. 2. Respondent, hereinafter referred to as Mother, resides at 1157 Easy Road, Carlisle, Cumberland County, Pennsylvania 17015. 3. The parties are the parents of the minor child, Zoe Ann Leeper,born March 16, 2001. 4. A Custody Order was entered on June 29, 2006,by The Honorable J. Wesley Oler, Jr. In pertinent part, the Order grants the parties shared legal custody. Mother has primary physical custody and Father has periods of partial physical custody on alternating weekends from Friday until Sunday at times to be agreed upon by the parties. (See Attached Exhibit A) 5. Mother is in contempt of the current custody order for the following reasons: a. Mother has not complied with the terms of the Custody Order and has determined when Father is permitted to have periods of custody. b. Mother does not respond to Father's telephone calls or text messages trying to confirm custodial exchanges. Most recently, Mother failed to respond to Father's attempts to confirm his custodial period until 24 hours later when Father had already started the drive to get Zoe for a weekend visit. c. Mother's deliberate refusal to allow Father's custodial periods of time as set forth in the Custody Order negatively impacts the father/daughter relationship. 6. Father resides with his fiancee and son in a home that he has had for 6-7 years and is fully capable of caring for Zoe for his periods of partial physical custody. 7. Father has tried to remain a consistent part of Zoe's life and has acquiesced to Mother's control over the custody schedule to keep the peace and get what time he could with Zoe. Mother's actions have continued to decrease Father's time with Zoe and he can no longer continue to allow the variances from the existing Custody Order. 8. Mother's actions reflect intentional steps to try to interfere with Father's relationship with Zoe regardless of the impact on her well-being. 9. Father is requesting that the parties comply with the terms of the June 29, 2006 Custody Order. 10. Counsel for Father is not able to reach Mother and it is believed that she would not concur with the relief requested. WHEREFORE, Father respectfully requests that this Court order the following: a. Mother is in contempt of the June 29, 2006 Custody Order b. This matter is scheduled for conciliation to address Mother's contempt. c. Until the conciliation conference, Mother must comply with the terms of the June 29, 2006 Custody Order and immediately allow Father to exercise his custodial weekend beginning the first Friday after the entry of this Order. d. Any other relief this Court finds just and proper. Respe t submitted, Jessi it olst, Esquire MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 VERIFICATION The above-named PETITIONER, JOHN IVAN LEEPER, III, verifies that the statements made in the above Petition for Contempt are true and correct. PETITIONER understands that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: /7 /3 i / Ij'N IVAN LE"PER, III EXHIBIT A • RECEIVED JUN 28 JAIME LYNN LEEPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA v : NO.04-2114 CIVIL ACTION-LAW JOHN IVAN LEEPER,III, : IN CUSTODY Defendant COURT ORDER AND NOW,this 2'It day of Tv-,a. ,2006,upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's Order of July 13,2004 is vacated and replaced with the following Order: 1. The Mother, Jaime Lynn Leeper, and the Father, John Ivan Leeper, III, shall enjoy shared legal custody of Zoe Ann Leeper,born March 16,2001. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy periods of temporary physical custody of the minor child as follows: A. On alternating weekends from Friday until Sunday the times for exchange to be agreed upon by the parties. B. At such other times as agreed. 4. Each party shall enjoy at least one week of vacation time during the summer months with the minor child subject to the party giving the other parent at least two weeks'notice. 