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HomeMy WebLinkAbout09-5879SBzan HESSOU 313A West Shady Lane Enola. PA 17025 (Plaintiff) V. Cheri Ann HESSOU 313A West Shady Lane Enola, PA 17025 (Defendant) IN COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA FAMILY COURT No. O ?' S'k'I l MOTION FOR CUSTODY ORDER: On the fifth day of January, 2009, Cheri Ann HESSOU, defendant, and Sezan Prudence HESSOU, plaintiff, have entered a civil Child Custody Agreement. For the following reasons below, Plaintiff S&an Prudence HESSOU would like to motion this court to enforce the custody agreement through an order. 1. Both parties have previously already agreed and entered a civil custody agreement. 2. Both parties mutually and voluntarily, without any duress or coercion, agreed and signed the above mentioned civil agreement. 3. Both parties have appeared before a Notary Public in the court of Common Pleas in Dauphin County at the time of signature. 4. The Notary Public's commission is still valid at the time of signature and notarization, and expires only on January 5a', 2010. 5. There has been violations from the defendant's part on numerous occasion of the civil and notarized agreement. 6. Plaintiff has to make certain decisions and act accordingly for the child best interest in the near future. 7. Plaintiff tried on numerous occasions to solve by means of words and discussions to solve the multiple issues that rose from the defendant's violations of the civil agreement WHEREFORE, I, Plaintiff Sezan Prudence HESSOU solemnly request from this Honorable Court that this civil agreement for custody and visitation in enclosure be enforced through a court order. 1 Very Truly Yours, Sezan H SOU 9)2- -at? (Enclosure: Exhibit 1: Child Custody And Visitation Agreement) DISTRIBUTION: Cheri Ann HESSOU 313A West Shady Lane Enola, PA 17025 DISTRICT COURT ADMINISTRATION, Cumberland County Courthouse,1 Courthouse Square Carlisle, PA 17013 - OFFICE OF PROTHONOTARY, Cumberland County Courthouse, 1 Courthouse Square Carlisle, PA 17013 - Sezan Prudence HESSOU 313A West Shady Lane Enola, PA 17025 2 .. ?XHiBtTC? (+HiLD CUSTODY AND VISITATION AGREEMENT SEZANP. HESSOU ("Custodian") shall have primary and full custody of XANDER T. HESSOU ("Child"), and control and supervision of his upbringing, subject to this Child Custody and Visitation Agreement ("Agreement") as the follows: 1. CHERI A. HESSOU ("Non-Custodial Parent") shall have the right to visit Child as she desires, on any day of the week and at any time during the day, so long as the day and time selected does not interfere or conflict with Custodian's or Child's schedules as determined exclusively by Custodian. 2. The intention of Custodian and Non-Custodial Parent is that Non-Custodial Parent's right of visitation shall be entirely optional to Non-Custodial Parent, and should Non-Custodial Parent so desire, Non Custodial Parent may waive the privilege of visitation on any occasion and for any reason, without waiving Non-Custodial Parent's right to future visits. 3. Non-Custodial Parent shall not be entitled to take Child away from Custodian's home for any period of time. However, if at a later date, at the sole discretion and consent of Custodian, Non- Custodial Parent may be granted partial custody away from Custodian's home. 4. Custodian shall promptly notify Non-Custodial Parent in the event of illness of the Child. The word "illness" shall be deemed to mean any illness, other than any illness from which Child is now suffering, which shall confine Child to bed for more than two (2) days. 5. On all matters of importance relating to Child's health and education, Custodian may consult and confer with Non-Custodial Parent, with a view to implementing and following a harmonious policy. However, if a harmonious policy is not possible, Custodian shall have sole discretion on these matters. 6. Custodian is granted the power and ability to take XANDER T. HESSOU (Child) out of the country when he sees it fit, without any burden of illegal or criminal prosecution instigated by Non- Custodial Parent and/or anyone on her behalf. In which case, Custodian is to help facilitate contact/communication between XANDER T. HESSOU (Child) and Non-Custodian Parent, until child is able to fluently communicate. 7. Custodian is hereby granted the power to administer any of XANDER T. HESSOU's present and future benefits, income, and/or assets as he sees fit for the child's best interest until he is legally responsible to do so himself. T 8. Non-Custodian Parent must and shall, to the best of her ability, manage to contribute or help with XANDER T. HESSOU's care and/or expenses, in all ways, except when she's unable; in which case she will not be held liable. *Inability in this case is defined as a total/whole loss of income due to involuntary loss of employment, natural Page 1 of 1 catastrophe, disability, or any circumstances out of Non-Custodian Parent control. 9. Non-Custodian Parent has to carry a life and accidental insurance on herself and make XANDER T. HESSOU (Child) her sole beneficiary, should any accidental disability harm her and cause any insufficiency in her ability to provide for XANDER T. HESSOU (Child.) 10. Neither Custodian nor Non-Custodial Parent shall do anything which may estrange Child from the other. 11. This agreement has no bearing on whether SEZAN P. HESSOU (Custodian) and CHERI A. HESSOU (Non-Custodian) end up divorced, separated, together, or in any other known and legal matrimonial status, according to the laws of the Commonwealth Of Pennsylvania. 12. This Agreement shall be interpreted according to the laws of the Commonwealth of Pennsylvania. 13. Custodian and Non-Custodial Parents agree that any change to any term in this Agreement must be in writing and signed by Custodian and Non-Custodial Parent. 14. This Agreement shall be effective as of the date set forth below as signed by Custodian and Non-Custodial Parent. IMPORTANT: THIS AGREEMENT CONTAINS THE ENTIRE AGREEMENT BETWEEN CUSTODIAN AND NON-CUSTODIAL PARENT. IF EITHER CUSTODIAN AND/OR NON- CUSTODIAL PARENT DO NOT UNDERSTAND ANY OF THE TERMS AND/OR PROVISIONS CONTAINED IN THIS AGREEMENT, PLEASE MAKE SURE YOU CONSULT WITH AN INDEPENDENT ATTORNEY. AND NOW, this 5 'th - day of June, 2009, the above Child Custody and Visitation Agreement has been read, approved, and understood by Custodian and Non-Custodial Parent and the receipt of a copy of it is acknowledged. The terms set forth are agreeable. By Custodian Parent: SEZAN HESSOU By Non-Custodial Parent: Page 2 of 2 w ' OL,-- L?-? CHERI HESSOU NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN On this day of June, 2009, SEZAN P. HESSOU and CHERI A. HESSOU, known to me to be the persons named as the in the foregoing instrument, personally appeared before me, a Notary Public within and for the above State and County, and acknowledged that he freely and voluntarily executed the same for the purposes stated therein. ?J ' ?o+?r?br?? ?ovpti? Co?rt1? My Commission expires Page 3 of 3 Date: 6/5/%009 Dauphin County NO. 0194636 Time: '027.46 PM Receipt Page 1 of 1 Received of: Cheri Ann Hessou Twelve and 00/100 Dollars Notary Registration Total: Payment Method: Cash Amount Tendered: Clerk: SGRIFFITH 12.00 By: Stephen E Farina , Prothonotary $ 12.00 Amount 12.00 12.00 Deputy Clerk I `LED -ij . Ulm R1` 07 'iC_.r r; v 2C 21 1 ?' 32 1 cl', IM. - :\ ;v j ?lA ? r r"? ?T I;?S,5-?Gdp/.W Me e 161, j-7 7y-;Z 12- ti's Sizan HESSOU 313A West Shady Lane Enola, PA 17025 (Plaintiff) V. Cheri Ann HESSOU 313A West Shady Lane Enola, PA 17025 (Defendant) IN COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA FAMILY COURT No. o ? - U Y if V CERTIFICATE OF SERVICE I, Sezan HESSOU, plaintiff, solemnly swear that a true copy of the foregoing has been served upon Cheri Ann HESSOU, defendant, via certified mail this _Z '? t-A day of August, 2009. Respectfully submitted on... .. ?? S6zan P. HESSOU .. fU N For delivery informAtion visit our website at www.usps.corn,, 43 co Postage Certified Fee C3 Return Receipt Fee 2?stmark re O (Endorsement Required) C3 v ?0; C3 Restricted Delivery Fee $0.00 (Endorsement Required) U ` ; s C3 - rq Total Postage & Fees $ :3.41 r-1 Sent T E'r-. -------------------------------- --??_ O Street, Apt. No.; +,{ Q or PO ---- A.A\ _ N City State, ZIP+4 Z PS Form 3800 A,qu,1 2006 ScRc,verse for Instructions I OF THE P! 2009 AUG 27 PMH2: 25 CUM_ ! 1;,J jy Skzan HESSOU 313A West Shady Lane Enola, PA 17025 (Plaintiff) V. Cheri Ann HESSOU 313A West Shady Lane Enola, PA 17025 (Defendant) IN COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA FAMILY COURT No. t ORDER: After careful review and evaluation of the Plaintiffs motion to enforce the CHILD CUSTODY AND VISITATION AGREEMENT entered in by both Plaintiff S6zan Prudence HESSOU and defendant Cheri Ann HESSOU, the Court hereby adopts this proposed order. The parties shall comply with the terms and provisions of the CHILD CUSTODY AND VISITATION AGREEMENT mutually and voluntarily signed and notarized before Notary Public on June 5'", 2009 thereof 00 Date OF THE PP D',.-? CNICDARY 7009 SEP -2 PM 1: 4° C aZ.l?t -- Ens ?'"?'