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HomeMy WebLinkAbout09-7375l 73 7z a*ffo Centre County Prothonotary Room 102 Courthouse Bellefonte, PA 16823 (814) 355-6796 Page N tuber: 1 GENERAL Filed......... 04-27-2004 Case Number: 04-1746 CUSTODY 01:42 Sat/Dis/Gntd.. -------------------------------------------------------------------------------- -------------------------------------------------------------------------------- Litigants -------------------------------------------------------------------------------- Plaintff(s) Lawyer(s) for the Plaintiff(s) ------------ ------------------------------ B RNS, DONNA KAY 2 7 NORTH RIDGE STREET B LLEFONTE, PA 16823 ( /14/08) B RNS, SHAWNEE KAY 1 8 S. FREDERICK STREET 1 T FLOOR M CHANICSBURG, PA 17055 ( /14/08) CERTIFIED from the records as entered and fil thi ffice of .0. 20 rot ono a nd erk of the Court Defendant(s) UCK, JALEA DREW 2 40 ADMIRAL COURT T LLAHASSEE, FL 32308 ( /14/08) Lawyer(s) for the Defendant(s) ------------------------------ G SNOT, CHRISTOPHER MATTHEW C O ROBERT GUENOT 2 30 W. GATESBURG ROAD W RIORS MARK, PA 16827 ( /14/08 -------'------ ) ---------------------------- - - - - ------------- - -- - ----- -------------------------- Proceedings ------------------------------------------------------------------- 04-27-2004 CUSTODY AGREEMENT FILED. 05-11-2,004 ORDER OF COURT, FILED. (CUSTODY AGREEMENT EXECUTED BY THE PARTIES IS ENTERED AS AN ORDER OF COURT.) (TIME-STAMPED COPIES GIVEN TO PLAINTIFFS; AND DEFENDANT, JALEA LAUCK ON 05-11-2004.) (TIME-STAMPED COPY MAILED TO DEFENDANT, CHRISTOPHER GUENOT (AT BOTH ADDRESSES] ON 05-12-2004.) 04-12-2006 PETITION FOR ODIFICATION OF A PARTIAL CUSTODY OR VISITATION ORDER, FILED. GAVE TO JUDGE APRIL 13, 2006. 04-17-2?J06 AFFIDAVIT OF SERVICE, FILED. 04-18-2M ORDER OF COURT, FILED. (CUSTODY CONFERENCE: MAY 3, 2006 AT 11:00 A. M., IN ROOM #203.) (TIME-STAMPED COPY MAILED TO PLAINTIFFS; DEFENDANT JALEA LAUCK; AND, DEFENDANT, CHRISTOPHER GUENOT {AT ALL ADDRESSES) ON 04-19-2006.) 04-24-206 COPY OF "ORDER OF COURT" OF APRIL 18, 2006 MAILED TO JALEA LAUCK AT BOALSBURG, PA, #9, RETURNED BY POST OFFICE ON 04-24-2006 MARKED "NOT DELIVERABLE AS ADDRESSED-UNABLE TO FORWARD" - REMAILED TO SAME ADDRESS AT #8 ON 04-24-2006. 05-02-206 COPY OF "ORDER OF COURT" OF APRIL 18, 2006 MAILED TO JALEA LAUCK AT #8, BOALSBURG, PA RETURNED BY POST OFFICE ON 05-02-2006 MARKED "UNABLE TO FORWARD" - DID NOT REMAIL. 05-18-206 ORDER, FILED. (CONFERENCE: AUGUST 14, 2006 AT 1:15 P. M. IN THE CHAMBERS OF PRESIDENT JUDGE CHARLES C. BROWN, JR., ROOM 203.) (TIME-STAMPED COPY GIVEN TO ATTORNEY MUIR; AND, ATTORNEY COOPER ON 05-19-2006.) i Centre County Prothonotary Room 102 Courthouse Bellefonte, PA 16823 (814) 355-6796 Page Number: Case Number: 2 GENERAL Filed......... 04-27-2004 04-1746 CUSTODY 01:42 Sat/Dis/Gntd.. --------------------- 05-26-12006 -------- ---------------------------------- EMERGENCY CUSTODY PETITION FOR SPECIAL RELIEF PURSUANT TO PA.R.C.P NO 1915.13 PROHIBITING PARTIAL CUSTODY BY DEFENDANT CHRISTOPHER MATTHEW GUENOT OF TWO YEAR, NINE MONTH OLD LEAH COEY VAUGHN LAUCK, TOMORROW, SATURDAY, MAY 27, 2006, SUNDAY , MAY, 28, 2006 AND THEREAFTER FOR THE SAFETY AND WELL BEING OF 07-17-0006 LEAH COEY VAUGHN LAUCK WITH CERTIFICATE OF SERVICE, FILED. CUSTODY AGREEMENT FILED. (SENT TO JUDGE 7/17/06) 07-17- 006 CHRISTOPHER MATTHEW GUENOT'S PETITION TO VOLUNTARILY TERMINATE 07-27-006 HIS PARENTAL RIGHTS, FILED. (SENT TO JUDGE 7/17/06) NOTICE OF HEARING , FILED. (HEARING: SEPTEMBER 8 2006 AT , 8:30 A. M. IN COURT ROOM #1.) (TIME-STAMPED COPY GIVEN TO ATTORNEY MUIR; AND, COPY MAILED TO ATTORNEY ROSENFELD; 09-08-006 PLAINTIFFS; AND, DEFENDANT, JALEA LAUCK ON 07-28-2006.) ORD ER, FILED. (THE HEARING SCHEDULED FOR THIS DATE IS CONTINUED UNTIL FURTHER ORDER OF THIS COURT.) (TIME-STAMPED COPY GIVEN TO ATTORNEY MUIR {IN BOX AT 4:00 P M ON . . 09-08-20061; AND, COPY MAILED TO ATTORNEY ROSENFELD; PLANTIFFS; AND, DEFENDANT, JALEA LAUCK ON 09-11-2006.) 07-16-008 ORDER, FILED. (REGARDING CUSTODY) (TIME-STAMPED COPY MAILED i 10-14-009 TO PLAINTIFFS; AND, DEFENDANTS ON 07-18-2008.) ORDER F , ILED. (PROTHONOTARY IS DIRECTED TO TRANSFER ABOVE CAPTIONED CASE TO CUMBERLAND COUNTY, COURT OF COMMON PLEAS . THIS CASE SHOULD BE TRANSFERRED IMMEDIATELY.) (MAILED COPY TO 10-16-009 PLNTFFS AND TO DEFS 10-16-09) CASE T RANSFERRED TO CUMBERLAND COUNTY. (CERT. MAIL)(MAILED 10/19/09)(#7003 050 0 0004 0901 1363) ------ ------ --------------------------------------------------- ---------------- Fees ------ ------ ------------------------------------------------------ CUSTODY - SEPARATE ACTION 100.00pd 04-27-2004 100.00 End of case print-out • III?IIIMIIII IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DONNA KAY BURNS AND SHAWNEE KAY BURNS, Plaintiffs V. No. 2004-1746 JALEA DREW LAUCK AND CHRISTOPHER MATTHEW GUENOT, Defendants Attorney for Plaintiffs: Attorney for Defendants: Pro Se Pro Se O R D E R AND NOW, this 14th day of October, 2009, it is hereby ORDERED as follows: The Prothonotary is directed to transfer the above captioned case to Cumberland County, Court of Common Pleas, 9th Judicial District, One Courthouse Square, Carlisle, Pennsylvania 17013-3387. N This case should be transferred immediately. =off ?-.4;;0 -, r*i = 3 - Q c z c-? r co- z? -0 rn .Z, <r BY THE COURT: v Gamela A. Ruest, Judge 1 • IIMI??11111? IN THE COURT OF COMMON PLEAS, CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DONNA KAY BURNS and SHAWNEE KAY BURNS, Plaintiff V. JALEA DREW LAUCK and CHRISTOPHER MATTHEW GUENOT, Defendants Attorney for Plaintiffs: Attorney for Defendants: ORDER No. 2004-1746 _ , . C3 Pro Se y -0 Pro Se u. AND NOW, this 14th of July, 2008, Plaintiffs Donna Kay Burns and Shawnee Kay Burns appearing and Defendant Christopher Matthew Guenot via telephone, all without representation, and after conference among the parties and upon agreement of the parties, it is ORDERED as follows: 1. Legal Custody Plaintiffs Donna Kay Burns and Shawnee Kay Burns shall have joint legal custody of the minor child, Leah Coey Vaughn Lauck. 2. Physical Custody Plaintiffs Donna Kay Burns, maternal grandmother, and Shawnee Kay Burns, maternal aunt, shall have primary physical custody of the minor child. The minor child shall primarily reside with Plaintiff Shawnee Kay Burns in Cumberland County, Pennsylvania. Defendants Jalea Drew Lauck and Christopher Matthew Guenot shall have periods of visitation and/or partial physical custody as agreed and arranged with Plaintiffs. 3. Transportation All parties shall share responsibility for transporting the child. 4. Holidays Holidays shall be agreed and arranged between the parties. 5. Access to Records Plaintiffs shall have full access to all relevant medical, dental, psychological, educational and religious records of the child. Both Plaintiffs may obtain such records directly from the provider without the other parties' consent. The Plaintiffs shall provide Defendants with any records not easily obtainable by Defendants. Any school district in which the child attends school shall provide Plaintiffs identical Ift information. The Plaintiffs shall provide to the Defendants all school papers, projects, or other products of the child's development, so as to allow a sharing of those items as fully as possible. 6. Decision Making The parties shall use their best efforts to engage in joint decision-making with respect to the child. In the event the parties are unable to reach an agreement, they shall exchange written proposals, including their explanations of their positions, after which they shall meet and discuss their positions in person, if necessary. If they still cannot resolve their differences the Court will, upon written request, schedule a hearing or conference. 7. Implementation In implementing the provisions of this order, all parties shall be flexible and act in the child' best interest. All parties shall use their best efforts in presenting unity to the child and in shielding the child from an awareness of the parties' discussions and differences. All parties shall use their best efforts to insure that their spouses, significant others, extended families and household members cooperate in carrying out in the intent and spirit of this order. All parties shall encourage the child in the exercise of the other parties' custody rights and shall have the child ready, and properly clothed and fed at the appropriate times. The parents shall endeavor to encourage and stimulate the child to maintain a positive and healthy relationship with the other and the other's family. The parties shall cooperate in giving the others reasonable notice of their respective scheduling as it may affect periods of custody and to facilitate each of the parties' individual planning and scheduling. 8. Major Events All parties shall be notified of, and invited to, major events in the child's life, including, but not limited to, graduations, awards presentations, performances by the child, academic and athletic competitions in which the child participates, and similar extracurricular activities. 9. Illness. Accidents, and other Emergencies All parties shall promptly notify the other of any serious accident or illness or any legal or educational emergency involving the child while in that party's custody. If the child is taking medication, that medication or a prescription for the medication shall be made available to the other party. The non-custodial party shall be provided copies of medical assistance and insurance documents. 