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2HADD E. RONK V. RAYETTE I. (RONK) SLOOP : IN THE COURT OF COMMON PLEAS : OF THE 41ST JUDICIAL DISTRICT : OF PENNSYLVANIA : JUNIATA COUNTY BRANCH : NO. 436 of 1997 .O. R D E R AND NOW, October 31, 2001, upon review of the letter ~ndums submitted by both parties, through counsel of record on the issue of change of venue, IT IS HEREBY ORDERED AND DIRECTED that venue in this case is hereby transferred from Juniata County to Cumberland County, · s the present residence of the mother and two subject children and has been the residence of the children for the past two years, as per order of court dated August 27, 1999. It should also be noted that father now resides in Mifflin County. It should also be noted that the contempt petition has been ~d by order of court. The Prothonotary of Juniata County is hereby directed to :ertify the records and transfer the case to Cumberland County. Judith F. Dolgos, Esq. ~T~gmas s. Diehl, Esq. AW'~°t h°n°tary-Cumb. Co File ' Ce[tiffed: A Itu8 Copy ~-~rothonotarV · My Commission Expire irs~ Monday in Jan. 2004~ BY THE COURT: Among the Records and Proceedings enrolle,d in the Court of Common Pleas in and for the County of Juniata, in the Commonwealth of Pennsylvania, to No. 436 OF 1997 Term, I , is contained ~he following: COPY OF DOCKET ENTRY CHADD E. RONK PLAINTIFF VS RAYETTE I. RONK DEFENDANT NO. 436 OF 1997 - CIVIL 12/15/97 ol/o5/98 01/20/98 o3/2o/98 04/27/98 06/24/98 07/31/98 09/02/98 09/03/98 09/30/98 10/09/98 04/16/99 04/23/99 05/20/99 08/16/99 09/02/99 09/10/01 09/14/01 09/14/01 o9/18/Ol 09/18/01 09/18/01 09/19/01 09/26/01 10/23/01 11/06/01 COMPLAINT IN DIVORCE FILED @ 9:10 AM. ORDER FILED @ 4:10 PM. AFFIDAVIT OF SERVICE FILED @ 8:30 AM. ORDER FILED @ 10:15 AM. ORDER FILED @ 8:30 AM. AFFIDAVIT OF CONSENT OF PLAINTIFF FILED @ 8:30 AM. ORDER FILED @ 9:35 AM. AFFIDAVIT OF CONSENT OF DEFENDANT FILED @ 8:05 AM. PRAECIPE TO TRANSMIT RECORD FILED AT THIS TIME ALSO. DECREE IN DIVORCE FILED @ 8:05 AM. ORDER FILED @ 8:00 AM. ORDER FILED @ 8:20 AM. PETITION FOR MODIFICATION FILED @ 2:05 PM. ORDER FILED @ 11:00 AM. ORDER FILED @ 8:30 AM. ORDER AND MEMORANDUM FILED @ 8:40 AM. ORDER FILED @ 3:35 PM. PETITION FOR CHANGE OF VENUE FILED @ 8:05 AM. PRELIMIANRY OBJECTIONS AND RESPONDENTS RESPONSE FILED @ 10:00 AM. PETITION FOR SPECIAL RELIEF FILED @ 10:05 AM. ORDER FILED @ 2:00 PM RULE TO SHOW CAUSE FILED @ 2:10 PM. ORDER FILED @ 2:15 PM. CERTIFICATE OF SERVICE FILED @ 8:00 AM. CERTIFICATE OF SERVICE FILED @ 8:00 AM. ORDER FILED @ 8:30 AM. QRDER FILED @ 8:15 AM. Commonwealth of Pennsylvania, County of Juniata SS. I, JOAN E. CLARK , Prothonotary, of the Court of Oomraon Pleas in and for said Co.unty, .do hereby certify that the foregoing is a full, true arid correct c~py of the whole record of the case therein stated, wherein and CHADD E. RONK Plaimtiff , RAYETTE I. RONK Defendant , so f,ull and entire ms the same remains of record before the said Court at No. 436 of 1997 Term, A. D. 1 In Testimony Whereof, I have hereunto set my han~d and affixed the seal of said Court, this day of NOVEMBER A.D. X 2001 10AN E. CtARK ~ ..~ Prothonotary ~x~ ~ .~,' ~ ~,~ My Commission Expires (~ /"~"/.A~ ~. ~,~.. First Monda,Lin Jan. 20041 · .'~,~.: ............................ I~L uLhunu Lary'. I, KEITH B. QUIGLEY , President Judge of the Forty-first Judicial Dist- rict composed of the Counties of Juniata and Per:v, do certify that JOAN E. CLARK by whom the annexed record, certificate and atteotation were made and given, and who in his own proper handwriting, thereunto subscribed his name and affixed the seal of the Cou,rt of Common Pleas of .said County, was a~ the time of ao doing and now is Prothonotary in and for said County of Juniata, in the Co~am~nwealth of Pennsylvania, duly commissioned and qualified, to all of whose acts, as such full faith and credit are and ought to be given, as well in Courts of Judic&ture as else- where; and that the ,said record, andre cerfificate in due form of law, and made by the proper officer. ........................ President Judge. Commonwealth of Pennsylvania, County of Juniata SS. I, JOAN E. CLARK , Pro~thonotary .of lhe Court of Common Pleas in and for the so;id County, do certify that the Honorable KEITH B. QUIGLEY , by whom the foregoing attestation was made, and who has thereu.n,to s.ubscribed his name, was at the time of making thereof and still is President Judge of the Co.urt of Common Pleas, Orptmns' Court and Court of Quarter Sessions of the Peace in and for said County, duly commissioned and qualified; to all whose aets as such, full faith and credit and ought to be given, as well in Courts of Judieat.ure as. elsewhere. In Testimony Whereof, I have hereunto set my hand and affixed the ~eal of said Court, this~'~'~' day of ~~ A. D.~O ~z JOAN E. CLARK Prothonotary My Commission Expires First Monday in Jan. 2004 Prothonotary. IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT OF PA. JUNIATA COUNTY BRANCH CHADD E. RONK, Plaintiff VS. RAYETTE I. RONK, Defendant CIVIL ACTION - DIVORCE No. 436 of 1997 ORDER You are ordered to appear in person at the Main Courtroom, Second Floor, Juniata County Co~rthouse, Mifflintown, Pennsylvania, on --~=~(~ , the ~\~ day of "~.~,,~ , 19~, at ~ :~[~ ~.M., ~ev~iling tim~, for ~ CO,-,,.. ..... TI__. ~ / x / A ~--~-,-~- -r?, "'~" _.. l'~_ED'r~mTnS!- CONFERENCE. / / A PRETRIAL 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Keystone Legal Services, Inc. 2054 East College Avenue State College, PA 16801 (814) 238-4958 or (800) 326-9177 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Juniata County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. BY THE COURT, ~.., / ~o~nonotaty ~ IN THE COURT OF COMMON PLRAS OF THE 41ST JUDICIAL DISTRICT OF PA. JUNIATA COUNTY BRANCH CHADD E. RONK, Plaintiff VS. RAYETTE I. RONK, Defendant CIVIL ACTION - DIVORCE No. of 1997 NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree Of Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at Juniata County Courthouse Main & Bridge Streets Mifflintown, PA 17059 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Keystone Legal Services, Inc. 2054 East College Avenue State College, PA 16801e (814) 238-4958 or (800) 326-9177 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Juniata County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT OF PA. CHADD E. RONK, VS. RAYETTE I. RONK, JUNIATA COUNTY BRANCH : CIVIL ACTION - DIVORCE Plaintiff : : : No. of 1997 : : Defendant : COMPLAINT UNDER SECTION 3301(c) and/or (d) OF THE DIVORCE CODE COUNT I DIVORCE 1. Plaintiff is Chadd E. Ronk, who currently resides at R.R.#i, Box 331, Honey Grove, Juniata County, Pennsylvania 17035 since 1995. 2. Defendant is Rayette I. Ronk, who currently resides at 235 Baltimore Street, Mt. Holly Springs, Cumberland County, PA 17065 since October 20, 1997. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 27, 1993, at Pine Glenn, Mifflin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. COUNT II CUSTODY 9. Paragraphs one (1) through eight (8) hereof are incorporated herein by this reference thereto. 10. Plaintiff seeks custody of the following children: Christian Robert Ronk (b. 12/21/94) and Josie May Ronk (b. 12/5/96). The children were not born out of wedlock. The children are presently in the custody of Chadd E. Ronk, who resides at R.R.#1, Box 331, Honey Grove, PA 17035. 11. During the past five (5) years, the children have resided with the following persons and at the following addresses: List Ail Persons Chadd E. Ronk and Rayette I. Ronk Chadd E. Ronk and Rayette I. Ronk Chadd E. Ronk List Ail Addresses R.R.#2 McVeytown, PA 17051 R.R.#i, Box 331 Honey Grove, PA 17035 R.R.#i, Box 331 Honey Grove, PA 17035 List Ail Dates 12/21/94 - 11/95 11/95 - 10/20/97 10/20/97 - present 12. Plaintiff, Chadd E. Ronk, is the natural father of the children and he is married. 13. Defendant, Rayette I. Ronk, is the natural mother of the children and she is married. 