? lk4 SEZAN HESSOU IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CHERI ANN HESSOU 1)EFt:NDANT • 2009-5$79 CIVIL ACTION LAW IN CUSTODY ORDF,R OF COURT AND NOW, ,___, Monday, March 08, 2010 _______, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esy. ,the conciliator, at 39 West Mam Street, Mechanicsbur , PA 17055 _ on Wednesday, April 07, 2.010 at 12:30 PM for aPre-}~-searing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot he accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Faih~re 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 alt 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/ Dawn S. Sunday, Esq_~ __ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to compiy 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 ccantact our office. Alt 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 PAPEK TO YOUR AT'TORNF,Y A'I' ONCE. IF YOU DO NO'F HAVF_. AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR'TF1 BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County I3ar Association 32 So~ith Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,, ~F ~ Ilpr ~ ~~ ,=,`Ci ~7' ~, .~?Y 2010 MAR -g Af~111:1~ 7 r ~ =PIE ,, L~~, ~~ ff`V i~( t,. ~;, ~Olo ~u(~ (p QWt I ~55 G ,r i,~;-~.,. .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SEZAN HESSOU Plaintiff v. CHERI ANN HESSOU Defendant No. 2009-5879 Civil Action- Complaint for Child Custody MOTION TO WITHDRAW AS COUNSEL FOR SEZAN HESSOU AND NOW comes Rachelle J. Armbruster, Esquire, counsel for plaintiff Sezan Hessou, who respectfully requests to withdraw as counsel in the above-captioned matter for the following reasons: 1. No hearing or other such event is currently scheduled before this court or any other in regard to the above-captioned matter; 2. Attorney Armbruster is moving out of the state of Pennsylvania at the end of August 2010 and will therefore no longer be practicing in Central Pennsylvania; 3. Plaintiff Sezan Hessou has been given notice of this fact as of early July 2010 and has been supplied with attorney references for any future legal needs; 4. Pennsylvania Disciplinary Rules of Professional Conduct 1.16(b)(1) holds that withdrawal may be granted if it can be accomplished without material adverse effect on the interests of the client; 5. Withdraw can be accomplished without material adverse effect in the present case as there is no issue at hand presently and the client has been given ample notice and attorney references for any future legal needs. Y WHEREFORE, Rachelle J. Armbruster, Esquire respectfully requests to withdraw from the above-captioned case due to a change in geographic practice area and the lack of adverse effect on the client and the case. x.30-~0 Rach e J. Armbruster, Esquire Date ID #307077 503 Bridge Street, Suite 212 New Cumberland, PA 17070 717-635-9641 ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SEZAN HESSOU Plaintiff v. No. 2009-5879 Civil Action- Complaint for CHERI ANN HESSOU Defendant Child Custody CERTIFICATE OF CONSENT TO WITHDRAW AS COUNSEL FOR SEZAN HESSOU 1, Sezan Hessou, hereby consent to the withdraw as counsel of Rachelle J. Armbruster, Esquire in the above-captioned case in Cumberland County, Pennsylvania. Effectively immediately Attorney Armbruster no longer represents me in any legal matter. Accordingly, 1 will pursue new legal counsel in the future, if necessary. -P sac/ ~ ~ ~ 1 Z~ Sezan Hessou Date t f i SEZAN HESSOU, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW CHERI ANN HESSOU, Defendant NO. 09-5879 CIVIL TERM IN RE: MOTION TO WITHDRAW AS COUNSEL FOR SEZAN HESSOU ORDER OF COURT AND NOW, this 13th day of August, 2010, upon consideration of the Motion To Withdraw as Counsel for Sezan Hessou, the motion is granted and Rachelle J. Armbruster, Esq., is hereby permitted to withdraw as counsel for Sezan Hessou. Rachelle J. Armbruster, Esq,. 503 Bridge Street Suite 212 New Cumberland, PA 17070 Sheri Coover, Esq. 44 South Hanover Street o Carlisle, PA 17013 uT . w ?a. :rc C®p?es 1?to, .led ??/3?id Ny .: BY THE COURT, SEZAN HESSOU IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVAN?4 r ? V. M 2009-5879 CIVIL ACTION LAW C= C-7 CHERI ANN HESSOU IN CUSTODY DEFENDAN T yc.. =;rt? ORDER OF COURT AND NOW, Wednesday, June 08, 2011 , upon consideration of the attached Co mplai nt, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator, at _ 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, July 05, 2011--__ at 12:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Dawn S. Sunda Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 C1??Lp? Telephone (717) 249-3166 s/?-?. copy /ha!l?°o/ ? ?? ,raf 1»dilec! 4v r/f. 6 lell 0 ICs 1 Sezan HESSOU 313A West Shady Lane Enola, PA 17025 (Plaintiff) V. Cheri Ann HESSOU 1611 Market Street, Apt. B Camp Hill, PA 17011 (Defendant) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION IN CUSTODY c o --n -OZ _ -4 No. 2009- 5879 CVO ? - o° Z zo a zii To Move For Continuance I, plaintiff Sezan HESSOU hereby file the following motion for continuance of the Pre- Hearing Custody Conference of the case referenced above and initially scheduled for Tuesday, July 05, 2011 for the following reasons: 1. On 6/15/2011, I received through regular post office mailing system an order for Pre-Hearing Custody Conference signed on Wednesday, June 8, 2011 by the Custody Conciliator Dawn S. SUNDAY, Esq., to appear before her on Tuesday, July 05, 2011. 2. I was never served any motion by opposing counsel, therefore I was never given the opportunity to review and/or address (concur or oppose) the motion. 3. I was not aware of any sort of issue pertaining to the current order in place. From a recent telephonic communication (through text messaging system) with the defendant, I came to discover that I should be expecting something in the mail regarding the defendant's intention to file for primary custody. Upon my attempt to inquire why, the defendant never replied. Therefore I was and am not aware of any complaint. See text messages below: r 2 Cheri (717) 576-8629 - mobile 6/6/11 1:19 PM 9 days ago Cheri: I don't deal with myspace anymore 12:00 PM Me: Oh but I do 12:01 PM Me: Have u forgotten how to handle it? 12:02 PM Cheri: Probably not. But I don't have a computer with internet access 12:02 PM Cheri: Not sure if I can do it from my cell 12:03 PM Me: K 12:03 PM Me: I hear you have some mail for me? 12:38 PM Cheri: It should be coming this week or next 12:53 PM Cheri: I thought you were out of state, so wasn't sure how often you get your mail 12:54 PM Me: Okay 12:55 PM Me: What is it? 12:55 PM Me: And I am not out of state 12:55 PM Cheri: Petition for modification of the custody order 1:06 PM Me: What kind? 1:07 PM Me: Of modification? 1:07 PM Cheri: I want primary 1:19 PM Me: Oh why is that? 1:50 PM 4. I started to work recently for a company that require a probation period before any new hire could take any sort of leave. Taking any sort of leave before August 31, 2011 could result in the termination of my employment. 5. 1 am a full time student at Pennsylvania State University with a schedule that only allows opens up Mondays and Wednesdays after 3:30 PM, and Friday mornings anytime before 12:00 noon. (Please see a copy of my schedule enclosed) 6. My legal counsel in this matter had moved out of the state and suggested I hire a new one that she recommended. 7. The defendant has sought and successfully been granted modifications of this court's order (which she freely directed, negotiated, agreed, and willingly entered into without duress or coercion both times) twice already. 8. Considering I did not anticipate another modification of the current order this early, for I managed to voice no objection whatsoever in the last two times (including that from our first conciliatory hearing) to fit the defendant's wishes/schedule and needs to make it work, I never hired a new counsel. . L 3 9. It will take some time to consult with my previous counsel's recommendation, or interviewing and hiring a new counsel. I, Sezan HESSOU, the plaintiff, respectfully request that the hearing be rescheduled for after August 31, 2011, on any Monday or Wednesdays after 3:30 PM, or Friday mornings anytime before 12:00 noon.. Very Truly Yours, Sezan HESSOU (Enclosure: A copy of my academic schedule) DISTRIBUTION: - District Court Administration, Cumberland County Prothonotary, Suite 100, 1 Courthouse Square, Carlisle, PA 17013, Phone: 717-240-6195 - Sheri D. COOVER, Esquire, 44 Hanover Street, Carlisle, PA 17013, Phone: 717-960-0075, Fax: 717-960-0074 - Dawn S. SUNDAY, Esquire, 39 W Main St # 1Mechanicsburg, PA 17055 Phone: 717- 766-9622, Fax: 717-795-7280 Student Schedule Weekly Calendar - FALL 2011 8:OOA EC -- 109 -- 08:( 9:OOA 10:OOA 11: 12: 1:OOP C 01:0 2:OOP 3:OOP :OOP 5:OOP 6:OOP :OOP P: 261E 02:0 Help Logout Page 1 of 2 Monday Tuesday Wednesday Thursday Friday SGN 100S --------------------- EDSGN 100S --------------------- --------- ------ ENGR LAB --------- ------------- 109 ENGR LAB ----------------------- --------------- OA - 10:40A ----------------------- -------------- - - - ---- ----- - ------ --------- 08:OOA - 10:40A --------------------- ---------------------- ----------------------- ----- - ---------------- -------------- ---------------- ----- - ------ -- ------------- -- - - --------- - -------- ----------------------- CMPSC 122 --------- - ------------ - - ------ - ------ - ---- ------------------- CMPSC 122 - - ------------- --------- - ----- -------- ------ ---------------- ----------------- 252E OLMSTED --------------------- 252E OLMSTED ---------------- ----------------- ----------------- -- - ------------ -- - ------ - ---- ---------------- 10:25A - 11:40A --------- - --- -------- ----------------------- - --------------------- ----- - -- - ------ - ---- - --- - ---------------- 10:25A - 11:40A ------ -- ------- - ---- --------------- ---------------- ---------------- - - ------ - ----- -- - ------------ --------------- ---------------- HEM 210 ------------- - -------- - - ------ - ------------ ------------- --------- ------------- --------- --------------------- ----- - ------ - -------- ----------------------- ----- ----------------- ------------- --------- CHEM 210 --------- - ------------ - - -------------- - ---- ---------------------- --------------------- ---------------------- ------------- - - --------------- ---------------- CHEM 2' 127 TL ----------------------- 127 TL --------------------- 127 TL OP - 01:50P ENGL 202C 01:OOP - 01:50P ENGL 202C 01:OOP - 01 ---------------- 013C OLMSTED ----------------- ----- 013C OLMSTED ------------- -- ;YCH 100 01:30P - 02:45P PSYCH 100 01:30P - 02:45P PSYCH 1 OLMSTED 261 E OLMSTED 261 E OLMIc OP - 02:50P 02:OOP - 02:50P 02:OOP - 02 ---------- - ---- CMPSC 360 ----------------------- -------------------- CMPSC 360 ---------------- ----------------- ---------------- 265E OLMSTED ----------------------- 265E OLMSTED ---------------- ---------------- ---------------- ---------------- ---------------- ---------------- --------------- --------------- ---------------- ---------------- --------------- ---------------- ---------------- ---------------- ---------------- ---------------- ---------------- 03:OOP - 04:15P ----------------------- ------------- - -- ----- ------------------ ---- --------------------- ----------------------- ----------------------- -------- ----------------- ----- ----- - -- - ------------ ----------------------- ----------------- ----- ----- ----------------- -- ----------- ----------------------- ----------------------- ----------------------- ----------------- ----- ----- ----------------- ---------------------- --------- - ------------ ----------------------- ------------- --------- ----------------------- ----- - ---------------- ------------- --------- ---------------------- ----------------------- ----------------------- ---------------------- --------------------- ----------------------- ----------------------- 03:OOP - 04:15P ----------------------- - - ------ - ------------ ----------------- ----- ---------------------- ----------------------- - --------------------- ----------------------- ----------------------- ----------------------- ----------------------- --------------------- --------- ------------- - - ------------------ - ----------------------- - - - --------------- ---------------I ---------------- ----------------- ------------- - -- ----------------- ----------------• - --------------- ----------------- ----------------- ----------------- --------- - ------ ---------------- ----------------- ----------------- ----------------- ----------------- 0 50P )0 TED 50P https://elion.psu.edu/cgi-bin/elion-student.exe/submit 6/21/2011 Pa,;c _' o 8:OOP 9:OOP 10:OOP Messages Your registration for fall semester will be complete when all tuition and fees are paid. Billing for the fall semester starts in July and continues up to the first day of classes. You can view and/or pay your semester charges by selecting 'Bills Tuition/Other' from the eLion left-hand menu. You will be provided with a personalized final exam schedule at approximately the fifth week of the semester.The final examination policy (44-20) requires end 9f semester evaluations (exams, papers and projects) worth more than 10% of the course grade to be completed during finals week. Select another semester or format I( Print schedule 1 Privacy and Legal Statements I Copyright ; Browser Compatibility For assistance, contact us ©2006 The Pennsylvania State University Last Update: August 24. 2010 11 1 inn, . A Sezan HESSOU IN THE COURT OF COMMON PLEAS 313A West Shady Lane CUMBERLAND COUNTY, PENNSYLVANIA Enola, PA 17025 (Plaintiff) CIVIL DIVISION V. IN CUSTODY Cheri Ann HESSOU No. 2009- 5879 CV 1611 Market Street, Apt. B Camp Hill, PA 17011 (Defendant) CERTIFICATE OF SERVICE I, Sezan HESSOU, plaintiff, solemnly swear that a true copy of the foregoing has been served upon Sherri D. COOVER, defendant's counsel, via fax transmission this 2 I day of June, 2011. Tke4 4- 2V Respectfully submitted on .. s ? ?i.I * 07e 21 ) Sezan P. HESSOU DISTRIBUTION: - District Court Administration, Cumberland County Prothonotary, Suite 100, 1 Courthouse Square, Carlisle, PA 17013, Phone: 717-240-6195 - Sheri D. COOVER, Esquire, 44 Hanover Street, Carlisle, PA 17013, Phone: 717-960-0075, Fax: 717-960-0074 - Dawn S. SUNDAY, Esquire, 39 W Main St # 1Mechanicsburg, PA 17055 Phone: 717- 766-9622, Fax: 717-795-7280 QQ II i (? N ote 44e- -too N stl?red eAlLve es S P,t9't i f- ? a P1 L Xe r o-??Q d t? J+ dot s ? Se. SEZAN HESSOU, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW CHERI ANN HESSOU, Defendant NO. 09-5879 CIVIL TERM IN RE: CONTINUANCE ORDER OF COURT AND NOW, this 28h day of June, 2011, upon consideration of Plaintiffs motion for a continuance, and pursuant to a recommendation of the custody conciliator, the conciliation conference scheduled for July 5, 2011, will be rescheduled through the custody conciliation process and this matter is referred to Dawn Sunday, Esq., custody conciliator. Sezan Hessou 313A West Shady Lane Enola, PA 17025 Plaintiff, pro Se / Sheri D. Coover, Esq. 44 South Hanover Street Carlisle, PA 17013 Attorney for Defendant Dawn S. Sunday, Esq. 39 West Main Street Mechanicsburg, PA 17055 Custody Conciliator C0?je-5 /xa,1joW 4/a7?1f BY THE COURT, J{W sley OlerVJr., J. a cm n rn-- M -Am ro r-a a° o ? - A? N .r- ).frn X?i Jason D. Arnold, Esq. Po Box 6462 Harrisburg, Pa 17112 717-412-1734 (f) 717-307-3417 jda@jdarnoldlaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SEZAN HESSOU CIVIL DIVISION © `=' PLAINTIFF : IN CUSTODY?,, r- rn- - = :;o ? urn CD VS. p NO. 2009-5879 CV 1 -+o CHERI ANN HESSOU 'BCD - r? ` rv ? rn DEFENDANT MOTION FOR CONTINUANCE OF CUSTODY CONCILIATION CONFERENCE Plaintiff Sezan Hessou, by and through his attorney undersigned below, makes the following motion. 1. Mr. Hessou has recently retained Attorney Arnold's services for his custody dispute. 2. Attorney Arnold currently has a hearing in Hanover, York County for the same day as the scheduled custody conciliation. 3. He is unable to cover both hearings. 4. Additionally, it will take some time in order for Attorney Arnold to best represent Mr. Hessou. 5. In addition, Mr. Hessou is unable to attend the hearing in person until later in the month of August due to work and school obligations, as previously represented. Wherefore, Plaintiff Hessou would ask to continue the custody conciliation until after August 31'. Respectfully Submitted Jason D. Arnold, Esq. Attorney for Sezan Hessou Date: z`j? Jason D. Arnold, Esq. Po Box 6462 Harrisburg 17112 717-412-1734 (f) 717-307-3417 jda@jdarnoldlaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SEZAN HESSOU PLAINTIFF VS. CHERI ANN HESSOU DEFENDANT CIVIL DIVISION IN CUSTODY NO. 2009-5879 CV CERTIFICATE OF SERVICE Pursuant to Pa.RC.P. 440, the undersigned does hereby verify that a true and correct copy of the Plaintiffs motion for continuance was served via facisimile and first class mail, postage pre-paid to Sheri D. Coover, Esq. 44 Hanover St, Carlisle Pa 17013 FAX 717 960 0074 Attorney for Defendant Dawn S. Sunday Esq. 39 W. Main St. #I Mechanicsburg, Pa 17055 Fax 717 795 7280 Conciliator On July 28, 2011 Jason D. Arnold, Esq. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SEZAN HESSOU PLAINTIFF VS. CHERI ANN HESSOU DEFENDANT To the Prothonotary, CIVIL DIVISION IN CUSTODY NO. 2009-5879 CV ENTRY OF APPEARANCE Kindly enter my appearance in the above captioned matter on behalf of Sezan Hessou, the plaintiff. Jason D. Arnold, Esq. Po Box 6462 Harrisburg, Pa 17112 717-412-1734 (f) 717-307-3417 jda%„i^?noldlawct)ui fir.. Jason D. Arnold, Esq. Attorney for Plaintiff Date: r SEZAN HESSOU, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW CHERI ANN HESSOU, Defendant NO. 09-5879 CIVIL TERM IN RE: MOTION FOR CONTINUANCE OF CUSTODY CONCILIATION CONFERENCE ORDER OF COURT AND NOW, this 8`" day of August, 2011, upon consideration of Plaintiff's Motion for Continuance of Custody Conciliation Conference, and it being the Court's understanding that Plaintiff's counsel was permitted by the Custody Conciliator to participate in the conference by telephone, the motion is deemed moot. BY THE COURT, /Jason D. Arnold, Esq. P.O. Box 6462 Harrisburg, PA 17112 Attorney for Plaintiff Sheri D. Coover, Esq. 44 South Hanover Street Carlisle, Pa 17013 Attorney for Defendant Dawn S. Sunday, Esq. 39 W. Main Street Mechanicsburg, PA 17055 Custody Conciliator J. e1(oh c - . c; _,,f rc Sheri D. Coover, Esquire c-) o ri Law Office of Sheri D. Coover -OX = --i Attorney ID 93285 r-nCo c =-n 44 S. Hanover Stree t rn ;0 Carlisle, Pa 17013 -<> o W o (717) 960-0075 (telephone) <r= (717) 960-0074 (facsimile) ?C-1 x o C:) a -n a 5:c: rv orn .t n :v SEZAN HESSOU, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. CASE NO. 09-5879 CHERI ANN HESSOU, Defendant CUSTODY PETITION TO WITHDRAW DEFENDANT'S PETITION TO MODIFY CUSTODY AND NOW, comes Defendant Cheri Ann Hessou by and through her attorney, Sheri D. Coover, Esquire and files the following PETITION TO WITHDRAW PETITION TO MODIFY CUSTODY ORDER and in support thereof avers as follows: 1. On June 3, 2011, Defendant filed a Petition seeking to modify the April 21, 2010 Custody Order which was entered on the above-captioned matter regarding custody of the minor child Xander T. Hessou. 