10. Other Notice Requirements All parties must notify the other of any changes of residential or work address or telephone number. During periods when the child will be away from home for more than an overnight period, the party who has custody of the child shall notify the 2 other party of the travel and lodging plans, a method of contacting the child and the identity of the person with whom the child will be traveling or staying. 11. Behavior Around Children No party shall consume drugs or excessive amounts of alcohol nor be under the influence of drugs or alcohol nor permit others to use drugs or abuse alcohol in the presence of the child. Neither party shall operate a vehicle transporting the child while the parent is under the influence of drugs or alcohol. All parties shall insure that the child use appropriate seat belts when being transported in vehicles by that party or by another person on that party's behalf. No party shall harass, annoy or malign the other, his or her extended families or his or her friends in the presence of the child. 12. Telephone Contact The party who does not have custody shall be entitled to reasonable telephone contact with the child. Such contact shall not be monitored, or interrupted, by the custodial party. In the event of long distance calls, the parties shall agree on specific times when the child will be available to receive calls. 13. Sanctions Violation of the provisions of this Order may result in the violator being found in contempt of court and being subject to sanctions imposed by the Court. BY THE COURT: Pamela A. Ruest, Judge 3 v? • 1MImIMbNIA02M$ IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL DIVISION DONNA KAY BURNS and SHAWNEE BURNS Plaintiffs V Docket No.2004-1746 ?r- JALEA DREW LAUCK and r _ CHRISTOPHER MATTHEW GUENOT Defendants k ORDER; ap AND NOW, this day of May, 2006, Plaintiffs appearing and being represented by Stephanie L. Cooper, Esquire, and Defendant Christopher Matthew Guenot appearing and being represented by Karen G. Muir, Esquire, and after conference between the parties and upon agreement of the parties, it is hereby ORDERED as follows: 1. Legal Custody Plaintiff, Donna Kay Burns, and Defendant, Christopher Matthew Guenot, shall have joint legal custody of the minor child, Leah Coey-Vaughn Lauck. 2. Custodial Parent Plaintiff, Donna Kay Burns, and Defendant, Christopher Matthew Guenot, shall have shared physical custody of the minor child, with Defendant, Christopher Matthew Guenot, exercising his periods of physical custody as follows: a. on Sunday, May 7, 2006, from 4:00 p.m. until 6:00 p.m. at Holmes-Foster Park in State College, in the presence of Donna Kay Burns; b. on Monday, May 8, 2006, from 2:00 p.m. until 4:00 p.m. at Holmes-Foster Park in State College, in the presence of Shawnee Burns; C. on Saturday, May 13, 2006, from 2:00 p.m. until 5:00 p.m. at Holmes-Foster Park in State College, in the presence of Donna Kay Burns; • d. on Sunday, May 14, 2006, from 2:00 p.m. until 5:00 p.m., to be in the presence of his parents; e. on Saturday, May 27, 2006, from 10:00 a.m. until 6:00 p.m.; 6:00 p.m.; 6:00 p.m.; f. on Sunday, May 28, 2006, from 10:00 a.m. until g, on Saturday, June 10, 2006, from 10:00 a.m. until h. on Sunday, June 11, 2006, from 10:00 a.m. until 6:00 p.m.; i, beginning on Saturday, June 24, 2006, on alternating weekends from 10:00 a.m. on Saturday until 6:00 p.m. on Sunday; and j. at other times as the parties may mutually agree. 3. Transportation The parties shall share responsibility for transporting the child, with the party who is getting custody picking up the child. 4. Access to Records Both parties shall have full access to all relevant medical, dental, psychological, educational and religions records of the child. Each party may obtain such records directly from the provider without the other party's consent. The parties shall provide each other with any records not easily obtainable by the other party. Any school district in which the child attends school shall provide both parents identical information. The custodial party shall provide to the non-custodial party on a weekly basis, all school papers, projects, or other products of the child's development, so as to allow a sharing of those items as fully as possible. • ' w 5. Decision Making Both parties shall use their best efforts to engage in joint decision-making with respect to the children. In the event the parties are unable to reach an agreement, they shall exchange written proposals, including their explanations of their positions, after which they shall meet and discuss their positions in person, if necessary. In the event they still cannot resolve their differences, the Court will, upon written request, schedule a hearing or conference. 6. Schedule Conflicts In the event certain provisions in this custody Order are inconsistent, then the provisions set forth concerning specific holidays and vacations shall supersede provisions concerning weekends. 7. Implementation In implementing the provisions of this Order, all parties shall be flexible and act in the child's best interest. All parties shall use their best efforts in presenting a united front to the child and in shielding the child from an awareness of her parents' and families' discussions and differences. All parties shall use their best efforts to insure that their spouses, significant others, extended families and household members cooperate in carry out in the intent and spirit of this Order. Each party shall encourage the child in the exercise of the other party's custody rights and shall have the child ready and properly clothed and fed at the appropriate times. The parties shall endeavor to encourage and stimulate the child to maintain a positive and healthy relationship with the other and the other's family. Each party shall cooperate in giving the other reasonable notice of their respective scheduling as it may affect visitation or non-visitation to facilitate each of the parties' individual planning and scheduling. • • 8. Major Events All parties shall be notified of, and invited to, major events in the child's life, including, but not limited to, graduations, awards presentations, performances by the child, academic and athletic competitions in which the child participates, and similar extracurricular activities. 9. Illness Accidents and other Emergencies Each party shall promptly notify the other of any serious accident or illness or any legal or educational emergency involving the child while in that party's custody. If the child is taking medications, that medication or a prescription for the medication shall be made available to each party. The non-custodial party shall be provided copies of medical assistance and insurance documents. 10. Other Notice Requirements Each party must notify the other of any changes of residential or work address or telephone number. During periods when the child will be away from home for more than an overnight period, the party who has custody of the child shall notify the other party of the travel and lodging plans, a method of contacting the child and the identify of the person with whom the child will be traveling or staying. 11. Behavior Around Child Neither party shall consume illegal drugs or excessive amounts of alcohol nor be under the influence of illegal drugs or alcohol nor permit others to use illegal drugs or abuse alcohol in the presence of the child. Neither party shall operate a vehicle transporting the child while the party is under the influence of illegal drugs or alcohol. All parties shall insure that the child uses appropriate seat belts when being transported in vehicles by that party or by another person on that party's behalf. Neither party shall harass, annoy or malign the other, his or her extended families or his or her friends in the presence of the child. 12. TelMhone Contact The party who does not have custody shall be entitled to reasonable telephone contact with the child, in addition to the specifics outlined above. Such contact shall not be monitored, or interrupted, by the custodial party. In the event of long distance calls, the parties shall agree on specific times when the child will be available to receive calls. 13. Removal from Centre County Plaintiff shall not move her residence from Centre County without an Order from the Court/or written agreement between the parties. 14. Sanctions Violation of any of the provisions of this Order may result in the violator being found in contempt of Court and being subject to sanctions imposed by the Court. 15. Conference A further conference on custody shall be scheduled for the 14 tl% day of LICI s , 2006, at rJ aaa./p.m. in the chambers of President Judge Charles C. Brown, Jr., Room 203, Centre County Courthouse, Bellefonte, Pennsylvania. Y Brown, Jr., • • 111111111111 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY PENNSYLVANIA CIVIL ACTION-LAW Donna Kay Burns and Shawnee Kay Burns, Plaintiffs Docket No vs. Jalea Drew Lauck and Christopher Matthew Guenot, Defendants Type of Case CUSTODY AGREEMENT 1. Leah Coey Vaughn Lauck was born August 30, 2003. 2004-1746 Custody C' M-0e' W C7- =? c =D o OZn J =rn C-) ui a N 2. Defendant, Christopher Matthew Guenot, Father, has voluntarily terminated his parental rights to Leah Coey Vaughn Lauck. 3. Plaintiff, Donna Kay Burns, maternal grandmother and in loco parentis of Leah Coey Vaughn Lauck and Plaintiff, Shawnee Kay Burns, maternal aunt and in loco parentis of Leah Coey Vaughn Lauck, have had joint legal and physical custody of Leah Coey Vaughn Lauck since she was approximately five months old. 4. Defendant, Jalea Drew Lauck, Mother of Leah Coey Vaughn Lauck, Plaintiff, Donna Kay Burns, maternal grandmother and in loco parentis of Leah Coey Vaughn Lauck and Plaintiff, Shawnee Kay Burns, maternal aunt and in loco parentis of Leah Coey Vaughn Lauck agree and desire that Donna Kay Burns and Shawnee Kay Burns shall continue to exercise and shall have joint legal and physical custody of Leah Coey Vaughn Lauck who shall continue to reside with them. 5. Plaintiff, Donna Kay Burns, Plaintiff, Shawnee Kay Burns and Defendant, Jalea Drew Lauck agree and desire that this Custody Agreement shall be immediately entered as a r • • court order and shall supersede any previous custody agreements or court orders regarding Leah Coey Vaughn Lauck. 