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HomeMy WebLinkAbout09-5420Howard B. Krug, Esquire PA Supreme Court ID# 16826 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 Fax: (717) 234-0409 hkrugOakh com CASEY A. REED, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : DOCKET NO. JENNIFER B. REED, Defendant : CIVIL ACTION - CUSTODY COMPLAINT IN CUSTODY AND NOW, comes CASEY A. REED, by his attorneys, Purcell, Krug & Haller and files the following Complaint for Custody: 1. The Plaintiff is CASEY A. REED, residing at 108 Green Lane Drive, Camp Hill, York County, Pennsylvania 17011. 2. The Defendant is JENNIFER B. REED, residing at 38 Robin Court, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff seeks custody of the following child: Name Present Residence Date of Birth (Age) Caleb M. Reed 108 Green Lane Drive May 12, 2007 (2 years) Joshua T. Reed Camp Hill, PA 17011 May 12, 2007 (2 years) 4. The children were not born out of wedlock. 5. The children are presently in the custody of Plaintiff, Casey A. Reed, currently residing at 108 Green Lane Drive, Camp Hill, Pennsylvania. 6. Since birth, the children have resided with the following persons at the following addresses: Name Address Neonatal Intensive Care Unit Harrisburg Hospital Father, Mother & Paternal Grandparents 108 Green Lane Drive Camp Hill, PA Father and Mother 38 Robin Court Mechanicsburg, PA Father & Paternal Grandparents 108 Green Lane Drive Camp Hill, PA Dates Birth to August 2007 August 2007 to November 2007 November 2007 to July 31, 2009 July 31, 2007 to Present 7. The Mother of the children is Defendant, Jennifer B. Reed. She is married to the Plaintiff. 8. The Father of the children is Plaintiff, Casey A. Reed. He is married to the Defendant. 9. The relationship of Plaintiff to the children is that of Father. Plaintiff currently resides with the following persons: Name Relationship Bradford N. Reed Father Irene S. Reed Mother 10. The relationship of Defendant to the children is that of Mother. Defendant currently resides with the following persons: Name Relationship N/A. 2 11. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 12. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 13. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 14. The best interests and permanent welfare of the children will be served by granting Plaintiff legal and physical custody. 15. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as a party to this action. WHEREFORE, Plaintiff respectfully requests this Honorable Court grant him legal and physical custody of the minor children. PURCELL, KRUG & HALLER Date: August 4, 2009 3 Harrisburg, PA 17102 (717) 234-4178 Attorney for Plaintiff VERIFICATION 1, CP Casey A. Reed , hereby verify that the facts contained in the foregoing CUSTODY COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: CERTIFICATE OF SERVICE I, ANGELA S. SHAFFER, an employee of the law firm of Purcell, Krug & Haller, counsel for Plaintiff, hereby certify that service of the foregoing COMPLAINT IN CUSTODY was made upon the following by Certified Mail, Return Receipt Requested, Postage Prepaid and Regular Mail on August 5, 2009: Jennifer B. Reed 38 Robin Court Mechanicsburg, PA 17055 Defendant -• Angel . Shaffer ??, ??; _. r1r TI ?f _?J - ?? , f, ?.' r4 i`r ? L ?L u.'? ...?: - t .. ? !I W /?lrl = ?l/S'? SlJ ??s? Howard B. Krug, Esquire PA Supreme Court ID# 16826 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 Fax: (717) 234-0409 hkruaQ_Qkh.com CASEY A. REED, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. JENNIFER B. REED, Defendant DOCKET NO. 9411^5aVl : CIVIL ACTION - CUSTODY EMERGENCY PETITION FOR SPECIAL RELIEF AND NOW, comes Plaintiff, Casey A. Reed, and files the following Emergency Petition for Special Relief: 1. The Petitioner, Casey A. Reed (hereinafter "Father"), is the Plaintiff in the above-captioned matter. 2. The Respondent, Jennifer B. Reed (hereinafter "Mother"), is the Defendant in the above-captioned matter. 3. The parties are the parents of identical twins, Caleb M. Reed and Joshua T. Reed (hereinafter "Children"), born on May 12, 2007. 4. The aforesaid Children were born prematurely and suffer the following problems requiring skilled nursing care: a. Chronic lung disease for which oxygen is administered during sleep; and, b. Developmental problems, as they do not chew, speak, or use their hands at the expected level for two year olds. 5. The nursing care is provided to the Children through Gateway for working parents who cannot utilize daycare due to physical and/or mental issues presented by minors; however, if one parent is home, the hours of such care are reduced. 6. The parties separated on July 31, 2009, at which point Father and Children moved to 108 Green Lane Drive, Camp Hill, Pennsylvania. 7. Father left the marriage with the Children due to Mother's mental and emotional instability and the potential danger she presents to herself, Father, and the Children; to wit: a. Approximately two years ago Mother was admitted for three (3) days at the Psychiatric Unit of Hershey Medical Center, owing to suicide threats with the handgun owned by Father. Father has since discovered his gun missing on April 3, 2009 and reported same to police. See Exhibit "A" attached hereto. Mother denies all knowledge, although she is the only other adult resident of the household; b. Mother continues to threaten suicide to Father and third parties, as late as August 3, 2009; C. Mother shows irrational favoritism for Joshua over Caleb; d. Mother has access to and may excessively utilize legal narcotic medications; e. Mother throws hysterical fits and screaming over nursing schedules, stating she does not want to care for the Children by herself (when Father is working); 2 f. Mother has engaged in inappropriate yelling, screaming and striking Children out of uncontrolled anger for minor things, such as when they touched her computer mouse while she was on the computer; g. Mother engages in frequent angry shouting, cursing, and throwing items around Children; h. Mother has threatened bodily harm and physically assaulted Father on numerous occasions. 8. The Children are currently in the custody of Father; however, he cannot leave his residence to go to work, as Wife has made it clear she will get the Children with police assistance from his parents once he is away. 9. On August 3, 2009, Mother called Father and told him she could not live without him and the children. She also told him that she loved him and asked that he tell the children that she loved them. When Mother would not promise Father that she would do nothing to hurt herself, he immediately contacted police, who suggested he sign a Form 302, as Mother "stated she was fine now". 10. Father signed the Form 302 at Holy Spirit Hospital on August 4, 2009 and has been informed that the police will be sent to bring her to Holy Spirit Hospital for evaluation. 11. Mother is not currently represented by counsel. 12. This is a new case and, therefore, no Judge has been previously assigned; however, this Petition is being filed simultaneously with a Complaint in Custody. 3 WHEREFORE, Father requests this Honorable Court enter an Order giving Father sole legal and primary physical custody, pending a full psychiatric evaluation of Mother, after which supervised visitation with Mother for a reasonable period may follow, as per expert recommendation, such to remain in effect until a full custody evaluation and hearing. PURCELL, KRUG & HALLER By: -D Date: 4 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney for Petitioner/Father Complaint Report sue, v,4 a sti Commonwealth of Pennsylvania Lower Allen Twp Complaint Number Locked Record Follow Up all For Service 1 0 rEPPROLIVI Description PPROPRIY LOSTIMISS Status Priority Method Received Date/Time Received Cleared 5 IPersonal Visit 1 0410312009 1 Day of the Week Friday How Handled Officer signed Complaint Nature Casey Allen Reed reported a lost / missing Smith & Wesson .44 Magnum sometime between November 2007 and earlier this y ear. NCIC entr y made. Street Number 38 Street Block Predirection treat Name rFRobin - Street Type CT I Postdirection PO Box Cross-Predirection Cross-Street Name rross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Cumberland Jurisdiction Number Location Township Lower Allen nship Magisterial District 09-1-01 City/Town ura Political Subdivision State P Zone Number 2 Zip Code 17055 Area Grid 1208 Residence Type Unit Type 1 Unit Number Latitude Longitude I Location Type llesidencefflor ne Country United States of America Location Description 8/4/2009 12:22:01 PM EX 151T Page 1 of 3 a 8 Salutation First Name ICasev I Middle Name AIlen l Last Name Reed Suffix Date of Birth 01121/1973 ?hlte e ex rM,I Address 38 Robin Court Apartment City State Zip Code Phone Number 1 Area Code 717 1 Number 6208575 IlEx, Phone Type Phone Number 2 Area Code 717 Number 7374531 Ext Type Zk Notify Complainant Call Taker ID Dispatcher ID cNET Complaint A: 1932853 User Defined Field 1 User Defined Field 2 Property User Defined Field 3 User Defined Field 4 Curt -1812 - Lower Allen Twa IReaortina Officer 11812 Dispatched Enroute 04103/2009 Airived Cleared 04/03/2009 1 04/03/20 9 11: uennea mesa i-z uerinea rieia z 8/4/2009 12:22:01 PM Page 2 of 3 & Wesson .44 Ma num, double action revolver. VERIFICATION 1, CASEL.A.•.. hereby verify that the facts contained in the foregoing EMERGENCY PETITION FOR SPECIAL REL.TMe true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: CERTIFICATE OF SERVICE 1, ANGELA S. SHAFFER, an employee of the law firm of Purcell, Krug & Haller, counsel for Plaintiff, hereby certify that service of the foregoing EMERGENCY PETITION FOR SPECIAL RELIEF was made upon the following by Certified Mail, Return Receipt Requested, Postage Prepaid and Regular Mail on August 5, 2009: Jennifer B. Reed 38 Robin Court Mechanicsburg, PA 17055 Defendant Angel .Shaffer LUL w od 'I7? do CASEY A. REED, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : DOCKET NO. OQ - S`Y 1.0 0;. i `?F,2yvi JENNIFER B. REED, Defendant : CIVIL ACTION - CUSTODY ORDER AND NOW, this / d day of , 2009, upon consideration of the foregoing Emergency Petition for Special Relief, a hearing shall occur on e /Sec,,*. 2009, in Courtroom 3 , at the Cumberland County Courthouse. BY TH RT: Judge istribution: H ward B. Krug, Esquire, 1719 North Front Street, Harrisburg, PA 17102 nnifer B. Reed, 38 Robin Court, Mechanicsburg, PA 17055 C tts ? g ?o?? f1F T H F- PFR I_t:, ; N 3 ?1F?Y 2009 AUG 10 H s : 0 2 CASEY A. REED, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS NO. 09-5420 CIVIL TERM JENNIFER B. REED, Defendant CIVIL ACTION - CUSTODY IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 11th day of August, 2009, after a brief hearing, we enter the following order that is intended to be temporary only and shall not in any way prejudice either party's rights after a full hearing on the merits: 1. The parties shall have joint legal custody of their sons, Caleb Reed and Joshua Reed, born May 12, 2007. 2. Father shall have primary physical custody of the children. 3. Mother may visit with the children on a daily basis from 8 a.m. until 1 p.m. at the home of Father's parents 108 Green Lane Drive, Camp Hill, Pennsylvania 17011. Both parents may attend all doctor visits, therapy sessions, and any other medical appointments. Howard B. Krug, Esquire 1719 North Front Street Harrisburg, PA 17102 Susan K. Pickford, Esquire "n,?d 4 - ?? - c9 y Carrucoli & Associates, P.C. 875 Market Street " Suite 200 Lemoyne, PA 17043 :mlc Y NIf V+.J_ . 71"09 2 C;A CASEY A. REED, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. JENNIFER B. REED, Defendant NO. 2009-5420 CIVIL ACTION - LAW IN CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I, Howard B. Krug, Esquire, Attorney for the Plaintiff, Casey A. Reed, in the above action, hereby swear and affirm that on the 5th day of August, 2009, 1 sent, by certified mail, return receipt requested, restricted delivery, a Complaint in Custody and Emergency Petition for Special Relief to the Defendant, Jennifer B. Reed. The Return Receipt Card signed by the Defendant on August 11, 2009 is attached hereto as Exhibit "A". Sworn and subscribed to before me this 3tQ day of '2009. Notarial Seal Shaffer, Notary of Narrisburp, Dauphin -. ----------- ---- ---- --------------------------------------------- 2. Artide Number r Z W O N Q 7l tl N%4'l.. Au"^ 2L3? W M W -O 3. Service Type CERTIFIED MAIL W 4. Restricted Delivery? (Extra Fee) WYes !? V d d J i 1. Article Addressed to: W2O cc N Zy= dc o A. Repined by Date of Delivery C. Signature Agerd Addressee X 0 D. Is slivery address different from item 1? ? Yes If YES, enter delivery address below: ? No Jennifer B. Reed 38 Robin Court Mechanicsburg, PA 17055 EMS a ? r8 From 3911, J.rwn„ ?ota6 Don+e?Yc Rob" R4ow EXHIBIT "A" 20n n09 a ?? 4? p?, ??x , {S r+t 14 R3 . . OCT -12 2009 CASEY A. REED : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA No. 09-5420 Civil Term JENNIFER B. REED ,Y/ 5 Defendant : ACTION IN CUSTODY Prior Judge: Edward E. Guido, J. COURT ORDER AND NOW, this 14 n day of October 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. All prior Orders are hereby VACATED and replaced with this Order. 2. The custody docket number 09-5398 and custody docket number 09-5420 are hereby consolidated. All future pleadings shall be filed under 09-5420. 3. Legal custody: The Mother, Jennifer Reed, and the Father, Casey Reed, shall have shared legal custody of Caleb Reed and Joshua Reed, both born 05/12/2008. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 4. Physical Custody: Father shall have primary physical custody of the Children subject to Mother's partial supervised physical contact as follows: a. Mother shall have supervised contact with the Children thirty-five (35) hours per week; the exact times by mutual agreement. In the absence of agreement regarding the times, Mother shall have supervised contact with the Children from 8:00 am until 1:00 pm. b. Mother's periods of supervised contact may occur at paternal grandparents' residence at 108 Green Lane Drive, Camp Hill, PA 17011. C. In the alternative, Mother's periods of supervised contact with the Children may occur in the community as arranged between Mother and a representative of Links to Care (specifically Chrystal if she is available). d. It is understood that Mother shall continue with her mental health treatment and follow any and all recommendations from her psychiatrist. It is further understood that once Mother follows through with her mental health treatment, the parties shall agree to some sort of shared physical custody arrangement. e. Mother shall have additional periods of physical custody of the Children at such other times and locations as the parties may mutually agree. 5. Co-parenting Counseling: The parties are strongly encouraged to engage in co- parenting counseling. The cost of said counseling, after appropriate payment through insurance, shall be split equally between the parties. 6. Mental Health Counseling: Mother shall continue with her mental health counseling and follow any and all recommendations. Mother has agreed to have an independent psychiatrist evaluate her and that she shall sign releases so that the evaluator may have access to people, information and documents to comprehensively evaluate her. It is expected that a report will be generated regarding Mother's potential risk to herself and the Children. 7. Both parents may attend all doctor visits, therapy sessions, and any other medical appointments. 8. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 9. Holidays: The parties shall alternate and share holidays as the parties may mutually agree. 10. Neither parent shall take the Children out of state without notifying the other parent at least within forty eight hours of departure of the intended destination and a telephone number at which they can be reached. 11. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Children. 12. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 13. During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 14. Relocation: The parties have initiated the instant custody action based upon the parties' residence in Cumberland County. If either party intends to establish residency a substantial distance from where they currently reside, he or she must give to the other parent at least ninety (90) days' written notice in advance of the proposed move, in order to allow the parties to confer prior to the move and to establish a mutually satisfactory arrangement in light of the changed circumstances. In the event the parties are unable to reach an agreement, the parties agree that the Court of Common Pleas of Cumberland County shall have jurisdiction over them to fashion an appropriate custody Order. 15. The parties are hereby authorized to contact the assigned conciliator directly to schedule another conciliation conference (within ninety days of the date of this Order) if the parties can not resolve their differences relating to custody of the Children. 16. The parties may modify this Order by mutual agreement in writing. In the absence of mutual consent, the terms of this Order shall control. tribution: dy Hribal, Esq., 875 Market Street, Ste 120, Lemoyne, PA 17043 M M and Krug, Esq., 1719 North Front St., Harrisburg, PA 17102 M J. Mangan, Esq. Olt S. 14)g =ZKY) CASEY A. REED : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. JENNIFER B. REED Defendant Prior Judge: Edward E. Guido, J. : No. 09-5420 Civil Term ACTION IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Caleb Reed 05/12/2007 Primary Father Joshua Reed 05/12/2007 Primary Father 2. Apparently, both Mother and Father filed Petitions for Special Relief and/or Emergency Relief. An Order of Court had been issued August 11, 2009 awarding Father primary physical custody of the Children. A Conciliation Conference was held on September 15, 2009 with the following individuals participating: The Mother, Jennifer Reed, with her counsel, Cindy Hribal, Esq. The Father, Casey Reed, with his counsel, Howard Krug, Esq. The parties agreed to the entry of an Order as attached. Date: // Jo gan, Esquire C tod Conciliator 7 i777 THE P,'-+ 2009 Chi' 15 Ail 10: 18 C` ,?° 11/10/2009 14:43 7172218403 PURDY LAW OFFICE PAGE 02/02 Pamela L. Purdy, Esquire Supreme Court I.D. #85783 308 N. 2nd Street; Ste. 200 PO Box 11544 Harrisburg, PA 17108 PH: (717) 221-8303 FX: (717) 221-8403 plpurdy0verizon.net Attomey for Defendant CASEY A. REED, Plaintiff V. JENNIFER B. REED, Defendant : IN THE COURT OF COMMON PLEAS OI : CUMBERLAND COUNTY, PENNSYLVAP NO. 09-5420 CIVIL ACTION - LAW IN CUSTODY PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly withdraw the appearance of Cindy Hribal, Esquire as counsel for the Defendant, Jennifer B. Reed, and enter the appearance of Pamela L. Purdy, Esquire. 1 , y ribal Pamela L. Purdy PA I. No 6A?a :?;- PA ID No. 85783. 875 Market Street 308 N. 2"d St., Ste. 200 Lemoyne, PA 17043 PO Box 11544 (717) 761-1274 Harrisburg, PA 17108 (717) 221-8303 Dated: t „Date:. 7 FlLE&-OFFICE OF THE PROTHONOTARY 2049 NOV 19 PM 12: 4 9 C t&---I ,; °3 t G"")Ujwy PENNSYLVANLA L . CASEY A. REED PLAINTIFF V. JENNIFER B. REED DFF'FNDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-5420 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW. Wednesday, August 25, 2010 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle Oil Monday, September 27, 2010 at 10:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entrv 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: _ lsljohnj. Mangan, Jr., E's 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 A ITORNEY 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 i t6 (W%\t-? 32 South Bedford Street n `'= Carlisle, Pennsylvania 17013 _tv- s, ?6 Telephone (717) 249-3166 $` • - ?ac?d ? n I?c? q an `s -? I e . $-. 2 S• l O C?D? U Benjamin D. Andreozzi Attorney ID #89721 ANDREOZZI & ASSOCIATES, P.C. 215 Pine St., Ste. 200 Harrisburg, PA 17101 JENNIFER B. REED, Plaintiff vs. CASEY A. REED, Defendant ATTORNEY FOR PLAINT'~~~ PfO~'HOt~OT,4R~` ~Q~~ ~~~ ~~ ~~ ~~ ~ S CUMBERLA"~D C(~t1PdTY ~EM~dSYLYANiA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 09-5420 Civil Term ACTION IN CUSTODY PRAECIPE TO ENTER APPEARANCE Please enter the appearance of Benjamin D. Andreozzi, Esq., as counsel for the Plaintiff, Jennifer Reed, in the above captioned matter. Kespecttully, D B 'amin D. eozzi Date COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CASEY A. REED, Plaintiff ) V. ) No. 09-5420 } JENNIFER B. REED, `-' Defendant } =? -a Fri -'r Certificate Of Service's --r - -77 Ja I, JENNIFER B. REED, Defendant in the above matter, hereby certify that on e -? C Qq/o / 1 0 , I mailed a true and correct copy of the Petition for Mo f tiq I by certified mail, return receipt requested, restricted delivery, and another copy of the same rv document by first class mail, postage prepaid, to: CASEY A. REED 339 Oak Drive New Cumberland, PA 17070 I certify that (check ALL of the following which are true): Certified mail: [X] The green and white sender's receipt is attached. (ATTACH receipt.) [ ] The green recipient's receipt is attached; CASEY A. REED signed the certified mail receipt on (ATTACH receipt.) [ ] The certified mail was returned to me unsigned, with the notation that the certified mail was: [ ] refused [ ] unclaimed [ ] other notation: [ ] Neither the certified mail envelope nor the certified mail receipt was returned to me. Regular mail: [] The regular mail has not been returned to me. [ ] The regular mail was returned to me, with the notation: Certificate of Service Page 1 of 3 I verify that the information in the Certificate of Service is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C,S.A. § 4904, relating to unworn falsification to authorities. Date: 09 I.2Iab 1 d (Sign) JtRNIFER B. REED STAPLE OR TAPE THE CERTIFIED MAIL RECEIPTS BELOW: M M 0 u'l u ? Re"n R 4.' (F.ndorsemant Required) Fee E ry 0 ( nd rt RegWred) rU M Total Posmpe & Fees ni ¦ Compute Items 1, 2, and & Also conoete item 4 If Rest icted Ddvery is desired. ¦ Print your name and address on the reverse ed that we carr ht1mffw kid to you. ¦ Attach this card to the back of the mailpucik or on the front if space permits. 1. Artide Addressed to- 33q po,k be.ve 1-10,10 - x153 I X Apmt I?M(:*I°? ? 1516i Of D*wy D. 1s daWary alfdlaes dMkrant tbm lFerrl 1? Oyes if YES, erdw dewory addross bebw: 13 No s. s.rvb.lype 0twfflsd Md 13 Bova Md 17 Paswww O Ratum Pwasipt for Maraw a w ? kwired Mall. _-Qc as 2 ArUdeNumber 7009 2820 0002 5969 5033 i *DM Ps Form 3811, February 2004 DonwrUc Retum Receipt t Certificate of Service Page-2 of 3 oc~ -~ 2 Zoo ~ CASEY A. REED IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. . No. 09-5420 Civil Term JENNIFER B. REED '"? ~ ~ ~~ Defendant : ACTION IN CUSTODY ~,~ ~ ~~ ~ "-' ~-. ~ ._ r,, ~ ,. ~ Prior Judge: Edward E. Guido, J. { _ ~ --- COURT ORDER ~''~ "'„ ~-~ < , __~ ~`= .~ ~_, AND NOW, this ~~ day of October 2010, upon consideration of tii'e~~=! ,- . attached Custody Conciliation Report, it is ordered and directed that: - ~ -`- All prior Orders are hereby superseded with this Order. 2. Legal custody: The Mother, Jennifer Reed, and the Father, Casey Reed, shall have shared legal custody of Caleb Reed and Joshua Reed, both born 05/12/2008. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: Father shall have primary physical custody of the Children subject to Mother's partial physical custody as follows: a. Mother shall have one overnight unsupervised with the Children per week for the next ten (10) weeks. It has been agreed that a representative from Links to Care (Chrystal) shall be the supervisor the afternoon preceding the overnight and also the next morning after the overnight. The parties shall communicate with each other in regard to their respective work schedules to establish the precise day for the overnights. b. It is understood that Mother shall continue with her mental health treatment and follow any and all recommendations from her psychiatrist and psychologist. c. Mother shall have additional periods of physical custody of the Children at such other times and locations as the parties may mutually agree. 5. Co-parenting Counseling: The parties are strongly encouraged to engage in co- parenting counseling. The cost of said counseling, after appropriate payment through insurance, shall be split equally between the parties. 6. Mental Health Counseling: Mother shall continue with her mental health counseling and follow any and all recommendations. 7. Both parents may attend all doctor visits, therapy sessions, and any other medical appointments. 8. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 9. Holidays: The parties shall alternate and share holidays as the parties may mutually agree. It has been agreed to that Mother shall have custody of the Children on Christmas Eve 2010 from 6:00 pm until Christmas Day 11:00 am. It is anticipated that a more comprehensive holiday schedule shall be established at the conference call on December 20, 2010. 10. Neither parent shall take the Children out of state without notifying the other parent at least within forty eight hours of departure of the intended destination and a telephone number at which they can be reached. 11. It has been agreed to that the Children shall be cared for by mutually agreed upon appropriate adults at all times. 12. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Children. 13. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 14. During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 15. Relocation: The parties have initiated the instant custody action based upon the parties' residence in Cumberland County. If either party intends to establish residency a substantial distance from where they currently reside, he or she must give to the other parent at least ninety (90) days' written notice in advance of the proposed move, in order to allow the parties to confer prior to the move and to establish a mutually satisfactory arrangement in light of the changed circumstances. In the event the parties are unable to reach an agreement, the parties agree that the Court of Common Pleas of Cumberland County shall have jurisdiction over them to fashion an appropriate custody Order. 16. A telephonic conference is hereby scheduled for December 20, 2010 at 8:30 am. The assigned conciliator shall initiate the call. 17. The parties may modify this Order by mutual agreement in writing. In the absence of mutual consent, the terms of this Order shall control. Distribution: ~enjamin Andreozzi, Esq., 215 Pine St., Ste 200, Harrisburg, PA 17101 ~oward Krug, Esq., 1719 North Front St., Harrisburg, PA 17102 .~~ohn J. Mangan, Esq. t F's' J~-'1.,~ l ~, to ~~~~~ J. ' . ~~ ~ 2 2010 CASEY A. REED IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. No. 09-5420 Civil Term JENNIFER B. REED Defendant : ACTION IN CUSTODY Prior Judge: Edward E. Guido, J. 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: The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Caleb Reed 05/12/2007 Primary Father Joshua Reed 05/12/2007 Primary Father 2. Apparently, both Mother and Father filed Petitions for Special Relief and/or Emergency Relief. An Order of Court had been issued August 11, 2009 awarding Father primary physical custody of the Children. A Conciliation Conference was held on September 15, 2009, an Order issued October 14, 2009 and a conciliation conference was held October 11, 2010 with the following individuals participating: The Mother, Jennifer Reed, with her counsel, Benjamin Andreozzi, Esq. The Father, Casey Reed, with his counsel, Howard Krug, Esq. 3. The parties agreed to the entry of an Order as att~.ched. Date: G / Z ~~ ~ Jo J. angan, Esqui C sto Conciliator CASEY A. REED V. JENNIFER B. REED Defendant WITHDRAWAL OF APPEARANCE Kindly withdraw my appearance as attorney of record forte so mark the docket. / Dated: March, 2012 C)m ') C) _ - ff, Casey A. Re AR 1719 N. Front Street Harrisburg, PA 17102 IN THE COURT OF COMMON PLEAS CUMBF,RLAND COUNTY, PENNSYLVANIA NO. 09-5420 ,., C- CIVIL ACTION - LAW CUSTODY;VISI'I'ATION Plaintiff ENTRY OF APPEARANCE Kindly enter my appearance as attorney of record for Plaintiff, Casey A. Reed, and so mark the docket. Dated: March. 2012 JOHN F. KING LAW. P.C. ,? -- Esquire o n F.19 #61919 4076 Market Street Camp Hill, PA 17011 (717) 695-2?22 CASEY A. REED IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVAA C= ' ;7, --e V MCC 2009-5420 CIVIL ACTION LAW :X -L, cn -- 1-, -?r ?- C JENNIFER B. REED M C? IN CUSTODY o- DEFENDAN T ?Lp - F3 ORDER OF COURT AND NOW, Tuesday, March 13, 2012 , upon consideration of the attached Compl aint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, April 17, 2012 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/ john j. Mangan, Jr., Esq. Ipj 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. `, shy o'1?1?dn96lni/+° .Copy 07 • copy P/ace& ?n '? Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 CO?ic?la1?? CASEY A. REED IN THE COURT OF COMMON PLEAS J' rrjW PLAINTIFF CUMBERLAND COUNTY, PENNSYLV ?? 7V r- y \ N IT V. _ +,.R 2009-5420 CIVIL ACTION LAW ` ^f I C.: JENNIFER B. REED :v IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, March 26, 2012 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, April 27, 2012 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 Custodv orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ john j. Mangan, Jr., Esq. l1r 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 riOd -10 RiyTelephone (717) 249-3166 . Cer4. copy ma . COPY maded k Rty A7dn A41 file- C,nci?a?r y P4ec? ??' ?? y 3,/ .0 7/z I ? i°-l' r'% L L_ CvL AP -2 FPS 2: 25 "'?.JMBERL AND COUNT", "E"NSYLVAHM Benjamin D. Andreozzi Attorney ID 489271 Heather E. Verchick Attorney ID #201310 ANDREOZZI & ASSOCIATES, P.C. 215 Pine St., Ste. 200 Harrisburg, PA 17101 717-525-9124 Ben@midstatelaw.com Attorney for Respondent JENNIFER B. REED, Plaintiff VS. CASEY A. REED, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 09-5420 Civil Term ACTION IN CUSTODY PLAINTIFF'S RESPONSE TO DEFENDANT'S PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF A CUSTODY ORDER AND NOW comes the Plaintiff, Jennifer B. Reed, and responds to Defendant's Petition for Civil Contempt for Disobedience of a Custody Order as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. The averments contained in paragraph 4 contain conclusions of law to which no response is required. To the extent that it is deemed otherwise, it is specifically denied. A. Admitted. B. Admitted. C. Denied as stated. Respondent does not have sufficient information to form a belief as to the truth of Petitioner's thoughts and actions. By way of further response, Respondent avers that she created the schedule at the request of Stanley E. Schneider, Ed.D. of Guidance Associates of Pennsylvania, who the parties were Ordered to meet with for an evaluation. Respondent further avers that Dr. Schneider thought that it was in the best interests of the children for the parties to create a consistent schedule that worked with each party's work schedule rather than following a schedule that could potentially change every week. Finally, Respondent avers that the new agreed upon schedule is manageable and has been working well. D. It is admitted that Petitioner, through legal counsel, advised Respondent's counsel that he was withdrawing his consent to modification of the terms of the September 20, 2011 Court Order. Any inference as to the legality of this withdrawal of consent is a conclusion of law to which no response is required. To the extent that it is deemed otherwise, such inferences are denied. E. Denied as stated. The averments contained in paragraph 4E contain conclusions of law to which no response is required. To the extent they are deemed otherwise, they are denied. 5. Admitted. 6. Denied. Respondent is without sufficient information to form a truth as to the averments contained in Paragraph 6 regarding the legal fees incurred by the Petitioner, thus they are denied. The remaining averments are conclusions of law to which no response is required. To the extent that they are deemed otherwise, they are denied. WHEREFORE, Respondent requests that this Honorable Court deny Petitioner's Petition for Civil Contempt. NEW MATTER 7. Respondent's responses to paragraphs 1 through 6 are incorporated herein by reference as though they were set forth in their entirety. 8. The parties met with Stanley E. Schneider, Ed.D. of Guidance Associates of Pennsylvania pursuant to the September 20, 2011 Order of Court. 9. Dr. Schneider advised the parties to come to an agreement about a consistent custody schedule based on each party's work schedule. 10. Respondent prepared this schedule and brought it to a conference between the parties and Dr. Schneider. IL . At the conference, the parties discussed a 50/50 custody arrangement as well as possible pick up and drop off times. 12. After the conference, Respondent made some changes to the schedule, and ensured that each party had 21 days of custody over a six week period pursuant to Petitioner's request. 13. Both parties signed the Custody Agreement and revised schedule on January 4, 2012. 14. Thus, as of January 4, 2012, the September 20, 2011 Order of Court was modified by written agreement of the parties. l 5. If Petitioner no longer agrees to the modified Custody schedule, then Respondent avers that the proper procedure should be to file for modification of the subsequent agreement. 16. Furthermore, Petitioner was living in New Cumberland when the September 20, 2011 Court Order was entered and when the parties modified the custody schedule on January 4, 2012. 17. Thus, Petitioner and Respondent lived ten minutes from each other. 18. On January 19, 2012, Petitioner sent an e-mail to Respondent advising her that he was moving to a new address in Camp Hill on January 21, 2012. 19. Petitioner provided his new address to Respondent, and subsequently moved three days later. 20. Respondent was never given a chance to object to this move, as she only received three days notice via e-mail. 21. Petitioner now lives thirty minutes from Respondent and in a separate county. 22. This move has resulted in difficulties in exchanging custody by increasing the total driving time for Respondent by approximately forty minutes. 23. Additionally, since the parties now live in separate counties, Respondent is having a difficult time setting up various medical services for the children. 24. As such, Respondent requests a modification of the modified schedule to account for Petitioner's move, and such other relief as the Court deems appropriate. WHEREFORE, Respondent requests that this Honorable Court deny Petitioner's Petition for Civil Contempt, modify the existing schedule to account for Petitioner's move, and grant such other relief as the Court deems appropriate. Date: ? / */ ;? Respectfully Submitted, ANDREOZZI & ASSOCIATES, P.C. 4 By: Heather E. Verchick Attorney ID #201310 215 Pine St., Ste. 200 Harrisburg, PA 17101 (717) 525-9124 Counsel for Respondent VERMCATION I verify that the statements made in my Responses to Defendant's Petition for Civil Contempt for Disobedience of a Custody Order 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 unworn falsification to authorities. Date_ 3?aar Jennifer B. Reed v? CERTIFICATE OF SERVICE I, Heather E. Verchick, Esquire, hereby state that I have this day caused to be served a true and correct copy of the Plaintiff s Petition for Modification of an Existing Support Order to all counsel of interest at the address below named, by U.S. Mail, First-Class, postage prepaid: John F. King John F. King Law, P.C. 4076 Market Street Suite I Camp Hill, PA 17011 Dated: 31 By:9(?Pt 4A _ Heather E. Verchick, Esq Counsel for Respondent JOHN F. KING LAW, P.C. John F. King, Esq. 4076 Market Street Camp Hill, PA 17011 (717) 695-2222 FAX (717) 695-2207 johnfkin lg aw.L?mail.com CASEY A. REED V. IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER B. REED Defendant NO. 09-5420 CIVIL ACTION - LAW CUSTODYNISITATION PREVIOUS CONCILIATOR: John Mangan, Esq. PREVIOUS JUDGE: Hon. Edward E. Guido SUPPLEMENT TO PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF A CUSTODY ORDER TO THE HONORABLE JUDGES OF THE SAID COURT: r-- AND NOW COMES the Petitioner, Casey A. Reed, by and through his attorneys, John F. King Law, P.C., and brings this Petition for Contempt, pursuant to Pa.R.C.P. 1915.12, averring as follows: 1. The Petitioner is Casey A. Reed, Plaintiff in the above-captioned action, and Father of the minor children, with a current address of 1107 Yverdon Drive, Apt. C-2, Camp Hill, PA 17011. 2. The Respondent is Jennifer B. Reed, Defendant in the above-captioned action, and Mother of the minor children, with a current address of PO Box 225, 316 West Front Street, Lewisberry. PA 17339. This is a supplement to Plaintiffs Petition for Civil Contempt for Disobedience of a Custody Order filed on March 22, 2012. 4. In addition to Respondent/Mother's willful failure to abide by the Custody Order of September 20, 2011, as described in Plaintiffs Petition of March 22, 2012, Respondent/Mother has repeatedly sought medical care and treatment of the minor children, without informing Father before or after said care and treatment, all in violation of paragraph 2 of said Order. Father is aware of the following dates and medical providers: September 4, 2011, at York Hospital (treatment for both children), and September 29, 2011 (treatment for Joshua). 6. The Petitioner has incurred significant legal fees as a result of the Respondent's contemptuous action, and her failure to remedy said contemptuous action. WHEREFORE, the Petitioner requests that the Respondent be held in contempt of Court, and further requests that the Court award legal fees and costs. Dated: April Ai-, 2012 Respectfully submitted, JOHN F. KING LAW, P.C. tF. King, Esquire I 1919 - 4076 Market Street Camp Hill, PA 17011 (717) 695-2222 VERIFICATION I, Casey Reed, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Supplement to Petition for Civil Contempt; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: / ? Li 113 1 ? Z ?Nq t / Casey Reed CERTIFICATE OF SERVICE I hereby certify that I am this _? day of April, 2012, serving the supplement to motion for contempt upon the person and in the manner indicated below which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service by First Class Mail addressed as follows: Heather Verchick, Esq.. 215 Pine Street Suite 200 Harrisburg, PA 17103 John Mangan, Esq. 17 W. South Street Carlisle, PA 17013 .L - 2 Sharry Semans Con, 1f• c???a?.? r h?? P J C.. r a ?. kj A Benj,min. D. Andreozzi Attorney ID #89271 Heather E. Verchick Attorney ID #201310 ANDREOZZI & ASSOCIATES. P.C. 215 Pine St., Ste. -200 Hanisbuig, PA 17101 7 l 7-52 5-9124 Ben(amidstatelaw.corn Attorney for Respondent CASLY A, REFD. ? IN THE COti RT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, 1"ENNSYLVANIA vs. I No. 09--,420 Civil Tern; JENNIFER B. REED, Defendant I ACTION IN CUSTODY PETITION FOR CONTEMPT OF CUSTODY ORDER. AND NOW comes the Plaintiff through her attorneys Andre07Zi & Associa'es. and avers the following: 1. The Petitioner is Jennifer B. Reed, Defendant in the above-captioned action, and Mother of the minor children, with a current address of-3 16 West Front Street, Lewisberry, PA 1 7339 (hereinafter "Mother'') ?. The Respondent is ( asev .,5. Reed. i'laintilf in the above-captioned action, and Father of the minor chil::iren, with a current address of 1107 Yverdon drive, Apt. C-2, Camp Hill, P.:'. ? '01 nc:reinafter "Father"). 3 "1 lie parties are the parents of two children, namely Kaleb Reed and Joshua Reed, both barn ot? May 12, '007 (hereinafter "the Children"). C? 4. On September 20, 2011, this Honorable Court entered an Order pursuant to an Agreement by the parties. A true and correct copy of this Order is attached as Exhibit "A." _i. Under this Order, the parties share legal custody of the Children. See Exhibit A at paragraph 2. 6. Also under this Order, the Children shall be cared for by rr?ut.ually agreed upon approirriate adults at all time. See Exhibit A at paragraph 11. ?. Additionally, under this Order, neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party. See ExhV I A at paragraph 12. 8. bather has repeatedly violated paragraph 2 of the Order by: a. Scheduling parent/teacher conferences without Mother's knowledge. Spec] ficalty. Father signed up for a parent/teacher conference on April 16 2012 and did not inform tvlother of same. Mother saW the sign-up sheet at the school and signed her name next to Father's. Father °?vas surprised when Mother arrived for the conference. Mother does not know if there vi ere other conferences; b. Failing to keep Mother advised of school activities and functions. Specifically, Father resists Mothers involvement with the Children's preschool and rarely provide:. her with documents received from the school irnclad.ing any progress r,.-ports and ne?w7S etI ers published by the school; ;. Failing to pry-ivide Mother with a copy of the Children's health insurance cards. Social Security cards and birth certificates, which leads to issues when Mother is trying to set up appointments and therapy for the Children; d. Failing to cooperate with Mother in tilling out paperwork at physician's offices and insisting on being the only address listed and the only signator, which results in the physician's office only contacting Father regarding treatment and services for the bons: C. Changing the boy's health insurance from York County to Cumbertand Countv without seeking a joint decision or even informing Mother ahead of time. This has created numerous problems with the Chhdren's vai 1, ?w: medical treatments and has prevented the Children from getting necessary wraparound services; and f. Unilaterally deciding to keep the boys in their CATU/preschool rath:,r than enrolling th,-i iii Kinds >arr??n `ape-ifcaItN., Father 3tid Mother had discussed this isso-I b.,( had not yet a joint de-ision 1,ather rnent one.d at th.e April 16, ?012 parent/teach+;r conference that he signed the paperwork to keep the bob s in CAIN/preschool. 'I his paperwork w:ts signed without advising Mother ahead of time or obtaining a joint decision on this issue. 9. Father has repeatedly violated paragraph 11 of the Order by allowing his girlfriend. Mariana Pacheco to care for the Children and physically discipFrt-.? thci-o thioui4h the ,ise of a suck or a switch despite the fact that Mother has never agreed to Mariana caring for the Childre!i. does not believe that she is an appropriate adult to care for the Children, a.nd vehemently disagrees with her choice of discipline. 1( ' Father lras repeatedl} violaters parar rapt 12 of the `'rrder by s.)vI ng dispafagino things aho>>t Mother and allowing his family rnoml,er. to say disp-,imping things aho'll "oilier it front of and to di,: C"hildren i 1. The Petitioner has Lricurred significant legal fees as a result of the Respondent's contemptnouS action. 12. This matter is currently scheduled for a conciliation on April 24, 2012 at 10:30 a.m. with John Mangan. We request that this Petition be heard at that time. Wherefore, Plaintiff requests this Honorable Court find Plaintiff Casey A. Reed in Contempt of the September 20, 2011 Order and require him to pay sanctions and reasonable attorney's fees for the preparation and argument of this Petition. Date: `? /I? //?- Respectfully submitted, ANDR-FOZZI & ASSOCIATES. P.C I?v. Heai-her E. Vercluck. Esquire Attorney ID # 89271 215 Pine St., Ste. 200 Harilsburg, PA 1? 101 (717) 525-9t24 Attorney for Plaintiff EXHIBIT A ? '? ? kEED EN;?IFER B. i"EED Plam-iff T THE COURT OF CO 1:1,10 ,; r'I E:4S C 1\JBEI'.` AND ! 'OL??T','.. F Defendant : ACTION !?,T CUSTODY for Tudgc: Edward E. Guido, J. COURT ORDER AND NOW, this O __ day of September 2Ol1, upon considerat-on of .h __ttached Custody Conciliation Report, it i5 ordered and directed that: _AJ] prior Orders are hereby superseded with this Order. Legal custodv: The Mother, Jeniuer Reed, and the Father, Casey Reed, shall have shared legal custody of Caleb Reed and Joshua Reed, both born O5 1 ?1007. The parties shall have ar_ -qua] right to make all major non-emergenc11decisions affecting the Children's general well-being including, but not limited to.. all decisions regarding their health, ed-ication and religion. Pursuant to The terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and infor-ir-at.ion pertaining to the Children including, but not limited to, medical, den'::.al raligious or school records, the residence address of the Children and of the ot1_Zer parent. To the extent one parent has possession of any such records or inforz?_lation, that parent shall be required to share the same, or copies thereof. with the other parent within such reasonable time as to make the records and information of re; scr_abIc ase to tl,e other parent. 3 Physical Custody: Father shall. have primary physical custody ofthe Children subject to .Mother's partial physical custody as follows: a. Mother sha`1 have three (3) overnights unsupervised v,-ith tll?c Children per iveek according to td2e days she has offoi vvorl- After each of Moiher's overnights, Father shall see the Children from 9 am until 12 nm in the morning. The other day that Mother is o-EF of work, Mother shall have custody 10 am until b pm, ho-,vever_ if Father is ofi'of work the same day Mother is off, Father shall ha-,,e the first option to care for the Children. The parties sh1 communicate with each other in regard to their respective work schedules to establish the precise days for the ove nights. Due consideration shall' e given when Father is o i from v,or- a -d I when Father needs to worl`. in order to 1-,!aXL7n1:?, Mothers custodial periods. It is unciE:rstoM t.aT ,lother sl.all aniime ; ith leer r, e -s:1 .ea]th treatment and follow any and a'1 ecommendaticr s l=ot 1 :_ e- psychiatrist and psychologist. Mother shall have additional pe17, of phrrsiral custc,d.? or the mutually ag ee Co-Darenting: Counseling: The p sties are strongly encouraged To ri?ra it cc- parenting counseling. The cost of said counseling-, after appropriate yh Th insurance, shall be split equally between t-ae parties. Mental Health Counselinz: Mother shall continue with her mental health counseling and follow any and all recommendations. TI.e parties have agreed to engage in a custody evaluation ith Guidanc,_ Ssociates. Father shall forward the evaluation fee with the Dndersianding that lie may seek at a f iture date for a re-allocation of the fee. Both pa-eats may attend all doctor visits, therapy sessions, and any other ?-rledical appointments. ?. The non-custodial parent shall have liberal telephone contact with the Ch dren. on a reasonable basis. Holidays: The parties shall alternate and share holidays as the parties m..i` mutually agree. It has been agreed to that Mother shall have custody o L- -,-Children on Christmas Eve 2010 from 6:00 pm untl Christmas Day ? 1aI1 -1. _ 0. N°ither parent shall take t'ae Children out of state xithout notiTMIng th° ether arena ut least 'v ithln forty eight hours of depar raTe of the ?mended CeSTLa?70? and a telephone number at which they can be reached. It has been weed to that the Children shall be cared for by_ ]?utuall}' a ,:?.°d ?spon ar3propriate adults at all =es. Neither party may say or do anything nor permit a tnird park, to do or say anything that may estrange the Children from the other pa ty, or injure the o :ii!ion of the Children as to the other party; or may hamper the free and natLral development of the Children's love or affection for the other party. To -?: e?tent possible both parties shall not a_low third parties to disparage the other pa eat in the presence of the Children. 1 In the event of a medical emergency; the custodial part-y shall Doti the other rar y as soon as possible after the emergency is handled. V acation: Each parent- ';hall haVC' one wttk SzVCIl CGI1SeClltly? d_">'' , 11t. 2" ,v ith the, Children per ar. The legLeStir:gl.ar"e.r_ shad give th,' other 1 .:nt 30 jars advance notice of hc requested tune and t,_:s vac:zticn we "'k X11 pcr;??Cle a.e e`er lar physical c.us oc ; in the e', ent the panes Bch con1llcting vacations, ilt party ff1St pr(:'vid117R 1`:I-tten rlorlC,.c Shall 11 hoI . +1 i ; A o .+1 ta h _nfon-l3tlon regard' Lg ?1 e L tj -vac,at on d 'st',i2 Lort aI,d a tClel lher at v,,hich they can be rea,hed dL?i:ae (nr vacation. T.e pa ties r,lay sand :his aCatlorl tine Dy In11t l8' ?Q' emeT' .. > atller '.S Spc;(1 1C(iil j !Ut11CP_1-:. 1 -- to ?.-acat on in Allegher y Park in ^ V 1 01 rL rler 211? ] . j. During any periods of ct.stody or %isitation, the parties shall not possess cr use. illezal s-ibstances or consume/be under the influence of alcoholic bevera«es to the point of intoxication. The pantie;, shall likewise assure; to t- -e extent poss,bl.-, that other hmis-thold membcrS an^;or 110USe 0-LLeST_S cC11!T y x'1?':t _1LS rr0"'i.Sl! I'. i R-.1ocatk)n: !,be parties i].ave' Inlt:a.cd the Instar!t ::UStod} action base(1 +L ?C?rl i'lc parti(--s' residence in Cumberland County. If either party intends to establish residencv a substantial distance zion) where, they ctirrently reside, he or she r:iust gi e to the other parent at least ninety (90 days' +.ri?tC.n non e >-n a('.-v-:aT o 'tie proposed move, in order io allow ta,° part' :"s to co_?,fer prior to the 17,1"l establish a mutually satisfactory arrangement in licrht of the changed circurLstances. In the event the T pi-ties are unable ,o eac'r( an agrtenien_.:h )arties a? ee that the Court of Corr non fleas of Cumberland Count-. hal ,y i?,e iurisdicd ,)n ever them to fashion A appropriate CL"Lody 01der. It p2T 7(.'s may' mod' `J t-1S )TLici ?V -aUnIai dL'Tee1! 17 In 1'r1`Sl i I, bsen .e cfml.tual cons-n'. 1,1',e teirLS of?pis 0?rd,-r ;h :)rt'ol. B . `THE C R fist nIILion: Ben a=in Andreozzi, Esq., 215 Pine St., Ste 200, Har 'sburg, PA 17101 Howard ti ig Esq., 1719 North Front St., .i?amsbi:f(', PA 17107 Jahn J. Mangan, Esq. = TRUE COPY FROM RECORD In Testfrnorry wfeered., f here unto set my hand and ft ssal of said Curt at Carlisle, Pa. C:?: e i (S dayd' --- 0 -_ Prothonotary, ,J ? VERIFICATION I verify that the statements nude in this Petition 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. Jennifer Reed Dale:.! j CERTIFICATE OF SERVICE 1, Heathei E. Verchick, Esquire, hereby state that I have this day caused to be served a true and correct copy of the Defendant's Petition for Contempt of Custody Order to all counsel of interest at the address below named, 'by U.S. Mail, first-Class, postage prepaid: John. F.:King, P?