2. After some consideration, Defendant (Mother) has decided that she is not interested in seeking the modification of custody at this time. 3. The Honorable Judge Oler was previously assigned to this case. 4. Opposing counsel and the conciliator have been notified by electronic mail regarding Defendant's desire to withdraw her petition. Neither have responded but it is assumed that neither will object to the withdraw of the custody modification request. WHEREFORE, Defendant respectfully requests that this Court grant her withdraw of her Petition to Modify Custody action. submitted, Xri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 Sheri D. Coover, Esquire Law Office of Sheri D. Coover Attorney ID 93285 44 S. Hanover Street Carlisle, Pa 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) SEZAN HESSOU, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. CASE NO. 09-5879 CHERI ANN HESSOU, Defendant CUSTODY ATTORNEY VERIFICATION I, Sheri D. Coover, Esquire hereby certify that I have reviewed the facts contained in the foregoing PETITION TO WITHDRAW DEFENDANT'S PETITION TO MODIFY CUSTODY and that my client has verified with me that all of the facts contained therein are true and correct to the best of my knowledge, info 'on and belief. I understand that I can be subject to penalties both criminally and civ under Pennsylvania and federal law for any false statements contained therein. I.30-ni I i D. Coover, Esquire Date M Sheri D. Coover, Esquire Law Office of Sheri D. Coover Attorney ID 93285 44 S. Hanover Street Carlisle, Pa 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) SEZAN HESSOU, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY PENNSYLVANIA v. CASE NO. 09-5879 CHERI ANN HESSOU, Defendant CUSTODY CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certifies that on this day of kg' +' , 2011, I caused the foregoing PETITION TO WITHDRAW DEFENDANT'S PE ION TO MODIFY CUSTODY to be served upon counsel for the Plaintiff/Respondent by United States first class mail addressed as follows: Jason Arnold, Esquire PO Box 6462 Harrisburg, PA 17112 submitted, S ri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 n r.a C= O -V X z_ Sheri D. Coover, Esquire =rri CU M Attorney ID 93285 cnf-- w 44 S. Hanover Street CD Carlisle, PA 17013 (717) 960-0075 _ (717) 960-0074 1 Attorney for Defendant Cheri Ann Hessou 4 -?' CA - SEZAN HESSOU, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. : CASE NO. 09-5879 CHERI ANN HESSOU, Defendant IN DIVORCE MOTION TO WITHDRAW ATTORNEY APPEARANCE AND NOW, comes Attorney Sheri Coover and files the following MOTION TO WITHDRAW AS COUNSEL and in support thereof avers as follows: 1. Undersigned counsel entered her appearance on behalf of the Defendant Cheri Ann Hessou in the above-mentioned captioned matter and has filed two Petitions to modify custody on the Defendant's behalf and represented the Defendant in two conciliation conferences. 2. Defendant has represented to undersigned counsel that she is not interested in pursuing the current modification of custody that is pending before the Court (a separate Petition to Withdraw Petition to Modify Custody is being filed at the same time as this Motion.) 3. Defendant has expressed to undersigned counsel that for financial reasons she no longer requests the services of undersigned counsel. ^i rn? 'urn M6 x-n °xzi orn 4. The Honorable Judge Oler has previously been assigned to this case. 5. Attorney Jason Arnold, counsel for Plaintiff Sezan Hessou has been contacted regarding this Motion. As of the time of the filing of this motion, he has not responded. His position on this matter is unknown. WHEREFORE, undersigned counsel hereby requests that this Court grant her Motion to Withdraw as Counsel. submitted, S ri D. Coover, Esquire ttorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 (717) 960-0074 Attorney for Defendant Cheri Ann Hessou SEZAN HESSOU, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CASE NO. 09-5879 CHERI ANN HESSOU, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on this 30th day of August, 2011, I caused a copy of the foregoing motion to be served upon the following persons by United States First Class mail postage pre-paid addressed as follows: Jason Arnold, Esquire PO Box 6462 Harrisburg, PA 17112 Cheri Ann Hessou 1611 Market Street, Apt. B Camp Hill, PA 17011 submitted, h D. Coover, Esquire A orney ID 93285 44 S. Hanover Street Carlisle, PA 17013 C _ C C: rrjw cn MF ? Z "Orn Sheri D. Coover, Esquire i ? op Law Office of Sheri D. Coover <Q --4 C) Attorney ID 93285 vc~3 a =F 44 S. Hanover Street ° L? °+ Carlisle, Pa 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) SEZAN HESSOU, Plaintiff v. CHERI ANN HESSOU, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CASE NO. 09-5879 : CUSTODY ORDER AND NOW, this day of , 2011, upon consideration of the attached petition, it is hereby directed that the P ITION TO MODIFY CUSTODY that was filed by Defendant/Petitioner is hereby WITHDRAWN. Distribution List: Sheri D. Coover, Esquire (for the Defendant/Petitioner) 44 S. Hanover Street, Carlisle, PA 17013 Jason Arnold, Esquire (Plaintiff/Respondent) PO Box 6462, Harrisburg, PA 17112 ?Copal ql,?(11 D X6 SEZAN HESSOU, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW N 0 CHERI ANN HESSOU, _-°,. co rn?-, Defendant NO. 09-5879 CIVIL TERM ? r R IN RE: MOTION TO WITHDRAW ATTORNEY APPEARANC' c3 n =C = oM ORDER OF COURT v z AND NOW, this 1St day of September, 2011, upon consideration of the Motion to Withdraw Attorney Appearance, a Rule is hereby issued upon Plaintiff and Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 14 days from the date of this order. BY THE COURT, Jason D. Arnold, Esq. P.O. Box 6462 Harrisburg, PA 17112 Attorney for Plaintiff Sheri D. Coover, Esq. 44 South Hanover Street Carlisle, Pa 17013 Attorney for Defendant ? Sezan Hessou 313A West Shady Lane Enola, PA 17025 J Pesley Ole , Jr., Ma;,led Gies ^ I 0 :rc SEZAN HESSOU, Plaintiff V. CHERI HESSOU, Defendant woo *ft"k,42t &00 L 1wow IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT No. 2009-5879 CIVIL TERM IN RE: DEFENDANT'S ATTORNEY 7 N D. ARNOLD' PETITION TO WITHDRAW ORDER OF COURT AND NOW, this 17th day of February, 2012, upon consideration of Jason D. Arnold, Esq., attorney of record for Plaintiff Sezan Hessou, a Rule is issued upon Plaintiff and Defendant to show cause why the relief requested in Attorney Arnold's Petition should not be granted. RULE RETURNABLE within 20 days from the date of this order. By the Court, ThomaYAJ Placey C.P.J. Distribution List: ca Jason D. Arnold, Esq -n3 x? P.O. Box 6462 MUD rn rn Harrisburg, PA 17112 - =Oc 'j CD r --Ic Sezan P. Hessou 313 A West Shady Lane Enola, PA 17025 p- Cc Cheri Hessou 1611 Market Street Apt. B Camp Hill, PA 17011 X0)01 X3.5 M,1 je4 )OVI - n SEZAN HESSOU IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2009-5879 CIVIL ACTION LAW CHERI ANN HESSOU Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of 2013, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Courtroom Number,j`- of the Cumberland County Courthouse on the ,-)S L day of , 2013, at at which time testimony will be taken. For purposes of the hewing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least 10 days prior to the hearing date. 2. Pending the hearing and further Order of Court, the Mother shall have primary physical custody of the Child and the Father shall have partial physical custody in accordance with the following schedule: A. Saturday, March 23, 2013 from 9:00 a.m. through 6:00 p.m. Sunday, March 24, 2013 from 9:00 a.m. through 6:00 p.m. Saturday, March 30, 2013 from 12:00 noon through 6:00 p.m. Sunday, March 31, 2013 from 9:00 a.m. through 6:00 p.m. B. Thereafter, every weekend from Friday at 6:00 p.m. from daycare through Sunday at 6:00 p.m. 3. The parent receiving custody of the Child shall be responsible to provide transportation for the exchange of custody. 4. Both parties shall refrain from using physical discipline with the Child. 