3"%-L ? . ?A& Shawnee Kay Burns, Plaintiff CONSENTED TO: Donna Kay Burns, Plaintiff Date 11166 Date 1 o? 4a'Drew Lauck, Defen ant Dat IININI a;lt? ? • IIMINI MOM CCOPROOR" IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DONNA KAY BURNS and NO. 2004-1746 SHAWNEE KAY BURNS VS. JALEA DREW LAUCK and Christopher Matthew Guenot's Petition to Voluntarily CHRISTOPHER MATTHEW Terminate his Parental Rights to Leah Coey Vaughn GUENOT Lauck ORDER i AND NOW, September 8, 2006, the hearing scheduled for this date on Christopher Matthew Guenot's Petition to Voluntarily Terminate his Parental Rights to Leah Coey Vaughn Lauck is continued until further Order of this Court. BY THE COURT: Charl s C. Brown, Jr. President Judge o CZ= F O rn ? O % Illillll illlllll ilill I? IIN III III III IN OWULU CCOPR007/00 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DONNA KAY BURNS AND ) SHAWNEE KAY BURNS, ) Plaintiffs ) V. ) No. 2004-1746 JALEA DREW LAUCK AND ) CHRISTOPHER MATHEW GUENOT, ) Defendants ) Attorney for Plaintiffs. Pro Se Attorney for Defendant Jalea D. Lauck. Pro Se Attorney for Defendant Christopher M. Guenot: Karen G. Muir, Esq. NOTICE OF HEARING AND NOW, this 27th day of July, 2006, upon consideration of a Petition to Voluntarily Terminate His Parental Rights to Leah Coey Vaughn Lauelk filed by and through his attorney, Karen G. Muir, Equire, it is ORDERED as follows: A hearing shall be held on `4ec4e , 2006, at $:3 l .m. Courtroom No.Centre County Courthouse, Bellefonte, Pennsylvania. BY THE COURT: M "- r N B=w c? fl- Lei fV ... • 111111111111 Cl) r a c? -? z-0v ::Dm F rri C") CD Q x L7 -? 0 %i7 gyp- >-s D :Z7 rn -<r-- , c? IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY PENNSYLVANIA CIVIL ACTION-LAW ORIGINAL Donna Kay Burns and Shawnee Kay Burns, Plaintiffs vs. Jalea Drew Lauck and Christopher Matthew Guenot, Defendants Docket No: 2004-1746 Type of Case: Custody Type of Pleading: Christopher Matthew Guenot's Petition to Voluntarily Terminate His Parental Rights to Leah Coey Vaughn Lauck Filed on Behalf of Christopher Matthew Guenot Counsel of Record for this Party: Karen G. Muir, Esquire 1315 West College Avenue, Suite 300, State College, PA 16801 (814) 867-4799 PA. ID. # 60044 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY PENNSYLVANIA CIVIL ACTION-LAW Donna Kay Burns and Shawnee Kay Burns, Plaintiffs vs. Jalea Drew Lauck and Christopher Matthew Guenot, Defendants Docket No: 2004-1746 ° Co o rn-i m c r- v Type of Case: Custody M o > - co_. x D m --c?m s' o Type of Pleading: Christopher cn o Matthew Guenot's Petition to Voluntarily Terminate His Parental Rights to Leah Coey Vaughn Lauck Filed on Behalf of Christopher Matthew Guenot CHRISTOPHER MATTHEW GUENOT'S PETITION TO VOLUNTARILY TERMINATE HIS PARENTAL RIGHTS TO LEAH COEY VAUGHN LAUCK 1. Defendant, Christopher Matthew Guenot, represented by counsel, hereby freely and voluntarily petitions the Court to permanently and irrevocably terminate and forever relinquish my parental rights to Leah Coey Vaughn Lauck, born August 30, 2003. 2. I believe that it is in the best interests and permanent welfare of Leah Coey Vaughn Lauck to voluntarily terminate my parental rights and I respectfully request that the Court approve the same without any further notice, hearing or proceedings and sign the enclosed Order terminating my parental rights forthwith. 3. All parties to this within matter have indicated their consent to my voluntary termination of parental rights by signing and dating their consent to this petition. 4. There is no adoption proceeding and any requirements of the Adoption Act are inapplicable. 1 0 0 5. Defendant, Jalea Drew Lauck, mother of Leah Coey Vaughn Lauck, shall continue payment of child support. 6. Plaintiff, Donna Kay Burns, maternal grandmother and in loco parentis of Leah Coey Vaughn Lauck, and Plaintiff, Shawnee Kay Burns, maternal aunt and in loco parentis of Leah Coey Vaughn Lauck, who have had joint legal and physical custody of Leah Coey Vaughn Lauck since she was approximately five months old, both before and after the May 11, 2004 court order signed by President Judge Charles C. Brown, Jr. providing them with joint legal and physical custody, attached hereto and made a part hereof as Exhibit 1, shall continue to exercise joint legal and physical custody of Leah Coey Vaughn Lauck who shall continue to reside with them. 7. Plaintiff, Donna Kay Burns, Plaintiff, Shawnee Kay Burns, and Defendant, Jalea Drew Lauck, have signed a Custody Agreement and they have submitted it for the Court's signature as a Custody Order, indicating that I have voluntarily terminated my parental rights and that Plaintiff, Donna Kay Bums and Plaintiff, Shawnee Kay Burns, shall continue to exercise joint legal and physical custody of Leah Coey Vaughn Lauck who shall continue to reside with them, attached hereto and made a part hereof as Exhibit 2. 8. I am listed on the birth certificate as the father of Leah Coey Vaughn Lauck, said birth certificate attached hereto and made a part hereof as Exhibit 3. 9. An Adjudication of Paternity was entered on October 15, 2003, attached hereto and made a part hereof as Exhibit 4. 10. I saw Leah Coey Vaughn Lauck for the first time for a short period approximately one and one half years ago. 11. I had some supervised visitations with Leah Coey Vaughn Lauck in May of 2006. 12. Effective Sunday, May 28, 2006, I voluntarily stopped any and all contact with Leah Coey Vaughn Lauck. I believe that it is in her best interest and permanent welfare to permanently terminate my parental rights. 13. The May 26, 2006 Petition for Special Relief filed by Plaintiff, Donna Kay Burns, requested that the Court approve any voluntary termination of my parental rights. 14. Plaintiff, Donna Kay Burns, has terminated the support action against me. Please fine attached hereto and made a part hereof as Exhibit 5 a copy of the June 9, 2006 Order indicating that my support obligations have been terminated and that there are no outstanding arrears. 0 0 15. I am represented by counsel and I hereby knowingly, freely, voluntarily, unconditionally, irrevocably and permanently terminate and forever relinquish any and all parental rights and duties to Leah Coey Vaughn Lauck. I understand that my voluntary consent to terminate my parental rights can not be revoked after the Court enters an order terminating my parental rights. 16. I respectfully request that without any further notice, hearing or proceedings that the Court sign the enclosed Order terminating my parental rights forthwith. Respectfully submitted, hristo er Matthew Guenot, Defendant at VERIFICATION I verify that the statements made in this Petition to Voluntarily Terminate My Parental Rights to Leah Coey Vaughn Lauck are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsifications to authorities. /A &.' - Christopher Matthew Guenot, Defendant Date CONSENTED TO: I have read Defendant's, Christopher Matthew Guenot's, Petition to Voluntarily Terminate His Parental Rights to Leah Coey Vaughn Lauck and I hereby consent to his request to voluntarily terminate his parental rights. Donna K ay Burns, Plaintiff Date I have read Defendant's, Christopher Matthew Guenot's, Petition to Voluntarily Terminate His Parental Rights to Leah Coey Vaughn Lauck and I hereby consent to his request to voluntarily terminate his parental rights. A " -?Wm ? . U A. \1 I Shawnee Kay Burns, Plaintiff Date • • I have read Defendant's, Christopher Matthew Guenot's, Petition to Voluntarily Terminate His Parental Rights to Leah Coey Vaughn Lauck and I hereby consent to his request to voluntarily terminate his parental rights. J Drew Lauck, Defe ant Date f Ij 4 EXHIBIT 1 IN THE OV COMMON VLHIAS OF CENTRE VENNSYLVANIA QVJ 1, ACT JON I,AW DONNA KAY BURNS r SHAWNEE KAY BURNS r r Plaintiff, r vs. NO. 2004-1746 JALEA DREW LAUCK r CHRISTOPHER MATTHEW GUENOT r r Defendant ORDER OF COURT AND NOW, this._ day of the attached Custody Agreement executed by the parties is entered as an Order of: Court. z-0 Co ;0 rn C:) CO ---I ?;o M: > C7 - -? a:M -C r N 2> _ rn 0 C7 • • DpNNA KAY BURNS SHAWNEE KAY BURNS 04-1746 VS JaALEA DREW LAUCK 'IRISTOPHER MATTHEW GUENTTustody Agreement Sworn to and befon?a ' day Of Otarial Richard E. ROmi Seal otary Public MY Chan Rio p u tY? Courtly xpiros Apr. 7, 2007 Member. PennsylvanlsAnWbbonofNofaries Christopher Matthew Guenot and Jalea Drew Lauck, parents of Leah Coey-Vaughn Lauck shall give joint legal custody to Donna Kay Bums, Grandmother and Shawnee Kay Burns, Aunt. Donna Kay Bums and Shawnee Kay Burns shall have joint physical and legal custody as mutually agreed to by the parents. Plaintiff w o/ ?Acks y?i// D?2 /o Plaintiff ?sl fir , y°,4 /mod 7 &t.A q fA /6r?27, ??rn m _?zn on ?z. D3 ??rn Z~ _b A N _J 47 N r rn 0 O M C-) Q q 0 0 EXHIBIT 2 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY PENNSYLVANIA CIVIL ACTION-LAW Donna Kay Burns and Shawnee Kay Burns, Plaintiffs vs. Jalea Drew Lauck and Christopher Matthew Guenot, Defendants A Docket No: 2004-1746 t Type of Case: Custody CUSTODY AGREEMENT 1. Leah Coey Vaughn Lauck was born August 30, 2003. 2. Defendant, Christopher Matthew Guenot, Father, has voluntarily terminated his parental rights to Leah Coey Vaughn Lauck. 