(j uire JOHN F. KING LA?V, P.C. 4076 Market Street Camp Hill, PA 17011 Date(I 8- ------ - ----- (- -- --- - ( Heather E. Verchick, Esq Counsel for Plaintiff C) -,3 CASEY A. REED IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLV V. JENNIFER B. REED : No. 09-5420 Civil Term Defendant : ACTION IN CUSTODY Prior Judge: Edward E. Guido, J. COURT ORDER AND NOW, this-3 A'day of July 2012, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: This Order is entered pursuant to a Custody Conciliation Conf rence. A Custody Hearing is hereby scheduled on the 100' day of , 2012 at :/s am/ptlin Courtroom number 3 in the Cumberland County Court of Common Pleas, Carlisle, PA 17013 at which time testimony will be taken in regard to the physical custody for the subject Child. For purposes of this hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the hearing date. 2. Legal custody: The Mother, Jennifer Reed, and the Father, Casey Reed, shall have shared legal custody of Caleb Reed and Joshua Reed, both born 05/12/2007. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Each parent shall inform the other of medical/therapy/educational appointments that are scheduled for the twins. 3. Physical Custody: Father shall have primary physical custody of the Children subject to Mother's partial physical custody as follows: a. Mother shall have three (3) overnights unsupervised with the Children per week according to the days she has off of work. The other day that Mother is off of work, Mother shall have custody 10 am until 6 pm, however, if Father is off of work the same day Mother is off, Father shall have the first option to care for the Children. The parties shall communicate with each other in regard to their respective work schedules to establish the precise days for the overnights. Due consideration shall be given when Father is off from work and when Father needs to work in order to maximize Father's and Mother's custodial periods. b. It is understood that Mother shall continue with her mental health treatment and follow any and all recommendations from her psychiatrist and psychologist. C. Mother shall have additional periods of physical custody of the Children at such other times and locations as the parties may mutually agree. 4. Co- arp enting Counseling: The parties are strongly encouraged to engage in co- parenting counseling. The cost of said counseling, after appropriate payment through insurance, shall be split equally between the parties. 5. Mental Health Counseling: Mother shall continue with her mental health counseling and follow any and all recommendations. 6. The parties have agreed to engage in a custody evaluation with Guidance Associates. Father shall forward the evaluation fee with the understanding that he may seek at a future date for a re-allocation of the fee. 7. Both parents may attend all doctor visits, therapy sessions, and any other medical or educational appointments. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 9. Holidays: The parties shall alternate and share holidays as the parties may mutually agree. It has been agreed to that Mother shall have custody of the Children on Christmas Eve 2010 from 6:00 pm until Christmas Day 11:00 am. 10. Neither parent shall take the Children out of state without notifying the other parent at least within forty eight hours of departure of the intended destination and a telephone number at which they can be reached. 11. It has been agreed to that the Children shall be cared for by mutually agreed upon appropriate adults at all times. 12. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Children. 13. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 14. Vacation: Each parent shall have one week (seven consecutive days) of vacation with the Children per year. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. 15. During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 16. Relocation. The parties are advised that neither party shall hereafter relocate the child or children if such relocation will significantly impair the ability of a non- relocating party to exercise his or her custodial rights unless (a) every person who has custodial rights to the child/children consents to the proposed relocation or (b) the court approves the proposed relocation. The party seeking relocation must follow the procedures required by 23 Pa.C.S. §5337. 17. The parties may modify this Order by mutual agreement in writing. In the absence of mutual consent, the terms of this Order shall control. THE CO RT, C') J. c rnw t._ X-M Distribution: Heather Verchick, Esq., 215 Pine St., Ste 200, Harrisburg, PA 17101 may, ` /John King, Esq., r-- ? John J. Mangan, Esq. tom-, i 5: 00 WP,eS ." de d rv )W( s uo -TI 0 n Tj r~? CASEY A. REED IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLV. V. No. 09-5420 Civil Term JENNIFER B. REED Defendant : ACTION IN CUSTODY Prior Judge: Edward E. Guido, J. 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 Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Caleb Reed 05/12/2007 Primary Father Joshua Reed 05/12/2007 Primary Father 2. Apparently, both Mother and Father filed Petitions for Special Relief and/or Emergency Relief. An Order of Court had been issued August 11, 2009 awarding Father primary physical custody of the Children. A Conciliation Conference was held on September 15, 2009, an Order issued October 14, 2009, a conciliation conference was held October 11, 2010, an Order issued October 13, 2010, a telephonic conference was held 12/20/10, an Order issued January 19, 2011, a conference was held June 27, 2011, an Order issued September 20, 2011, both parents filed contempt petitions and a conference was held April 27, 2012 with the following individuals participating: The Mother, Jennifer Reed, with her counsel, Heather Verchick, Esq. The Father, Casey Reed, with his counsel, John King, Esq. 3. Father would like to maintain having primary physical custody and offers Mother alternating "weekends" (her three days off) plus a right of first refusal. Father indicates that the twins are developmentally delayed and receive a significant amount of therapy. Father indicates that the twins are not ready for kindergarten and are currently in a three year old pre-school class. Father indicates that the twins are still in diapers. Father asserts that Mother has problems getting the twins to school on time and that she is often late. Father alleges that he is better able to get the twins to school as he does not start work until 1 pm. A custody evaluation was performed; however, Father does not feel that a comprehensive evaluation was done in that certain individuals did not have an opportunity for input. 4. Mother indicates that she would like more of a shared custody situation, possibly with her having primary. Mother has concerns about being left out of decisions regarding the twins, specifically medical/therapy treatment and the educational aspect. Mother asserts that she is not being informed of appointments. Mother is also upset that Father switched some services from York County to Cumberland County without informing her. 5. The Conciliator recommends an Order in the form as attached scheduling a Hearing and entering an Order of Court regarding custody as outlined. It is the Conciliator's belief that this would be in the Child's best interest. It is expected that the Hearing will require one day. 6. The proposed recommended Order may contain a requirement that the parties file a pre-trial memorandum with the Judge to whom the matter has been assigned. Date: Z , Esquire John RCMiliator Custo Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA J vs. No. 09-5420 Civil Term C _ eft kr F. CASL4L ,.REED rn cN.. rn Defendant ACTION IN CUSTODY - p o ::0 C r L 1 ro CS, WITHDRAWAL OF APPEARANCE Zo c7 ? Kindly withdraw the appearance of Heather E. Verchick, Esquire, and Andreozaz Associates, P.C. for Plaintiff Jennifer B. Reed, in the above-captioned matter. Respectfully Submitted, ANDREOZZI & ASSOCIATES. P.C. Date: / IJ 311.1 By: Heather E. Verchick, Esquire Attorney ID #201310 215 Pine Street Suite 200 Harrisburg, PA 17101 717.525.9124 Phone 717.525.9143 Fax ENTRY OF APPEARANCE Kindly enter my appearance as Pro Se in the above-captioned matter. Date: o77 "-s J 3- By: ?'22ed? J fer B. Reed CASEY A. REED, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. JENNIFER B. REED, CIVIL ACTION - LAW Defendant NO. 09-5420 CIVIL TERM IN RE: CUSTODY ORDER OF COURT AND NOW, this 10th day of August, 2012, after hearing, it is hereby ordered and directed as follows: 1. All prior custody orders are hereby vacated and replaced with the following order. 2. The mother, Jennifer Reed, and the father, Casey Reed, shall have shared legal custody of Caleb Reed and Joshua Reed, both born 5/12/2007. The parties shall have an equal right to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education, and religion. Pursuant to the terms of 23 Pa. C.S. Section 5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. The parties shall share physical custody on a 50/50 basis according to the following schedule: A. Primary physical custody shall alternate on a week on/week off basis with the exchange taking place at noon on Sundays. B. The non-custodial parent shall be entitled to two overnights of visitation each week which shall correspond with his or her days off work. Provided however, that if the party's days off coincide, father's days off shall be given priority. 4. The parties are ordered to engage in co-parent counseling which shall commence within 30 days of today's date. Any cost of said counseling not covered by insurance shall be divided equally between the parties. 5. Mother shall continue with her mental health counseling until successfully discharged and shall continue to take all prescribed medications. 6. Both parents may attend all doctor visits, therapy sessions, and any other medical appointments. Any parent who schedules such a session or appointment shall notify the other parent as to the time and place as soon as practical after the appointment is made. 7. The non-custodial parent shall have liberal A telephone contact with the children on a reasonable basis. 8. The following holiday schedule shall supercede any other provision of this order: A. In even numbered years mother shall have the children from Christmas Eve at 6:00 p.m. to Christmas Day at noon and father shall have the children from noon on Christmas Day until noon on December 26th. In odd numbered years these times shall be reversed. B. In even numbered years mother shall have the children from 6:00 p.m. the day before Thanksgiving until 2:00 p.m. Thanksgiving Day and father shall have them from 2:00 p.m. Thanksgiving Day until 2:00 p.m. the day after Thanksgiving. In odd numbered years these times shall be reversed. 9. Neither parent shall take the children out of state without notifying the other parent at least forty eight hours prior to departure of the intended destination and a telephone number at which they can be reached. 10. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the children from the other party or injure the opinion of the children as to the other party or may hamper the free and natural development of the children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the children. 11. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 12. Each parent shall have one week [7 consecutive days] of vacation with the children each year. Unless otherwise agreed, these seven days shall occur during the parent's scheduled week of primary custody. The vacationing parent shall give the other parent thirty days advance notice. 13. During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 14. No party shall have any firearms in the home when the children are present unless said firearms are safely under lock and key. 15. No party shall be permitted to relocate the residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the Court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa. C.S. Section 5337. 16. The children shall continue to attend St. Timothy's Preschool and to participate in the Leg Up Farm Program unless both parents agree to terminate them from participation. 17. The parties may modify any provision in this order by mutual agreement. In the absence of mutual agreement, the terms of the order shall control. ? John King, Esquire For the Plaintiff v Jennifer B. Reed Pro se By the Court, Edward E. Guido, J . tv rV, c : 1 f h Q; es 1 d 44 JOHN F. KING LAW, P.C. John F. King, Esquire 12' ID #61919 4076 Market Street GUMSERU'04u Camp Hill, PA 17011 Attorney 44laintiff 717-695-2222 / 717-695-2207 FAX CASEY A. REED : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-5420 JENNIFER B. REED : CIVIL ACTION - LAW Defendant : CUSTODY/VISITATION PREVIOUS CONCILIATOR: John Mangan, Esq. PREVIOUS JUDGE: Hon. Edward E. Guido PLAINTIFF'S PETITION FOR MODIFICATION OF A CUSTODY ORDER 1. The Petitioner is Casey A. Reed, Plaintiff in the above-captioned action, and Father of the minor children, Caleb M. Reed and Joshua T. Reed, (DOB: 5/12/2007), with a current address of 1107 Yverdon Drive, Apt. C-2, Camp Hill, PA 17011, and is represented by John F. King, Esq., 4076 Market Street, Ste. 1, Camp Hill, PA 17011. 2. The Respondent is Jennifer B. Reed, Defendant in the above-captioned action, and Mother of the minor children, with a current address of 316 West Front Street, Lewisberry, PA 17339, and is believed, and therefore averred, to be appearing pro se. 3 The Petition of Plaintiff respectfully represents that on August 10, 2012, an Order of Court was entered by the Honorable Edward E. Guido, for the custody and visitation of the subject minor children, a true and correct copy of which is attached hereto and marked as Exhibit "A". 4. This Order should be modified because: ��/�ee A. Paragraph 4 of the current Order requires co-parent counseling, which by the terms of the Order states should have commenced within thirty (30)days of the date of the Order. B. The Petitioner complied with the terms of the Order, and did directly thereafter make contact with Interworks to commence co-parenting counseling. C. Despite the terms of paragraph 4 of the Order, Mother failed and refused to comply. It is believed, and therefore averred,that Mother scheduled and cancelled a series of appointments, resulting ultimately in Interworks being unable to provide any co-parenting counseling and also refusing to attempt to provide any in the future. See copy of memo from Interworks attached as Exhibit "B", D. Paragraph 5 of the current Order requires Mother to continue with her mental health counseling until successfully discharged, and she is further ordered to take all prescribed medications, and to date, no evidence of any continuance of mental health counseling or successful discharge has been provided by Mother. E. Paragraph 16 of the current Order requires the children to continue to attend St. Timothy's Preschool and to participate in the Leg-up Farm Program. F. Despite the terms of the Order in paragraph 16, Mother was unable to transport the children to the school for approximately a four month period subsequent to the issuance of the Order,thereby requiring Father to provide all transportation, including periods of Mother's custody when Mother was unable, and since February 2013, when Mother again was able to provide transportation,there have been numerous incidences of Mother's failure to get the children to the preschool program, which is particularly problematic because of the children receiving occupation therapy and inclusion therapy from the Capitol Area Intermediate Unit while in attendance at St. Timothy's. G. In addition to the occupation therapy and inclusion therapy, the children also have been receiving speech therapy for approximately one year provided by the Capitol Area Intermediate Unit at the Lemoyne Preschool Center in Lemoyne, PA. H. Despite the scheduled speech therapy, Mother has caused the children to miss appointments while in her care and custody. I. The subject children will be six years of age on May 12, 2013, and are registered in the West Shore School District, with anticipated attendance at Washington Heights Elementary, but which attendance may change due to the aforementioned Intermediate Unit services. J. Mother has evidenced a pattern of inability to ensure the children's attendance at scheduled events. K. There is no enforcement of attendance by the school district at the kindergarten level. L. It is believed, and therefore averred, that it is critical that the children regularly attend kindergarten. M. Father has evidenced an ability to follow the schedules of the children, and to ensure that the children attend their scheduled events. N. Mother has failed and refused to evidence a willingness to co-parent with Father. O. It is believed, and therefore averred, that it is in the best interests of the children to revise the current Order to remove the Leg-Up Farm's therapy requirement in paragraph 16 upon commencement of kindergarten, at which time all services will be coordinated through the West Shore School District and the Intermediate Unit. P. It is believed, and therefore averred, that upon beginning kindergarten, it would be in the children's best interests to reside primarily in Father's home so as to provide more stability and a regular schedule with the children. WHEREFORE, Petitioner/Father respectfully requests that the Court modify the existing Order and award primary physical custody to Father. Dated: March .57�\111 , 2013 Respectfully submitted, JOHN F. KING LAW, P.C. F9King, Esquire "J 4076 Market Street Camp Hill, PA 17011 (717) 695-2222 VERIFICATION 1, Casey A. Reed, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Petition to Modify a Custody Order; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Casey A. Reed Dated: March�, 2013 CASEY A. REED, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. JENNIFER B . REED, CIVIL ACTION - LAW Defendant NO. 09-5420 CIVIL TERM IN RE: CUSTODY ORDER OF COURT AND NOW, this 10th day of August, 2012, after hearing, it is hereby ordered and directed as follows : 1 . All prior custody orders are hereby vacated and replaced with the following order. 2 . The mother, Jennifer Reed, and the father, Casey Reed, shall have shared legal custody of Caleb Reed and Joshua Reed, both born 5/12/2007 . The parties shall have an equal right to make all major non-emergency decisions affecting the children' s general well-being including, but not limited to, all decisions regarding their health, education, and religion. Pursuant to the terms of 23 Pa. C. S . Section 5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent . To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent . 3 . The parties shall share physical custody on a 50/50 basis according to the following schedule : A. Primary physical custody shall alternate on a week on/week off basis with the exchange taking place at noon on Sundays . B . The non-custodial parent shall be entitled to two overnights of visitation each week which shall correspond with his or her days off work. Provided however, that if the party' s days off coincide, father' s days off shall be given priority. 4 . The parties are ordered to engage in co-parent counseling which shall commence within 30 days of today' s date . Any cost of said counseling not covered by insurance shall be divided equally between the parties . 5 . Mother shall continue with her mental health counseling until successfully discharged and shall continue to take all prescribed medications . 6 . Both parents may attend all doctor visits, therapy sessions, and any other medical appointments . Any parent who' schedules such a session or appointment shall notify the other parent as to the time and place as soon as practical after the appointment is made. 7 . The non-custodial parent shall have liberal telephone contact with the children on a reasonable basis . 8 . The following holiday schedule shall supercede any other provision of this order: A. In even numbered years mother shall have the children from Christmas Eve at 6 : 00 p.m. to Christmas Day at noon and father shall have the children from noon on Christmas Day until noon on December 26th. In odd numbered years these times shall be reversed. B. In even numbered years mother shall have the children from 6 : 00 p.m. the day before Thanksgiving until 2 : 00 p.m. Thanksgiving Day and father shall have them from 2 : 00 p.m. Thanksgiving Day until 2 : 00 p.m. the day after Thanksgiving. In odd numbered years these times shall be reversed. 9 . Neither parent shall take the children out of state without notifying the other parent at least forty eight hours prior to departure of the intended destination and a telephone number at which they can be reached. 10 . Neither party may say or do anything nor permit a third party to do or say anything that may estrange the children from the other party or injure the opinion of the children as to the other party or may hamper the free and natural development of the children' s love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the children. 11 . In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 12 . Each parent shall have one week [7 consecutive days] of vacation with the children each year. Unless otherwise agreed, these seven days shall occur during the parent ' s scheduled week of primary custody. The vacationing parent shall give the other parent thirty days advance notice. 13 . During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 14 . No party shall have any firearms in the home when the children are present unless said firearms are safely under lock and key. 15 . No party shall be permitted to relocate the residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the Court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa . C. S . Section 5337 . 16 . The children shall continue to attend St . Timothy' s Preschool and to participate in the Leg Up Farm Program unless both parents agree to terminate them from participation. 