5. As requested by the Father, the parties shall select a Guardian Ad Litem by agreement to represent the Child and shall submit an appointment order by stipulation to the Court for entry. BY THE COURT, Christylee P k J. cc: v John M. Kerr Esquire—Counsel for Father Jane Adams Esquire—Counsel for Mother D w t rn as rri X- Cn PAIL =c.. a - SEZAN HESSOU IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 2009-5879 CIVIL ACTION LAW CHERI ANN HESSOU Defendant IN CUSTODY Prior Judge: Christylee Peck CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Xander T. Hessou November 3, 2007 Mother 2. A custody conciliation conference was held on March 21, 2013, with the following individuals in attendance: the Father, Sezan Hessou, with his counsel, John M. Kerr Esquire, and the Mother, Cheri Ann Hessou, with her counsel, Jane Adams Esquire. 3. Under the prior custody Order dated April 21, 2010, the Father had primary physical custody of the Child and the Mother had partial custody. In September, 2012, an incident occurred in which the Mother alleged that the Child had been injured by the Father, and as a result, Children & Youth Services conducted an investigation and criminal proceedings were initiated. The Children& Youth Services investigation did not result in a finding of abuse and the criminal proceedings resulted in a plea from simple assault to harassment to the child. Judge Guido sentenced the Father to 90 days of probation on the day before the conciliation conference and the bail conditions were dropped. The Protection from Abuse Order entered by agreement after the incident, modified the existing custody order pending further custody proceedings or until the bail conditions are "otherwise modified". 4. The Mother filed this Petition to Modify seeking primary physical custody of the Child on an ongoing basis. The Father objected to the Mother's request and seeks to reimplement the existing custody Order dated April 21, 2010 under which the Father has primary custody. 5. The parties were unable to reach an agreement and it will be necessary to schedule a hearing in this matter. 6. The Mother's position on custody is as follows: The Mother believes the Father abused and injured the Child on September 29. When the Mother came to pick up the Child on that date, she stated that the Father told her he had pinched the Child's ears and hit him with a paper across the cheek when the Child was unable to write his numbers correctly. The Father suggested she put ice on the Child's ear. The Mother stated that she took the Child to the Emergency Room to document the incident and took pictures of the Child's face and ear with her phone. Since that time, due to Children & Youth proceedings and the pending criminal charges,the Mother has had exclusive custody of the Child. The Mother stated that the Child is fearful of the Father and does not want to reestablish contact. The Mother seeks primary physical custody of the Child but indicated her willingness for the Father to have custody on weekends beginning with daytimes only until the Child has readjusted. The Mother is concerned about the Child's safety in the Father's extended custody. 7. The Father's position on custody is as follows: The Father adamantly denied the allegations of abuse and indicated that he simply pinched the Child's ears and swatted him on the cheek with a paper to help him focus while writing his numbers. The Father believes that the Mother has set up the situation so that she could obtain primary custody. The Father emphasized that Children & Youth Services did not make a finding of abuse and the criminal simple assault charges were ultimately reduced to a plea of harassment. The Father denied that the Child had the brush burns (indicated on the photographs)to his face when he left the Father's custody on September 29. The Father noted that the Child had an accident on his bike a few days before and was hit with a toy while in daycare but that neither of these incidents caused the facial scrapes in the photograph on the Mother's phone. The Father believes there is no reason that he should not resume having primary physical custody under the existing Court Order dated April 21, 2010. The Father does not agree to a reduction in his custodial time on an ongoing basis. 8. After obtaining guidance from the Court, the conciliator recommends an Order in the form as attached scheduling a hearing in this matter and establishing temporary custodial arrangements pending the hearing. 9. It is requested that the hearing be expedited to the extent possible on the Court schedule. It is anticipated that the hearing will not require more than one-half day. J lr; J y /J 4 Date Dawn S. Sunday, Esquire Custody Conciliator SEZAN HESSOU, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA v. .• • . 2009-5879 CIVIL ACTION LAW CHERI ANN HESSOU, • Defendant/Petitioner : IN CUSTODY ORDER OF COURT AND NOW, this 25th day of June, 2013 , this being the time and place set for a hearing on the Petition for Custody Modification, and both parties having presented their cases in full, the evidence is hereby deemed closed, and this matter is taken under advisement . By the Court, ;?AeA:: Chris lee L. Peck ✓ John M. Kerr, Esquire C For the Plaintiff/Respondent -cis. w -i Jane Adams, Esquire, c=z) N x7r For the Defendant/Petitioner ,.�� ,� , vae 3>y ec /�//)� • ?C) ,L' x/21//3 . --1/12 SEZAN HESSOU, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION—LAW CHERI ANN HESSOU, Defendant. NO. 09-5879 CIVIL TERM IN RE: CUSTODY ORDER OF COURT AND NOW, this 23rd day of July, 2013, following a hearing concerning the parties' legal and physical custodial responsibilities for their minor child, Xander Tonan Hessou ("the Child"), born November 3, 2007, it is hereby ORDERED AND DECREED that, in the child's best interests, the "Parenting Plan" shall be as follows: 1. LEGAL CUSTODY Plaintiff Sezan Hessou ("Father") and Defendant Cheri Ann Hessou ("Mother") shall have shared legal custody of the Child. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5336, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to medical, dental, religious or school records, the residence address of the Child and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the Child. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. PHYSICAL CUSTODY In General: a. Mother and Father shall equally share physical custody of the Child, alternating week-on, week-off. This general week-on, week-off schedule shall begin on August 18, 2013 with Mother having the Child during that week. In addition to the above, Mother shall have the Child each year for the week prior to the start of the Child's school year, even if that week would normally be Father's week-on with the Child, provided that the Child is still enrolled in the same school district where the Mother resides. b. Father shall have the following periods of physical custody of the Child: i. Every Sunday evening, during Father's respective week-on with the Child, from 6:30 p.m. through the following Sunday evening at 6:30 p.m. Father will assure that the Child is transported to Mother's residence by 6:30 p.m. on the returning Sunday evening for the start of her week of custody. Father 2 will assure that the Child is transported to and from school each day on a timely basis, such that the Child is not tardy to school, during his period of custody. ii. For an additional period of three weeks every summer during the last week of July and first two weeks of August. This year Father's three week period of custody will begin Sunday, July 28, 2013 at 6:30 p.m. and end Sunday, August 18, 2013 at 6:30 p.m. Father will assure that the Child is transported to Mother's residence on Sunday, August 18, 2013 by 6:30 p.m., at which time the regular week-on, week-off schedule will resume. c. Mother shall have the following periods of physical custody of the Child: i. Every Sunday evening, during Mother's respective week-on with the Child, from 6:30 p.m. through the following Sunday evening at 6:30 p.m. Mother will assure that the Child is transported to Father's residence by 6:30 p.m. Sunday evening for the start of his week of custody. Mother will assure that the Child is transported to and from school during her period of custody on a timely basis such that the Child is not tardy to school. Education: As long as Mother remains a resident of Camp Hill, the Child shall be enrolled as a student in the Camp Hill School District. Should Mother relocate outside of the Camp Hill School District, then Father may exercise the right to enroll the Child in the West Shore School District, provided 1) he first gives Mother written notification of his intent, 2) the Child's schooling is not 3 interrupted, and 3) the transition occurs at a reasonable date given in consideration of the school calendar such that the transition may be accomplished smoothly for the Child. This provision can be modified only by order of court. Holidays and Vacations: The parties have agreed to determine the holiday and vacation schedule for the Child through mutual consent. The parties, however, shall provide each other with complete addresses and telephone numbers where they can be reached while on vacation with the Child if they vacation away from their residence. Such notification will occur no less than one week prior to the respective holiday or vacation. 