3. Plaintiff, Donna Kay Burns, maternal grandmother and in loco parentis of Leah Coey Vaughn Lauck and Plaintiff, Shawnee Kay Burns, maternal aunt and in loco parentis of Leah Coey Vaughn Lauck, have had joint legal and physical custody of Leah Coey Vaughn Lauck since she was approximately five months old. 4. Defendant, Jalea Drew Lauck, Mother of Leah Coey Vaughn Lauck, Plaintiff, Donna Kay Burns, maternal grandmother and in loco parentis of Leah Coey Vaughn Lauck and Plaintiff, Shawnee Kay Burns, maternal aunt and in loco parentis of Leah Coey Vaughn Lauck agree and desire that Donna Kay Burns and Shawnee Kay Burns shall continue to exercise and shall have joint legal and physical custody of Leah Coey Vaughn Lauck who shall continue to reside with them. 5. Plaintiff, Donna Kay Burns, Plaintiff, Shawnee Kay Burns and Defendant, Jalea Drew Lauck agree and desire that this Custody Agreement shall be immediately entered as a ?K • court order and shall supersede any previous custody agreements or court orders regarding Leah Coey Vaughn Lauck. CONSENTED TO: Donna Kay Burns, Plaintiff 3M&L ?-- ?"?6 Shawnee Kay Burns, Plaintiff (.Al j r7 1 d Date /11A? Date t 1 Pa Drew Lauck, Defen ant Dat ,0? K 0 0 EXHIBIT 3 • 'mr °BIR H 08-30-2003 NO, 0892560-2003 DATE FILED 09-02-2003 COUNTY OF CENTRE ISSUED 06-15-2006 NAME SEX FEMALE LEAH COEY-VAUGHN LAUCK FATHERS NAME CHRISTOPHER MATTHEW GUENOT MOTHERS MAIDEN NAME JALEA DREW LAUCK 16 This is to certify that this is a true copy of the record which is on file in the Pennsylvania Department of Heafth, in accordance with Act 66, PI 304, approved by the General Assembl y, June 29, 1953. Calvin B. Johnson, M.D., M.P.H. H105.105 Rev 02/04 Charles Hardesler Secretary of Health State Registrar UCW • 13461414 EXHIBIT 4 • IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION JALEA D. LAUCK Plaintiff vs Support No. 2003-410-S PACSES No. 959105760 CHRISTOPHER M GUENOT o . T t""•'1 i? w y r Defendant -< ? ADJUDICATION OF PATERNITY 1_ .. J) AND NOW, this 15th day of October, 2003 , upon verification from the co Centre County Domestic Relations Section, that Defendant has acknowledged paternity of Leah Coev-Vaughn Lauck it is hereby ordered that: Defendant, Christopher M. Guenot , is the biological father of the child, Leah Coev-Vaughn Lauck , born on August 30. 2003 to Jalea D. Lauck CERTIFIED from the records as entered and filed in this office l? da3F-JU-U--'A. D. 2UCY'D Prothonotary and Clerk of the Court EXHIBIT 5 In the Court of Common Pleas of CENTRE County, Pennsylvania DOMESTIC RELATIONS SECTION DONNA K. BURNS ) Docket Number 2004-00567-S Plaintiff ) vs. ) PACSES Case Number 404106981 CHRISTOPHER M. GUENOT ) Defendant ) Other State ID Number ORDER AND NOW, to wit, on this 9TH DAY OF JUNE, 2006 IT IS HEREBY ORDERED that the support order in this case be Q Vacated or Q Suspended or ® Terminated without prejudice or Q Terminated and Vacated, effective JUNE 7, 2006 , due to : PLAINTIFF HAS REQUESTED CASE CLOSURE AND ALL ARREARS HAVE BEEN PAID IN FULL. m rn-? C= o o? c rnm n? - o oo? fV 7Z7x `CD ?0 ° 73 - o ? o Form OE-504 Service Type M Worker ID 14101 • IN9I?NIIIN?9? 0 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY PENNSYLVANIA CIVIL ACTION-LAW ORIGINAL Donna Kay Burns and ) Shawnee Kay Burns, ) Plaintiffs ) Docket No: 2004-1746 vs. ) Type of Case: Custody Jalea Drew Lauck and Christopher Matthew Guenot, Defendants co Lf) CIJ . Type of Pleading: Emergency Custody Petition for Special Relief Filed on Behalf of Counsel of Record for this Party: Shawnee Burns Plaintiff, Pro Se 710 Quaker Circle Apartment 2 Lewisberry, PA 17339 717-315-2244 • • IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY PENNSYLVANIA CIVIL ACTION-LAW Donna Kay Burns and Shawnee Kay Burns, Plaintiffs ) - Docket No: 2004-174k w vs. ) Type of Case: Custody Jalea Drew Lauck and ) Christopher Matthew Guenot, ) Defendants ) Type of Pleading: Emergency Custody Petition for Special Relief EMERGENCY CUSTODY PETITION FOR SPECIAL RELIEF PURSUANT TO PA.R.C.P. NO. 1915.13 PROHIBITING PARTIAL CUSTODY BY DEFENDANT CHRISTOPHER MATTHEW GUENOT OF TWO YEAR, NINE MONTH OLD LEAH COEY VAUGHN LAUCK, TOMORROW, SATURDAY, MAY 27, 2006, SUNDAY, MAY 28, 2006 AND THEREAFTER FOR THE SAFETY AND WELL BEING OF LEAH COEY VAUGHN LAUCK. 1. INTRODUCTION AND RELIEF REOUESTED 1. I, Shawnee Burns, Plaintiff, Program Director of the Child Development Center of Easter Seals in York, Pennsylvania, maternal aunt, in loco parentis of Leah Coey Vaughn Lauck (hereinafter referred to as Coey) having joint legal and physical custody of Coey, pursuant to the May 11, 2004 Court Order signed by the Honorable Charles C. Brown, Jr., President Judge, and signed by Plaintiff, Donna Burns, Plaintiff Shawnee Burns, Defendant Jalea Lauck and Defendant Christopher Guenot on April 22, 2004, attached hereto and made a part hereof as Exhibit 1, bring this Emergency Custody Petition for Special Relief on behalf of two year, nine month old Coey, who was born on August 30, 2003, to prohibit Defendant, Christopher Matthew Guenot from exercising partial custody of Coey, tomorrow, Saturday, May 27, 2006, Sunday, May 28, 2006, and thereafter for the safety and well-being of Coey. 2. Plaintiff, Donna Burns, maternal grandmother of Coey, in loco parentis of Coey, having joint physical and legal custody of Coey pursuant to the aforesaid May 11, 2004 I 0 • 10 Custody Order, and Defendant, Jalea Drew Lauck, mother of Coey, join in this Petition for Special Relief and the relief requested. 3. For the reasons stated in this Petition, including but not limited to concerns raised in the May 23, 2006 letter by Coey's pediatrician, Dr. Tracey Trudel, M.D., attached hereto and made a part hereof as Exhibit 2, we respectfully request that the Court err on the side of Coey's safety and welfare in prohibiting partial custody as the potential harm and risk to Coey is too great to allow at this time. 4. Defendant, Christopher Guenot, has totally abandoned Coey for the past three years and has seen her only one time one and one half years ago. 5. Coey's grandmother, Donna Burns and I have had custody and have raised Coey since she has been approximately five months old. 6. Coey never in her life has ever experienced nightmares. Immediately following supervised visitation this month with Defendant, Christopher Guenot, Coey has experienced continuous and significant nightmares, crying and need for a pacifier, which she has not used for the past six months prior to the supervised visitation, all of which have continued for days after the supervised visitation, abate and then renew again after supervised visitation. 7. As I will specify later in much greater detail, said nightmares are also addressed in the May 23, 2006 letter of Dr. Trudel, M.D., Exhibit 2, in which she notes the significant regressions Coey has been experiencing after her supervised visitation with Defendant, Christopher Guenot, who is a total stranger to her. Dr. Trudel, M.D. recommends psychological intervention and extended supervised visits prior to any partial custody. Dr. Trudel's letter will be addressed in greater detail hereafter. 8. In addition, Defendant, Christopher Guenot, failed to demonstrate appropriate and proper parenting abilities, skills and attention during supervised visits this month, which will be elaborated upon further in this petition. If Defendant was incapable of properly caring for Coey during supervised visits lasting a couple of hours, then he is not capable of complete custodial care during an entire day. 9. Nothing is known about Defendant's residence, nor has Coey ever been there. Nothing is known about additional strangers Defendant is introducing to Coey such as his current girlfriend. 10. We have great concerns about Defendant's admissions of his sexual molestation and abuse by family members since Coey is only two years and nine months old. 11. For the reasons included in this petition, we are asking the Court to prohibit any partial custody between Defendant and Coey until the various issues raised are adequately addressed for Coey's sake, safety and well being. 2 1 1. 2. PRIOR HISTORY • 12. Defendant had been living with Coey's mother and he moved out when she was three months pregnant, indicating that he wanted nothing to do with the child. 13. Co-Plaintiff, Donna Burns, Coey's grandmother, and I have had sole custody and have raised Coey since she was approximately five months old, each having been intricately involved in Coey's life since her birth. 14. Defendant only visited with Coey one time, approximately one and one half years ago when he arrived at Coey's grandmother's home with his girlfriend, who is a different one than his current girlfriend. 15. Coey's grandmother impressed upon him the importance of maintaining contact with Coey and of maintaining a consistent schedule of contact with Coey. The Defendant promised that he would come every week but he never came again. 16. On April 22, 2004 Defendant, Coey's mother, Coey's grandmother, and I signed a Custody Agreement in which Coey's grandmother, Co-Plaintiff, Donna Burns, and I have joint physical and legal custody of Coey. 17. Said Custody Agreement was made an Order of the Court by the Honorable Judge Charles C. Brown, Jr., President Judge, on May 11, 2004. 18. Defendant, Christopher Guenot, by virtue of his actions of abandonment of Coey since her birth, probably waived any parental rights which could be legally terminated. 19. On March 29, 2006 there was a domestic relations hearing at which Christopher Guenot's child support payment increased. Please find enclosed a copy of the Order scheduling the modification conference signed by the Honorable David E. Grine, attached hereto and made a part hereof as Exhibit 3. 