5. The holidays shall be handled as follows: A. For Christmas, the Mother shall always have custody from Christmas Eve at noon until Christmas Day at noon, and the Father shall have custody of the minor child from Christmas Day at noon until December 26`'at noon. B. For Thanksgiving, the Father shall have custody during the day on Thanksgiving and return the child at approximately 5:00 p.m. to the Mother. C. Other major holidays shall be shared or alternated between the parties as they agree. BY THE COURT, "dfdr . I esley Oler ge Cc: John Mangan,Esquire % Michael J.Whare,Esquire / —10—O(o Cifi4.44 • JAIME LYNN LEEPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA : NO.04-2114 CIVIL ACTION-LAW JOHN IVAN LEEPER,III, : IN CUSTODY Defendant Prior Judge: The Honorable J.Wesley Oler,Jr. CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Zoe Ann Leeper,born March 16,2001 2. A Conciliation Conference was held on June 22,2006 with the following individuals in attendance: The Mother,Jaime Lynn Leeper,with her counsel Michael J.Whare,Esquire Legal Counsel for the Father,John Mangan,Esquire The Father,John Ivan Leeper,HI,did not appear 3. The parties agreed to the entry of an Order in the form as attached. Date: June DZ 1 ,2006 Hubert X.G' y,Esquire Custody Co dilator %-tra-tr Jaime Lynn-bee} : IN THE COURT OF COMMON PLED S OF Plaintiff : CUMBERLAND COUNTY, PENNSYYVAIA •• rrl CD ca vs. : NO. 2004 - 2114 cnilLtEklm 'y' • John Ivan Leeper, III Defendant : CUSTODY CRIMINAL RECORD/ ABUSE HISTORY VERIFICATION I John Leeper, III , hereby swear or affirm, subject to penalties of law including 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities that: 1. Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or pled no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act,42 Pa.C.S. § 6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check Crime Self Other Date of conviction, Sentence all that household guilty plea, no apply member contest plea or pending charges ❑ 18 Pa.C.S. Ch. 25 ❑ ❑ (relating to criminal homicide) ❑ 18 Pa.C.S. § 2702 ❑ ❑ (relating to aggravated assault) ❑ 18 Pa.C.S. § 2706 ❑ ❑ (relating to terroristic threats) ❑ 18 Pa.C.S. § 2709.1 ❑ ❑ (relating to stalking) Check Crime Self Other Date of conviction, Sentence all that household guilty plea, no apply member contest plea or pending charges ❑ 18 Pa.C.S. § 2901 ❑ ❑ (relating to kidnapping) ❑ 18 Pa.C.S. § 2902 ❑ ❑ (relating to unlawful restraint) ❑ 18 Pa.C.S. § 2903 ❑ ❑ (relating to false imprisonment) ❑ 18 Pa.C.S. § 2910 ❑ ❑ (relating to luring a child into a motor vehicle or structure) ❑ 18 Pa.C.S. § 3121 ❑ ❑ (relating to rape) ❑ 18 Pa.C.S. § 3122.1 ❑ ❑ (relating to statutory sexual assault) ❑ 18 Pa.C.S. § 3123 ❑ ❑ (relating to involuntary deviate sexual intercourse) ❑ 18 Pa.C.S. § 3124.1 ❑ ❑ (relating to sexual assault) Check Crime Self Other Date of conviction, Sentence all that household guilty plea,no apply member contest plea or pending charges ❑ 18 Pa.C.S. § 3125 ❑ ❑ (relating to aggravated indecent assault) ❑ 18 Pa.C.S. § 3126 ❑ ❑ (relating to indecent assault) ❑ 18 Pa.C.S. § 3127 ❑ ❑ (relating to indecent exposure) ❑ 18 Pa.C.S. § 3129 ❑ ❑ (relating to sexual intercourse with animal) ❑ 18 Pa.C.S. § 3130 ❑ ❑ (relating to conduct relating to sex offenders) ❑ 18 Pa.C.S. § 3301 ❑ ❑ (relating to arson and related offenses) ❑ 18 Pa.C.S. § 4302 ❑ ❑ (relating to incesti ❑ 18 Pa.C.S. § 4303 ❑ ❑ (relating to concealing death of child) Check Crime Self Other Date of conviction, Sentence all that household guilty plea, no apply member contest plea or pending charges ❑ 18 Pa.C.S. § 4304 ❑ ❑ (relating to endangering welfare of children) ❑ 18 Pa.C.S. § 4305 ❑ ❑ (relating to dealing in infant children) ❑ 18 Pa.C.S. § 5902(b) ❑ ❑ (relating to prostitution and related offenses) ❑ 18 Pa.C.S. §5903(b)/(d) ❑ ❑ (relating to obscene and other sexual materials and performances) ❑ 18 Pa.C.S. § 6301 ❑ ❑ (relating to corruption of minors) ❑ 18 Pa.C.S. § 6312 ❑ ❑ (relating to sexual abuse of children) ❑ 18 Pa.C.S. § 6318 ❑ ❑ (relating to unlawful contact with minor) ❑ 18 Pa.C.S. § 6320 ❑ ❑ (relating to sexual exploitation of children) A Check Crime Self Other Date of conviction, Sentence all that household guilty