14. The relationship of Plaintiff to the children is that of natural father. persons: Name No one The Plaintiff currently resides with the following Relationship 15. natural mother. persons: Name Harold Sloup The relationship of Defendant to the children is that of The Defendant currently resides with the following Relationship Paramour 16. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 17. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 18. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 19. The best interest and permanent welfare of the children will be served by granting the relief requested because Plaintiff wishes to have a close relationship with the children and he can give them a stable environment and permanent residence. 20. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant custody of the children. BARRON ~ERF~N ~neys for Plaintiff I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to u~sworn falsification to authorities- ~_ ~l - - - Chaad-EV Ronk ~ Plaintiff BARRON & ZIMMERMAN COUNSELLORS-AT-LAW 119 WEST MARKET STREET LEWIST.O~,rN, PA 1,7044 (717) 248-5479 IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT OF PA. JUNIATA COUNTY BRANCH CHADD E. RONK, Plaintiff VS. RAYETTE I. RONK, Defendant CIVIL ACTION - DIVORCE No. 436 of 1997 ]~_FFIDAVIT OF SERVICE AND NOW, January 16, 1998, comes David W. Barron, Esquire, pursuant to the provisions of Pa.R.C.P. No. 1930.4(c) and deposes and says that he is a competent adult who represents the Plaintiff in the above captioned divorce proceedings; and that on behalf of said Plaintiff he did serve the Divorce Complaint in said proceedings on the Defendant named therein, Rayette I. Ronk, by forwarding a true and correct copy thereof to her by Certified Mail, Return Receipt Requested, Restricted Delivery to Addressee Only, posted at the Lewistown Post office on January 7, 1998, receipt and return receipt for said mailing being attached hereto and, by this reference, in~ein' D~arron, EsqUire sworn and subscribed to before me this 16th day of January, 1998. Notary Public ! .=~---.;-:--.-----..--'---' I,.~'-'~''] I Rayette I. Ronk ~1 · 235 Baltimore Street ~'~'~' .......I ! .t..o~y s~r~',~,, ~ I____~'T... ~ ~ · J! pS Fom~ ~811, eceipt P 175 405 642 US postal Service Receipt for Certjfi~e~l_?ail No Insurance Coverage ~5 L CHADD E. RONK vs RAYETTE I. RONK IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT OF PENNSYLVANIA JUNIATA COUNTY BRANCH NO. 436 of 1997 CUSTODY ORDER AND NOW, March 17, 1998, it is Ordered and Directed that hearing in the above matter be held on Thursday, April 23, 1998, a 9:00 a.m., in the Courtroom, Juniata County Courthouse, Mifflintown Pennsylvania. cc: BY THE COURT, C. JO David Barron, Esq. Doug Hearn, Esq., Keystone Legal Services File CHADD E. RONK v. RAYETTE I. RONK : IN THE COURT OF COMMON PLEAS : OF THE 41ST JUDICIAL DISTRICT : OF PENNSYLVANIA : JUNIATA COUNTY BRANCH : NO. 436 of 1997 CUSTODY ORDER AND counsel, )urpose ~utually NOW, April 23, 1998, upon request of Plaintiff's the record in this matter is hereby kept open for the of a psychological evaluation to be performed by a agreeable professional, the cost of which shall be borne solely by the Plaintiff. Pending further order of court, the previous custody arrangement shall continue. :c: David Barron, Esq. Douglas Hearn, Esq. File BY THE COURT: C. JOSEPH IN THE COURT OF COMMON PT.RAS OF THE 41ST JUDICIAL DISTRICT OF PA. CHADD E. RONK, VS. RAYETTE I. RONK, Plaintiff Defendant JUNIATA COUNTY BRANCH : CIVIL ACTION - DIVORCE : : : No. 436 of 1997 : : : AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 15, 1997. 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to~__unsworn falsification to authorities. ~/FL~_ /~ , 1998 Cha--dd ~.~J'Ronk -- P~inti~f WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF TRR. DIVORCE CODE notice. I consent to the entry of a final Decree of Divorce without 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce i~^'g.