20. After the domestic relations support hearing, Defendant, Christopher Guenot, tried to make arrangements with Donna Burns to pay child support "under the table" instead of through domestic relations. Donna Burns refused. 21. Almost immediately thereafter, on April 12, 2006, Defendant, filed a Petition to Modify Custody. 22. It clearly appears that Defendant, Christopher Guenot, who has had no interest or contact with Coey for years, and purportedly abandoned his legal rights regarding Coey, filed the Custody Modification Petition in retaliation for an increase in child support. • • 23. Plaintiff's are more than willing to terminate child support if Defendant voluntarily terminates his parental rights or they are involuntarily terminated. 24. It is a concern of ours when Defendant, Christopher Guenot, visited our respective homes, since he has committed various thefts from us, been charged with the same and plead guilty to the same. 25. Defendant, Christopher Guenot, has stolen my purse and the $400.00 from the same, stolen a CD collection from my sister, Sarah Lauck, has committed access device fraud against Coey's mother, Defendant Jalea Lauck and was charged with intimidating her as a witness regarding the same. 26. Please find enclosed, attached hereto and made a part hereof as Exhibit 4, the criminal complaint against Defendant, Christopher Guenot, regarding access fraud, theft, and receiving stolen property. 27. Please find enclosed, attached hereto and made a part hereof as Exhibit 5, Defendant, Christopher Guenot's, April 12, 2004 sentencing order, regarding his misdemeanor conviction for access device fraud, signed by the Honorable David E. Grine. 28. Please find enclosed, attached hereto and made a part hereof as Exhibit 6, the criminal information against Defendant, Christopher Guenot, regarding witness intimidation, false reports and harassment. 29. Please find enclosed, attached hereto and made a part hereof as Exhibit 7, the April 12, 2004 sentencing order by the Court concerning harassment with regard to the same. 3. DEFENDANT. CHRISTOPHER GUENOT'S SEXUAL ABUSE BY FAMILY MEMBERS 30. Particularly of concern, given the fact that Coey is only two years and nine months old, no one knows what Defendant, Christopher Guenot's residence is like or who would be there if Coey would be there alone with him, is the fact that Defendant, Christopher Guenot, has indicated that his brother and step father sexually abused him, including but not limited to making him play sexual games with them in the woods, including but not limited to oral sex. 31. During the May 3, 2006 custody conference the issues raised in this petition were not addressed. 32. A visitation schedule was arranged by attorneys for supervised visitation with the Plaintiffs, Defendant and Coey at Holmes Foster Park for May 7, 2006 from 4:00 p.m. to 6:00 p.m., May 8, 2006, from 2:00 p.m. to 4:00 p.m., May 13, 2006 from 2:00 p.m. to 5:00 p.m., May 14, 2006 from 2:00 p.m. to 5:00 p.m., all of which occurred. 4 0 0 s 33. Defendant, Christopher Guenot, was to have partial custody on this Saturday, May 27, 2006 from 10:00 a.m. to 6:00 p.m., this Sunday, May 28, 2006 from 10:00 a.m. to 6:00 p.m., June 10, 2006 from 10:00 a.m. to 6:00 p.m., June 11, 2006 from 10:00 a.m. to 6:00 p.m., June 24, 2006, Saturday, from 10:00 to Sunday, May, June 25, 2006 at 6:00 p.m. and alternating weekends thereafter. 34. The current developments and concerns, which will now be addressed had not occurred at the time of the custody conference since there had been no contact whatsoever between Defendant, Christopher Guenot and Coey except for one time one and one half years ago. 4. CURRENT DEVELOPMENTS AND CONCERNS FOR COEY'S SAFETY AND WELL-BEING REGARDING PARTIAL CUSTODY WITH DEFENDANT THIS WEEKEND AND THEREAFTER 35. Coey has never previously had nightmares before. She stopped using her pacifier six months ago. 36. Since the supervised visits with Defendant this month, there is a clear pattern related to those visits of Coey having nightmares, crying and regressing to having to use her pacifier. 37. The night after the first visit, Coey awakened May 8, 2006 at around 1:00 a.m. and again at 4:00 a.m. sweating and screaming for her grandmother. It took almost one half hour each time that she awakened for Coey to be able to return to sleep. 38. Following the visit with Defendant the next day, Coey awakened on May 9, 2006 at 1:15 a.m. crying, screaming and calling for her grandmother and myself. It took almost one hour for Coey to return to sleep. 39. The following day, Wednesday, May 10, 2006 at about 2:00 a.m., Coey awakened crying and upset. 40. The nightmares stopped until they resumed again after the next supervised visit with Defendant on May 13, 2006. 41. On May 14, 2006 at about 1:30 a.m., Coey awakened sweating and screaming and calling for me. She was so upset that it took one hour and fifteen minutes for her to return to sleep. 42. After the next supervised visitation with Defendant, Coey awakened the following evening, May 15, 2006, at 1:50 a.m., screaming and yelling for her grandmother. She was sweating profusely and was unable to calm down. 0 0 43. Tuesday, May 16, 2006 at both 2:30 a.m. and 4:10 a.m. Coey awakened, screaming loudly for her grandmother. She slept restlessly throughout the night. 44. On Wednesday, May 17, 2006 at 2:00 a.m. Coey awakened, yelling for me. 45. Each time Coey awakened with a nightmare, she requested her pacifier which she had not used for six months. 46. Clearly Coey was awakening immediately after the supervised visits and then the nightmares stopped until the next supervised visit. 47. She has not had nightmares since. Of course, much more than there being another supervised visit scheduled, there is partial custody scheduled for this weekend. I shudder to think what Coey's reaction will be. 48. Other regressions that Coey has experienced is that she becomes extremely upset if her grandmother or I leave her and she continues crying for an extended period of time. 49. Coey's daycare teacher has indicated that it seems as if Coey is afraid of being left. 50. Defendant has failed to demonstrate appropriate and proper parenting ability and skills and attention to Coey during these supervised visits. 51. Coey loves parks and swings and it was a way of trying to break the ice and introducing her to this total stranger, Defendant, Christopher Guenot, by going to Holmes Foster Park and the swings there. 52. As an example of Defendant's lack of involvement, in a span of one hour he spoke no more than ten words. He never brought any food, drink, diapers or toys for Coey. We provided the same. He never changed or looked at her diaper. I tried as much as possible to let Coey alone with Defendant. At the end of each supervised visit Coey indicated that she was wet because Christopher had never checked nor changed her diaper. 53. While Christopher did not bring any drink for Coey, he made it a point to bring a drink for himself. 54. When either one of us would walk away to use the restroom or get something from the car for Coey, we observed Defendant with his back to Coey and he was not engaged with her. Upon seeing us return he would immediately become "engaged" with Coey. During each visit I would bring a book to read and while I read my book I would catch Defendant out of the corner of my eye often watching me rather than Coey. 55. The majority of time during the supervised visit Defendant spent taking hundreds of digital photos of posed pictures of Coey rather than interacting with 6 • • her. While he brought no food, drinks, diapers, toys for Coey, he was sure to bring his cameras with him. 56. In fact, I discovered on the internet that Defendant has posted pictures of himself and Coey on the popular web page, MySpace.com. This makes me very uncomfortable to have Coey's picture posted on the internet. Please find enclosed a copy of page one of a photo of said internet posting, attached hereto and made a part hereof as Exhibit 8. 57. During the supervised visit on Saturday, May 13, 2006, I walked to the end of the park. I observed Defendant chatting with his girlfriend who came to the visit with him. Defendant was approximately five steps away from the swing while Coey sat idly on the swing. 58. When Defendant saw Coey for the only other time in her life one and one half years ago, he had a different girlfriend than he currently brought with him to the supervised visits in the park this month. This girlfriend is a total stranger, has no relation whatsoever with Coey and we know nothing whatsoever about her. That girlfriend, whose first name is Amanda, stood during one visit about fifteen feet away from Coey and announced out loud that she did not feel like interacting. 59. Defendant is a total stranger to Coey and the introduction of even more strangers especially if Defendant is alone with Coey will just be more difficult, confusing and upsetting to Coey. 60. In addition, Defendant was observed on the weekend of Saturday of May 20, 2006, holding hands with a pregnant woman, other than the girlfriend who he brought to the supervised visit at the park to visit with Coey. 61. During the supervised visits, Coey would often yell out my name. 62. We know nothing about where Defendant lives, nor has Coey ever been there. There is not any indication or demonstration of Defendant's parenting skills when alone with a child Coey's age and the only indications are his lack of those skills during the past supervised visits. 63. I was sufficiently concerned and alarmed by the situation to solicit the advice of Coey's pediatrician and a child psychologist. Coey's pediatrician in her May 23, 2006 letter suggested psychological intervention. 