plea, no apply member contest plea or pending charges ❑ 23 Pa.C.S. § 6114 ❑ ❑ (relating to contempt for violation of protection order or agreement) �� new, d'n el *or b* t',-1 ❑ Driving under the ❑ atoq 0,,Aiffth influence of drugs or alcohol ❑ Manufacture, sale, ❑ 1 a v< #At ire delivery,holding, offering for sale or possession of any controlled substance or other drug or device 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check Self Other Date all that household apply member ❑ A finding of abuse by a Children & ❑ ❑ Youth Agency or similar agency in Pennsylvania or similar statute in another jurisdiction ❑ Abusive conduct as defined under the ❑ ❑ Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction 1 T Check Self Other Date all that household apply member ❑ Other: ❑ ❑ 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child: 5. If you are aware that the other party or member of the other party's household has or have a criminal/abuse history, please explain: I verify that the information above is true and correct to the best of my knowledge, information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §.4904 relating to unsworn falsification to authorities. ,(ature el Printed Name JAIME LYNN LEEPER N/K/A STALKER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA) V. 2004-2114 CIVIL ACTION LAW JOHN IVAN LEEPER, III IN CUSTODY "7 DEFENDANT rr CZ ORDER OF COURT c: ,4 r. cx AND NOW, Wednesday,October 09,2013 , 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,November 07,2013 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. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in-person contact with the court(including, but not limited to, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P.No. 1915.17 regarding relocation. FOR THE COURT, By: /8/ Hubert X. Gilroy, Esq.,/N i Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with isabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled dividuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior 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 -TORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT -IERE YOU CAN GET LEGAL HELP. 1 f:S t L L Cumberland County Bar Association 32 South Bedford Street ►�„("cA L.€? 4 S „ s, Carlisle, Pennsylvania 17013 Telephone (717)249-3166 1f N• OLT 1 41 43 2/l t � JAIME LYNN STALKER, : IN THE COURT OF COMMON PLEAS OF (Formerly JAMIE LYNN LEEPER), : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff C. . v 2004-2114 CIVIL ACTION - LAV 3 =f'r! o 111 JOHN IVAN LEEPER, III, • v.)`— Defendant : IN CUSTODY C , "r1 COURT ORDER ° co c4 r AND NOW, this l `'l day of November, 2013, upon consideration ofthe attached Custody Conciliation Report,the following Custody Order is entered: 1. A hearing is scheduled in Court Room o. of the Cumberland County Courthouse on the ash day of /J , 201 3 at/040A..m. At this hearing, the Court will consider father's petition to hold mother in contempt of the Custody Order of June 29, 2006. The only issue the Court will consider at this hearing is whether the mother has deliberately failed to abide by the prior Order of Court. 2. Pending said hearing or further Order of Court, the mother, Jaime Lynn Stalker, is directed to comply with all terms of the June 29, 2006, Order of Court in this matter. Failure of the mother to comply with these terms after the entry of this Order will weigh heavily against the mother at the contempt hearing. 3. In light of the fact that the mother did not attend the Custody Conciliation Conference, in the event mother retains counsel and legal counsel for the parties believe a second Custody Conciliation Conference in this matter would aid in resolving the case before the hearing scheduled above, counsel for both parties may contact the Custody Conciliator directly to schedule another Conciliation Conference. 