~, ._ WOW 3. I unders~0%~l~~6~8~ced until a Divorce Decree is entered by the '~ ~]~~~_~ Decree will be sent to me i~ediately after '~ ~:~'~~~~~otary. I verify that..the: ~~.~ ~_Walver are true/ and correct. I under~tahd ~.~.~~ ~in ~re m~e ~ubject to the penalties of 18 ~'P~. ~ST~_~9~u~ ~i~o U~~"~t"i~';~"~ falsification to aut~'~.~ ~" /~ ~ /~ /~-~ Il, ~"~i-,.,,v~ '~ Y8 /' Z/f ': ~ ' ' Chadd E. 'Ronk - P~a~i~f~2,?3~],~.''~t?.'~J Address within the Cemmomfealth of Pe~,sylvani, where all netice~ and pleadin~ shall be delivered: ] ]9 WEST MARKET STREET LEWlSTOWN, PENNSYLVANIA 17044 I~mlL~ OR ~ ~ OF ~CO~ AN ATTES'rED ~ OOPY HEREOF BY UNITED 8TATE~ I~.. Iiq~TA~IE PREPAID POSTED AT ~. PENNSYLVANIA i ADDRESSED AS ~I~O~SED ON PRIOR ~,/~, Z~IERMAN BY / : ^ ~..r~mYs ~OR ?/~,~)~ CHADD E. RONK vs RAYETTE I. RONK IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT OF PENNSYLVANIA JUNIATA COUNTY BRANCH NO. 436 OF 1997 CUSTODY ORDER AND NOW, July 30, 1998, it is Ordered and Directed that hearing in the above matter be held on Monday, September 28, 1998 at 1:00 P.M., in the Courtroom, Juniata County Courthouse Mifflintcwn, Pennsylvania. CC: Douglas Hearn, Esq. David Barron, Esq. File BY THE COURT, C. JOSEPH REHCP~GE IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT OF PA. JUNIATA COUNTY BRANCH CHADD E. RONK, Plaintiff VS. RAYETTE I. RONK, Defendant CIVIL ACTION - DIVORCE No. 436 of 1997 AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 15, 1997. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. 0 notice. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF T~R DIVORCE CODE I consen~ to',the entry of a final Decree of Divorce without I und~r~tand that I may lose rights concerning alimony, division of prOPe~{y~' !l.'a.w~r's fees or expenses if I do not claim them before a divor'c~' ~S 3g~ted. 3. I under~tand that-.~I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after .~ bs filed with the Prothonotary· I verify that the statements made in this Waiver ~r~e"~r~e 'and correct· I understand that false statements herein are made subject, to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Rayette I. Ronk - Defendant 19, ,,~2¢ N .!" c~3~'O'dock_ ~ Address within the Commonwealth of Pennsylvania where all notices and pleadings shall be delivered: ] 19 WEST MARKET STREET LEWISTOWN, PENNSYLVANIA 17044 866! ~lC?"' . 19 ~.~.~, WE "¢ : ~ ~ LEGAL PAPER WA8 -, '~:"} }~4ig ~3ATE BY MAILING TO ALL .~,, :'!~$ OF[ THEIR COUNSEL OF RECO~ ~ ~'~e~ TRUE COPY H~EOF BY ~ ~TA?ES MAIL, ~STAGE PREPAID, ~.'-~ AT LEWIST~N. P~NSYLVANIA. := :~[FD AS ENDORSEO ON PRIOR BARRON &_~J~MERMAN IN THE COURT OF CO~ON PLEAS OF THE 41ST JUDICIAL DISTRICT OF PA. JUNIATA COUNTY BRANCH CHADD E. RONK, : Plaintiff : : VS. : : RAYETTE I. RONK, : Defendant : CIVIL ACTION - DIVORCE No. 436 of 1997 PRAECIPE TO TRANSMIT RECOPJ) To The Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: January 10, 1998, by Certified Mail, Return Receipt Requested, Restricted Delivery To Addressee Only, as appears in Affidavit of Service filed of record. 3. Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff August 19, 1998; by Defendant June 19, 1998. (b) (1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code N/A , 199 ; (2) Date of filing and service of plaintiff's affidavit upon the respondent: N/A , 199 Related claims pending: None Complete either paragraph (a) or (b): (a) Date and manner of service of the Notice of.Intention to Request Entry of Divorce Decree, a copy of which is attached: N/A 3W ~t,, ,.. ~ .,~ , ~ . . (b) Da~,t~i~n.~'~4~.~.i~er o,f::Not~ce Sectzon 330t(c) D~vorce was filed with %b4e~t~.q~~J~e ,~24, 1998. ~e~/~~,'~f No~ice Section 3301(0) Divorce was filed with the ~~~"~~er ~ , 1998~ ' ~ ?:~ .~3 t T~ ' 'BARRON ~ ZI~E~N A~orneys Fo~ 'P~~ Address within I~e ~'dllt of Pennsylvanie wlte~e ~11 m~ice~ and I~teadinRs shall be defh~ered: ! 