3. GENERAL RULES OF CONDUCT a. Promoting Affection: Each parent shall promote the natural development of the Child's love and affection toward the other parent or the other parent's extended family, and shall make a conscience effort to do so. To the extent possible, the parents shall prevent third parties from alienating the Child's affections from the other parent as well as the other parent's extended family. b. Promoting Respect: It shall be the duty of each parent to hold out the other parent as one the Child should respect and love. Each parent shall speak respectfully of the other whether it is believed the other reciprocates or not. Each parent shall refer to the other by the appropriate role name such as Mom, Dad, your grandmother, or other familial name of respect. 4 c. Emergencies: Health insurance coverage of the Child is provided by Mother through her employer. Emergency decisions regarding the Child shall be made by the parent then having custody. However, in the event of any emergency or serious illness of the Child at any time, the party then having custody of the Child shall immediately communicate with the other party by telephone or any means practical, informing the other party of the nature of the illness or emergency so that the other parent can become involved in the decision making process as soon as practical. d. Communication: At all times, the parents shall civilly and respectfully communicate about co-parenting, legal custody issues, and changes in schedules whether by telephone, via letters, faxes, texts, email, in person, or by whichever means is the most appropriate for the matter. When the communication deals with a scheduling issue it shall be acknowledged by the other party. The parents shall refrain from encouraging the Child to provide reports about the other party. Communication should always take place directly between parents, without using the Child or others as an intermediary. e. Transportation: Transportation shall be by the terms of this Order or shared as agreed by the parties. f. Notice: The parents shall give each other five hours of notice of any conflict that may prevent the transportation of the Child so that other arrangements may be made through mutual agreement. 5 g. Alcohol and Drug Use: During any period of custody, the parties shall not possess or use illegal substances or consume or be under the influence of alcoholic beverages to the point of intoxication. Any prescribed medications shall be taken only to assure therapeutic levels. The parents shall, to the extent possible, ensure that other household members and or guests comply with this provision. h. Modification: The parties may modify the terms of this Order, but in order to do so, the Court makes it clear that both parties must be in complete agreement to any new terms, meaning that both parties must consent in writing on what the terms of the custody arrangement or schedule shall be. In the absence of mutual consent, the terms of this Order shall control. The reason this Order is set out in such detail is so both parties have it to refer to and to govern their relationship with the Child and with each other in the event of a disagreement. i. Proposed Modifications: Both parents shall use their best efforts to engage in joint decision-making with respect to the Child. In the event the parents are unable to reach an agreement, they shall exchange written proposals, including appropriate explanations of their positions, after which they shall discuss their modification proposals, if necessary, to reach a decision in the best interests of the Child. This shall be done prior to contacting their respective attorneys. 4. RELOCATION a. Relocation is defined as a change in residence of the Child which significantly impairs the ability of a non-relocating party to exercise custodial rights. No relocation shall occur unless every individual who has custody rights to the Child 6 consents to the proposed relocation or the court approves the proposed relocation. If a party seeks to relocate, that party shall notify every other individual who has custody rights to the Child. Both parties must follow the statutory requirements contained in 23 Pa.C.S. §5337. Specifically, the relocating party must notify every other individual who has custody rights to the Child by certified mail, return receipt requested. The notice must then comply with the following requirements: i. Notice must be sent no later than: (1) the 60th day before the date of the proposed relocation. (2) the 10`" day after the date that the individual knows of the relocation if the individual did not know and could not reasonably know of the relocation in sufficient time to comply with the 60 day notice requirement and it is not reasonably possible to delay the date of relocation so as to comply with the 60 day notice requirement. ii. Unless otherwise excused by law, the following information must be included in the notice: (1) the address of the intended new residence. (2) the mailing address, if not the same as the address of the intended new residence. (3) names and ages of the individuals in the new residence, including individuals who intend to live in the new residence. (4) the home telephone number of the intended new residence, if applicable. 7 (5) the name of the new school district and school. (6) the date of the proposed relocation. (7) the reason(s) for the proposed relocation. (8) a proposal for a revised custody schedule. (9) any other information which the party proposing the relocation deems appropriate. (10) a counter-affidavit as provided under subsection (d)(1) which can be used to object to the proposed relocation and modification of a custody Order. (11) a warning to the non-relocating party that, if the non-relocating party does not file with the court an objection to the proposed relocation within 30 days after receipt of notice, non-relocating party shall be foreclosed from objecting to the relocation. iii. If any of the aforementioned information is not known when the notice is sent but is later made known to the party seeking the relocation, then that party shall promptly inform every individual who received notice. iv. If the non-relocating parent objects to the proposed move, he/she must do so by filing the counter-affidavit with the court and the other party within 30 days. The notice of objection to the opposing party must be sent by certified mail, return receipt requested. If no objection is made in the manner set forth above then it shall be presumed that the non-relocating parent has consented to the proposed relocation and the court will not 8 accept testimony challenging the relocation in any further review of the custodial arrangements. V. The court shall hold an expedited full hearing on the proposed relocation after a timely objection has been filed and before relocation occurs. The court may permit relocation before a full hearing if the court finds that exigent circumstances exist. 5. ENUMERATED OFFENSES This Court was presented with certified copies of Father's criminal records. Since 2011, Father's criminal history is as follows: Disorderly Conduct under 18 P.S. §5503(a)(2), One Way Roadways and Rotary Traffic Island under 75 P.S. §3308(a), Criminal Mischief under 18 P.S. §3304(a)(1); Criminal Trespass, a felony of the second degree, under 18 P.S. 3503(a)(1)(2); Bad Checks under 18 P.S. §4105(a)(1), and Harassment under 18 P.S. §2709(a)(1). Mother testified that she has no criminal convictions. Mother testified the Rob Noll, her boyfriend, does not have any criminal convictions. Taking the evidence presented and testimony into consideration, this Court has determined that the parents pose no threat of harm to the Child. See 23 Pa.C.S.A. § 5329. 