17 . The parties may modify any provision in this order by mutual agreement . In the absence of mutual ._ agreement, the terms of the order shall control . By the Court, a+fr r^ Edward E. Guido, J. John King, Esquire For the Plaintiff TRUE COPY FROM RECORD In Testimony whereof, 1 here unto set my hand and the seal of said Court at Carlisle,Pa. Jennifer B . Reed This .9l day of ,'"� 20 A--) Pro se /3 Prothonotary R DATE: 02/27/13 TO: John King,Esq. FROM: Deborah L.Salem,CAADC, LPC RE: Casey Reed V.Jennifer Reed I am writing to advise you about the status of the above referenced matter. I did an intake interview with Casey Reed on 09/26/12 and was schedule to do the same with Jennifer reed on 09/27/12. However Jennifer canceled that first appointment first by having Casey let me hear a voicemail she left on his phone cancelling and then via email transcribed below:I apologize thatI was not able to attend our appointment yesterday. I hopeyou received my telephone message. It is difficult not having internet access at home,because I understand thatyou may not always get phone messages. I had obligated myse�f to provide transportation for the boys'preschool field trip on 9126, but it was postponed at the last minutefor 9127 and Casey had to work during the time of the trip. Hopefully we can reschedule,perhapsfor a time that the boys are with Casey and there is less[likelihood] ofsomething like that happening again. Jennifer Reed Jennifer rescheduled for 11/15/12; but subsequently canceled that one via phone message transcribed below: Hi, this isjennifer Reed,I have an appointment at one o'clock today,and I have a problem, the person who was supposed to provide a carfor me bailed on me at the last minute last night That probably means 171 need to reschedule, unfortunately right now I don't have a car because I was in an accident and haven't yet gotten a newcar. Please give me a call,my number is 717-480-8407,thankyou. (111159:13am) It was not until 02/07/13 that I received an email from Jennifer,transcribed below: I am sending an email as I understand it is the best way to reach you. However,please understand that I do not have internet access and have to drive into the next town to use the internet as I live in a rural area (and until last week I did not even have an automobile). Please do not use email to reply to me as I onl go check email weekly or so. Your email may be lost amongst ads and spam,etc.,before/check my email again,so the best way tn contact meb6ytelephone. Since Ifirst spoke with you,/have gone through quite o trying time. /had un automobile accident ond exacerbation ofon injury that had me out of work,and I am currently not working pending a settlement. The settlemeothusbeenagro*dupuqbut/tw/0toke4'6weukstn/Ynolize / was able to get o vehicle last week with severance pay from my employer(the settlement is work comp),so I now have transportation to get to an appointment,but I am still awaiting the money. /f there bany way to work out a paymentplan that can be paid when the settlement is paid,I can seeyou ASAP. Reed` C. vReoc{, J. Page 1 of2 TTnduta 02.27.13 Also, a lot has obviously changed for me since I filled out the original paperwork, especially about current stress in my life (which has changed completely), so if you could,please resend those forms. If you call and tell me to look for the email, 1 can go then and get it but as I mentioned, if 1 do not know to expect it, I may notfind it Thankyou, Jennifer Reed (717)480-8407 In her email, while Jennifer indicates that she is ready to schedule with me she further indicates that she will need a payment arrangement until she gets settlement from her automobile accident which she assumes will be 4-6 weeks from the Th. I reached out to her via email on 02/10/13 to advise her that I do not have a payment arrangement per say. I then had a staff person call her on 02/19/13 realizing her plight about emails. Via phone message she was advised that she would not be able to schedule until she could pay and was reminded of the fee. On 2/21/13 Jennifer left a phone message that it would be three weeks before she could schedule. At this time, although it may be disappointing to Casey Reed, I am returning the case to you and am suggesting that if the court does take action against Jennifer Reed for failure to follow through, that another person be appointed to do the co-parenting counseling. From the beginning I believed this case was much more complicated than what co-parenting counseling could manage. However, I respect the Judges directive that he at least wanted the parents to work on their significant animosity and I was willing to give it a try. In addition to my lack of confidence in the parties ability to benefit from co-parenting counseling, I am no longer willing to work with this case because I have spent a good deal of administrative time; held a place in my busy schedule for a situation that has not come to fruition with reasonable efforts to get it off the ground for five months; the primary reason being that I am still waiting for Jennifer Reed to schedule. In essence, I don't want to turn away other work waiting for the possibility that Jennifer Reed will eventually schedule. If you have any questions please don't hesitate to contact me. I can be reached via email at frontdeskOinterworksonline.com. Best regards, f Deborah L. Salem, CAADC, LPC Clinical Director Reed, C. v Reed, J. Page A of AT E : 02/17A9A31DO CASEY A. REED IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-5420 CIVIL ACTION LAW r i M MS. JENNIFER B. REED IN CUSTODY DEFENDANT mac=° �► y ORDER OF COURT AND NOW, Tuesday,April 02,2013 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan,Jr.,Esq. ,the conciliator, at 4th Floor,Cumberland County Courthouse,Carlisle on Friday,May 10,2013 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/ john-1. Mangan, Jr.,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 fe��r 7 C ��c� y r °°i T. i es 1;491;11 CASEY A. REED IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA No. 09-5420 JENNIFER B. REED ;��► r�7 ACTION IN CUSTODY C Defendant C5 ANSWER TO PLAINTIFF'S PETITIONfOR MODIFICATION OF A CUSTODY ORDER AND NOW comes the Defendant, Jennifer B. Reed,pro se, and responds to the Plaintiff's Petition for Modification of a Custody Order, as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. The averments in paragraph 4 contain conclusions of law to which no response is required. To the extent that it is deemed otherwise, it is specifically denied. A. Admitted. B. .Denied as stated. Both Parents made multiple attempts to contact Deb Salem after the Order for co-parenting counseling was issued. However,Ms. Salem was found to be unreachable via telephone. Mother then emailed Ms. Salem on September 9,2012,requesting that Ms. Salem contact either Father or Mother. Ms. Salem did respond to Mother's email and requested that Mother have Father contact her as well. The emails between Parents and Ms. Salem are attached and marked exhibit"A." C. Denied as stated. Mother did make every attempt to comply with the Order. Mother did cancel the first appointment scheduled on September 26, 2012 due to a change in the Children's preschool schedule. As Mother found this out only the day before her scheduled appointment, she first called the Father to relay the message as soon as possible to Ms. Salem during his appointment, due to Ms. Salem's stated difficulty with her telephone system, and then emailed Ms. Salem as soon as possible. On October 15,2012, Mother was involved in an automobile accident that left her injured and unable to work, as well as without transportation. This caused the Mother to not only suffer serious financial difficulties, as well as the lack of transportation. Mother had over two months without any income, and when short-term disability began it was minimal and followed by another six weeks without income. As noted in Ms. Salem's memo, Mother did attempt to make financial arrangements,but none were available. While it is unfortunate, Mother understands Ms. Salem's choice not to hold a counseling position for her while she was unable to pay. D. Mother has been successfully discharged from her mental health counseling. As such Mother requests that this requirement be removed from the current Order. E. Admitted. F. Denied as stated. Mother was unable to provide much of the transportation of the Children during her recuperation from the accident and until she was able to acquire a vehicle. Father did provide a majority of transportation. During this time, Mother did request that Father allow the Children be registered in York county for Medical Assistance. Had Father allowed this, much of the transportation could have been provided through Medical Assistance. Since Mother obtained transportation,here have only been rare occurrences in which the Children were not at scheduled events due to illness or her vehicle needing work. G. Admitted. H. Denied as stated. Response is contained in Defendant's response to paragraph 4F. 1. Admitted. J. Denied. Mother has overcome a short period of difficulty in which she made alternate arrangements to ensure the.Children were able to attend scheduled events. It is also noted that Father has ongoing difficulty ensuring that the Children attend Leg Up Farm therapies, as he works afternoons and the Father's mother and grandmother have been unable to consistently provide transportation. K. Denied. Mother is.informed by the West Shore School District that despite the fact that children are not required to attend school until the age of eight, if parents choose to enroll younger children in kindergarten,parents are subject to all applicable truancy laws,which are enforced. Mother welcomes this as this should end Father's spurious claims of lack of attendance. L. Admitted. M. Denied. Father works during the hours the Children attend Leg Up Farm, delegates his responsibility of ensuring their attendance to his mother and grandmother. However,The Father's mother and grandmother struggle to provide transportation on a regular basis. N. Denied. Mother is fully willing to co-parent,but Father has evidenced unwillingness to communicate with Mother and has made many efforts to exclude Mother from the Children's lives and decisions regarding the Children. 0. .Denied. The Children have benefited greatly from therapy at Leg Up Farm. The therapies received there are ordered by the Children's pediatrician. These orders are attached and labeled exhibit`B." Mother understands the Father's difficulty in obtaining transportation for the children while he is working, and is therefore willing to provide transportation on a regular basis. Additionally,upon commencement of kindergarten,the Intermediate Unit will no longer provide services, and services will only be provided by the West Shore School District, which does not provide comparable services to Leg Up Farm. Additionally,Mother believes, and therefore avers,that it is not the school district's responsibility to provide necessary treatment to the Children, but it is the responsibility of the Parents. P. Denied. Because Father delegates his parental responsibilities to other family members,the Children will not be able to have a stable living environment, and will not have a parent consistently caring for them and helping with homework, as well as ensuring that the children attend scheduled events. Conversely,Mother works only two overnight shifts per week and will be available every day after school and will ensure that the children receive all treatment and therapy they require. It is believed, and therefore averred,that it is in the Children's best interest to reside primarily with the Mother. NEW MATTER 5. Mother is currently employed at Holy Spirit Hospital as a Registered Nurse in the float pool,working two twelve-hour night shifts per week. AS such,mother will be home and available after school to care for the children. The Father works afternoon shift five days per week and required alternative caregivers to care for the children. Additionally,the Father regularly has the Children cared for by babysitters when Mother is available. It is believed and therefore averred that it is in the Children's best interest to be in the care of a parent whenever possible. 6. As a Registered Nurse,Mother is fully able to understand the Children's special needs and arrange for:and participate in the Children's treatments and therapies. Father repeatedly denies the Children's special needs and prevents recommended therapies for the Children. Specifically,the Children recently had the opportunity to receive music therapy,which was recommended by both the Children's play therapist and pediatrician,but Father refused to allow this. In addition,Father seeks to cease the Children's participation at Leg Up Farm in retaliation due to the Children's play therapist's testimony at the custody trial. He also allows disparaging comments about the therapist to be made in the presence of the Children. 7. Father has abused his privilege of having his days off work take priority for the purposes of determining which parent shall have custody,as in paragraph 3B of the Order. Father has taken a full seven days off work on his custodial week and demanded Mother exercise her entitled to overnights of his choosing,which coincided with the Mother's scheduled work. It is respectfully requested that privilege be removed from the Order as it has been abused. 8. Mother makes every effort to include Father in the care of the Children and does not seek to interfere with the Father's relationship with them. However,Father seeks to exclude Mother from the Children's lives. 9. It is averred that it is in the Children's best interest that the Children reside primarily with the Mother as the Mother can provide the most stability and will ensure that the Children's educational, emotional,and other special needs are met. WHEREFORE,Mother respectfully requests that the Court award primary physical custody to the Mother. Dated: May 2013 Respectfully submitted. Jennifer B.Reed Jennifer B.Reed,Pro se 316 West Front Street PO BOX 225 Lewisberry,PA 17339 (717)480-8407 Verification I, JENNIFER B. REED, Defendant, verify that the facts stated in the foregoing Answer to Plaintiffs Petition for Modification of a Custody Order are correct to the best of my knowledge, information, and belief. Defendant understands that false statements therein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsifications to authorities. Date: 0S�o JENNIFER B. REED moo-parenting counseling-Yahoo! Mail Page 1 of 1 1 MAIL Co-parenting counseling From: "Jennifer" <wincharm99 com> Sunday, September 9, 2012 9:42 PM To: frontdesk @interworksonline corn My former spouse and I have been ordered by Cumberland County family court counseling, and the judge recommended Deb Salem by name. Casey Reed is former forme spo se and my to have co-parenting name is Jennifer Reed. We have left multiple voicemail messages. Please contact one of us. Jennifer Reed: (717)480-8407 or respond to this email Casey Reed: Cell: (717) 364-2740, home: (717) 730-7213, email: case allenreed ahoo.com Thank you, Jennifer Reed htt)://Us.mc12O7.rnail.yahoo.com/mc/showMessage?smd=42&fid=Sent&filterB = y &.rand... 4/21/2013 -tw: Re: Co-parenting counseling-Yahoo! Mail Page I of I ,"50L3aC001F* MAIL Fw: Re: Co-parenting counseling Tuesday,September 11, 2012 3:17 AM From: "Jennifer" <wincharm99@yahoo.com> To: "Casey Reed" <caseya11enreed@yahoo.com> ---On Sun, 9/9/12, Front Desk<frontdesk@interworksontine.com>wrote: From: Front Desk<frontdesk@interworksonline.com> Subject: Re:Co-parenting counseling To: "Jennifer"<wincharm99@yahoo.com> Date: Sunday, September 9,2012, 11,30 PM Dear Jennifer I am very sorry for your inconvenience. I am currently out of town. I will be back on Thursday. Email is your best option to contact me as I am switching my phone system right now. It is in general best because I can address responses after hours. Please have Casey also email. As it is very late, I will give you appointment times tomorrow. Best regards Deb saken Sent from my iPhone On Sep 9, 2012, at 9:42 PM,Jennifer<wincharm99(M-yahoo.com>wrote: My former spouse and I have been ordered by Cumberland County family court to have co-parenting counseling,and the judge recommended Deb Salem by name. Casey Reed is my former spouse and my name is Jennifer Reed. We have left multiple voicemail messages. Please contact one of us, Jennifer Reed: (717)480-8407 or respond to this email Casey Reed: Cell: (717)364-2740, home: (717)730-7213, email: caseyallenreed(&yahoo.com Thank you, Jennifer Reed http://us.mcl207.mail.yahoo.com/mc/showMessage?sMid=41&fid=Sent&filterBy=&.rand... 4/21/2013 r,-e: t-o-parenting counseling-Yahoo! Mail Page I of 2 mA- 1-L Re: Co-parenting counseling Wednesday, September 12, 2012 12:53 PM From: "Casey Reed" <caseyallenreed@yahoo.com> To: "frontdesk@interwo rkson line.com" <frontdesk@interworksonline.com>, Iennifer Reed" <wincharm99@yahoo.com> Dear Ms. Saken: Hi. I am Casey Reed(the ex-husband of Jennifer Reed). This is my confirmation e-mail so we can set up a time to begin. Please feel free to contact me at any time. Thank you. Here is all of my personal contact information. Casey Allen Reed Apartment C-2 1107 Yverdon Drive Fairmount Park Apartments Camp Hill,PA 17011-1250 Phones:Home-(717)730-7213 & Cell -(717)364-2740 Dear Jennifer I am very sorry for your inconvenience. I am currently out of town. I will be back on Thursday. Email is your best option to contact me as I am switching my phone system right now. It is in general best because I can address responses after hours. Please have Casey also email. As it is very late,I will give you appointment times tomorrow. >Best regards >Deb saken >Sent from my iPhone >On Sep 9,2012, at 9:42 PM, Jennifer<wincharm99@yahoo.com>wrote: >My former spouse and I have been ordered by Cumberland County family court to have co- parenting counseling, and the judge recommended Deb Salem by name. Casey Reed is my former spouse and my name is Jennifer Reed. We have left multiple voicemail messages. Please contact one of us. >>Jennifer Reed: (717)480-8407 or respond to this email >>Casey Reed: Cell: (717)364-2740, home: (717) 730-7213, email: caseyallenreed@yahoo.com f http://us.mcl207.mail.yahoo.com/mc/showMessage?sNfid=13&fid==`�/�2540S`�/�2540Search... 4/21/2013 Re: Co-Parenting counseling-Yahoo! Mail Page 2 of 2 >>Thank you, >>Jennifer Reed httP://us.mc l207.mail.yahoo.com/mc/showMessage?sMid=13&fid=%2540S%2540Search ... 4/21/2013 Co-parenting Counseling--Jennifer& Casey Reed -Yahoo! Mail Page 1 of 1 j MAIL Co-parenting Counseling--Jennifer&Casey Reed Saturday, September 15, 2012 6:52 AM From: "Jennifer" <wincharm99 @yahoo.com> To: frontdesk @interworksonline.com Hopefully you have received an email from Casey Reed by this time. Please contact me at your earliest convenience, either by phone or email, so we can discuss appointment times. Thank you. Jennifer Reed (717)480-8407 http://us.mc l207.mail.yahoo.com/mc/showMessage?sMid=38&fid=Sent&filterBy=&.rand... 4/21/2013 Re: Co-parenting Counseling--Jennifer& Casey Reed-Yahoo! Mail Page 1 of 1 Re: Co-parenting Counseling—Jennifer&Casey Reed Saturday, September 15, 2012 2:03 PM From: "Front Desk" <frontdesk @interworksonline.com> To: "Jennifer" <wincharm99 @yahoo.com> Yes did and I will send n email jointly offering the two of you time for the next two weeks. Once I start seeing clients, it is very difficult for me to keep up with scheduling until Monday and Tuesday when I focus on such things. I'm sorry for keeping you waiting. Deb Salem Sent from my iPad Deborah L. Salem On Sep 15,2012,at 6:52 AM,Jennifer<wincharm99(a')vahoo.com>wrote: Hopefully you have received an email from Casey Reed by this time. Please contact me at your earliest convenience, either by phone or email, so we can discuss appointment times. Thank you. Jennifer Reed (717)480-8407 http://us.mcl207.mail.yahoo.com/mc/showMessage?sMid=l l&fid=%25405%2540Search... 4/21/2013 RE: Co-parenting counseling OFFERING Wednesday September 26th at 11:30 AM-Ya... Page 1 of 3 �H �i MAIL*- RE: Co-parenting counseling OFFERING Wednesday September 26th at 11:30 AM Wednesday, September 19, 2012 12:50 AM From: "Jennifer" <wincharm99 @yahoo.com> To: "InterWorks front desk" <frontdesk @interworksonline.com> Dear Ms. Salem, I would be able to meet with you on Thurdsay, Sept 27 at 1 pm so that Casey can meet with you during the earlier time. It will not affect my work schedule, and I know the earlier time on 9/26 will work better with Casey's schedule. Thank you for your response and I will see you on 9/27. Jennifer Reed --On Tue, 9/18/12,InterWorks front desk <frontdesk@interworksonline.com>wrote: From: InterWorks front desk<frontdesk @interworksonline.com> Subject: RE: Co-parenting counseling OFFERING Wednesday September 26th at 11:30 AM To: "'Casey Reed"'<caseyallenreed @yahoo.com>, "'Jennifer Reed"'<wincharm99 @yahoo.com> Cc:frontdesk @interworksonline.com Date:Tuesday, September 18, 2012, 10:01 AM Dear Jennifer and Casey: Attached are forms for you to complete prior to your first session with me. I can either do an individual session with each of you then a con joint session or begin immediately with a con joint session. If you want an immediate conjoint session, I am offering Wednesday September 26th at 11:30 AM. Some people prefer to talk to me alone for one hour first and then begin the conjoint process. This is usually because they feel best able to give me their perspective on matters causing tension when they are alone and become less able when in the room with the other person. If you want separate sessions, I can see one of you at the time I offered and then the other on Thursday September 274h at 1 PM. Do your best to fill out the attached forms by then. At the least I would like the referral form; the contract; and the issues causing tension form. Best regards' Deb Salem Deborah L. Salem, CAADC, LPC http://us.me 1207.mail.yahoo.com/mc/showMessage?sMid=37&fid=Sent&filterBy=&.rand... 4/21/2013 RE: Co-parenting counseling OFFERING Wednesday September 26th at 11:30 AM-Ya... Page 2 of 3 Clinical Director INTER WORKS 2201 North Second Street,2nd Floor Harrisburg, PA Ph 717-236-6630, Fox 717-236-6677 This email contains PRIVILEGED and CONFIDENTIAL INFORMATION intended only for the use of the recipient named above. The information may be protected by state and federal laws, including, without limitation, the provisions of the Health Insurance Portability and Accountability Act of 1996 (HIPAA), which prohibit unauthorized disclosure. If you are not the intended recipient, you are hereby notified that any use or dissemination of this information is strictly prohibited. If you have received this email in error, please immediately notify the sender by reply email at the address provided above and delete this message. Thank you. From: Casey Reed [mailto:caseyallenreed @yahoo.com] Sent: Wednesday, September 12, 2012 12:54 PM To: frontdesk @interworksonline.com; Jennifer Reed Subject: Re: Co-parenting counseling Dear Ms. Saken: Hi. I am Casey Reed(the ex-husband of Jennifer Reed). This is my confirmation e-mail so we can set up a time to begin. Please feel free to contact me at any time. Thank you. Here is all of my personal contact information. Casey Allen Reed Apartment C-2 1107 Yverdon Drive Fairmount Park Apartments Camp Hill, PA 17011-1250 Phones: Home -(717)730-7213 & Cell -(717)364-2740 Dear Jennifer I am very sorry for your inconvenience. I am currently out of town. I will be back on Thursday. Email is your best option to contact me as I am switching my phone system right now. It is in general best because I can address responses after hours. Please have Casey also email. As it is very late, I will give you appointment times tomorrow. >Best regards >Deb saken >Sent from my iPhone >On Sep 9, 2012, at 9:42 PM, Jennifer<wincharm99(a,yahoo.com>wrote: >My former spouse and I have been ordered by Cumberland County family court to have co-parenting counseling, and the judge recommended Deb Salem by name. Casey Reed http://us.me l207.mail.yahoo.com/mc/showMessage?sMid=3 7&fid=Sent&filterBy=&.rand... 4/21/2013 RE: Co-parenting counseling OFFERING Wednesday September 26th at 11:30 AM-Ya... Page 3 of 3 is my former spouse and my name is Jennifer Reed. We have left multiple voicemail messages. Please contact one of us. >>Jennifer Reed: (717)480-8407 or respond to this email >>Casey Reed: Cell: (717)364-2740, home: (717) 730-7213, email: caseyallenreednyahoo.com >>Thank you, >>Jennifer Reed http://us.me 1207.mail.yahoo.com/mc/showMessage?sMid=3 7&fid=S ent&filterBy=&.rand... 4/21/2013 Re: Co-parenting counseling OFFERING Wednesday September 26th at 11:30 AM-Yah... Page 1 of 3 x400L m I- Re: Co-parenting counseling OFFERING Wednesday September 26th at 11:30 AM Tuesday, September 18, 2012 12:20 PM From: "Casey Reed" <caseyallen reed @ yahoo.com> To: "InterWorks front desk" <frontdesk @interworksonline.com>, "Jennifer Reed" <wincharm99 @yahoo.com> Dear Ms. Salem: I would definitely prefer to have an individual session prior to any joint sessions. I work on both of the dates that you listed below. Since I have to be at work by 1:30 P.M., Wednesday/09/26/12/at 11:30 A.M. would be the only session feasible for me to attend. Unless you inform me otherwise, I will plan for now on seeing you at that date and time. Sincerely, Casey From: InterWorlks front desk<frontdesk@interworksonline.com> To: 'Casey Reed'<caseyallenreed @yahoo.com>; 'Jennifer Reed'<wincharm99 @yahoo.com> Cc: frontdesk @interworksonline.com Sent:Tuesday, September 18, 2012 10:01 AM Subject: RE: Co-parenting counseling OFFERING Wednesday September 26th at 11:30 AM Dear Jennifer and Casey: Attached are forms for you to complete prior to your first session with me. I can either do an individual session with each of you then a con- joint session or begin immediately with a con joint session. If you want an immediate conjoint session, I am offering Wednesday September 26th at 11:30 AM. Some people prefer to talk to me alone for one hour first and then begin the conjoint process. This is usually because they feel best able to give me their perspective on matters causing tension when they are alone and become less able when in the room with the other person. If you want separate sessions, I can see one of you at the time I offered and then the other on Thursday September 270' at 1 PM. Do your best to fill out the attached forms by then. At the least I would like the referral form; the contract; and the issues causing tension form. Best regards' Deb Salem http://us.mel207.mail.yahoo.com/mc/showMessage?sN id=9&fid=%2540S%254OSearch&... 4/21/2013 Re: Co-parenting counseling OFFERING Wednesday September 26th at 11:30 AM-Yah... Page 2 of 3 Deborah L. Salem, CAADC, LPC Clinical Director INTER WORKS 2201 North Second Street,2nd Floor Harrisburg, PA Ph 717-236-6630, Fax 717-236-6677 This email contains PRIVILEGED and CONFIDENTIAL INFORMATION intended only for the use of the recipient named above. The information may be protected by state and federal laws, including, without limitation, the provisions of the Health Insurance Portability and Accountability Act of 1996 (HIPAA), which prohibit unauthorized disclosure. If you are not the intended recipient, you are hereby notified that any use or dissemination of this information is strictly prohibited. If you have received this email in error, please immediately notify the sender by reply email at the address provided above and delete this message. Thank you. From: Casey Reed [mailto:caseyallenreed @yahoo.com] Sent: Wednesday, September 12, 2012 12:54 PM To: frontdesk @interworksonline.com;Jennifer Reed Subject: Re: Co-parenting counseling Dear Ms. Saken: Hi. I am Casey Reed(the ex-husband of Jennifer Reed). This is my confirmation e-mail so we can set up a time to begin. Please feel free to contact me at any time. Thank you. Here is all of my personal contact information. Casey Allen Reed Apartment C-2 1107 Yverdon Drive Fairmount Park Apartments Camp Hill,PA 17011-1250 Phones: Home-(717)730-7213 & Cell -(717)364-2740 Dear Jennifer I am very sorry for your inconvenience. I am currently out of town. I will be back on Thursday. Email is your best option to contact me as I am switching my phone system right now. It is in general best because I can address responses after hours. Please have Casey also email. As it is very late, I will give you appointment times tomorrow. >Best regards >Deb saken >Sent from my iPhone >On Sep 9, 2012, at 9:42 PM, Jennifer<wincharm99(a,yahoo.com>wrote: >My former spouse and I have been ordered by Cumberland County family court to have co- parenting counseling, and the judge recommended Deb Salem by name. Casey Reed is my http://us.me l207.mail.yahoo.com/mc/showMessage?sMid=9&fid=%2540Sa/`254OSearch&... 4/21/2013 Re: Co-parenting counseling OFFERING Wednesday September 26th at 11:30 AM-Yah... Page 3 of 3 1 former spouse and my name is Jennifer Reed. We have left multiple voicemail messages. Please contact one of us. >>Jennifer Reed: (717)480-8407 or respond to this email >>Casey Reed: Cell: (717) 364-2740, home: (717)730-7213, email: casgallenreed(a,yahoo.com >>Thank you, >>Jennifer Reed http://us.mel207.mail.yahoo.com/mc/showMessage?sN id=9&fid=%25405%2540Search&... 