19 W£ST MARK£! STREEt £EWI$'rOWN, PENNSYLVANI~ !7044 PARTIES OR ~ (XIIJI~EL OF RECORD AN ATTESTED TI~J~ ~N~II~Y HEREOF BY UNITED STATES ~,,o {II~TA(~E PREPAID. POSTED AT L~, I~[NNSYLVANIA. ADDRESSED A~, ~IIO~'~ON PRIOR aY ~ ~ IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT OF PA. JUNIATA CO~TY BRANCH CHADD E. RONK, Plaintiff VS. RAYETTE I. RONK, Defendant CIVIL ACTION - DIVORCE No. 436 of 1997 DECREE AND NOW, ~Al 3 , 1998, it is ordered and decreed that Chadd E. Ronk, Plaintiff, and Rayette I. Ronk, Defendant, are divorced from the bonds of matrimony. The Court retains jurisdiction of any claims raised by the parties in this action for which a final order has not yet been entered. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. CHAD E. RONK v. RAYETTE I. RONK : IN THE COURT OF COMMON PLEAS : OF THE 41ST JUDICIAL DISTRICT : OF PENNSYLVANIA : JUNIATA COUNTY BRANCH : NO. 436 of 1997 ORDER AND NOW, September 28, 1998, after conclusion of the continued hearing, this Court reserves its decision on this custody matter and counsel shall have one (1) week from this date within which to either get back to this Court with an agreement or this Court will make its decision in this matter. BY THE COURT: C. JOSEPH RE~ cc: Douglas Hearn, Esq. David Barron, Esq. File IHADD E. RONK ¥. ',AYETTE I. RONK :IN THE COURT OF COMMON PLEAS :OF THE 41ST JUDICIAL DISTRICT :OF PENNSYLVANIA- :JUNIATA COUNTY BRANCH :NO. 436 of 1997 :CUSTODY ORDER AND NOW, October 8, 1998, upon review of the testimony ~resented at the hearings held in this matter, it is hereby ~DERED AND DIRECTED that the parties shall enjoy shared legal custody arrangement and also a shared physical custody arran, with a weekly exchange between the parties, being Sunday evening at 5:00 p.m. with the party receiving custody providing trans Upon a change of circumstances, the Court would consider a change in this custodial arrangement upon petition of either ,arty. David Barron, Esq. Douglas Hearn, Esq. File BY THE COURT, C. JOSEPH ¸on. IN THE COURT OF COMMON PLEAS OF THE 41 ST JUDICIAL DISTRICT OF PENNSYLVANIA JUNIATA COUNTY BRANCH CIVIL DIVISION-LAW CHADD E. RONK : : Plaintiff : : V. .. RAYETTE I. (RONK) SLOOP : ; Defendant : .' No. 436 Of 1991~ _.QORDER OF COURT You, CHADD E. RONK, Plaintiff/Respondent, have been sued in court to modify custody of the minor children Christian Ronk and Josie Ronk. You are ordered to appear in l~rson at The Juniata Coun C · Miffiintown, Pennsylvan~aonthel__t-~__dayof"~m~a~t/°unty our~use, Bndge Street, ~ - ~ conference ~ a pretrial 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator's Office Perry County Courthouse New Bloomfield, Pennsylvania (717) 582-2131 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of the 41't Judicial District, Juniata County Branch, is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Pro~honota~y IN THE COURT OF COMMON PLEAS OF THE 41 ST JUDICIAL DISTRICT OF PENNSYLVANIA JUNIATA COUNTY BRANCH CIVIL DIVISION-LAW CHADD E. RONK : Plaintiff : : V. : RAYETTE I. (RONK) SLOOP : Defendant : No. 436 Of 1998 PETITION FOg MODIFICATION OF A SHARED CUSTODY ORDER I. The Petition of Rayette I. (Ronk) Sloop, respectfully represents that on October 8, 1998, an Order of Court was entered for shared custody. attached. A true and correct copy of which is 2. This order should be modified for reasons including but not limited to: A. The Defendant/Petitioner, Rayette Sloop, has observed the lack of progress that the minor child Christian Ronk has made with his speech and language skills. B. Because of her concern for Christian onk s development and education, on R ' February 23, 1999, Defendant/Petitioner had Christian Ronk tested by the Headstart program for Cumberland County. C. Christian Ronk failed all language related tests, except for one section pertaining to comprehension. D. Defendant/Petitioner was informed by Headstart that it was important to enroll Christian Ronk in a preschool program such as theirs as soon as possible, both for his sake and for his younger sister, Josie Ronk, who mimics him. E. In order for Christian Ronk to benefit from the preschool program run by Headstart, he needs to attend every week. This is not possible because