4. In all other respects,this Court's prior Order of June 29, 2006, shall remain in place. No party shall be permitted to relocate the residence of the child where said relocation will significantly impair the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the court approves the proposed relocation. Any party proposing to relocate MUST comply with 23 Pa. C.S. § 5337. B RT, Judge cc: "Jessica Holst, Esquire ` Ms. Jaime Lynn Stalker /s'//3 JAIME LYNN STALKER, : IN THE COURT OF COMMON PLEAS OF (Formerly JAMIE LYNN LEEPER), : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v : 2004-2114 CIVIL ACTION - LAW • JOHN IVAN LEEPER, III, Defendant : 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: Zoey Ann Leeper, born March 16, 2001. 2. A Conciliation Conference was held on November 7, 2013, with the following individuals in attendance: The father,John Ivan Leeper,III,with his counsel,Jessica Holst,Esquire. The Mother did not appear. However, Attorney Holst provided the Conciliator with verification that the mother did receive,via certified mail on October 5,2013,a copy of the petition and the notice of the hearing. 3. Father has filed a petition to hold the mother contempt because mother has, according to father,essentially been refusing father contact with the minor child since July of this year. The parties have an Order from June of 2006 that provided mother with primary custody, and father with temporary custody on alternating weekends, other times as agreed and a holiday schedule. The father indicates he calls and texts the mother but the mother simply does not respond and,accordingly,he has not been able to set up any visitation with the minor child. The mother has taken no action to file any motion to modify the existing Custody Order. 4. A hearing is needed to enforce the prior Order, and the Conciliator recommends an Order in the form as attached. Date: November U , 2013 Hubert X. Gil y, Esquire Custody Co ciliator JAIME LYNN STALKER, : IN THE COURT OF COMMON PLEAS OF (Formerly JAMIE LYNN LEEPER), : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • v : 2004-2114 CIVIL ACTION- LAW • JOHN IVAN LEEPER, III, Defendant : IN CUSTODY MEMORANDUM TO THE COURT ADMINISTRATOR'S OFFICE The Conciliator estimates that the hearing in this case shall take no more than 2 hours since it is simply a limited petition for contempt. It is recommended that the case be assigned to a Judge who can fit this case into a hearing before the holidays as the father has not seen the child since July of this year. Judge Oler previously handled the case. Date:November , 2013 _ �. Hubert X. G', oy,Esquire Custody C ciliator 'CUMBERLAND U T PENNSYLVANIA JAIME LYNN STALKER, : IN THE COURT OF COMMON PLEAS OF Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action-Law : No. 2004- Civil Term JOHN IVAN LEEPER, III, Petitioner : IN CUSTODY MOTION TO SCHEDULE A CONCILIATION CONFERENCE AND NOW, comes the Respondent, Jaime Lynn Stalker, by and through her counsel, Michael J. Whare, Esquire and avers as follows: 1. A contempt hearing is currently scheduled for November 25, 2013, at 10:30 a.m. before the Honorable Edward E. Guido. 2. Respondent indicates that she never received notice of the conciliation conference that she failed to appear for on or about November 7, 2013. 3. Respondent has recently retained undersigned counsel in regards to this matter and due to a scheduling conflict, undersigned counsel is unavailable for the contempt hearing on November 25, 2013 at 10:30 a.m. 4. Respondent believes this matter can be resolved at a conciliation conference and respectfully request that the hearing on November 25, 2013 be cancelled and this matter be rescheduled for a conciliation conference. 