5. DR. PETER MONTMM, PH.D. 64. I conversed with consulting clinical psychologist Dr. Peter Montminy, Ph.D. who was unable to schedule an appointment immediately with Coey. However, he suggested that a go slow approach is best and that I contact Coey's pediatrician. • • 6. DR. TRUDEL, M.D. 65. Dr. Trudel indicates in her May 23, 2006 letter that Coey has been her patient for the past year. Dr. Trudel most recently saw Coey on March 31, 2006 at which time Coey appeared to be a healthy two and one half year old living with her grandmother and myself. 66. Dr. Trudel indicates the significant regressions in Coey's behavior in the past couple of weeks, including waking several times a night screaming with nightmares, taking a while to settle down, waking up at naps during daycare and asking for her pacifier which she has not done for six months. It all began after the supervised visitation with Defendant who is a total stranger to Coey. 67. It would improve but then it started again after the most recent visitation. 68. Dr. Trudel recommended that psychological intervention would be beneficial and suggested extending supervised visits with the father before Coey spends any significant time alone with him. 69. Defendant is a total stranger to Coey and has not demonstrated appropriate and proper parenting skills or attention with Coey during supervised visitations. Introducing additional strangers to Coey of Defendant's family and friends, when we know nothing about Defendant's living arrangements is not in Coey's best interest. I have serious concerns regarding Defendant's admissions of being sexually abused. He is obsessed with taking hundreds of pictures of Coey rather than interacting with her and Defendant is now posting Coey's picture on the internet. Given the recommendations of Dr. Trudel and Dr. Montminy, I would never choose to leave Coey alone with Defendant at this time, especially since she is only two years and nine months old. 70. The separation anxiety alone will be overwhelming traumatic, the harm incalculable and possible irrevocable. 71. We have asked Defendant through his attorney not to have partial custody this weekend and provided a copy of Dr. Trudel's May 23, 2006 letter. 72. Defendant insists upon his partial custody alone with Coey this weekend. 73. If there were not a custody matter involved and Coey demonstrated the significant regressions in her behavior that she has demonstrated, as her parent I would try to figure out what has changed or what has been different and try to figure out the cause of her nightmares and fears and problems. The obvious cause is the sudden introduction of the Defendant, who is a total stranger in her life. 0 0 74. In addition, based upon Defendant's past and current behavior, the unknowns about him and the red flags that have been raised, it would be unthinkable that any parent would allow their child to have unsupervised partial custody with him or that a court would so order at this time. 75. I respectfully request that the Court err on the side of safety and concern of Coey and prohibit any partial custody at this time. Since Defendant has never had partial custody of Coey during her entire life it would be of no harm to him to prevent partial custody this weekend compared to the overwhelming and detrimental effects on Coey as indicated in this petition. 76. It defies common sense and all parental instincts to allow partial custody at this time. It is in the best interests of two year, nine month old Coey to err on the side of her safety and well-being by prohibiting partial custody with Defendant on this weekend and thereafter. 7. COURT RELIEF REQUESTED I respectfully request that the Court sign the enclosed proposed Order that: A. Defendant, Christopher Matthew Guenot, shall be prohibited from having partial custody of Leah Coey Vaughn Lauck until further Order of this Court; B. Defendant, Christopher Matthew Guenot, shall be prohibited from having supervised visitation of Leah Coey Vaughn Lauck pending a court hearing after the results of a court ordered investigation and home study of Defendant's living situation, including but not limited to Defendant's interaction with other third parties, including but not limited to his friends, girlfriends and relatives, including but not limited to Defendant's admissions that he was sexually abused by family members, upon completion of Defendant's successful participation of appropriate and necessary parenting classes for the care of a two years and nine month old child, upon completion of psychological evaluations ordered by the Court; C. Defendant, Christopher Matthew Guenot, shall be prohibited from posting photographs of Leah Coey Vaughn Lauck in the public domain, including but not limited to on the internet and is ordered to remove any said photos currently posted, including but not limited to photos on www. MySpace.com; D. Any future supervised visitations between Defendant and Leah Coey Vaughn Lauck shall be coordinated with Donna Burns and Shawnee Burns and shall occur in public places; E • E. Approve Defendant's voluntary termination of his parental rights if submitted by Defendant; F. Upon completion of the aforesaid investigations, a hearing shall be scheduled regarding the involuntarily termination of Defendant's parental rights; G. Plaintiffs Shawnee Burns and Donna Burns shall continue to exercise joint legal and physical custody of Leah Coey Vaughn Lauck and shall be allowed to continue to take the child out of county including but not limited to the residence of Shawnee Burns in Lewisberry, PA, in York County; H. This order shall supersede any previous orders of the Court regarding Leah Coey Vaughn Lauck. RESPECTFULLY SUBMITTED, - W? ?? Shawnee Burns 710 Quaker Circle Apartment 2 Lewisberry, PA 17339 717-315-2244 May 26, 2006 10 • VERIFICATION r? I verify that the statements made in this Emergency Custody Petition for Special Relief are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsifications to authorities. Shawnee Kay Burns, Plaintiff Date 11 C .7 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY PENNSYLVANIA CIVIL ACTION-LAW Donna Kay Burns and ) Shawnee Kay Burns, ) Plaintiffs ) Docket No: 2004-1746 vs. ) Type of Case: Custody Jalea Drew Lauck and ) Christopher Matthew Guenot, ) Defendants ) Type of Pleading: Emergency Custody Petition for Special Relief CERTIFICATE OF SERVICE I certify that a true and correct copy of Plaintiff, Shawnee Burns', May 26, 2006 Emergency Custody Petition for Special Relief and proposed court order was mailed first class mail on this date to Plaintiff, Donna Kay Burns, 201 Jack's Mill Drive, Apartment 10, Boalsburg, PA, 16827, and Defendant, Jalea Drew Lauck, 2140 Admiral Court, Tallahassee, Florida, 32308. I certify that a true and correct copy of Plaintiff, Shawnee Burns', May 26, 2006 Emergency Custody Petition for Special Relief and proposed court order was mailed first class mail and hand delivered on this date to Karen Muir, Esquire, attorney for Defendant, Christopher Matthew Guenot, 1315 West College Avenue, Suite 300, State College, PA, 801. Shawnee Kay Burns, Plaintiff Date c 12 = - 0 • . t 1 N '1'111•: IM111 '1' OF (:Ot*l()N L'I,t..(S t?I I:1' N I I:I IAN I 1'I,:NN,iYI.VAN I A CLVJL. ACl'l(I I 1,AW DONNA RAY BURNS SHAWNEE RAY BURNS Plaintiff, ' VS. NO. 2004-1746 JALEA DREW LAUCK , CHRISTOPHER MATTHEW GUENOT , , Defendant , ORDER OF COURT AND NOW, this day of the attached Custody Agreement executed by the parties is entered as an Order of Court. t Zoo ? -- om c Co ---I =o =y - ?? m c) N CD o c - DONNA KAY BURNS SHAVNEE KAY BURNS vs JAL" DREW LADCK cnR l STOPMR HATTaEW GIIENTTustody Agreement r. 04-1746 Christopher Matthew Guenot and Jalea Drew Lauck, parents of Leah Coey-Vaughn Lauck shall give joint legal custody to Donna Kay Bums, Grandmother and Shawnee Kay Burns, Aunt. Donna Kay Bums and Shawnee Kay Burns shall have joint physical and legal custody as mutually agreed to by the parents. Plaintiff w of ?As.fJi// Die..!o ?g7sbcu?, Pi4 /Gg? 1 944" Y_ Plaintiff ?sdur9, p r\,-,in U_ E?efendant -? a,0JpeY6M11,04,4 `l A,,V Defendanf Swam to and before day of ?o'' chard E. Romi', ofPublic :6J nyda County Mommission xpies Apr 7, 2007 Member PennsylvanlaAa1oaetiondNoWn t Z -v C7 ?o CD .LSD 0 N T > ? N • lsv? Cardinal r 1 LJ Centwe Medical and • Surgical Associates, F.C. Ttup H T A I * I 5t r P 0 t 1 5 f I F01 t'f' \tay '3, 2006 1•tr! L•xeeu:r:c O.'11ter r Ar?rr„?.srra,;ve OlExrar Joni1 ?. 1r1[Qu•? 'XPA K"T or 00-MOC6 R;baccj A a.yrn iw' D V'ma.U c4,r. tt,mu.) Cnig N (7.4-rah V..1) Lnreua A Tnnd'?I. W) \p?YA S 14wat l? M U Kr sue 1• K+uln,. M.l). t,Ca'Fr M MCLA ,nkCk. M U Stc-:n'TMVnee. ?A CXV11.. SeI, rmnc?,er, PAL Teruo M tmmulmgm PA-L To Whom h n,-13,, Conccr. RE; i.FAHCL s,T"_K S-QN: 162-32-9358 DOD, 8130!2003 Dear Sir: Leal has been a patient iri our office si;ice April 2005. She has bccn se-.n by many of my pariaie;s, and I have seen her most recently on March 31, 2006 at which point she appeared to be a hcaldiv two and oiler-57&.11 ?Yea;' old witli ti0 -mal d,!