under the existing custody order, Christian Ronk spends alternate weeks with his father in Juniata County. WHEREFORE the Defendant/Petitioner requests that the Court's Order be changed to grant pr/mary physical custody of the minor children to her with liberal partial physical custody to the Respondent/Plaintiff, Chadd Ronk. Respectfully Submitted: Keystone Legal Services, Inc. 2054 E. College Avenue State College, PA 16801 (814) 238-4958 VERIFICATION I verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. /qqq Date Raye e I. (Ronk) Sloop Defendant/Petitioner 2HADD E. RONK vs RAYETTE I.. (RONK) SLOOP IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT OF PENNSYLVANIA JUNIATA COUNTY BRANCH NO. 436 OF 1997 CUSTODY ORDER AND NOW, May 18, 1999, It is Ordered and Directed that a hearing in the above matter be held on Thursday, July 1, 1999, at :00 p.m., in the Courtroom, Juniata County Courthouse, Mifflintown, 'ennsylvania. cc: David Barron, Esq. Douglas Hearn, Esq. File BY THE COURT, En~red and ~/ed ~ o CHADD E. RONK ¥. RAYETTE I. (RONK) SLOOP :IN THE COURT OF COMMON PLEAS :OF THE 41ST JUDICIAL DISTRICT :OF PENNSYLYANIA- :JUNIATA COUNTY BRANCH :NO. 436 of 1997 ORDER AND NOW, August 10, 1999, in accordance with the reasons set forth in the attached Memorandum, it is hereby Ordered and Directed that the parties shall enjoy a shared legal custody arrangement with primary physical custody of the two (2) minor children awarded to mother, Rayette I. Sloop, subject to liberal temporary custody and visitation rights in father as the parties shall agree by stipulation to be submitted to the Court. Absent an agreement, this Court will review schedules of temporar custody and visitation submitted by both parties through counsel of record within twenty (20) days and adopt one or the other schedules or a combination thereof. cc: David Barron, Esq.~ ~ REHK k ~DGE~MP,~U - Keystone Legal Se Douglas Hearn, Esq. ~rvice~-- File CHADD E. RONK V. :IN THE COURT OF COMMON PLEAS :OF THE 41ST JUDICIAL DISTRICT :OF PENNSYLVANIA- :JUNIATA COUNTY BRANCH RAYETTE I. (RONK) SLOOP :NO. 436 of 1997 MEMORANDUM The undersigned Judge has Presided over three (3) hearings in the above captioned matter, the first being April 23, 1998, the second being September 28, 1998, and the last hearing occurring on July 1, 1999. At the request of counsel for father, this Court ordered transcripts of the two (2) prior hearings and has received a transcript of the September 28, 1998 hearing and I am satisfied to proceed with a decision of this case without a transcript of the first hearing. Mother s life has Stabilized greatly since the initial hearing and she is now married to a man a lot older than herself, but who has helped make her life happier as a stay-at-home mother and housewife. Father,s situation has basically been the same, however, he is currently working at a job further than his home than at the last hearing held on September 28, 1998, and must leave by 3:00 a.m. each working day and a babysitter comes into his home at that time, wakes up the children around 6:30 a.m. and goes to her home in Mifflintown where she cares for the two (2) young children and another child. The Mennonite babysitter uses time out and when that doesn't work, does paddle the children three (3) times with a paddle. Mother,s attorney presented a picture of the younger child showing a black and blue mark on the rear end which babysitter denies she made with the paddle. Nevertheless, the babysitter did admit that the younger child had teething problems and did become upset With the child and did paddle the child on at least one or more occasions. The older Child who is approximately four and one-half (4 1/2) years of age is having speech problems and needs some therapy and both parents have consulted With local agencies and are prepared to address this problem once this Court decides the issue of where the children should live Primarily. Since Mom is home full time and Dad must Work, it comes down to a case