6. ASSESMENT In arriving at this plan, the Court considered the following factors: a. Permitting or Encouraging Contact: Both parents exhibit a willingness to allow the other parent to play a role in the Child's life. Communication has been a problem between the parents in the past and both parents must 9 improve communication regarding the availability and transportation of the Child's asthma medication between houses and parents. b. Present and Past Abuse: In September of 2012, Father pinched the Child's ears and hit the Child with a paper when the Child was not doing his homework. The Child said his nose had been bleeding and that he had asked Father to stop but he had not. This left the Child with bruising but the injuries were not severe. This incident resulted in a guilty plea by Father to a Harassment charge and a Protection from Abuse Order being entered by consent of the parties against Father. In addition, when the Child was a one- year-old he was burned by water that was too hot while under the supervision of Father. Mother expressed concern regarding Father's ability to supervise the Child. Father uses corporal punishment. Mother has spanked the Child only as an extreme measure of discipline. c. Parental Duties: Mother is thirty years old and works for Menlo Worldwide Logistics. Father is thirty-six years old and is a student at Penn State University, Harrisburg campus, where he studies electrical engineering and works as a research assistant and teacher's aide. He is scheduled to graduate in December of 2014. Both parents love the Child. Father is a stricter disciplinarian than Mother. Father appears to provide greater structure to the Child's day through the delineation of the Child's activities. Father also appears to place a greater priority on the Child's 10 education. Mother does not appear to have as structured an interaction with the Child. d. Stability and Continuity in the Child's Life: Mother resides with her boyfriend, Mr. Noll. Mr. Noll is twenty-three years old and employed as a warehouse worker/material handler. Mother testified that Mr. Noll makes the Child meals, picks the Child up from school, plays with the Child, and helps the Child with assignments. Mother testified that the Child and Mr. Noll get along well. Father shares a residence in New Cumberland with Carol Abraham, from whom he rents a residence on a month to month basis. The Child has a separate bedroom at this residence. The Father intends to keep the Child at this residence during his periods of custody. The Father has also rents a one room apartment near campus where the Child sleeps on a bed and Father sleeps on a sofa. The above custody schedule is designed to provide the most continuity in the Child's schedule. e. Availability of Extended Family: Neither party has extended family readily available. Mother's extended family, her mother, lives in the Pocono Mountains in Pennsylvania and Mother visits every few months. Father has a cousin in Philadelphia. The rest of Father's extended family live overseas. Father emigrated from Africa and has Permanent Resident status in the U.S. f. Child's Sibling Relationships: The Child has no siblings at either residence. 11 g. Child's Preference: The Child, age 6, was not present at the hearing. Mother reported at the hearing that the Child said he was okay with spending time with both parents. h. Attempts to Turn the Child Against the Other Parent: There does not appear to be any attempt by either parent to turn the Child against the other parent. i. Maintaining a Relationship: Both parents appear to be able to maintain a loving, stable, consistent, and nurturing relationship with the Child adequate for the Child's emotional needs. j. Attending to the Needs: Both parents appear to be capable of attending to the daily physical, emotional, developmental, and educational needs of the Child which is reflected in this Order's equal division of physical custody between the parents. k. Proximity of Residences: The parties' residences are a twenty-five minute drive apart from each other. 1. Availability of Care: Mother has made the representation to this Court that her work schedule will be changing within the next four to six weeks. Her current work schedule is 12:04 noon to 9:00 p.m., Monday through Friday. Her new work schedule will be 9:00 a.m. to 6:00 p.m., Monday through Friday. Father made the representation to this Court that his daily schedule as a student is typically 8:00 a.m. to 5:00 p.m. Based on these representations by the parties, both parents are available, willing, and able to care for the Child. 12 m. Level of Conflict: There is a moderate level of conflict between the parents but the parents I exhibit a willingness to cooperate with one another as demonstrated by their ability to agree on the Child's vacation and holiday schedule. n. History of Drug and Alcohol Ise: No evidence of drug or alcohol use was presented. Neither parent appears to abuse alcohol or drugs at this time. o. Mental and Physical Condition: Father testified that he does not have any mental health issues and is not taking any medication. Mother was diagnosed with depression earlier in life. She testified that in 2001, she had an issue cutting herself. She is currently taking no medication. Mother testified that Mr. Noll is not taking any medication. At the present, the mental and physical condition of Father and Mother are satisfactory to this Court. A copy of this final order of custody shall be sent to both attorneys, who shall provide a copy to their client. BY THE COURT, _ " rO N�— /, ` ' CD ins' risty ee L. Peck, J. ` ' -s� Ch r-o /John M. Kerr, Esq. 5020 Ritter Road, Suite 104 Mechanicsburg, PA 17055 Attorney for Plaintiff 13 • O V Jane Adams, Esq. 17 West South Street Carlisle, PA 17013 Attorney for Defendant 14 IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA, CUMBERLAND COUNTY CIVIL DIVISION-LAW Sezan Prudence HESSOU IN CUSTODY (Plaintiff) • Docket No. 2009—5879 CV vs. Cheri Ann HESSOU (Defendant) Motion To Compel 1. The Plaintiff is Sezan Hessou residing at 47 Drexel P1.,New Cumberland, Pennsylvania 17070. 2. Plaintiff is a full time student at Pennsylvania State University. 3. The Defendant is Cheri Ann Hessou residing at 1611 Market St., Apt. B Camp Hill, Pennsylvania 17011. 4. This Court has jurisdiction over this matter as both Plaintiff and Defendant reside in Cumberland County, Pennsylvania. 5. Defendant is a unique child and has no sibling anywhere in the continental United States (US) or in the world. 6. Plaintiff and Defendant have a 6 year old boy together. 7. The child has no direct blood relative in the US, beside his blood parents(Defendant and Plaintiff), a cousin in Philadelphia, and his mother's mom as grandmother. 8. Their child has always had a passport that allows both parents to take him out of the country to visit the father's family abroad. 9. Plaintiff and Defendant have been separated since 2009. rnw - rn �. 70 .."( 10. Plaintiff was initially granted full custody of the child. _<> c) < 11. There is a current custody order in place. z -; 5 N 12. The current custody in place was issued by this court and grants shared custody to both parents. 13. With the shared custody, Plaintiff also was also granted an additional period of three (3) weeks with the child during the summer. 14. Both Plaintiff and Defendant are in compliance with the current order. 15. Plaintiff is currently a constituent of Cumberland County, of Pennsylvania, and of the US. 16. Even though a US constituent, plaintiff is also a foreign national. 17. Defendant was aware of the latter before committing with plaintiff in a marital union that lasted 6 years. 18. Back when Plaintiff and Defendant were still married, Defendant had a passport as well and traveled with Plaintiff and their child abroad as well. 19. On May 6, 2014, Plaintiff contacted Defendant to notify her of the expired passport of their son. 20. Plaintiff also notified Defendant of his intention to take their son abroad this summer during his additional custody time to visit their family. 21. The same day (May 6, 2014), Defendant replied to oppose the passport renewal on the ground that she opposes taking the child abroad where the child has a bigger family. Indeed the child has 26 brothers and sisters still alive; the majority of which already have child(ren). Some of them visited the child on numerous occasions and would like the child to visit as well. See exert of telephonic conversation between Defendant and Plaintiff as follows: Me:Cheri, This is to follow up on the boy's health.I never heard back from you. He is currently underweight, which is bad and unhealthy. 6:45 AM Me:Please make sure he sleeps ore and longer as well as better, in a calming environment without any disturbance. He need to eat no fat free food food. He must eat some fat, his fruit, veggies, green,proteins, and carbs. You also need to keep checking his weight on a daily basis. 6:47 AM Me: You should also consult his doctor for advice. 6:47 AM Me:On a separated note, this is an FYI only. It is also an offer to you.Xan will be starting to go to CHURCHES AFFILIATED CHILD CARE CENTERS, HOOVER ELEMENTARY(717) 737-4515, 420 S 24TH ST, CAMP HILL, PA 17011-5309 on Monday, May 12, 2014. 8:31 AM Me: This is to prevent any tardies to drop hi off and pick him up for any reason as the center is located in the ulti purpose room of the school he goes to. You are welcome to use that service as well. You can take him directly to school or drop him of at the center and they will ensure he goes to class every day. You can also pick hi up late if you are unable to get him at 3:05 PM immediately, as long as you get him before 5:30 PM 8:33 AM Me: The center closes at 6:00 PM 8:33 AM Me:But if you will be using this service at all, I will need to know so I can tell the center that he will be there every week. But if you know for sure you will not be using this service, I will go ahead and tell them he will only be coming every other week. Either way, I need to know today so I can go ahead and fill out the paperwork for submission. 8:35 AM Me:Finally for today, I would like to go with you to the postal office to renew Xan's passport.I am taking him home this Summer and he will need his passport renewed. 9:06 AM Cheri Hessou:I will not be using the child care service, but thanks for the offer. 