-Velopirentt except for soma speech delay for which she was seeing a. speech therapist at the rase Service Unit, Silo was living with hvr gt•r.nemmilacr ,vbo also lxas joiat cus ody with the aunt. I am writing tiiis letter today in response to a phone call from the Patient's suns who is quite eoncenne.d that she has had sivaircant regressions in tier behavior in the last couple of Nveelcs including walcing several times a n.i-crht screaming Mth nig;b(m.ares that take a while to settle dovm. She ha: also baen noted by the day care with waking up at naps. She is also now asking for her pacifier., something she has not done in six mantlis. Accordiue to the aunt this has stared sine the child has had sugcrvi3cd visits with the father who was a strtangeer ts, her until the first supervised visit. These behaviors apparently unproved as the week went on but started again after the inost recent visit. I have recommended to :..zap, s aunt that site would benefit from sceirg a psychologisi to help, wil-h this tre nsitionine. In addition, exte-rding the supervised V1sits wit$ her fa, her m;r1it help tin : trav sitionbefere she is srerd;, ? iLziiEcaui time alone with him. If I ca-i answer arty q-jesnons, pleas: let :ae how. n' ' ; ; a::? v 1 ?hadel ; •?t .I:?. T(.e:ti;a f 901LOL- f. W1-.?-.. (1p ^.? r :1)' -;'Ai- a.... r.r 1', a C.. - . IS./t..r+•, . .•: .P.n.'. a ., ^ , . aq...l"t. 4Y?M ''. ar,...vto- 1r mntr LL o: a7r5 r ZIG. R:,.t? • 11".-."c."-" . r nc:? 0,3. a e .1 9+ .-]7. . .:.) a a.4 n. r ?Card3nal • 3 • FILED FOR RECORD In the Court of Comma tIC4S !0f•. - L AT I 0 4ZEN rRE County, Pennsylvania DOMESTIC RELATIONS SECTION 100h FEB 28 A 9: 05 DOiNA R. BURNS ) Docket Number 2004-00567-S PlaintiREPUTY PROTHONOTARY) vs.; CENTRE COUNTY. PA ) PACSES Case Number 404106981 CHRISTOPHER M. GUENOT ) Defendant ) Other State ID Number ORDER OF COURT - APPEAR AT A MODIFICATION CONFERENCE ;. Initial Conference 0 Rescheduled Conference You, CHRISTOPHER M. GUENOT , Respondent have been sued in Court to modify an existing support order. You, CHRISTOPHER M. GUENOT DONNA R. BURNS at! CENTRE CO DOMESTIC RELATIONS 47,0 HOLMES STREET, BELLEFONTE, PA. 16823 Respondent, and You, Petitioner, are ordered to appear in person t on the 29TH DAY OF MARCH, 2006 at 10 :30AM for a conference and remain until dismissed by the Court. If the Petitioner of this action fails to appear as provided in this Older, this petition may be dismissed. If the Respondent of this action fails to appear as provided in this Order, an Order for Modification may be entered against the Respondent. You are further required to bring to the conference: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income and Expense Statement attached to this order as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you, Form OM-503 Service Type M Worker ID 14502 PACSES Case Number: 404106981 BURNS v- GUENOT THE APPROPRIATE COURT OFFICER MAY MODIFY OR TERMINATE THE EXISTING ORDER IN ANY MANNER BASED UPON THE EVIDENCE PRESENTED. If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. An appropriate order may be entered against either party based upon the evidence „ presented without regard to which party initiate Date of Order: '4a g ? A, JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENC9 AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER GAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CENTRE CO COURT ADMINISTRATOR COURTHOUSE BELLEFONTE PA 16823 (814) 355-6727 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CENTRE 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 at: (814) 3 55 - 6741 . All arrangements must be de at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference. Page 2 of 2 Form OM-503 Service Type M Worker ID 14502 • y • INFORMATION IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY Criminal Action 2003-2422 ..... ... ? ,, , COMMONWEALTH OF PENNSYLVANIA om GUENOT CHRISTOPHER M = = o . The District Attorney of Centre County, by this Information, charges that the Defendant, in the County of Centre, did: Count 1. Access Device Fraud, 18 Pa.C.S.A. 4106a(1)(ii); M2 on or about April 22, 2003, at 201 Jacks Mill Drive, Apartment #6, Harris Township, Centre County, Pennsylvania, use an access device to obtain or in an attempt to obtain property or services with knowledge that the access device was issued to another person who had not authorized its use, in that he did obtain thirteen dollars and one cent '($13.01), by using a SPE Federall Credit Union MAC card belonging to another, namely Jalea Lauck, Count 2. Access Device Fraud, 18 Pa.C.S.A. 4106a(1)(ii); M1 on or about April 22, 2003, at the aforesaid location, did use an access device to obtain ch- in an attempt to obtain property or services with knowledge that the access device was issued to another person who had not authorized its use, in that he did obtain sixty-one dollars and seventy-five dollars ($61.75), by using a SPE Federal Credit Union MAC card belonging to another, namely Jalea Lauck, Count 3. Access Device Fraud, 18 Pa.C.S.A. 4106a(1)(ii); M2 on or about April 23, 2003, at the aforesaid location, did use an access device to obtain or in an attempt to obtain property or services with knowledge that the access device was issued to another person who had not authorized its use, in that he did obtain two hundred two dollars and seventy-five cents ($202.75), by using!a SPE Federal Credit Union MAC card belonging to another, namely Jalea Lauck, Count 4. Theft by Unlawful Taking; 18 Pa.C.S.A. 3921; M1 on or between April 22 and 23, at the aforesaid location, did unlawfully take or exercise unlawfu_ control over movable property of another, to-wit: cash in the total amount of two hundred sleventy-seven dollars and fifty-one cents ($277.51), by using a SPE Federal Credit Union MAC card belonging to Jalea Lauck, with the intent to deprive the said owner of the same, All of which is against the Act of Assembly and the peace and dignity of the Commonwealth Pennsylvania, c- Attorn y for the Commonwealth l INFORMATION IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY Criminal Action 2003-2422 COMMONWEALTH OF PENNSYLVANIA V. CHRISTOPHER M. GUENOT ..... The District Attorney of Centre County, by this Information, charges that the Defendant, in the County of Centre, did: Count 5. Receiving Stolen Property; 18 Pa.C.S.A. 3925(a); M1 on or between April 22 and 23, 2003, at 201 Jacks Mill Drive, Apartment #6, Harris Township, Centre County, Pennsylvania, unlawfully and intentionally receive, retain or dispose of movable property as described in Count 4, knowing the said property to have been stolen or believing 'the said.property to have probably been stolen and without having received, retained or disposed of the said property with the intent to restore it to the owner, All of which is against the Act of Assembly and the peace and dignity of the Co weal f Pennsypania, Atto ey for a Commonwealth ?Cwdhig • C r 0k) • 'ilk ,,t^ IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CRIMINAL DIVISION COMMONWEALTH VS :;CHRISTOPHER M. GUENOT : NO. 2003-2422 Count 1, Access Device Fraud ORDER AND NOW, April 12, 2004, you, CHRISTOPHER M. GUENOT, are placed on probation s under the supervision of the Adult Probation and Parole Department of Centre County for a period !of six (6) months, subject to the following requirements: That you pay the costs of prosecution and supervision fee. 2. That you violate no law of this Commonwealth or any other jurisdiction during your probation period. 3. That you comply with all conditions, rules and regulations as required by the Centre 'County Probation and Parole Department. 4. That, if you have not already done so, you make restitution to Jalea Lauck in the !amount of Two Hundred Seventy-Seven Dollars and Fifty-One Cents (U.S. $277.51). 5. That all restitution, costs and fees be paid in accordance with a contract in which a payment schedule will be established by the Centre County Probation and Parole Department. This (contract will be approved by the Court. `i Judgment shall be entered against you and in favor of the Centre County Probation and Parole (Department for all restitution, fees and costs ordered to be paid by you. 6. That you undergo any evaluation deemed necessary and as arranged by the Centre County Probation and Parole Department and participate in any treatment programs as may be recommended as a result of any evaluation, dnd as approved by the Centre County Probation and 1 !Parole Department. In the event of intercounty transfer of supervision, the probation office of the receiving ;county is granted the authority to impose any special conditions deemed appropriate. Counts 2, 3, 4 and 5 are nol prossed. C1 V cc i` Q yti>. dr G ' tL Q .i L ca C.) L, ` IM 0- a d E. Grine, Judge 0 0 sncatdinal C :A INFORMATION IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY Criminal Action 2003-2330 COMMONWEALTH OF PENNSYLVANIA V. CHRISTOPHER M. GUENOT -.0 a 0• un , b this Information, charges that the Defendant, in the County of Centre, did: 'j"ne District Attorney of Centre Co tY y Pa.C.S.A. 4952a{3);F3 Borough of Count I. Intimidation Wit./Vict.; 18 Apartment 09, his Pennsylvania, with the intent to or with the knowledge that on or between November 18 and 19, 2003, at 2w 02 Jacks Mill nrto victim to withhold any State College, Centre Countede, impair, prevent or interfere with the administration of conduct would obstruct, imp to intimidate any witness or of a crime crimin41 justice, intimidate or attempt relating to the commission from any law testimony, information, document or thing enforcement officer, prosecuting official or judge, 4906b(1); M3 Reports to law enf. auth.; 18 Pa.C.s,A. Count 2. False did report to law that it had on or between November 18 and 19, 2003, at the aforesaid location, authorities an offense or other incident within their concern knowing enforcement rot occurred, COOP` 3 . ?( C7 M W -OO r" Z=rn Q? C- T, => -- p C) J ?U -4= - m tam iv o -o-<r- :;0 D Ln C7 peace and dignity of the Common lth P nnsylv/ania, All of which is against the Act of Assembly and the p Attorney for the Commonwealth 0 0 Ponfind r e- c "-1, IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CRIMINAL DIVISION COMMONWEALTH NO. 2003-2330 VS i :;CHRISTOPHER M. GUENOT : Amended Count 3, Harassment ORDER AND NOW, April 12, 2004, CHRISTOPHER M. GUENOT, having entered a plea of guilty ;to violating Section 2709 of the Crimes Code, Harassment, is ORDERED to pay a fine of Twenty- ''Five Dollars (U.S. $25.00), plus costs. Judgment shall be entered against you and in favor ofthe Centre County Probation and Parole Department for all fines and costs ordered to ' ' by you. 