5. Undersigned counsel has spoken with Petitioner's counsel, Jessica Holst, Esquire, and she concurs with Respondent's request for this matter to be rescheduled for a conciliation conference before Hubert Gilroy, Esquire. Wherefore, Respondent respectfully requests that this Honorable Court grant her motion to cancel the hearing on November 25, 2013 and to reschedule this matter for a conciliation conference. Respectfully submitted, Date: . (/L-A Michael J. Whare, tsquire Attorney for Respondent Supreme Ct. Id. No. 89028 37 East Pomfret Street Carlisle, PA 17013 717-243-3561 JAIME LYNN STALKER, : IN THE COURT OF COMMON PLEAS OF Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action-Law : No. 2004-2144 Civil Term JOHN IVAN LEEPER, III, Petitioner : IN CUSTODY ATTORNEY VERIFICATION I. Michael J. Whare, based on information provided to me, verify that the statements made in this Motion are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: L"�'4u".4 Michael J. Whare, Esquire Attorney for Respondent JAIME LYNN STALKER, : IN THE COURT OF COMMON PLEAS OF Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action-Law : No. 2004-2144 Civil Term JOHN IVAN LEEPER, III, Petitioner : IN CUSTODY CERTIFICATE OF SERVICE I, Michael J. Whare, Esquire, attorney for Respondent, do hereby certify that I this day served a copy of the Defendant's Motion to Schedule a Conciliation Conference upon the following by hand delivery: Jessica Holst, Esquire MidPenn Legal Services 401 East Louther Street, Suite 103 Carlisle, PA 17013 Date: 1-a a -/-T Gt, Michael J. Whar Esquire Attorney for Respondent w V JAIME LYNN STALKER, : IN THE COURT OF COMMON PLEAS OF Respondent : CUMBERLAND COUNTY,PENNSYLVANIA V. : Civil Action-Law 011 y No. 2004- Civil Term JOHN IVAN LEEPER, III, Petitioner IN CUSTODY ORDER OF COURT AND NOW,this j?jA1Wdayof1V,0YWX ,2013,upon consideration of the Respondent's Motion to Schedule a Conciliation Conference, IT IS HEREBY ORDERED ANDDIRECTED that the contempt hearing set for November 25,2013, at 10:30 a.m. is cancelled and the parties are to contact the Conciliator,Hubert Gilroy, Esquire to schedule a conciliation conference regarding this matter. By t urt: Edward E. Guido J. ? :r ✓Jessica Holst,Esquire -- Attorney for Petitioner ✓Michael J. Whare, Esquire Attorney for Respondent &p;es r ./eW leld JAIME LYNN STALKER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA • ca V. : Civil Action- Law ��°,c ca ==. r rri r- 3) (--) r- : No. 2004-2114 Civil cr JOHN IVAN LEEPER, III : r- = :' Defendant : c "- �.. : IN CUSTODY ? cri CRIMINAL RECORD /ABUSE HISTORY VERIFICATION I, Jaime Lynn Stalker,hereby swear or affirm, subject to penalties of law including 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities that: 1. Unless indicated by my checking the box next to a crime below, neither I nor any other member of my household have been convicted or pled guilty or plead no contest or was adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act, 42 Pa.C.S. §6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime in any other jurisdiction, including pending charges: Check Crime Self Other Date of Sentence all that household conviction, apply member guilty plea, no contest plea or pending charges ❑ 18 Pa.C.S. Ch. 25 ❑ ❑ (relating to criminal homicide) ❑ 18 Pa.C.S. §2702 ❑ ❑ (relating to aggravated assault) ❑ 18 Pa.C.S. §2706 ❑ ❑ (relating to terroristic threats) ❑ 18 Pa.C.S. §2709.1 ❑ ❑ (relating to stalking) ❑ 18 Pa.C.S. §2901 ❑ ❑ (relating to kidnapping) ❑ 18 Pa.C.S. §2902 ❑ ❑ (relating to unlawful restraint) ❑ 18 Pa.C.S. §2903 ❑ ❑ (relating to false imprisonment) ❑ 18 Pa.C.S. §2910 ❑ ❑ (relating to luring a child into a motor vehicle or structure) ❑ 18 Pa.C.S. §3121 ❑ ❑ (relating to rape) ❑ 18 Pa.C.S. §3122.1 ❑ ❑ (relating to statutory sexual assault) ❑ 18 Pa.C.S. §3123 ❑ ❑ (relating to involuntary deviate sexual intercourse) ❑ 18 Pa.C.S. §3124.1 ❑ ❑ (relating to sexual assault) ❑ 18 Pa.C.S. §3125 ❑ ❑ (relating to aggravated indecent assault) ❑ 18 Pa.C.S. §3126 ❑ ❑ (relating to indecent assault) ❑ 18 Pa.C.S. §3127 ❑ ❑ (relating to indecent exposure) ❑ 18 Pa.C.S. §3129 ❑ ❑ (relating to sexual intercourse with animal) ❑ 18 Pa.C.S. §3130 ❑ ❑ (relating to conduct relating to sex offenders) ❑ 18 Pa.C.S. §3301 ❑ ❑ (relating to arson and related offenses) ❑ 18 Pa.C.S. §4302 ❑ ❑ (relating to incest) ❑ 18 Pa.C.S. §4303 ❑ ❑ (relating to concealing death of child) ❑ 18 Pa.C.S. §4304 ❑ ❑ (relating to endangering welfare of children) ❑ 18 Pa.C.S. §4305 ❑ ❑ (relating to dealing in infant children) ❑ 18 Pa.C.S. §5902(b) ❑ ❑ (relating to prostitution and related offenses) ❑ 18 