4/21/2013 08/21/2012 07:27 FAX 17177912856 dDC IA003/004 Aug, 201 2011 10:04AM leguoiarm717H48071 Not 1368 P/ 2/1 PRESCRIPTION ^ten f 1 R1, BRIl1� T 1 Date._ Leg up Farm 4880 N.Sherman St. Mt.Wolf,PA 27347-9637 Phone.,(717)265-9294 FOX; (717)384-8071 NP4 1069148762 )) Child's Name: CA lr JRrG` A08: ( ti-I .----> DIAtmosls totw )t S, ' )�h calTherepy C) evaluation 901n$Treatment +N./Nnw•FYINMIYUUiu/auf YI+n..TUMMFYIYUIUNb+nnr/IYCNfM1NLuR/ynun.Ffnrunpnn•./u WY/NYVN\M+NY;MpINW a IfNM..wan/NRIUIIYV)iMr•.••u WNN/NYw/ ccupatlonalThempy Il Evaluation UA cfngTreatment NNN/n.mm�l NRlNaua\+i+nF111nF+FNRSfn+N.InIF111Y4vNNWu•../gllvnllNRftullW..uNfFF1lF/uulnrnRMillYlY lYf..nNRTY11Y111v1iYN L�Speech-Languege7herapy ❑ Evaluation ngoing'Creatmeftt aNFHYItN.NIl ful Ual..ntY,rtllYlYfiti6itil lvlNNININU fN1 NF.Y.+.I,NY+a+w//n,NUUw.ryulluuRYMIN,fiFnllu/FnaNnnF+../11/NN/11111nIWrv+•+nlMifllCtllin W vl nN, Mental Health/Counseling ❑ Evaluation 1914014 Treatment Comments., �Y Practica Name; J A2 10ed f r t In cz Practice Address;d"5 2chf jhlml ,{j7Gu1t� _ G�'� -, 1 e t1bm �-—> practice Phone: _?rl_ rftf Practice Fax: 7/7, 7 f j 4,p1&db --�->- Referring Physlclan-K ASF PRINT; , d r fh 222- physiclan5tg oasts.,, "-- MA Llcense : �.•x- CONPIRINtIA1,11Y NOTIC111 Thlo tfanIMIMIon may contain C0411donaai health Information that is Mrlaliy privdaled,This Information it InIonded for ode of tho nomad rodpterit(a)1 the authogrAd recipient of this Information Is prohibhed from discfoaine this Inf rMation to any partyurdou re4urred to do So by low or relutatton and la requved to dodroytho Information dUr its stated eeod has boon filled/If you Na notthe Intended recipionk yam era hereby nottlled that any dirdosure,coWns,dtstributlon,or action token in re(rtnot on the con[ants of this transmission is strictlyprobibited.lfyoutecohro this formInerror,pfassenotifythesonderimmdtateiytbarraryladltpositfonoftht Wwr at)orh t orrn 1{.,80(It Wed 02/2031) JllC 0$!21!2412 0'7:27 FAX 17177912856 W004/004 Aug, 20+ 2012 10:00AM Lewfaim7173848071 NO. 1373 Pr 2 PR55CRIPTION REF-911RINO T01 Dater Leg UP Farm 4884 N.Sherman St. Mt.Wolf,PA 17347-9637 Phone;(717)766.9294 Fax,(717)384"8011 NPit 1068748762 Child's Name, DOB,, lwdidett.�►Diegnosiscode(s): 1 . 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REED, hereby certify that service of the foregoing ANSWER TO PLAINTIFF'S PETITION FOR MODIFICATION OF A CUSTODY ORDER was made upon the following by certified mail, return receipt requested, restricted delivery, and another copy of the same document by first class mail, postage prepaid, to: CASEY A. REED JOHN F. KING,Esquire 1107 Yverdon Drive, Apt C-2 4076 Market Street Camp Hill, PA 17011 Camp Hill, PA 17011 05-07-43 Jenne VReed CASEY A. REED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. 09-5420 VS. C� JENNIFER B. REED ACTION IN CUSTODY c = , C__ « w; Defendant _ rCs F CD CjMi C l �r PETITION FOR CIVIL CONTEMPT OF CUSTODY ORDER AND NOW comes the Petitioner,pro se, and avers the following: 1. The Petitioner is Jennifer B. Reed, Defendant in the above-captioned action,and Mother of the minor children,with a current address of 316 West Front Street,PO Box 225,Lewisberry,PA 17339(hereinafter"Mother"). 2. The Respondent is Casey A.Reed,Plaintiff in the above-captioned action,and Father of the minor children,with a current address of 1107 Yverdon Drive,Apt. C-2, Camp Hill,PA 17011 (hereinafter"Father"). 3. The parties are the parents of two children, Caleb and Joshua Reed,both born on May 12,2007(hereinafter"the Children"). 2�Pe 7.3 4. On August 20, 2012,the Honorable Edward E. Guido entered an Order for shared physical custody of the subject minor children on a 50/50 basis. A true and correct copy of the Order is attached to this petition,and marked as Exhibit A. 5. Paragraph 2 of the Order states as follows: "each parent shall be entitled all records and information pertaining to the children, including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent." 6. Father has repeatedly and willfully violated Paragraph 2 of the Order by: a. In February of 2013,Father failed to inform Mother of an Open House scheduled by the West Shore School District for parents of incoming kindergarten students. b. While in attendance at the above-mentioned Open House, Father made an appointment to register the Children in kindergarten,using the Father's address and therefore making Father the"parent of record"with the school, which permits Father to be the recipient of all future communication from the school in regards to the Children. This decision was made by the Father unilaterally and without any regard to the wishes of the Mother as to which school the Children should attend or which parent should be the"parent of record." C. Father failed to inform the Mother that the appointment for kindergarten registration had been made,as Mother was only made aware of the existence of the appointment when she honored a request by the Children's Inclusion Specialist from the Capital Area Intermediate Unit to clarify parents' addresses and called the school system on 02/20/2013. d. On 02/20/2013,Mother contacted Father to inquire on the date and time of said appointment,but Father stated he did not have the information available at that time. Days later, Father texted Mother with the details of the appointment. In the interim, Mother had contacted the school with which the appointment was made and,after some difficulty, was informed of the appointment date and time. e. As all registration documents were forwarded to the Father as "parent of record,"Father was able to register Children at Washington Heights Elementary school without input from the mother. f. Upon dropping the Children off at St. Timothy Preschool on 04/03/2013, Mother found a sign-up sheet for parent-teacher conferences posted, and noticed that Father had signed up during the previous week for a conference time on 04/04/2013 at 9 a.m. Father did not inform Mother of this conference, and when he arrived in the school room at the appointed time, he stated he had forgotten about the conference. 7. Paragraph 16 of the custody Order states as follows: "The children shall continue to attend St. Timothy's preschool and to participate in the Leg Up Farm Program unless both parties agree to terminate them from participation. " 8. Father willfully violated Paragraph 16 of the Order when on 12/17/2012 he withdrew the Children from Equine Therapy at Leg Up Farm against Mother's wishes, stating cost, despite the fact that Father was informed by Mother and Leg Up Farm staff that financial assistance was available, for which Father refused to consider applying. Mother was able to have Equine Therapy resumed on 02/04/2013. 9. This matter is currently scheduled for conciliation on May 31,2013 at 9 a.m. with John Mangan. It is requested that this petition be heard at that time. WHEREFORE,the Petitioner requests that the Respondent be held in contempt of Court. Dated: May 03,2013 Respectfully submitted, Jennifer B. Reed Je er B. Reed,pro se 316 West Front Street PO BOX 225 Lewisberry,PA 17339 Verification I, JENNIFER B. REED, Petitioner, verify that the facts stated in the foregoing Petition are correct to the best of my knowledge, information, and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: 0 c ao(3 JE R B. REED CASEY A. REED, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. . JENNIFER B. REED, CIVIL ACTION - LAW Defendant NO. 09-5420 CIVIL TERM IN RE: CUSTODY ORDER OF COURT AND NOW, this 10th day of August, 2012, after hearing, it is hereby ordered and directed as follows: 1. All prior custody orders are hereby vacated and replaced with the following order. 2. The mother, Jennifer Reed, and the father, Casey Reed, shall have shared legal custody of Caleb Reed and Joshua Reed, both born 5/12/2007. The parties shall have an equal right to make all major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education, and religion. Pursuant to the terms of 23 Pa. C.S. Section 5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. The parties shall share physical custody on a 50/50 basis according to the following schedule: A. Primary physical custody shall alternate on a week on/week off basis with the exchange taking place at noon on Sundays. B. The non-custodial parent shall be entitled to two overnights of visitation each week which shall correspond with his or her days off work. Provided however, that if the party's days off coincide, father's days off shall be given priority. 4 . The parties are ordered to engage in co-parent counseling which shall commence within 30 days of today' s date. Any cost of said counseling not covered by insurance shall be divided equally between the parties. 5. Mother shall continue with her mental health counseling until successfully discharged and shall continue to take all prescribed medications. 6. Both parents may attend all doctor visits, therapy sessions, and any other medical appointments. Any parent who schedules such a session or appointment shall notify the other parent as to the time and place as soon as practical after the appointment is made. 7. The non-custodial parent shall have liberal telephone contact with the children on a reasonable basis. 8. The following holiday schedule shall supercede any other provision of this order: A. In even numbered years mother shall have the children from Christmas Eve at 6:00 p.m. to Christmas Day at noon and father shall have the children from noon on Christmas Day until noon on December 26th. In odd numbered years these times shall be reversed. B. In even numbered years mother shall have the children from 6:00 p.m. the day before Thanksgiving until 2: 00 p.m. Thanksgiving Day and father shall have them from 2:00 p.m. Thanksgiving Day until 2:00 p.m. the day after Thanksgiving. In odd numbered years these times shall be reversed. 9. Neither parent shall take the children out of state without notifying the other parent at least forty eight hours prior to departure of the intended destination and a telephone number at which they can be reached. 10. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the children from the other party or injure the opinion of the children as to the other party or may hamper the free and natural development of the children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the children. 11. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 12. Each parent shall have one week [7 consecutive days] of vacation with the children each year. Unless otherwise agreed, these seven days shall occur during the parent's scheduled week of primary custody. The vacationing parent shall give the other parent thirty days advance notice. 13. During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to- the extent possible, that other household members and/or house guests comply with this provision. 14. No party shall have any firearms in the home when the children are present unless said firearms are safely under lock and key. 15. No party shall be permitted to relocate the residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the Court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa. C.S. Section 5337. 16. The children shall continue to attend St. Timothy's Preschool and to participate in the Leg Up Farm Program unless both parents agree to terminate them from participation. 17. The parties may modify any provision in this order by mutual agreement. In the absence of mutual agreement, the terms of the order shall control. By the Court, Edward E. Guido, Mw ✓ John King, Esquire For the Plaintiff c1q Jennifer B. Reed Pro se :1 f h Q�es OW,.l � I�Jlt Verification L JENNIFER B. REED, Petitioner, verify that the facts stated in the foregoing Petition are correct to the best of my knowledge, information, and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Date: b /05/9o13 R B. REED CERTIFICATE OF SERVICE I, JENNIFER B. REED, hereby certify that service of the foregoing PETITION FOR CIVIL CONTEMPT OF CUSTODY ORDER was made upon the following by certified mail, return receipt requested, restricted delivery, and another copy of the same document by first class mail, postage prepaid, to: CASEY A. REED JOHN F. KING, Esquire 1107 Yverdon Drive, Apt C-2 4076 Market Street Camp Hill, PA 17011 Camp Hill, PA 17011 Jennife eed CASEY A. REED IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA (m= V. 2009-5420 CIVIL ACTION LAW = can rte-• -e ��'�' JENNIFER B. REED IN CUSTODY DEFENDANT Sy C r".) r ORDER OF COURT AND NOW, Thursday,May 16,2013 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan,_Jr.,Esq. , the conciliator, at 4th Floor,Cumberland County Courthouse,Carlisle on Friday,May 31,2013 9:00. AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished,to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders,and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ fohn . Man an r. Es q., Custody Conciliator IF 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 n Carlisle, Pennsylvania 1701.3 A7 Telephone (717) 249-3166 Ems. J s /?113 • V CASEY A. REED IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 09-5420 Civil Term JENNIFER B. REED Defendant : ACTION IN CUSTODY ; rn� c_ --:. Prior Judge: Edward E. Guido, J. m ° M;= cn r" ry COURT ORDER �' ° CD AND NOW, this day of June 2013,upon,consideration of the T!he Custody Conciliation Report, it is ordered and directed that: ! 1. By agreement of the parties, Mother's petition fro contempt is hereby DISMISSED. 2. Legal custody: The Mother, Jennifer Reed, and the Father, Casey Reed, shall have shared legal custody of Caleb Reed and Joshua Reed,both born 05/12/2007. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including,but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including,but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Each parent shall inform the other of medical/therapy/ educational appointments that are scheduled for the twins. 3. Physical Custody: Father and Mother shall share physical custody of the twins according to the following schedule: a. The parents shall share physical custody on a week on/week off basis from 12 pm Sunday until the following Sunday 12 pm. b. The parents have agreed to switch weeks so that Father can go on a pre-planned camping trip from 07/20/13 through 07/27/13. Mother shall choose and notify Father of a"make-up"week within two weeks of the instant Order. C. The non-custodial parent shall be entitled to two overnights of visitation each week which shall correspond with his or her days off of work. Provided however,that if the parties' days off coincide,Father's days off shall be given priority. It is understood that consideration by both parents is to be given to the amount of days each parent works in any given week. If one parent is off of work and the other parent has to work, the parents shall choose an overnight when the other parent is available to care for the twins. d. If the custodial parent is unavailable for the Children and the Children are to spend an overnight with a third party, said opportunity shall be offered to the non-custodial parent. 4. Co-parenting Counseling: The parties are strongly encouraged to engage in therapeutic family counseling(with the focus on co-parenting)with an agreed upon professional. Each parent shall ensure that they regularly attend any and all scheduled counseling appointments. The cost of said counseling, after appropriate payment through insurance, shall be split equally between the parties. 5. Mental Health Counseling: Mother shall continue with her mental health counseling until successfully discharged and shall continue to take all prescribed medications. In the event that Mother has been successfully discharged from her counseling,Mother shall provide Father with written verification from her counselor within two weeks of the instant Order. 6. Both parents may attend all doctor visits, therapy sessions, and any other medical or educational appointments. Any parent who schedules such a session or appointment shall notify the other parent as to the time and place as soon as possible after the appointment is made. 7. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 8. Holidays: The following holiday schedule shall supersede any other provision of this Order: Christmas: In even numbered years Mother shall have the Children from 12/24 at 12:00 pm until 12/25 at 12:00 pm and Father shall have the Children from 12/25 12:00 pm until 12/26.at 12:00 pm. In odd numbered years, these times shall be reversed. Thanksgiving: In even numbered years, Mother shall have the Children from Wednesday 6:00 pm until Thursday 2:00 pm and Father shall have the Children from Thursday 2:00 pm until Friday 2:00 pm. In odd numbered years,these times shall be reversed. 9. 'Neither parent shall take the Children out of state without notifying the other parent at least within forty eight hours of departure of the intended destination and a telephone number at which they can be reached. 10. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible,both parties shall not allow third parties to disparage the other parent in the presence of the Children. 11. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 12. Vacation:. Each parent shall have one week (seven consecutive days) of vacation with the Children per year. Unless otherwise agreed, these seven days shall occur during the parent's scheduled week of regular custody. The requesting parent shall give the other parent 30 days advance notice. 13. During any periods of custody or visitation,the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 14. No party shall have any firearms in the home when the Children are present unless said firearms are safely under lock and key. 15. Relocation. The parties are advised that neither party shall hereafter relocate the child or children if such relocation will significantly impair the ability of a non- relocating party to exercise his or her custodial rights unless (a) every person who has custodial rights to the child/children consents to the proposed relocation or(b) the court approves the proposed relocation. The party seeking relocation must follow the procedures required by 23 Pa.C.S. §5337. 16. The Children shall continue to attend school in Father's school district and both parents shall ensure that the Children attend and participate in any recommended therapy for the boys. Both parents shall further ensure that the twins attend school and any scheduled appoints on time during their respective custodial periods. 17. A conference call shall be initiated by the assigned conciliator Tuesday October 08, 2013 at 9:00 am to see whether the Children are regularly attending school on time and whether the parents/Children are regularly attending scheduled appointments. The parties may,modify this Order by mutual agreement in writing. In the absence of mutual consent, the terms of this Order shall control. BY CO J. Di tribution: nnifer Reed, 316 West Front Street, P.O. Box 225, Lewisberry, PA 17339 /John King, Esq., ,.�-Ioohn J. Mangan, Esq. CASEY A. REED IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 09-5420 Civil Term JENNIFER B. REED Defendant :ACTION IN CUSTODY Prior Judge: Edward E. Guido, J. 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 Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody Caleb Reed 05/12/2007 Primary Father Joshua Reed 05/12/2007 Primary Father 2. Apparently,both Mother and Father filed Petitions for Special Relief and/or Emergency Relief. An Order of Court had been issued August 11, 2009 awarding Father primary physical custody of the Children. A Conciliation Conference was held on September 15, 2009, an Order issued October 14, 2009, a conciliation conference was held October 11, 2010, an Order 'issued October 13, 2010, a telephonic conference was held 12/20/10, an Order issued January 19, 2011, a conference was held June 27, 2011, an Order issued September 20, 2011,both parents filed contempt petitions, a conference was held April 27, 2012, an Order issued July 03, 2012, an Order issued August 10, 2012 after hearing, Father filed a petition to modify, Mother filed a contempt petition, and a conference was held June 07, 2013 with the following individuals participating: The Mother, Jennifer Reed, self-represented party The Father, Casey Reed, with his counsel, John King, Esq. 3. The parties agreed to, and the undersigned recommends the entry of an Order in the form as attached. Date: 3 Jo angan, -Esquire Cuo Conciliator CASEY ALLEN REED, ) IN THE COURT OF COMMON PLEAS Plaintiff ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) No. 09-5420 _ JENNIFER BURTON REED, ) CIVIL ACTION Defendant ) IN CUSTODY ', -, :z r- Prior Judge: Edward E. Guido, J. =CD CJC EMERGENCY PETITION FOR SPECIAL RELIEF " -.< AND NOW COMES Jennifer Burton Reed, who files this Emergency Petition for Special Relief in Custody as follows: 1. A Petition for Contempt and Modification of Existing Custody Order was filed simultaneously with this Emergency Petition for Special Relief. 2. The Petitioner is Defendant, Jennifer Burton Reed, Mother of the Children, residing at 316 West Front Street,PO Box 225,Lewisberry, Pennsylvania 17339. 3. The Respondent is Plaintiff, Casey Allen Reed, Father of the Childre, residing at 1107 Yverdon Drive,Apartment C-2, Camp Hill, Pennsylvania, 17011. 4. The subject Children are: Caleb Michael Reed, age 6 Joshua Thomas Reed, age 6 5. The reason for this Petition is as follows: a. Mother fears for the safety of the Children due to the Children's aggressive and often violent behaviors. These behaviors were being treated through Play Therapy at Leg Up C �s� Farm, which has recently been terminated due to Father's erratic and threatening behavior, including a fixation on Jacque George, the Children's Play Therapist who testified at the last Custody Heating. Mother also feels that the Children needed to have additional interventions to alleviate their aggressiveness. Mother is prepared to present photographic evidence of the Children's injuries as well as witnesses to their aggressive behaviors. Additionally, in June of 2013,York County Children and Youth visited the home of the Mother in response to unfounded allegations of abuse by the Mother. During this visit,the caseworker also witnessed a violent outburst by one of the Children. Mother stated to the caseworker her concerns and belief the Children needed further therapy to ensure their safety. Mother was advised by the caseworker that this would need to be pursued through the Court. Unfortunately, since this time all behavioral therapy has been discontinued due to above-mentioned difficulties with Leg Up Farm. b. The Children have been denied Medical Assistance due to Father's refusal to act. State Medical Assistance is the only source the Children have to receive adequate therapy without having copays that present a financial hardship, as well as encountering calendar-year maximums through private insurance that would prevent Children from receiving treatment. The deadline for appeal for Medical Assistance is August 22,2013. Under the circumstances, Mother may be able to extend this deadline for a short time if the Court is unable to hear this petition before this date. However, her ability to appeal will be greatly time-limited. Currently, the Father has prevented Mother from being able to act in any way to deal with the County Office of Assistance through his insistence that only he be considered the parent of record. C. Father seeks to prevent Mother from participating in Children's education, making threats to physically be at the school to prevent Mother from"talking"to anyone there. d. The Children are to begin kindergarten on August 26, 2013 at Red Mill Elementary School. Mother is concerned about the Children's behaviors as school districts now have"Zero Tolerance" policies. Mother also fears difficulties with the school due to what has happened at Leg Up Farm and Father's threats to Mother as mentioned above. e. Father's behavior has become increasingly erratic, delusional, and paranoid. His behavior has also become threatening, making Mother fearful and contributing in large part to the termination of the Children's therapy at Leg Up Farm. Mother also fears for the safety of the Children while in the Father's care due to this erratic behavior. WHEREFORE, the Petitioner requests that the court grant the following relief: Mother respectfully request that primary physical and legal custody should be awarded to the Mother. Children should be allowed to receive therapy as medically ordered and necessary. Father shall not be permitted to prevent Mother's communication with school officials or any professional providing care to the Children. Mother also respectfully requests that Father be ordered to receive psychological evaluation due to his disturbing behaviors. Date: d ab 4 /ao i 3 By: Jennifer Burton Reed, Petitioner Pro se Verification I, JENNIFER B. REED,Petitioner, verify that the facts stated in the foregoing Emergency Petition for Special Relief are true and correct to the best of my knowledge, information, and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date: (3 FS I CQ/2•b 13 By: ennifer Burton Reed, Petitioner Pro se COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW CASEY A. REED, Plaintiff Maa V. ) No. 09-5420 0..m �t1 JENNIFER B. REED, ) C- E5 Defendant C.) " Petition for Contempt and Modification 1. Petitioner is Defendant, JENNIFER B. REED, who currently resides at 316 West Front Street, P.O. Box 225, Lewisberry, Cumberland County, PA 17339. 