of Mom as a primary care giver versus babysitter as a primary care giver plus Dad in the evening and Weekends. This Court has considered the testimony of Jerry Boyer, the psychologist, after review the transcript of the September 28, 1998 hearing and is satisfied with his analysis and since Mother has Stabilized since the initial separation of the parties and is home full time, this Court is satisfied that she should be the primary caretaker of these two young children at least until they reach school age. Mother is now married, has a three (3) bedroom home in which she lives With her husband who is gainfully employed and seems to enjoy functioning as a family unit with the two young children and his wife. Therefor, i, this Court is satisfied that it is in the best interests of these two young children to be with their mother during the week and With their father on weekends and as Often as possible due to his WOrk schedule. This Court WOuld encourage a very liberal temporary custody schedule With father who has been there for the children in the past when mother left the marital home. August 10, 1999 C. JOSEPH REHKAMP, JUDGE cc: David Barton, Esq. Douglas Hearn, Keystone Legal Services File CHADD E. RONK v. RAYETTE I. (RONK) SLOOP : IN THE COURT OF COMMON PLEAS : OF THE 41ST JUDICIAL DISTRICT : OF PENNSYLVANIA : JUNIATA COUNTY BRANCH : NO. 436 of 1997 ORDER AND NOW, August 27, 1999, this Court having entertained argument on the issue of temporary custody of father, IT IS HEREBY ORDERED AND DIRECTED that the parties shall enjoy a shared legal custody arrangement, with primary physical custody awarded to mother, subject to temporary custody and visitation rights in father, as follows: For the months of September through May, father shall have, commencing in September, two (2) weekends out of the month, being the second and fourth weekends, which weekends are defined as from Friday at 6:00 P.M. until Sunday at 6:00 P.M. and then father would have the children on the second, fourth and fifth weekends of the month of October and then alternating thereafter with two (2) weekends the following month and three (3) weekends the month thereafter and, if there is only four weekends in a particular month that father has three weekends, it should be the last three (3) weekends of the month: Father shall have three (3) days following Christmas each year from December 25th at 3:00 P.M. until December 28th until 3:00 P.M.; The parties shall share Thanksgiving and Easter at times to be determined by the parties and alternating other - 1 - holidays; During the summer months of June, July and August, each party shall have two (2) week blocks with the children and alternating during the summer months; The receiving party shall provide transportation; and reasonable telephone contact shall be allowed by the non-custodial parent. cc: BY THE COURT: C.~JOSEPH DGE David Barton, Esq. ~5 Douglas Hearn, Esq., K.L.S. File - 2 - CHADD E. RONK, Plaintiff/Respondent RAYETTE I. (RONK) SLOOP, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS : OF THE 41st JUDICIAL BRANCH : JUNIATA COUNTY, PENNSYLVANIA : : NO. 436 of 1997 CIVIL TERM : : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT ql io t Able, this day of ,2001, upon consideration of the attached, Petiti~hue, it is hereby ~t the Prothonotary's Office of juniata County~d copies of. the.docket e~tries, process, plea~ings, deposit~papers filed ~-captioned a~tion, t° the Prothonotary~ Court of Common Please, Cumber_land.C~ia, with the Pe" ' case, pursuant to Pa.R.C.P 1006(d)(3) ~ O BY THE COURT, CHADD E. RONK, Plaintiff/Respondent Vo RAYETTE I. (RONK) SLOOP, Defendant/Petitioner : 1N THE COURT OF COMMON PLEAS : OF THE 41 sT JUDICIAL BRANCH : JUNIATA COUNTY, PENNSYLVANIA : NO. 436 of 1997 CIVIL TERM : : CIVIL ACTION - LAW : IN CUSTODY PETITION FOR CHANGE OF VENUE AND NOW, comes the Petitioner, Rayette I. Sloop, by and through her legal counsel, Thomas S. Diehl, Esquire, who avers the following: 1. The Petition is Rayette I. Sloop, an adult individual who resides at 428 Chestnut Street, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 2. The Respondent is Chadd E. Ronk, an adult individual who resides at R.R. #4 Box 937, Miffiintown, Mifflin County, Pennsylvania 17059. 