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ORDER OF COURT G? co L ?,J 0 YOU, AAA `?`?E zma5 (ILFFA=" _') (RESPONDENT) HAVE BEET r-, C) m C') 0 c'J SUED IN COURT TO (OBTAIN) (MODIFY) CUSTODY, PARTIAL CUSTODY OR VISITATION OF THE CHILD(REN) 1-644 CaU-V-1/-/44,yp u /_RC. A YOU ARE ORDERED TO APPEAR IN PERSON IN COURT ON? DAY OF 20CKo AT W AM/WIN w- ROOM 203 . A C N IL TIQ1V OR MEDIATION CONFERENCE A CONFERENCE A HEARING BEFORE THE COURT IF YOU FAIL TO APPEAR AS PROVIDED BY THIS ORDER, AN ORDER FOR CUSTODY, PARTIAL CUSTODY OR VISITATION MAY BE ENTERED AGAINST YOU OR THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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. COURT ADMINISTRATOR CENTRE COUNTY COURTHOUSE BELLEFOt (814) r? Date IN THE COURT OF MMON PLEAS OF CENTRE COATY PENNSYLVANIA CIVIL ACTION - LAW III I?III INII IIIN Ilil NIII I I II IIII IIIIIIININI?IIN 0MAE10 CCGMO1=5 JUAJR ? ?yL?US St?Al,u/? _ ?l> S PLAINTIFF NO.d0 - VS -SA, ,F--A DQ&A u Q TOoW-,n M421 Ui LL C-KX ti DEFENDANT , G Cr ?r N - • C C) M PETITION FOR MODIFICATION OF A PARTIAL CUST(? M F C) Q r OR VISITATION ORDER > a 1. The Petition of n Q1?2 ?2 /Yl ?iVEfi respectfully represents that on MA4 1?}V , 20ALj_ an Order of Court was entered for (Partial Custody) (Visitation). A true and correct copy of which is attached. 2 Plaintiff is DbVAA t.gutn? JhllauJttnF? ?. (J?,?,t? who resides at ? 7? i ? aeh'Sn,TU nn ?T ? 1? j yaw n?>?:: -yuk ? ,? ?, , 3. Defendant is 0NQJ?,ROllia 6L eA oz /J AMA 0.14 who resides at I4V?47Jlo P?L.tAA Ae, CoLLEt,? Oro &&-it, I J ra -t,yu v im-- ud?tfl?, 4. This Order should be modified because: 74f- P,9,Pa&i 1; Cu'?am tw GAtc- Im z ragz4 . n _ _ •, - - L - - - r - - w - - 0-A&S09- rnEE6d6E5.74FN O/liz.ti 04U Me Aqe?, 7gEy Ta&f M 6YldjgLc?? ?t?rc? yc? ? OFMF 1?,M,?u i ? gi??- ? i% ? ?F ?tiFn 7,U 7?€?= 4?tS Tc.??4 Zvi ? 8L? AGLi IM 4,qt F tt 1.1TS1141M.u /k,sm? owL-q so S CA,J . WHEREFORE, Petitioner requests that the Court modify the existing order for (Partial Custody) (Visitation) because it will be in the best interest of the child(ren). Date Peritioner VERIFICATION I verify that the statements appearing in this foregoing Petition are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA.C.//S.A. Section 4904 relating to unsworn falsification to authorities qj? I' S" L IR Date Petitioner I: \FORMS\custodymodificaiton. wpd to Al 0 IN THE t.;U(!L<T' (q, (::OMMON (.'LEAS OI" GENTRI-, PENNSYI.VANI.A C1_VJI., ACTION -- 1,AW r DONNA RAY BURNS SHAWNEE RAY BURNS r Plaintiff, r Vs. NO. 2004-1746 p JALEA DREW LAUCR , CHRISTOPHER MATTHEW GUENOT r Defendant ORDER OF COURT AND NOW, this day of Aay- ' p the attached Custody Agreement executed by the parties is entered as an Order of Court.. j rn 0G7 - -i.. V -G r ; y Z.? c- DONNA KAY BURNS SHAWNEE ]KAY BURNS vs JALEA DREW LAUCK CHRISTOPHER MATTHEW GUENCffustody Agreement D4-1746 Christopher Matthew Guenot and Jalea Drew Lauck, parents of Leah Coey-Vaughn Lauck shall give joint legal custody to Donna Kay Bums, Grandmother and Shawnee Kay Burns, Aunt. Donna Kay Burns and Shawnee Kay Burns shall have joint physical and legal custody as mutually agreed to by the parents. Plaintiff ; o/ ?f eA!- // 104 At- /0 m ??rn Plaintiff a0??/sh,rs ///e # .?za ?s6ur9, 0°,f /W17 W C q n-cr 3-!? fendant JP as /P ??- cl Defendanf Swam to and bdm _. day of ?-;.. Notarial Seal Richard E. R0711, Noary Public Monroe yde tr County My Commission ?xpiras Apr. 7, 2007 Member, Pennsylvanl0 A$Sodation of Notaries ? d N T `_' C) N Check off list *Date DOCKET #: Copy(s) given to Atty,0 Plt. for service (circle one) Gave "certified" copy for service Gave certified copy(s) Cash in Drawer amount docket No. ?? I initials • FILED FOR RCcORD r 14% APR 24 A 1a 13 o DF8RA C IM1,1 !_ CE THONU TART. NTY. PA ?c c s lSy It+ iyt Ly tt? O co Cl) Z k?2 Go -M4 3T @vc -4 IMC zcT ? a3Z- opgoa ?prm1 0 a> ZW,w y V0 C-04 0M om.mIE J v Rf 2c GO c 2m m T H GO m ? v 0 to w C.* O O x d l 1 2 -,? a G r1 L J z m m m m r n ? n oO c Z m? n = O m D C,,: 0 M = N O W p !D D C) t spi. f at c a Q > Nx o UNir c , r A? v' A ?4 M co oOD N S > m (C), 1 C, N) CP 4 w N 0 t W G) c' { rys i v AMS • • z W ? v m m m n <D a 0 C Z FILED FOR RECORD m= I -,- n 1006 MAY - 3 A 9. 34u m o W Z (D DEBRA C ? . - FROTNON01 % ?, F COUNT ).: A S 0 cn n > 010 co ' =z H Z m m cm= OZ -ns;Z 4 =WCDC2a ?m7Dmg, 7?D VSi --4 co o o m dJ o m M-4 m H CA o 0 O 2 A tz t4 o°x n z N ? N d ? 0?0 ICI 00 0 0 0 ? o c? UNiTfi 4 ? O m W T --' ? co O 00 N O ?] O _> m uo!_? I W A-I a? o r.. t 0 IN THE COURT OF10MMON PLEAS OF CENTRE CO *Y, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff vs 04ko5)P?& 6Ut-0 c j 1ALE4 LACO Defendant IIIIIIIw1111 OOOQAVEO No. ZOcDi-(- I-74 AFFIDAVIT OF SERVICE I,QOpi??-(Z M. F.? (Maiati do swear according by law, that I have made service of the /ref `for?Ac-o-?paV? weoabov?captioned action upon(Plaintif4efendant), , by certified mail, return receipt requested. Service was accomplished on 4d a'.0 Attached hereto as evidence of said service is a signed return receipt. 1'WMk-L N45gE:- (Defendant) O M d5 i:: n . w , RETURN TO: Centre County Prothonotary Centre County Courthouse Bellefonte, PA 16823 Date Forms/cust/service b i r1 U ¦ ©ompkbe Renee 1, 2, and 3. Also complete hem 4 If Reetficted Delivery Is desired. • PdM your name and address on the reverse se tftat we can rstum the card to you. ¦ Adach this card to the back of the mai or on the front if space permits. 1. Ardcb Addressed to: 'Vrf*>A 4c qur YES C ?incc.w'??- ?'n CC 2c ? .)aGl??ov, to ? l 1 DIF Av+. l o PA- C • A Received by (P~ Nerve) C. Pete of address dNf e. from Item 1? ? Yee M "Very address below: ? No !s? ?a a ,PWT Cerdw Mali 0 MON 13 Registered MrK ium Receipt for Maciwdee O Inaxed mom ? C.O.D. 4. Restricted Delivery? PDxNa Foo ? Yes 2. Mfkreldumber 7006 0100 0000 9150 5866 f ils?reerl?a?e? aal+is?11.1 PS form 1. MMYMIyr 2f>C14 Dooteeft f%bwn A n Iiit 16fa1a cah1. CEP rig IED • (Domest ic Mail Onl For delive rv informatir O tr1 Postage $ O O CertiNed Fee O C3 Return Receipt Fee (Endorsement Required) C3 G Restricled DON-ry Fee rl- (6rdorsemerd Required) 101talFootage & Fees 9 ..0 C3 O nt o . ftm N ?1 id ? and 3. Also owpleft ¦ P*tt yow marls arid address on the reverse so VW wavan return the card to you. ¦ AMW this card to the back of the maliplece, or on the front H space permits. 1. Mauls Addressed to: ZO . -Jpe?M'>q, t; S)t _o n Postmadt 00000041 4 C=b - r c0 s A JZ?r\by (Mod Nerve) C. Date of Deftr.ry a n5 q-11S-10 D. Is delivery address di fererd from Nom 1? ? Yes D.4f YEs, enter delivery address below: ? No service lww ? Certried mom ? Express MeN E3 Registered ? Retire Receipt for Mer&auft ? Inased Mell ? C.O.D. 4. Restricted Ddhwy? (Extra F«I 0 Nu 2• AMWOOK 7006 0100 0000 9150 5851 ( onift'AelrrSWN"NlW , r P8 form 3811, FOnmy IM4 Danw.tlc Relum Receipt lessesela?e feeo c? T k t f u rr. r r] FILED FOR RECORD 16 NAY -2 A co 30 pF. It?oTty'n CE.O oN?: o?C7 z30 a z -a co '.y S mror,?.y_ ? r?.I b r`.I l czmpr:? r p9C=? > T7m. r- m C Cl ='y m H M 0 M O O m z. lit m z -3 13 v m cr ooo ocz 4 -< n 1 fn lo: -a, vc? OD 0 °' m = W _ N) z Q ,J r A o ni uNIT? 1 4 m o, W N O ? Q ? u N ? W ? r'k i f r r F 4. 1. t 1 {`{ [[t f k f rI I v • 11 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ? 1 11111111111111111111111 ?1-9z OOOOAUMQ CCOPRO OTAO LAINTIFF VS DEFENDANT . NO. . t. U 1 ORDER OF COURT 77 - O YOU, JLT/>/lf! ll` f Ft?' /?Lj/YJS (L)F-FFF,N??-A t) (RESPONDENT) HAVE BEEN SUED IN COURT TO (OBTAIN) (MODIFY) CUSTODY, PARTIAL CUSTODY OR VISITATION OF THE CHILD(REN) ZAW-if / v YOU ARE ORDERED TO APPEAR IN PERSON IN COURT ON DAY OF _NQAdj_ 200x_ AT AMAW IN BROOM, A C NCIL TIO,N OR MEDIATION CONFERENCE -QAo) EDP If A CONFERENCE A HEARING BEFORE THE COURT IF YOU FAIL TO APPEAR AS PROVIDED BY THIS ORDER, AN ORDER FOR CUSTODY, PARTIAL CUSTODY OR VISITATION MAY BE ENTERED AGAINST YOU OR THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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. COURT ADMINISTRATOR CENTRE COUNTY COURTHOUSE BELLEFOI -__ (814) rl ? . Date a I „_i4 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DONNA KAY BURNS SHAWNEE KAY BURNS Plaintiff , vs. r r r r r JALEA DREW LAUCK r CHRISTOPHER MATTHEW GUENOT r r Defendant , r NO. 2004-1746 ORDER OF COURT AND NOW, this 1115, - day of plv 3 gw? - , the attached Custody Agreement executed by the parties is entered as an Order of Courr a?S?,? IIyI I I L- 1 I 12d_ W?rnorS rA a P ftoz '(?X ? S-tophsu? rA l,l" Yom- a h ? 0 l m? y n? x? ri) r? H I y L? d H z I H 2'QD rn 'spa) A -` - s ? ;o _ r O °" v -? ? -0 ran y N O Cr I ?' 1 11 DONNA KAY BURNS SHAWNBE"IEKY" BURNS vs JALEA DREW LAUCK CHRISTOPHER MATTHEW GuEN(Justody Agreement D4-1746 Christopher Matthew Guenot and Jalea Drew Lauck, parents of Leah Coey-Vaughn Lauck shall give joint legal custody to Donna Kay Burns, Grandmother and Shawnee Kay Burns, Aunt. Donna Kay Burns and Shawnee Kay Burns shall have joint physical and legal custody as mutually agreed to by the parents. Plaintiff gyp/ ??cks i// e !o /1 z a F= K /l091-1 7 -? cagy sue. M. o ?pD N 0 Plaintiff 2QulfC4s 111111-.I AL J - o yr156?i?-91 164 7 - ? ca D -<r C fendant /?'l !! gy ?As , q ?? ? p L / A A Rl6lJllfzlj /f>t 1??7 S*wn to and bef m Of 20 e) Notarial Seal Richard E. Romig, Notary Public Monroe 'gy'p , Snyder t;ounty My CommissM Expires Apr. 7, 2007 Member, Pennsylvania AeloaaVon oflVotaries y' 10, -fe ?? C V A.??f A. I L ?,sv Cc?.rlti 2 3?2L ?G r--