2. Respondent is Plaintiff, CASEY A. REED, who currently resides at 1107 Yverdon Drive, Apartment C-2, Camp Hill, Cumberland County, PA 17011. 3. Petitioner and Respondent are the natural parents of the following children: Name Age JOSHUA T. REED 6 years CALEB M. REED 6 years 4. A custody order was entered on 08/10/2012, in the Cumberland County Court of Common Pleas. A copy of the custody order is attached. S. Respondent has willfully violated the custody order, as follows: On May 28, 2013, Father filed a Petition for Modification Of Custody, specifically requesting that the Order be revised to eliminate participation at Leg Up Farm. On May 24, 2013, the Father, without the knowledge of the Mother, held a meeting with Leg Up Farm administration and legal counsel withdrawing his consent for Play Therapy for the Children. Due to the fact that the presiding Order at the time, dated August 10, 2012, precluded the cessation of therapy at Leg Up Farm without consent of both parents, Leg Up Farm decided to �� od case 'Dntitinn fnr("nntPmrt and A/inriiPiratinn 'Dann 2 ^,F9 continue the therapy pending action of the Court. A copy of the letter describing the meeting, sent by Leg Up Farm's counsel, Attorney Michelle Pokrifka to the Father and dated June 7, 2013, is attached and labeled as exhibit "A" On June 7, 2013, a conciliation conference was held in which no changes were made to the Order in regards to Leg Up Farm. Since that time, Father has been increasingly belligerent and hostile to Leg Up Farm staff, as evidence by an email sent in the early morning of August 14, 2013, in which Father questions Jacque George regarding communication between the Mother and Dr. Jeanette Ramer, the Developmental Pediatrician at Hershey Medical Center treating the Children, in which Mother brought forth concerns shared with both her and the Father by Ms. George. A copy of this email, sent by the Father, as well as a copy of the emails between the Mother and Dr. Ramer referenced, is attached and labeled exhibit "B." Additionally, Mother is aware of other hostile communication that has been ongoing by the Father toward Leg Up Farm staff, particularly Ms. George. It should be noted that in the email to Ms. George, Father mentions that Red Mill Elementary School is located in "your hometown of Etters, PA." As this fact had no bearing on the communication in the email, it can be assumed that this remark was a veiled threat, implying that Father knew where Ms. George lived. On the afternoon of August 14, 2013, Parents received email communication from Leg Up Farm legal counsel informing the Parents of Leg Up Farm's decision to terminate therapy for the children due to the ongoing dispute between the Parents. A copy of this letter is attached and labeled as exhibit "C." In a separate but related matter, Mother became aware on August 13, 2013, that Father had changed the Children's insurance without the Mother's knowledge. The letter from the Father informing Mother of this change, dated August 8, 2013, is attached and labeled exhibit "D." in this letter, Father claims this change was due to the boys being denied continued state Medical Assistance coverage after the recertification completed by the Father was deemed insufficient. Un+itinn fnr f nntAmr�t and Ai r%A;4;ratinn UanP A r%r 2 However, the denial from Medical Assistance was dated July 23, 2013. The effective date of the Children's new insurance through the Father's employer is June 26, 2013, demonstrating Father's foreknowledge of the denial. The copy of the denial of letter for Medical Assistance fists little to no information provided from the Father. Mother has requested in the past to take responsibility for completing this paperwork, but Father has denied these requests. The result of this change is a copay being assessed for therapy, causing financial hardship to continue therapy. Also, Children are now subject to a calendar year maximum payout which will cause them to run out of benefits prior to the end of the year. Additionally, Father did not make Mother or Leg Up Farm aware of this change in a timely manner to make the information useful. Father sent the above-mentioned letter to Mother as well as a letter to the Leg Up Farm billing department on August 8, 2013, the effective termination date of the Children's Medical Assistance. This caused Leg Up Farm to inappropriately bill Gateway Health Plan as primary payor rather than Father's new insurance for all appointments from June 26, 2013 until August 8, 2013. This caused Leg Up Farm to have to re-bill for all of these services, and will leave copays unpaid for those appointments. As evidenced by the fact that Father was under the impression that Play Therapy would not be covered under his insurance, as well as the fact that the copays would become unaffordable, Mother believes this action was taken as yet another way to prevent the Children from receiving treatment at Leg Up Farm. Also, on August 15, 2013, Father called the Mother to discuss the transportation arrangements for getting the Children to school. When Mother expressed her intention be at the school on the Children's first day of Kindergarten to witness this childhood milestone, the Father's response was to question who the Mother was going to talk to at the school and stated he would be sure to be at the school to "make sure" Mother did not talk to anyone at the school. *copy of the-emai sent by the-Nfether-to i it it V ,DAtitr`r%" nrR 6. Petitioner seeks to modify the custody order because: Because of the Children's special needs, documented by both the Children's medical records and evaluations by the West Shore School District and already heard before the Court, the Children need to continue therapy. Father's inappropriate and threatening behavior toward Ms. George and Leg Up Farm has caused the facility to terminate the Children's therapy that had been greatly beneficial to the Children. Father has sought and is continuing to seek to prevent the Mother from having contact with the Children's school. 7. Petitioner believes the custody order should be changed as follows: It is the best interest of the Children to reside primarily with the Mother as the Mother will continue to provide for the Children's needs for therapy, as well as keep Father informed of changes affecting the Children, something Father has repeatedly failed to do. Primary residence with the Mother will also allow Mother to reapply for Medical Assistance. Father is currently in possession of original documents required for the Mother to do this, so Mother respectfully requests that the Court order Father to turn these documents over to the Mother. Mother also requests the appointment of a Guardian Ad Litem to represent the Children's best interest in this case. Mother further requests that the Honorable Court asses all fees and cost of the Guardian Ad Litem to the Father. Mother also respectfully requests that Father be ordered not to attempt to interfere with Mother's open communication with all physicians, care providers, and school personnel involved in the care or education of the Children. pPtitinn fnr f nnt,-mn+ and Aifnriifiratinn UanP F of R WHEREFORE, Petitioner respectfully requests that this Court find Respondent in contempt of Court and modify the Order as requested. Date: . ©-A 1 U/,9-0(-3 JE B. REED, Defendant Verification I, JENNIFER B. REED, Defendant, verify that the facts stated in the foregoing Petition are true and correct to the best of my knowledge, information and belief. Petitioner understands that false statements therein are subject to the penalties of 18 Pa. C.S.A. '4904 relating to unsworn falsification to authorities. Date: b 1 ca [ ,-)013 JE REED, Defendant APtitinn fnr rr%nt,-mnt and T% nrliFiratinn Uatto I of R CASEY A. REED, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. JENNIFER B. REED, CIVIL ACTION - LAW Defendant NO. 09-5420 CIVIL TERM IN RE: CUSTODY ORDER OF COURT AND NOW, this 10th day of August, 2012, after hearing, it is hereby ordered and directed as follows: 1. All prior custody orders are hereby vacated and replaced with the following order. 2.1 The mother, Jennifer Reed, and the father, Casey Reed, shall have shared legal custody of Caleb Reed and Joshua Reed, both born 5/12/2007 . The parties shall have an equal right to make all. major non-emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education, and religion. Pursuant to the terms of 23 Pa. C.S. Section 5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental., religious or school records, the residence address of the children and of the other parent. To the, extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3 . The parties shall share physical custody on a 50/50 basis according to the following schedule: A. Primary physical custody shall alternate on a week on/week. off basis with the exchange taking place at noon on Sundays. B. The non-custodial parent shall be entitled to two overnights of visitation each week which shall correspond with his or her days off work. Provided however, that if the party's days off coincide, father's days off shall be given priority. 4 . The parties are ordered to engage in co-parent counseling which shall commence within 30 days of today' s date. Any cost of said counseling not covered by insurance shall be divided equally between the parties. 5. Mother shall continue with her mental health counseling until successfully discharged and shall continue to take all prescribed medications. 6 . Both parents may attend all doctor visits, therapy sessions, and any other medical appointments. Any parent who schedules such a session or appointment shall notify the other parent as to the time and place as soon as practical after the appointment is made. 7. The non-custodial parent shall have liberal telephone contact with the children on a reasonable basis. 8. The following holiday schedule shall supercede any other provision of this order: A. In even numbered years mother shall have the children from Christmas Eve at 6: 00 p.m. to Christmas Day at noon and father shall have the children from noon on Christmas Day until noon on December 26th. In odd numbered years these times shall be reversed. B. In even numbered years mother shall have the children from 6:00 p.m. the day before Thanksgiving until 2 :00 p.m. Thanksgiving Day and father shall have them from 2:00 p.m. Thanksgiving Day until 2 :00 p.m, the day after Thanksgiving. In odd numbered years these times shall be reversed. I 9 . Neither parent shall take the children out of state without notifying the other parent at least forty eight hours prior to departure of the intended destination and a telephone number at which they can be reached. 10. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the children from the other party or injure the opinion of the children as to the other party or may hamper the free and natural development of the children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent i in the presence of the children. 11.. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 12. Each parent shall have one week [7 consecutive days] of vacation with the children each year. Unless otherwise agreed, these seven days shall occur during the parent 's scheduled week of primary custody. The vacationing parent shall give the other parent thirty days advance notice. 13 . During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 14. No party shall have any firearms in the home when the children are present unless said firearms are safely under lock and key. 15. No party shall be permitted to relocate the I residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the Court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa. C.S. Section 5337 . 16. The children shall continue to attend St. Timothy's Preschool and to participate in the Leg Up Farm Program unless both parents agree to terminate them from participation. 17. The parties may, modify any provision in this order by mutual agreement. In the absence of mutual agreement, the terms of the order shall control. By the Court, N ` Edward E. Guido, J. V John King, Esquire For the Plaintiff Jennifer B. Reed Pro se l f h �Q,es it,,led) �G 1 CASEY A.REED IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. No. 09-5420 Civil Term JENNIFER B.REED Defendant :ACTION IN CUSTODY Prior Judge: Edward E. Guido,J. 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 Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Caleb Reed 05/12/2007 Primary Father Joshua Reed 05/12/2007 Primary Father 2. Apparently,both Mother and Father filed Petitions for Special Relief and/or Emergency Relief. An Order of Court had been issued August 11,2009 awarding Father primary physical custody of the Children. A Conciliation Conference was held on September 15,2009,an Order issued October 14, 2009, a conciliation conference was held October 11,2010,an Order issued October 13,2010, a telephonic conference was held 12/20/10,an Order issued January 19,2011, a conference was held June 27,2011,an Order issued September 20,2011,both parents filed contempt petitions, a conference was held April 27,2012,an Order issued July 03,2012,an Order issued August 10,2012 after hearing,Father filed a petition to modify, Mother filed a . contempt petition,and a conference was held June 07,2013 with the following individuals participating: The Mother,Jennifer Reed,self-represented party - The Father,Casey Reed,with his counsel,John King,Esq. 3. The parties agreed to,and the undersigned recommends the entry of an Order in the form as attached. Date: �l / — 3 J?bip angan,Esquire Cloy Conciliator CASEY A.REED . IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. No. 09-5420 Civil Term JENNIFER B.REED Defendant ACTION IN CUSTODY � Prior Judge: Edward E. Guido,J. z� r COURT ORDER ° AND NOW,this day of June 2013,upon consideration of the he?0: Custody Conciliation Report,it is ordered and directed that: D q 1. By agreement of the parties,Mother's petition fro contempt is hereby DISMISSED. 2. Legal custody: The Mother,Jennifer Reed, and the Father,Casey Reed,shall have shared legal custody of Caleb Reed and Joshua Reed,both born 05/12/2007. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including,but not limited to,-all decisions regarding their health,education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including,but not limited to,medical,dental,religious or school records,the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information,that parent shall be required to share the same,or copies thereof,with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Each parent shall inform the other of medical/therapy/ educational appointments that are scheduled for the twins. 3. Physical Custody: Father and Mother shall share physical custody of the twins according to the following schedule: a. The parents shall share physical custody on a week on/week off basis from 12 pm Sunday until the following Sunday 12 pm. b. The parents have agreed to switch weeks so that Father can go on a pre-planned camping trip from 07/20/13 through 07/27/13. Mother shall choose and notify Father of a"make-up"week within two weeks of the instant Order. c. The non-custodial.parent shall be entitled to two overnights of visitation each week which shall correspond with his or her days off of work. Provided however,that if the parties' days off coincide,Father's days off shall be given priority. It is understood that consideration by both parents is to be given to the amount of days each parent works in any given week. If one parent is off of work and the other parent has to work,the parents shall choose an overnight when the other parent is available to care for the twins. d. If the custodial parent is unavailable for the Children and the Children are to spend an overnight with a third party,said opportunity shall be offered to the non-custodial parent. 4. - Co-parenting Counseling: The parties are strongly encouraged to engage in " therapeutic family counseling(with the focus on co-parenting)with an agreed upon professional. Each parent shall-ensure that they regularly attend any and all scheduled counseling appointments. The cost of said counseling,after appropriate payment through insurance,shall be split equally between the parties. 5. Mental Health Counseling: Mother shall continue with her mental health counseling until successfully discharged and shall continue to take all prescribed medications. In the event that Mother has been successfully discharged from her counseling,Mother shall provide Father with written verification from her counselor within two weeks of the instant Order. 6. Both parents may attend all doctor visits,therapy sessions,and any other medical or educational appointments. Any parent who schedules such a session or appointment shall notify the other parent as to the time and place as soon as possible after the appointment is made. 7. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 8. Holidays: The following holiday schedule shall supersede any other provision of this Order: Christmas: In even numbered years Mother shall have the Children from 12/24 at 12:00 pm until 12/25 at 12:00 pm and Father shall have the Children from 12/25 12:00 pm until 12/26 at 12:00 pm. In odd numbered years, these times shall be reversed. Thanksgiving: In even numbered years,Mother shall have the Children from Wednesday 6:00 pm until Thursday 2:00 pm and Father shall have the Children from Thursday 2:00 pm until Friday 2:00 pm. In odd numbered years,these times shall be reversed. 9. Neither parent shall take the Children out of state without notifying the other parent at least within forty eight hours of departure of the intended destination and a telephone number at which they can be reached. 10. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party,or injure the opinion of the Children as to the other party,or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible,both parties shall not allow third parties to disparage the other parent in the presence of the Children. 11. In the event of a medical emergency,the custodial party shall notify the other party as soon as possible after the emergency is handled. 12. Vacation: Each parent shall have one week(seven consecutive days)of vacation with the Children per year. Unless otherwise agreed, these seven days shall occur during the parent's scheduled week of regular custody. The requesting parent shall give the other parent 30 days advance notice. 13. During any periods of custody or visitation,the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure,to the extent possible,that other,household members and/or house guests comply with this provision. 14. No party shall have any firearms in the home when the Children are present unless said firearms are safely under lock and key. 15, Relocation.The parties are advised that neither party shall hereafter relocate the child or children if such relocation will significantly impair the ability of a non- relocating party to exercise his or her custodial rights unless(a)every person who has custodial rights to the child/children consents to the proposed relocation or(b) the court approves the proposed relocation.The party seeking relocation must follow the procedures required by 23 Pa.C.S. §5337. 16. The Children shall continue to attend school in Father's school district and both parents shall ensure that the Children attend and participate in any recommended therapy for the boys. Both parents shall further ensure that the twins attend school and any scheduled appoints on time during their respective custodial periods. 17. A conference call shall be initiated by the assigged conciliator Tuesday October 08,2013 at 9:00 am to see whether the Children are regularly attending school on time and whether the parents/Children are regularly attending scheduled appointments. 18. The parties may modify this Order by mutual agreement in writing. In the absence of mutual consent,the terms of this Order shall control. K. tY Distribution, Reed,316 West Front Street,P.O.Box 225, Lewisberry,PA 17339 ,/fohn King,Esq., ,.,lohn I Mangan,Esq. to OL CASEY ALLEN REED, ) IN THE COURT OF COMMON PLEAS Plaintiff ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) No. 09-5420 JENNIFER BURTON REED, ) CIVIL ACTION Defendant ) IN CUSTODY Prior Judge: Edward E. Guido, J. ORDER AND NOW THIS C/ day of A �Ltx dG,rt ' 20 /2% , upon consideration of the attached Emergency Petition for Special Relief, it is Hereby ordered as follows: ergency etrtion or pecia ehef is DENIED - - �.earingon-the-Emergency-P-etAion..fo.-S mened at k _m-in-C-ourtroom 4 , Cumberland.County.Courthouse, I-6eurthouse-Square;Car--lisle;Pennsylvania;L7._Q1.3-� +h-- — eaGy pat+ r F r C.n i�c.iicz.•• !`D AA T all,.w?. I �� Y `=- THE COURT: C) c3. t�r- Ujo- c �z mW Judge l S YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association Lawyer Referral Service Phone: (800)990-9108 AMERICAN WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. CASEY A. REED IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-5420 CIVIL ACTION LAW ,0 zM C F JENNIFER B.REED c � N IN CUSTODY .�x> CZ r DEFENDANT C3 j p ,T zr yC fat CD ORDER OF COURT CT" AND NOW, Friday,August 23,2013 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan,Jr.,Esq. , the conciliator, at 4th Floor,Cumberland County Courthouse,Carlisle on Tuesday,October 08,2013 9:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders,and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ John . Man q fr., 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 On Carlisle, Pennsylvania 17013 0 P/ Telephone (717) 249-3166 CASEY ALLEN REED IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-5420 CIVIL ACTION LAW -ow rn JENNIFER BURTON REED IN CUSTODY DEFENDANT :3r- -e- AND NOW, Tuesday,August 27,2013 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John JL Mangan,Jr.°'Emq. the conciliator, 4th Floor,Cumberland C Courthouse,Carlisle on Tuesday,October 08 2013 9:00 /kNW for u 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 tn appear ut the conference may provide grounds for entry ofn 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 tothe conciliator 48 hours prior to scheduled hearing. FOR THE COURT, 8y: 6/ john-f. Man ag fhvEsq.�el Custody Conciliator. The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with [)isohi|hea Act of )99O. 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 o,hearing. YOU SHOULD TAKE THIS PAPER,7D YOUR ATTORNEY ATONCE. 8P YOU DONOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE,G0TOOR TELEPHONE THE OFFICE SET FORTH 8EL()VV T8 FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Cor|io|� Pennsylvania l7Ol3 wJ~��«J /�*i/u�{ -L' ` ��or" '" r��-z�*x� T�|ophonc (717)249-3166 ' U/5 'Ale -� m�^^�u#� \J�� rw� �_m�V �*�u"� *\ 6��� [-i�l� �/ / / ��� CASEY A. REED : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 09-5420 Civil Term JENNIFER B. REED Defendant : ACTION IN CUSTODY 7 , C: Prior Judge: Edward E. Guido, J. I-71 _ (/D r.,, COURT ORDER w t_,`, AND NOW,this 4 N' day of October 2013,upon consideration of e -° attached Custody Conciliation Report, it is ordered and directed that: '`•' cr, _ 1. This Order is entered pursuant to a CustocliConciliation Conf nce. A Custody Hearing is hereby scheduled on the /qrn day of 0 , 2013 at :30 amAt 1 in Courtroom number 3 in the Cumberland County Court of Common Pleas, Carlisle,PA 17013 at which time testimony will be taken in regard to the physical custody for the subject Children. For purposes of this hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party(or a party unrepresented) shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the hearing date. 2. Legal custody: The Mother, Jennifer Reed, and the Father, Casey Reed, shall have shared legal custody of Caleb Reed and Joshua Reed,both born 05/12/2007. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including,but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including,but not limited to,medical, dental,religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Each parent shall inform the other of medical/therapy/ educational appointments that are scheduled for the twins. 3. Physical Custody: Father and Mother shall share physical custody of the twins according to the following schedule: a. The parents shall share physical custody on a week on/week off basis from 12 pm Sunday until the following Sunday 12 pm. b. The non-custodial parent shall be entitled to two overnights of visitation each week which shall correspond with his or her days j off of work. Provided however, that if the parties' days off // coincide, Father's days off shall be given priority. It is understood /, that consideration by both parents is to be given to the amount of �/ days each parent works in any given week. If one parent is off of work and the other parent has to work, the parents shall choose an overnight when the other parent is available to care for the twins. c. If the custodial parent is unavailable for the Children and the Children are to spend an overnight with a third party, said opportunity shall be offered to the non-custodial parent. 