10:42 AM Cheri Hessou:I will talk to his doctor, however at his well child check in March, his weight was perfectly healthy. In fact, the doctor was surprised that he gained about 9 pounds since the previous year, which the average for children his age is 5 a year 10:44 AM Cheri Hessou:And finally, and I know this will cause some problems, I will not sign for his passport to be renewed. I do not agree to taking him overseas, and its my legal right as his mother to say so. Ifyou feel otherwise,you're welcome to take it to court. 10:48 AM Cheri Hessou:Please don't blow up my phone over that last txt. Thanks 10:48 AM Me:No need to blow your phone. See you in court. I already have a motion drafted to proceed. ;)3:19 PM Cheri Hessou:Fine with me. 3:21 PM Me:If I may ask, what is your ground for denying him a passport?3:24 PM 22. The child's grandparents are overseas and the child has never visited them. 23. The child's grandfather just had a stroke and is physically fully paralyzed. Consequently he has expressed the need to see his grandchild before passing away and returning home to God. 24. The child cannot leave the country without a valid and unexpired passport. 25. The child is a US citizen from by Jus sol and Jus sanguinis. 26. By her refusal to cooperate, Defendant is removing all of the child constitutional rights provided by 22 U.S.C. § 211. WHEREFORE, Plaintiff requests this Honorable Court to compel Defendant to cooperate with the passport renewal process of their child, Xander Tonan Hessou. Respectfully, Sezan P. HESSOU Date_5/06/2014_ DISTRIBUTION: - Jane Adams, Esquire, 17 W. South St., Carlisle, Pa. 17013, (717) 245-8508 voice, (717) 241-2456 fax -DISTRICT COURT ADMINISTRATION, Cumberland County Courthouse, 1 Courthouse Square, Suite 301, Carlisle, PA 17013, Ph: 717.240.6200, Fax: 717.240.6460 - OFFICE OF PROTHONOTARY, Cumberland County Courthouse, 1 Courthouse Square Suite 100, Carlisle, PA 17013, Ph: 717.240.6195,Fox: 717.240.6573 IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA, CUMBERLAND COUNTY CIVIL DIVISION - LAW Sezan Prudence HESSOU IN CUSTODY (Plaintiff) Docket No. 2009—5879 CV vs. Cheri Ann HESSOU (Defendant) CERTIFICATION OF CONTESTATION,PURSUANT TO DAUPHIN COUNTY LOCAL RULE 208.2(d) I, Sezan P.HESSOU, Pro Se Plaintiff, hereby certify that the full text of this motion to compel and the proposed order were sent to all parties by electronic transmission. Concurrence to the motion and proposed order has been denied by defending party via text message exert above. However, after sending the full text of the motion to defendant's counsel,plaintiff never heard back from either party (Enclosure: Electronic communication to defending party) Respectfully submitted, ANINN Sezan P. Hessou Pro Se hessou @gmail.com 717-585-0188 Date 5/06/2014 IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA, CUMBERLAND COUNTY CIVIL DIVISION-LAW Sezan Prudence HESSOU IN CUSTODY (Plaintiff) Docket No.2009—5879 CV vs. Cheri Ann HESSOU (Defendant) VERIFICATION I verify that the facts contained in the above pleading are true and correct to the best of my knowledge, information and belief. I understand that the facts herein are verified subject to the penalties for unsworn falsification to authorities under Crimes Code, Section 4904 (18 Pa.C.S. § 4904). ....rm. IrI r1,.mom .airy`u V: arc •• Sezan P. Hessou Pro Se hessou@gmail.com 717-585-0188 Date 5/06/2014_ IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA, CUMBERLAND COUNTY CIVIL DIVISION- LAW Sezan Prudence HESSOU IN CUSTODY (Plaintiff) Docket No. 2009—5879 CV vs. Cheri Ann HESSOU • (Defendant) CERTIFICATE OF SERVICE I hereby certify that I am this day serving the foregoing document upon the person(s)and in the manner indicated below. Service by successful facsimile transmission pursuant to Pa R.C.P. 440d. (2)and(3)to: Jane Adams, Esquire 17 W. South St., Carlisle Pa. 17013 Ph: (717) 245-8508 Fax: (717) 241-2456 Sezan P. Hessou Pro Se hessou @gmail.com 717-585-0188 Date 5/06/2014_ Gmaai1-Con&w-rence https://mail.google.com/mail/u/0/?ui=2&ik=7705c41142&view=pt&se... iSezan Hessou <hessou @gmail.com> Concurrence 1 message Sezan Hessou <hessou @gmail.com> Wed, May 7, 2014 at 12:23 AM To: Jane Adams <esqadams@gmail.com> Jane, Please see PDF attachment for the texts of the motion to compel I am filing today and seeking your concurrence. I will appreciate any effort to get back to me today, so I can file it at the end of the day or on Thursday morning. Regards, Sezan P. HESSOU Electrical Engineering/Computer Sciences Dual MD/Ph. D Candidate IEEE Member IEEE Computer Society Member of the National Society of Black Engineers (NSBE) hessou @gmail.com 717-585-0188 "Don't count the days, make the days count." - Muhammad Ali in Motion To Compel Cheri For Xan's PP.pdf 216K 1 of 1 5/7/2014 9:49 AM Jane Adams ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esgadams@gmail.com. 1 -OFFICE ii 1 IiE pR0TH NU SAF± T 2011i MAY 13 PH 1:16 CU PENNSYLVAN A COUNTY SEZAN PRUDENCE HESSOU, : IN THE COURT OF COMMON PLEAS Plaintiff vs. : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2009 - 5879 Civil Term CHERI ANN HESSOU, : ACTION IN DIVORCE Defendant : CIVIL ACTION - LAW MOTHER'S RESPONSE TO FATHER'S MOTION TO COMPEL AND NOW COMES, Cheri Ann Hessou, by and through her attorney, Jane Adams, and hereby responds to Father's Motion to Compel as follows: 1. The parties are the natural parents of Xander T. Hessou, born November 3, 2007, age 6. 2. The parties are subject to a custody Order entered by this Honorable Court on July 23, 2013. 3. On May 7, 2014, Father filed a Motion to Compel requesting that Mother release the child's passport to Father so he can take the child overseas to see distant relatives. 4. Father is from Benin, which is a country in West Africa located between Nigeria, Togo, Niger and Burkina Faso and it is believed that he is proposing to take the child there, although not much information has been provided to Mother. 5. Mother is extremely concerned about the child's health, welfare, and safety and does not believe it would be in the best interest of the child to travel to this country, due to the child's age, maturity level, and the length and distance and location of the proposed trip. 6. The child has no meaningful or ongoing relationship with the relatives Father proposes to visit. 7. Mother opposes Father's request to take the child to Benin, West Africa, in the best interest of the child's health, safety and welfare. Date: WHEREFORE, Plaintiff requests the court to deny Father's Motion to Compel. Respectfully submitted, Adams, Esquire o. 79465 est South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ATTORNEY VERIFICATION Undersigned counsel, Jane Adams, Esquire, hereby verifies and states that: 1. She is the Attorney of record for Cheri Ann Hessou. 2. She is authorized to make this verification on her behalf. 3. Due to the urgent nature of this matter, the undersigned attorney forwarded the attached response to the client electronically, after which the client indicated that she reviewed this document and the facts contained therein were true and correct. 4. The facts set forth in the foregoing response which was written by the undersigned are true and correct to her to the best of her knowledge, information, and belief. 5. She is aware that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: 5\, (ic _It A OA a, Oh sic Adams, Esquire . South St. lisle, Pa. 17013 Attorney for Cheri Ann Hessou CERTIFICATE OF SERVICE AND NOW, this May 12, 2014, I, Jane Adams, Attorney for Cheri Arm Hessou, hereby certify that a copy of Mother's RESPONSE has been forwarded to the following parties, by first class mail, by placing such in a pre -addressed pre -stamped envelope, addressed to: Sezan P. Hessou 47 Drexel Place New Cumberland, Pa. 17070\ FATHER Adams, Esquire o. 79465 . South St. ar isle, Pa. 17013 (717) 245-8508 ATTORNEY FOR MOTHER SEZAN PRUDENCE HESSOU, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION – LAW CHERI ANN HESSOU, Defendant : NO. 09-5879 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO COMPEL ORDER OF COURT AND NOW, this 13th day of May, 2014, upon consideration of Plaintiff's Motion To Compel, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days from the date of this order. BY THE COURT, Xe:an Hessou 47 Drexel Pl. New Cumberland, PA 17070 Plaintiff, pro Se Jane Adams, Esq. 17 West South Street Carlisle, PA 1 7013 Attorney for Defendant rc :Co i4/iy ee—e Christyl g L. Peck, J. SEZAN PRUDENCE HESSOU, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION — LAW CHERI ANN HESSOU, Defendant : NO. 09 -5879 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO COMPEL ORDER OF COURT AND NOW, this 29th day of May, 2014, upon consideration of Plaintiff's Motion To Compel, and Defendant's Answer thereto, it is hereby ordered as follows: 1. Father's Motion to Compel is denied at this time without prejudice to re- petition the Court as the Child gets older; and 2. In the event Mother renews the Child's passport during the life of this Order, Mother shall provide access to the passport to Father. BY THE COURT, ezan Hessou 47 Drexel Pl. New Cumberland, PA 17070 Plaintiff, pro Se ,., .,y Jane Adams, Esq. r n 17 West South Street PA 1 7013 Attorney for Defendant C ") :rc 'e.s 02:1 t tsc.0 4,/9// y r.) w