Pa.C.S. §5903(c) or ❑ ❑ (d) (relating to obscene and other sexual materials and performances) ❑ 18 Pa.C.S. §6301 ❑ ❑ (relating to corruption of minors) ❑ 18 Pa.C.S. §6312 ❑ ❑ (relating to sexual abuse of children) ❑ 18 Pa.C.S. §6318 ❑ ❑ (relating to unlawful contact with minor) ❑ 18 Pa.C.S. §6320 ❑ ❑ (relating to sexual exploitation of children) ❑ 23 Pa.C.S. § 6114 ❑ ❑ (relating to contempt for violation of protection order or agreement) ❑ Driving under the ❑ ❑ influence of drugs or alcohol ,�/ L✓� Manufacture, sale, ❑ ll�/ rrIg J�1 m0/1ihs Nouse__ delivery, holding, Px'e.tC offering for sale or 6 m0/ pro possession of any controlled substance or other drug or device 2. Unless indicated by my checking the box next to an item below, neither I nor any other member of my household have a history of violent or abusive conduct including the following: Check Self Other Date all that household apply member ❑ A finding of abuse by a Children& Youth ❑ ❑ Agency or similar agency in Pennsylvania or similar statute in another jurisdiction ❑ Abusive conduct as defined under the ❑ ❑ Protection from Abuse Act in Pennsylvania or similar statute in another jurisdiction ❑ Other: ❑ ❑ 3. Please list any evaluation, counseling or other treatment received following conviction or finding of abuse: N/R 4. If any conviction above applies to a household member, not a party, state that person's name, date of birth and relationship to the child. N/fr 5. If you are aware that the other party or members of the other party's household has or have a criminal/abuse history,please explain: C.)/ , an03 Jobau ttj inudlvcd -fir Q6u5G his . Minor 2Jj/d. !hre_d , gam. e f.rOSS 'Rodvy, • I verify that the information above is true and correct to the best of my knowledge, information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. WAVY; S ;;nature Prid Name w : 2 JAIME LYNN STALKER, IN THE COURT OF COMMON PLEAS OF (Formerly JAMIE LYNN LEEPER), CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v 2004-2114 CIVIL ACTION-LAWS JOHN IVAN LEEPER,III, : ' Defendant IN CUSTODY 7`-- PRIOR JUDGE: The Honorable Edward E. Guido COURT ORDER,/ VA n t!AlL1 he attached AND NOW, this /3 day of , 201�upon consideration of t Custody Conciliation Report,the following Custody Order is entered: 1. The petition for Contempt filed by father,John Ivan Leeper,III, is dismissed without prejudice for the father re-institute that Petition at any point in the future in the event father asserts that mother is in contempt of the existing Order. 2. The parties are directed to continue to abide by the terms of the prior Order of Court dated June 29, 2006. 3. If either party desires a modification of the existing Order,that party may petition the Court to have the case again scheduled with the Custody Conciliator for a Conference and scheduled for a hearing, as appropriate,with the Court. No party shall be permitted to relocate the residence of the child where said relocation will significantly impair the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the court approves the proposed relocation. Any party proposing to relocate MUST comply with 23 Pa. C.S. § 5337. B HE CO 3 T Judge Edward E. Guido cc: ssica Holst, Esquire Michael J. Whare, Esquire i;es M.-I,Ld' �'1 i JAIME LYNN STALKER, IN THE COURT OF COMMON PLEAS OF (Formerly JAMIE LYNN LEEPER), CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v 2004-2114 CIVIL ACTION - LAW JOHN IVAN LEEPER, III, Defendant IN CUSTODY PRIOR JUDGE: The Honorable Edward E. Guido 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: Zoey Ann Leeper, born March 16, 2001. 2. A Conciliation Conference was held on January 10, 2014, with the following individuals in attendance: The father, John Ivan Leeper, III, with his counsel, Jessica Holst, Esquire, and the mother, Jaime Lynn Stalker, with her counsel Michael J. Whare, Esquire. 3. This case comes before the Conciliator on a contempt matter and the parties agree to the entry of an Order in the form as attached. Date: January J , 2014 �Wu Hubert X. Gilroy, Es uire Custody Conciliate