4. - Co-parenting Counseling: The parties are strongly encouraged to engage in therapeutic family counseling(with the focus on co-parenting) with an agreed upon professional. Each parent shall ensure that they regularly attend any and all scheduled counseling appointments. The cost of said counseling, after appropriate payment through insurance, shall be split equally between the parties. 5. Mental Health Counseling: Mother shall continue with her mental health counseling until successfully discharged and shall continue to take all prescribed medications. In the event that Mother has been successfully discharged from her counseling, Mother shall provide Father with written verification from her counselor within two weeks of the instant Order. 6. Both parents may attend all doctor visits, therapy sessions, and any other medical or educational appointments. Any parent who schedules such a session or appointment shall notify the other parent as to the time and place as soon as possible after the appointment is made. 7. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 8. Holidays: The following holiday schedule shall supersede any other provision of this Order: Christmas: In even numbered years Mother shall have the Children from 12/24 at 12:00 pm until 12/25 at 12:00 pm and Father shall have the Children from 12/25 12:00 pm until 12/26 at 12:00 pm. In odd numbered years, these times shall be reversed. Thanksgiving: In even numbered years, Mother shall have the Children from Wednesday 6:00 pm until Thursday 2:00 pm and Father shall have the Children from Thursday 2:00 pm until Friday 2:00 pm. In odd numbered years, these times shall be reversed. 9. Neither parent shall take the Children out of state without notifying the other parent at least within forty eight hours of departure of the intended destination and a telephone number at which they can be reached. 10. Neither party may say or do anything nor permit a third party to do or say • anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible,both parties shall not allow third parties to disparage the other parent in the presence of the Children. 11. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 12. Vacation: Each parent shall have one week(seven consecutive days) of vacation with the Children per year. Unless otherwise agreed, these seven days shall occur during the parent's scheduled week of regular custody. The requesting parent shall give the other parent 30 days advance notice. 13. During any periods of custody or visitation,the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 14. No party shall have any firearms in the home when the Children are present unless said firearms are safely under lock and key. 15. Relocation. The parties are advised that neither party shall hereafter relocate the child or children if such relocation will significantly impair the ability of a non- relocating party to exercise his or her custodial rights unless (a) every person who has custodial rights to the child/children consents to the proposed relocation or(b) the court approves the proposed relocation. The party seeking relocation must follow the procedures required by 23 Pa.C.S. §5337. 16. The Children shall continue to attend school in Father's school district and both parents shall ensure that the Children attend and participate in any recommended therapy for the boys. Both parents shall further ensure that the twins attend school and any scheduled appoints on time during their respective custodial periods. 17. The parties may modify this Order by mutual agreement in writing. In the absence of mutual consent,the terms of this Order shall control. Ern." RT, J. D' ennifer Reed, 316 West Front Street, P.O. Box 225, Lewisberry, PA 17339 hn King, Esq., hn J. Mangan, Esq. ,.SS/7/Z lect, /00.3 CASEY A. REED : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. . : No. 09-5420 Civil Term JENNIFER B. REED . Defendant : ACTION IN CUSTODY Prior Judge: Edward E. Guido, J. 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 Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Caleb Reed 05/12/2007 Primary Father Joshua Reed 05/12/2007 Primary Father 2. Apparently,both Mother and Father filed Petitions for Special Relief and/or Emergency Relief. An Order of Court had been issued August 11, 2009 awarding Father primary physical custody of the Children. A Conciliation Conference was held on September 15, 2009, an Order issued October 14, 2009, a conciliation conference was held October 11, 2010, an Order issued October 13, 2010, a telephonic conference was held 12/20/10, an Order issued January 19, 2011, a conference was held June 27, 2011, an Order issued September 20, 2011,both parents filed contempt petitions, a conference was held April 27, 2012, an Order issued July 03, 2012, an Order issued August 10, 2012 after hearing, Father filed a petition to modify, Mother filed a contempt petition, a conference was held June 07, 2013, an Order issued June 19, 2013, Mother again filed a contempt/modification/special relief petition and a conference was held October 08, 2013 with the following individuals participating: The Mother, Jennifer Reed, self-represented party The Father, Casey Reed, with his counsel, John King, Esq. 3. Mother's position on custody is as follows: As it stands now,the parents share custody on a week on/week off schedule. Both parents indicate that for the most part, the situation has not presented many difficulties. The parents have mutually agreed that full day kindergarten with specialized therapy at Red Mill Elementary is the best school for the Children. The Children currently attend speech therapy and occupational therapy in the classroom setting. Neither parent is reporting any problems in getting the Children to school. However, Mother believes that the Children need additional therapy outside the school setting. Mother is upset that the Children are no longer attending Leg Up Farm play therapy. Mother is further concerned that she is not informed about the medical insurance change issue. Mother indicates that the Children were covered by Medicaid previously and Father did not send in the correct paperwork for insurance coverage through Medicaid. Father has enrolled the Children through his private insurance and Mother states that the co-pays are somewhat of a financial hardship. Apparently Mother is going to be requesting primary physical custody of the Children due to Father allegedly making unilateral decisions without her being informed and her having input. 4. Father's position on custody is as follows: Father feels at a loss as to why Mother is requesting a hearing. Father indicates that the twins are doing extremely well now. By all accounts, the services offered at Red Mill Elementary are adequately meeting the Children's needs. Father indicates that he does not feel that the Children need additional services outside the school setting. While the Children did attend the Leg Up Farm therapy, they previously did so during the day. In order for the Children to attend Leg Up, the Children would have to be withdrawn from school for periods during the day; an option that Father does not believe is in the Children's best interest. At this point, there are not any openings for after school therapy with Leg Up. It should be noted that the parents are going to a developmental therapist (Dr. Ramer) at Hershey the first week of November 2013 to discuss the Children's developmental needs. Both parents have agreed to follow Dr. Ramer's recommendations. Father indicated that if additional therapy is warranted or recommended,he is willing to abide by the recommendation. In terms of the medical insurance issue, Father indicates that he currently has them covered through private insurance and that the coverage is very good. Father questions the motivation for Mother's request to have the Children covered through Medicaid. Father indicates that the co-pays for the current insurance is only$15.00 per Child. Finally, Father states that he does include Mother in decisions about the Children's welfare and that all decisions have been made for the Children with their welfare of paramount importance. 5. The Conciliator recommends an Order in the form as attached scheduling a Hearing and entering an Order of Court regarding custody as outlined. It is the Conciliator's belief that this would be in the Children's best interest. It is expected that the Hearing will require one half day. 6. The proposed recommended Order may contain a requirement that the parties file a pre-trial memorandum with the Judge to whom the matter has been assigned. Date: (a7 Fr7/2 Jo�4 J. i/ angan, Esquire C sto• Conciliator CASEY A. REED, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. • JENNIFER B. REED, : CIVIL ACTION - LAW Defendant : NO. 09-5420 CIVIL TERM ORDER OF COURT AND NOW, this 19th day of November, 2013 , we are satisfied that there has been no willful disobedience or violation of our Court Order, an any existing contempt petitions are vacated. By the Court, '°;,;;;;;;) Edward E. Guido, J. John King, Esquire For the Plaintiff /nifer B. Reed Pro se srs ? C3 11/17/13 cis tZtt CD MCI . i i I i i I i i i I i I i i i i • CASEY A. REED, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. ":j t.:.> .w. rri{ rn ES" JENNIFER B. REED, : CIVIL ACTION - LAW -* Defendant : NO. 09-5420 CIVIL TERM -<> cDr-) IN RE : CUSTODY zr 3>c, t,.; C „ ORDER OF COURT AND NOW, this 19th day of November, 2013, after hearing, it is hereby ordered and directed as follows : 1 . All prior Custody Orders are hereby vacated and replaced with the following Order. 2 . The mother, Jennifer Reed, and the father, Casey Reed, shall have shared legal custody of Caleb Reed and Joshua Reed, both born 5/12/2007 . The parties shall have an equal right to make all major non-emergency decisions affecting the children' s general well-being including, but not limited to, all decisions regarding their health, education, and religion. Pursuant to the terms of 23 Pa. C. S . Section 5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the residence address of the children and of the other parent . To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the 3 ' records and information of reasonable use to the other parent . 3 . The parties shall share physical custody on a 50/50 basis according to the following schedule: A. Primary physical custody shall alternate on a week-on/week-off basis with the exchange taking place at noon on Sundays . B. The non-custodial parent shall be entitled to two overnights of visitation each week which shall correspond with his or her days off work. Provided however, that if the party' s days off coincide, father' s days off shall be given priority. C. If the custodial parent is unavailable for the children and the children are to spend an overnight with a third party, said opportunity shall be offered to the non-custodial parent . The spouse of father shall not be deemed to be a third party for purposes of this provision of the Order. 4 . The parties are ordered to engage in co-parent counseling with Norman Stovall [or any other counselor mutually agreed upon] which shall commence within 30 days of today' s date . Any cost of said counseling not covered by insurance shall be divided equally between the parties . 5 . Both parents may attend all doctor visits, therapy sessions, and any other medical appointments . Any s ' parent who schedules such a session or appointment shall notify the other parent as to the time and place as soon as practical after the appointment is made . 6 . The non-custodial parent shall have liberal telephone contact with the children on a reasonable basis. This shall include the availability of mother to call children on father' s home phone when father is at work. 7 . Holidays : The following holiday schedule shall supercede any other provision of this Order: Christmas : In even-numbered years, mother shall have the children from 12/24 at 12 : 00p.m. until 12/25 at 12 : 00 p.m. and father shall have the children from 12/25 at 12 : 00 p.m. until 12/26 at 12 : 00 p.m. In odd-numbered years, these times shall be reversed. Thanksgiving: In even-numbered years, mother shall have the children from Wednesday at 6 : 00 p.m. until Thursday at 2 : 00 p.m. and father shall have the children from Thursday at 2 : 00 p.m. until Friday at 2 : 00 p.m. In odd-numbered years, these times shall be reversed. 8 . Neither parent shall take the children out of state without notifying the other parent at least 48 hours prior to departure of the intended destination and a telephone number at which they can be reached. 9 . Neither party may say or do anything nor permit a third party to do or say anything that may estrange the children from the other party or injure the opinion of the children as to the other party or may hamper the free and natural development of the children' s love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the children. 10 . In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 11 . Each parent shall have one week [7 consecutive days] of vacation with the children each year. Unless otherwise agreed, these seven days shall occur during the parent ' s scheduled week of primary custody. The vacationing parent shall give the other parent 30 days advance notice. 12 . During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 13 . No party shall have any firearms in the home when the children are present unless said firearms are safely under lock and key. 14 . No party shall be permitted to relocate the residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the Court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa. C.S . Section 5337 . 15 . The children shall continue to attend school in father' s school district, and both parents shall ensure that the children attend and participate in any recommended therapy for the boys . Both parents shall further ensure that the twins attend school and any scheduled appointments on time during their respective custodial periods . 16 . The children shall participate in speech and/or occupational therapy as recommended by their pediatrician. To the extent that the therapy is not covered by insurance or that there is a co-pay, the parties shall share those costs equally. 17 . The parties may modify any provision in this Order by mutual agreement . In the absence of mutual agreement, the terms of the Order shall control . By the Qom. Edward E . Guido, J. -hn King, Esquire ----Jennifer B. Reed For the Plaintiff Pro se srs t?4f/k022k1I.F4(.. // 1Q//3 JOHN F. KING LAW, P.C. John F. King, Esq. ID# 61919 4076 Market Street, Ste 100 Camp Hill, PA 17011 717-695-2222 717-695-2207 FAX LED-OFF10E CP THE PROTHON0TA,T1,' 2014 JUN 12 PM 3:Q5 CUMBERLAND COUNTY PENNSYLVANIA CASEY A. REED v. JENNIFER B. REED Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-5420 : CIVIL ACTION - LAW Defendant : CUSTODY/VISITATION Previous Judge: Honorable Edward Guido PETITION FOR LEAVE TO WITHDRAW AS PLAINTIFF'S COUNSEL AND NOW comes the Petitioner, John F. King Law, P.C., by John F. King, Esquire, seeking leave of this Honorable Court to withdraw as counsel for Plaintiff, Casey A. Reed, pursuant to the Rules of Professional Conduct Rule 1.16, and avers as follows: 1. Petitioner is counsel of record for Plaintiff herein, by virtue of having filed an Entry of Appearance on or about March 9, 2012. 2. On or about March 28, 2014, Plaintiff discharged Petitioner as attorney, and picked up his physical file. 3. Pursuant to the Rules of Professional Conduct Rule 1.16(a)(3), Petitioner should be allowed to withdraw due to having been discharged. 4. Pursuant to the Rules of Professional Conduct Rule 1.16(b)(1), Petitioner believes that withdrawal can be accomplished without material adverse effect on the interests of the client. 5. Pursuant to the Rules of Professional Conduct Rule 1.16(b)(7), Petitioner believes that other good cause exists. WHEREFORE, Petitioner seeks leave of this Honorable Court to terminate Petitioner's representation of the Plaintiff and to withdraw his appearance as counsel in the above -captioned matter. Date: June 2014 JOHNF.KI G LAW By: John F. King, Esq. D# 61919 4076 Market Street, Camp Hill, PA 17011 (717) 695-2222 (717) 695-2207 VERIFICATION I, John F. King, Esq., hereby acknowledge that I am the Petitioner in the foregoing action; that I have read the foregoing Petition to Withdraw; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: June ,2014 CASEY A. REED : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 09-5420 JENNIFER B. REED : CIVIL ACTION - LAW Defendant : CUSTODY/VISITATION ORDER OF COURT AND NOW, this 18TH day of JUNE, 2014, based upon counsel's assertions contained in the Petition, John F. King, Esquire, is hereby granted leave to withdraw as plaintiff's counsel. Edward E. Guido, J. istribution: }ohn F. King, Esq., 4076 Market Street, .Ste 100, Camp Hill, PA 17011 ennifer. Reed, 316 West Front Street, Lewisberry, PA 17339 ,,asey Reed, 1107 Yverdon Drive, Apt. C-2, Camp Hill, PA 17011-1250 i€s1c119//y /moi 1.0 ffl JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff CASEY A. REED, Plaintiff 1 F..�. Plr0 i -t0INO /•... 2 )IL SEP 25 PH 2:03 CUMBERLAND COUNT'- PENNSYLVANIA : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 09-5420 CIVIL TERM JENNIFER B. REED, : CIVIL ACTION - LAW Defendant : CUSTODY TO THE HONORABLE EDWARD E. GUIDO, JUDGE OF SAID COURT: DEFENDANT FATHER'S PETITION FOR CONTEMPT AND NOW comes the Plaintiff, Casey A. Reed, and respectfully avers the following in support of this Petition for Contempt: 1. Petitioner is Plaintiff above, Casey A. Reed, hereinafter referred to as Father, currently residing at 605 Market Street, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. Respondent is Defendant above, Jennifer B. Reed, hereinafter referred to as Mother, currently residing at 1931 Fulton Street, Harrisburg, Dauphin County, Pennsylvania, 17102. 3. There are two (2) dependent children from the relationship of the parties, namely Caleb Michael Reed, born May 12, 2007, and Joshua Thomas Reed, born May 12 2007, hereinafter referred to as the children. 4. The parties are subject to an Order of Court dated November 19, 2013. Said order is attached hereto as Exhibit A. 5. Mother has intentionally and wilfully violated paragraph 4 of the order in that she is refusing to cooperate with co -parenting counseling. She has repeatedly either failed to cooperate with $83.00 PD tom'`/ scheduling or has failed to appear after a counseling appointment has been scheduled and confirmed. To date, Mother has missed 16 of the 20 co -parenting sessions that were scheduled. 6. Father has incurred attorney's fees and filing fees discussing and pursuing the averments contained in the instant petition. Father seeks reimbursement of said fees and costs from Mother. 7. Mother is currently not represented by an attorney so her concurrence was not requested by undersigned counsel. It is believed that Mother opposes the requested relief. Respectfully Submitted: Date: By: JEANNE B. COSTOPOULO , ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff/Petitioner VERIFICATION I, Casey Allen Reed, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Date: I"y` CERTIFICATE OF SERVICE I, Jeanne B. Costopoulos, Esquire, hereby certify that this day I personally served a copy of the foregoing document upon the person indicated below by depositing a copy of the same with the United States Post Office through first class mail, prepaid, and addressed as follows: Jennifer B. Reed 1931 Fulton Street Harrisburg, PA 17102 By: E B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff/Petitioner EXHIBIT A CASEY A. REED, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA .7 N �4• is V . -u a w` --d PIM JENNIFER B. REED, : CIVIL ACTION - LAW a ,D Defendant : NO. 09-5420 CIVIL TERM -e:›110* up CD. IN RE: CUSTODY >r ORDER OF COURT - iv ) -< rn AND NOW, this 19th day of November, 2013, after hearing, it is hereby ordered and directed as follows: 1. All prior Custody Orders are hereby vacated and replaced with the following Order. 2. The mother, Jennifer Reed, and the father, Casey Reed, shall have shared legal custody of Caleb Reed and Joshua Reed, both born 5/12/2007. The parties shall have an equal right to make all major non -emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education, and religion. Pursuant to the terms of 23 Pa. C.S. Section 5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the -residence address of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. The parties shall share physical custody on a 50/50 basis according to the following schedule: A. Primary physical custody shall alternate on a week-on/week-off basis with the exchange taking place at noon on Sundays. B. The non-custodial parent shall be entitled to two overnights of visitation each week which shall correspond with his or her days off work. Provided however, that if the party's days off coincide, father's days off shall be given priority. C. If the custodial parent is unavailable for the children and the children are to spend an overnight with a third party, said opportunity shall be offered to the non-custodial parent. The spouse of father shall not be deemed to be a third party for purposes of this provision of the Order. 4. The parties are ordered to engage in co-parent counseling with Norman Stovall [or any other counselor mutually agreed upon] which shall commence within 30 days of today's date. Any cost of said counseling not covered by insurance shall be divided equally between the parties. 5. Both parents may attend all doctor visits, therapy sessions, and any other medical appointments. Any parent who schedules such a session or appointment shall notify the other parent as to the time and place as soon as practical after the appointment is made. 6. The non-custodial parent shall have liberal telephone contact with the children on a reasonable basis. This shall include the availability of mother to call children on father's home phone when father is at work. 7. Holidays: The following holiday schedule shall supercede any other provision of this Order: Christmas: In even -numbered years, mother shall have the children from 12/24 at 12:OOp.m. until 12/25 at 12:00 p.m. and father shall have the children from 12/25 at 12:00 p.m. until 12/26 at 12:00 p.m. In odd -numbered years, these times shall be reversed. Thanksgiving: In even -numbered years, mother shall have the children from Wednesday at 6:00 p.m. until Thursday at 2:00 p.m. and father shall have the children from Thursday at 2:00 p.m. until Friday at 2:00 p.m. In odd -numbered years, these times shall be reversed. •8. Neither parent shall take the children out of state without notifying the other parent at least 48 hours prior to departure of the intended destination and a telephone number at which they can be reached. 9. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the children from the other party or injure the opinion of the children as to the other party or may hamper the free and natural development of the children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the children. 10. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 11. Each parent shall have one week [7 consecutive days] of vacation with the children each year. Unless otherwise agreed, these seven days shall occur during the parent's scheduled week of primary custody. The vacationing parent shall give the other parent 30 days advance notice. 12. During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 13. No party shall have any firearms in the home when the children are present unless said firearms are safely under lock and key. 14. No party shall be permitted to relocate the residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the Court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa. C.S. Section 5337. 15. The children shall continue to attend school in father's school district, and both parents shall ensure that the children attend and participate in any recommended therapy for the boys. Both parents shall further ensure that the twins attend school and any scheduled appointments on time during their respective custodial periods. 16. The children shall participate in speech and/or occupational therapy as recommended by their pediatrician. To the extent that the therapy is not covered by insurance or that there is a co -pay, the parties shall share those costs equally. 17. The parties may modify any provision in this Order by mutual agreement. In the absence of mutual agreement, the terms of the Order shall control. By the c„...--16hn King, Esquire For the Plaintiff srs Edward E. Guido, Jennifer B. Reed Pro se Cesibis Mkt isZ. igh 3 JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff CASEY A. REED, Plaintiff THE ir;(t i SEP 25 Pti 2: 02 CUMBERLAND COUNT' PENNSYLVANIA : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 09-5420 CIVIL TERM JENNIFER B. REED, : CIVIL ACTION - LAW Defendant : CUSTODY TO THE HONORABLE EDWARD E. GUIDO, JUDGE OF SAID COURT: PLAINTIFF FATHER'S PETITION TO MODIFY ORDER OF CUSTODY AND NOW comes the Plaintiff, Casey A. Reed, by and through his attorney, Jeanne B. Costopoulos, Esquire, and respectfully avers the following: 1. Petitioner is Plaintiff above, Casey A. Reed, hereinafter referred to as Father, currently residing at 605 Market Street, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. Respondent is Defendant above, Jennifer B. Reed, hereinafter referred to as Mother, currently residing at 1931 Fulton Street, Harrisburg, Dauphin County, Pennsylvania, 17102. 3. There are two (2) dependent children from the relationship of the parties, namely Caleb Michael Reed, born May 12, 2007, and Joshua Thomas Reed, born May 12 2007, hereinafter referred to as the children. 4. The parties are subject to an Order of Court dated November 19, 2013. Said order is attached hereto as Exhibit A. 483.00 Pa 03115f(p 5. Father seeks to modify the November 19, 2014 order such that Father is granted primary physical custody of the children throughout the school subject to periods of partial custody with Mother when she is not working. 6. Such a modification would be in the best interests of the children for the following reasons: a. Mother's living arrangements are not stable. Mother was recently evicted from her residence in Lewisberry. Mother had previously moved three times between July of 2009 and the hearing held in 2012. b. Mother has a history of mental illness and suffers from personality disorder and depression. As a result, Mother often confuses her priorities and/or makes poor choices. c. Mother is currently residing in a section of Harrisburg which Father does not find suitable for the children to be residing on a 50/50 basis. The children have complained about the smell of Mother's new residence. d. Until recently, Mother resided 5 minutes from Red Mill Elementary School where the children attend school. Mother now resides over 45 minutes from Red Mill Elementary. The children had 10 unexcused absences during Mother's custody periods during the 2013-2014 school year and Father anticipates their attendance will only suffer more now that Mother has an even longer commute to get the children to school. e. Deb Salem dismissed herself from this case after Mother cancelled 4 to 5 appointments. The parties then enrolled in co -parenting counseling with Norman Stovall and to date Mother has only showed up for 4 of the 20 scheduled co -parenting sessions. f. Mother disparages Father to the children, the neighbors, school personnel and others. 7. Mother is currently not represented by an attorney so her concurrence was not requested by undersigned counsel. It is believed that Mother opposes the requested relief. WHEREFORE, Plaintiff, Casey A. Reed, respectfully requests this Honorable Court to modify the November 19, 2014 order such that he is granted primary physical custody of the ' children throughout the school year subject to periods of partial custody with Mother. Respectfully Submitted: Date: • JEANNE B. COSTOPOU ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff/Petitioner VERIFICATION I, Casey Allen Reed, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Date: Casey All=n Rd CERTIFICATE OF SERVICE I, Jeanne B. Costopoulos, Esquire, hereby certify that this day I personally served a copy of the foregoing document upon the person indicated below by depositing a copy of the same with the United States Post Office through first class mail, prepaid, and addressed as follows: Date: 7/W Jennifer B. Reed 1931 Fulton Street Harrisburg, PA 17102 By: NE B. COSTOPOULOS, 'ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff/Petitioner EXHIBIT A CASEY A. REED, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. JENNIFER B. REED, Defendant • : CIVIL ACTION - LAW : NO. 09-5420 CIVIL TERM IN RE: CUSTODY ORDER OF COURT AND NOW, this 19th day of November, 2013, after 4 hearing, it is hereby ordered and directed as follows: 1. Al']. prior Custody Orders are hereby vacated and replaced with the following Order. 2. The mother, Jennifer Reed, and the father, Casey Reed, shall have shared legal custody of Caleb Reed and Joshua Reed, both born 5/12/2007. The parties shall have an equal right to make all major non -emergency decisions affecting the children's general well-being including, but not limited to, all decisions regarding their health, education, and religion. Pursuant to the terms of 23 Pa. C.S. Section 5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to, medical, dental, religious or school records, the'residenceaddress of the children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. The parties shall share physical custody on a 50/50 basis according to the following schedule: A. Primary physical custody shall alternate on a week-on/week-off basis with the exchange taking place at noon on Sundays. B. The non-custodial parent shall, be entitled to two overnights of visitation each week which shall correspond with his or her days off work. Provided however, that if the party's days off coincide, father's days off shall be given priority. C. If the custodial parent is unavailable for the children and the children are to spend an overnight with a third party, said opportunity shall be offered to the non-custodial parent. The spouse of father shall not be deemed to be a third party for purposes of this provision of the Order. 4. The parties are ordered to engage in co -parent counseling with Norman Stovall [or any other counselor mutually agreed upon] which shall commence within 30 days of today's date. Any cost of said counseling not covered by insurance shall be divided equally between the parties. 5. Both parents may attend all doctor visits, therapy sessions, and any other medical appointments. Any parent who schedules such a session or appointment shall notify the other parent as to the time and place as soon as practical after the appointment is made. 6. The non-custodial parent shall have liberal telephone contact with the children on a reasonable basis. This shall include the availability of mother to call children on father's home phone when father is at work. 7. Holidays: The following holiday schedule shall supercede any other provision of this Order: Christmas: In even -numbered years, mother shall have the children from 12/24 at 12:00p.m. until 12/25 at 12:00 p.m. and father shall have the children from 12/25 at 12:00 p.m. until 12/26 at 12:00 p.m. In odd -numbered years, these times shall be reversed. Thanksgiving: In even -numbered years, mother shall have the children from Wednesday at 6:00 p.m. until Thursday at 2:00 p.m. and father shall have the children from Thursday at 2:00 p.m. until Friday at 2:00 p.m. In odd -numbered years, these times shall be reversed. 8. Neither parent shall take the children out of state without notifying the other parent at least 48 hours prior to departure of the intended destination and a telephone number at which they can be reached. 9. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the children from the other party or injure the opinion of the children as to the other party or may hamper the free and natural development of the children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the children. 10. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 11. Each parent shall have one week [7 consecutive days] of vacation with the children each year. Unless otherwise agreed, these seven days shall occur during the parent's scheduled week of primary custody. The vacationing parent shall give the other parent 30 days advance notice. 12. During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 13. No party shall have any firearms in the home when the children are present unless said firearms are safely under lock and key. 14. No party shall be permitted to relocate the residence of the child which significantly impairs the ability to exercise custody unless every individual who has custodial rights to the child consents to the proposed relocation or the Court approves the proposed relocation. A person proposing to relocate MUST comply with 23 Pa. C.S. Section 5337. 15. The children shall continue to attend school in father's school district, and both parents shall ensure that the children attend and participate in any recommended therapy for the boys. Both parents shall further ensure that the twins attend school and any scheduled appointments on time during their respective custodial periods. 16. The children shall participate in speech and/or occupational therapy as recommended by their pediatrician. To the extent that the therapy is not covered by insurance or that there is a co -pay, the parties shall share those costs equally. 17. The parties may modify any provision in this Order by mutual agreement. In the absence of mutual agreement, the terms of the Order shall control. By the c....1hn King, Esquire For the Plaintiff srs Edward E. Guido, -nifer B. Reed Pro se •cdri.str&i&Z, igha JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff CASEY A. REED, Plaintiff TI PRnTTICN,-- ? J? SEP 25 Pi 2: 02 CUMBERLAND COUNTY PENNSYLVANIA : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 09-5420 CIVIL TERM JENNIFER B. REED, : CIVIL ACTION - LAW Defendant : CUSTODY CRIMINAL RECORD / ABUSE HISTORY VERIFICATION I, Casey A. Reed, 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 all that apply Self ❑ 18 Pa.C.S. Ch. 25 (relating 0 to criminal homicide) ❑ 18 Pa.C.S. §2702 (relating Li to aggravated assault) Other household member LI Date of conviction, Sentence guilty plea, no contest plea or pending charges 18 Pa.C.S. §2706 (relating Li to terroristic threats) Li 18 Pa.C.S. §2709.1 Li (relating to stalking) Li 18 Pa.C.S. §2901 (relating El to kidnapping) 18 Pa.C.S. §2902 (relating to unlawful restraint) Li 18 Pa.C.S. §2903 (relating Li to false imprisonment) Li 18 Pa.C.S. §2910 (relating 0 to luring a child into a motor vehicle or structure) [1 LI 0 18 Pa.C.S. §31.21 (relating Ej LI to rape) 18 Pa.C.S. §3122.1 (relating to statutory sexual assault) 18 Pa.C.S. §3123 (relating Ci to involuntary deviate sexual intercourse) 18 Pa.C.S. §3124.1 (relating to sexual assault) Li 18 Pa.C.S. §3125 (relating Li Li to aggravated indecent assault) Li 18 Pa.C.S. §3126 (relating Li to indecent assault) LI 1.8 Pa.C.S. §3127 (relating to indecent exposure) 18 Pa.C.S §3129 (relating LI to sexual intercourse with animal) 18 Pa.C.S §3130 (relating LI LI 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) 0 18 Pa.C.S. §4303 (relating 0 to concealing the death of child) LI 18 Pa.C.S. §4304 (relating El to endangering welfare of children) 0 18 Pa.C.S. §4305 (relating to dealing in infant children) LI 18 Pa.C.S. §5902(b) (relating to prostitution and related offenses) El 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) LI LI LI LI Li 18 Pa.C.S. §6312 (relating to sexual abuse of children) 18 Pa.C.S. §6318 (relating Li Ci to unlawful contact with minor) 0 18 Pa.C.S. §6320 (relating Li Li to sexual exploitation of children) Li 23 Pa.C.S.§6114 (relating Li to contempt for violation of protection order or agreement) Driving under the influence of drugs or alcohol Li Manufacture, sale, 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, or involvement with a Children & Youth agency, including the following: Check Self Other household Date all that member apply A finding of abuse by a Children & Youth Li 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 Involvement with a Children & Youth ❑ Li Agency or similar agency in Pennsylvania or another jurisdiction. Where?: Other: State the date and circumstance of the child abuse, the named perpetrator of the abuse and the jurisdiction or location where the abuse took place. 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(ren): Identify all household members by name and age that currently reside with you, and were included in the responses to Questions 1-2 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: 6. State whether you or any member of your household was provided services by a child. welfare agency (eg., County Children, Youth & Families agency). If yes, please indicate: a. The individuals that received services: b. The type of services provided: c. The circumstances surrounding the provision of services: d. The time frame during which the services were or are being provided: e. The jurisdiction or location where services are being or were provided: VERIFICATION I, Casey Allen Reed, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Date: jN Casey All CERTIFICATE OF SERVICE I, Jeanne B. Costopoulos, Esquire, hereby certify that this day I personally served a copy of the foregoing document upon the person indicated below by depositing a copy of the same with the United States Post Office through first class mail, prepaid, and addressed as follows: Jennifer B. Reed 1931 Fulton Street Harrisburg, PA 17102 By: Date: 7/21 _?467 .TEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff CASEY A. REED PLAINTIFF V. JENNIFER B. REED DEFENDANT IN THE COURT OF COMMON PLEAS OF rv: , CUMBERLAND COUNTY, PENNSYLVANIA - 2009 -5420 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT r AND NOW, Tuesday, September 30, 2014 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq.. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 28, 2014 10:30 AM for a Pre -Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in-person contact with the court (including, but not limited to, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P. No. 1915.17 regarding relocation. FOR THE COURT, By: ls/ John J. Mangan, Jr., Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFF.ICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. p/cS ,I/ 0 &V/0h10f» £Sg- 17490907/9, 'CSa Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 CASEY A. REED PLAINTIFF v. JENNIFER B. REED DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANW rn rq 2009-5420 CIVIL ACTION LAW cnr— : IN CUSTODY <c) ORDER OF COURT AND NOW, Tuesday, September 30, 2014 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 28, 2014 10:30 AM for a Pre -Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in-person contact with the court (including, but not limited to, °Pa conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. • ) CZ") CO --< No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P. No. 1915.17 regarding relocation. FOR THE COURT, By: /s/ John J. Mangan, Jr., Esq., Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. pie./ Rat o be -P. o Cs40 Ise. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 v CASEY A. REED : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 09-5420 Civil Term C)J p - y-7 JENNIFER B. REED rnC - M Defendant : ACTION IN CUSTODYc73 �`'-ID fr n CI)1 I :s .1 ...< >Z- C'. , Prior Judge: Edward E. Guido, J. r"' x Cr:, Anticipated hearing length: One half day > c) . . COURT ORDER co 7.'' .) AND NOW, this �� day of November 2014, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. This Order is entered pursuant to a Custody Conciliation Con rence. A Custody Hearing is hereby scheduled on the ,sem day of , 20116 at am/fid in Courtroom number 3 in the Cumberland County Court of Common Pleas, Carlisle, PA 17013 at which time testimony will be taken in regard to the physical custody for the subject Children. For purposes of this hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party (or a party unrepresented) shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the hearing date. 2. Legal custody: The Mother, Jennifer Reed, and the Father, Casey Reed, shall have shared legal custody of Caleb Reed and Joshua Reed, both born 05/12/2007. The parties shall have an equal right to make all major non -emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Each parent shall inform the other of medical/ therapy/ educational appointments that are scheduled for the twins. 3. Physical Custody: Father and Mother shall share physical custody of the twins on a 50/50 basis according to the following schedule: a. b. c. The parents shall share physical custody on a week on/week off basis from 12 pm Sunday until the following Sunday 12 pm. The non-custodial parent shall be entitled to two overnights of visitation each week which shall correspond with his or her days off of work. Provided however, that if the parties' days off coincide, Father's days off shall be given priority. If the custodial parent is unavailable for the Children and the Children are to spend an overnight with a third party, said opportunity shall be offered to the non-custodial parent. The spouse of Father and the paternal grandparents shall not be deemed to be a third party for purposes of this provision of the Order. 4. Co -parenting Counseling: The parties are strongly encouraged to re-engage in therapeutic family counseling (with the focus on co -parenting) with an agreed upon professional. Each parent shall ensure that they regularly attend any and all scheduled counseling appointments. The cost of said counseling, after appropriate payment through insurance, shall be split equally between the parties. 5. Both parents may attend all doctor visits, therapy sessions, and any other medical or educational appointments. Any parent who schedules such a session or appointment shall notify the other parent as to the time and place as soon as possible after the appointment is made. 6. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. This shall include the availability of Mother to call the Children on Father's home phone when Father is at work. 7. Holidays: The following holiday schedule shall supersede any other provision of this Order: Christmas: In even numbered years Mother shall have the Children from 12/24 at 12:00 pm until 12/25 at 12:00 pm and Father shall have the Children from 12/25 12:00 pm until 12/26 at 12:00 pm. In odd numbered years, these times shall be reversed. Thanksgiving: In even numbered years, Mother shall have the Children from Wednesday 6:00 pm until Thursday 2:00 pm and Father shall have the Children from Thursday 2:00 pm until Friday 2:00 pm. In odd numbered years, these times shall be reversed. 8. Neither parent shall take the Children out of state without notifying the other parent at least within forty eight hours of departure of the intended destination and a telephone number at which they can be reached. 9. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Children. 10. In the event of a medical emergency, the custodial party shall notify the other party as soon as possible after the emergency is handled. 11. Vacation: Each parent shall have one week (seven consecutive days) of vacation with the Children per year. Unless otherwise agreed, these seven days shall occur during the parent's scheduled week of regular custody. The requesting parent shall give the other parent 30 days advance notice. 12. During any periods of custody or visitation, the parties shall not possess or use illegal substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 13. No party shall have any firearms in the home when the Children are present unless said firearms are safely under lock and key. 14. Relocation. The parties are advised that neither party shall hereafter relocate the child or children if such relocation will significantly impair the ability of a non - relocating party to exercise his or her custodial rights unless (a) every person who has custodial rights to the child/children consents to the proposed relocation or (b) the court approves the proposed relocation. The party seeking relocation must follow the procedures required by 23 Pa.C.S. §5337. 15. The Children shall continue to attend school in Father's school district and both parents shall ensure that the Children attend and participate in any recommended therapy for the boys. Both parents shall further ensure that the twins attend school and any scheduled appoints on time during their respective custodial periods. 16. The Children shall participate in speech and/or occupational therapy as recommended by their pediatrician. To the extent that the therapy is not covered by insurance or that there is a co -pay, the parties shall share those costs equally. 17. The parties have the option of contacting the assigned conciliator to schedule a conference prior to the scheduled hearing if that would be beneficial. 18. The parties may modify this Order by mutual agreement in writing. In the absence of mutual consent, the terms of this Order shall control. J. Distribution: /rnifer Reed, 107 Bungalow Rd., Enola, PA 17025 .../reanne Costopoulos, Esq. J. Mangan, Esq. LC, CASEY A. REED : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. JENNIFER B. REED : No. 09-5420 Civil Term Defendant : ACTION IN CUSTODY Prior Judge: Edward E. Guido, J. 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 Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Caleb Reed 05/12/2007 Primary Father Joshua Reed 05/12/2007 Primary Father 2. Apparently, both Mother and Father filed Petitions for Special Relief and/or Emergency Relief. An Order of Court had been issued August 11, 2009 awarding Father primary physical custody of the Children. A Conciliation Conference was held on September 15, 2009, an Order issued October 14, 2009, a conciliation conference was held October 11, 2010, an Order issued October 13, 2010, a telephonic conference was held 12/20/10, an Order issued January 19, 2011, a conference was held June 27, 2011, an Order issued September 20, 2011, both parents filed contempt petitions, a conference was held April 27, 2012, an Order issued July 03, 2012, an Order issued August 10, 2012 after hearing, Father filed a petition to modify, Mother filed a contempt petition, a conference was held June 07, 2013, an Order issued June 19, 2013, Mother again filed a contempt/modification/special relief petition, a conference was held October 08, 2013, an Order issued October 09, 2013, a hearing was held and an Order issued November 19, 2013 and a conference was held October 28, 2014 in regard to Father's contempt and modification with the following individuals participating: The Mother, Jennifer Reed, self -represented party The Father, Casey Reed, with his counsel, Jeanne Costopoulos, Esq. 3. Mother's position on custody is as follows: The parents have relatively recently litigated this custody matter. The parents had attempted some co -parenting counseling with a counselor both agreed to. However, Mother's attendance at the sessions had been sporadic (allegedly Mother attended 4/20 sessions). Mother reports that she had some transportation issues as well as she developed significant discomfort with the chosen counselor's religious leanings and views on corporal punishment. Mother indicated that she is moving soon to Enola which is going to be significantly closer to Father and the Children's school. Mother reports that she does get the Children to school and that any absences were primarily medically excused. Mother is mostly satisfied with the current shared situation. Mother has some concerns that the Children are spending a significant portion of time at paternal grandparents when Father is working. Mother reports that her financial situation has improved. Mother indicates that homework is being done on her watch and has concerns about homework being done when the Children are with Father. Mother indicated that an updated custody evaluation would be helpful as long as the parents split the cost; however, both parents indicated that they are not in a financial position to have the updated evaluation. Additionally, Mother would like a Guardian Ad Litem appointed to represent the Children, but was informed that she would have file a petition for a GAL to be appointed. Mother is requesting that Judge Guido speak to the Children at the scheduled hearing. 4. Father's position on custody is as follows: Father is upset and frustrated that Mother did not follow through with the family counseling. Both parents expressed a willingness to explore the possibility of another counselor and the undersigned strongly encouraged that to happen. Father still has concerns about Mother's MH and would like custody of the Children primarily between Monday and Friday. Father has concerns about the Children's absences, Mother's stability, moving quite a bit and unsanitary conditions of Mother's residence. Father indicates that the Children do not spend excessive amounts of time at the paternal grandparents as the Children go there one weekend every three weekends when Father has to work. Father has further concerns that Mother unduly tries to influence the twins. 5. The Conciliator recommends an Order in the form as attached scheduling a Hearing and entering an Order of Court regarding custody as outlined. It is the Conciliator's belief that this would be in the Children's best interest. It is expected that the Hearing will require one half day. 6. The proposed recommended Order may contain a requirement that the parties file a pre-trial memorandum with the Judge to whom the matter has been assigned. Date: /// R../// John . M gan, Esquire Cu • ody onciliator f CASEY A. REED, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA •• X 5`��ICCV v. NO. e.±.--2.54-CIVIL TERM JENNIFER B. REED, Defendant CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this 5th day of December, 2014, after hearing the Petition for Contempt is DISMISSED. By the Court, Edward E. Guido, J. Jeanne B. Costopoulos, Esquire Attorney for Plaintiff /Jennifer B. Reed 107 Bungalow Road Enola, PA 17025 srs co ies1\10°4 0-1101'7 p CASEY A. REED, Plaintiff v. JENNIFER B. REED, Defendant CIVIL ACTION - CUSTODY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 61-5140-0 NO. Y01 2-g4 CIVIL TERM ORDER OF COURT AND NOW, this 5th day of December, 2014, after hearing, Father's Petition to Modify the Custodial Arrangement is DENIED. Our Order of November 19, 2013, shall remain in full force and effect. By the Court, Edward E. Guido, J. '/ Jeanne B. Costopoulos, Esquire Attorney for Plaintiff • Jennifer B. Reed 107 Bungalow Road Enola, PA 17025 srs 'wr t GD ;