3. The parties are the natural parents of the children Christian Robert Ronk, born December 21, 1994; and Josie May Ronk, born December 5, 1996. 4. The parties are currently subject to a Custody Order dated August 27, 1999, of Juniata County, docketed at No. 436 of 1997, which granted the Petitioner primary physical custody of the children at issue. 5. For at least the past six months, the Petitioner and the children at issue have resided in Cumberland County, Pennsylvania. 6. For at least the past six months, Respondent has resided in Mifflin County. J'~ SEP 1 O 2t,,,;1 ..:2 2 Juniata C~,:.;,/i..:' vtary MIFFLiN'i'O','V~4, WHERFORE, the Petitioner respectfully requests this Honorable Court to enter an Order transferring the within case to Cumberland County, Pennsylvania. Dated: Respectfully submitted, Thomas 'S~ISiehl, E-'-'~quir~" Attomey for Plaintiff/Petitioner One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Tl~omas S D~ehl, Esquire Attorney for Petitioner CERTIFICATE OF SERVICE I hereby certify this ~ .~-~I'~ay offS__ 2001, that a true and correct copy of the foregoing document was served on the following individual via first-class mail, postage prepaid: Chadd E. Ronk R.R. #4 Box 937 Miffiintown, PA 17059 CHADD RONK, Plaintiff/Respondent V. RAYETTE I. SLOOP Defendant/Petitioner IN THE COURT OF COMMON OF THE 41ST JUDICIAL DIST ;: C-" OF PENNSYLVANIA JUNIATA COUNTY BRANCH NO. 436 of 1997 ORDER · ~'~: ,2001, upon AND NOW, this , ' day of attached Preliminary Objections and Respondent's ~Response to Defendant/Petitioner's CHADD RONK, Plaintiff/Respondent RAYETTE I. SLOOP Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DIST~JC'F OF PENNSYLVANIA JUNIATA COUNTY BRANCH NO. 436 of 1997 ORDER AND NOW, this l~'~d~ of ~~ , 2001, upon considem'~on of the attached Preliminary,O, bjecti_ons and Respen~lent's Response to DefendantJP. efifloner's ~etit~cn for BY THE COURT, '~tary CHADD RONK, Plaintiff/Respondent V. RAYETTE I. SLOOP Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT OF PENNSYLVANIA JUNIATA COUNTY BRANCH NO. 436 of 1997 PRELIMINARY OBJECTIONS and RESPONDENT'S RESPONSE TO DEFENDANT/PETITIONER'S PETITION FOR CHANGE OF VENUE AND NOW, comes Plaintiff/Respondent, Chadd Ronk, by and through his attorney, Judith F. Dolgos, and states the following in response to said Petition: 1. This action was properly originally brought in Juniata County. 2. Since the original action was brought, there have been a number of actions brought and successfully concluded in this Court. 3. There is currently an action by Petition for Special Relief, brought by Respondent, pending before this Court brought about by the actions of the Petitioner in that Petitioner is in violation of the existing custody Order dated August 27, 1999, by refusing to permit Respondent his custody rights as set forth in that Order. 4. It is Respondent's belief that a change of venue in this matter would be incorrect in that this matter could not have been brought originally in the venue now sought. 5. It would be inconvenient for the Respondent and for his witnesses should this Court grant the request for change of venue. 6. It is Respondent's belief that Petitioner has been unhappy with the past rulings of this Court and now seeks to "forum shop" for a venue more favorable to her. WHEREFORE, Respondent respectfully requests this Honorable Court to deny Petitioner's request for change of venue in this matter. Date: September 13, 2001 Respectfully submitted: No. 68738 PO Box 60809 Harrisburg, PA 17106 717 541-9660 VERIFICATION I, JUDITH F. DOLGOS, verify that the statements made in the foregoing Petition, are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. ~4904, relating to unsworn falsification to authorities. J h F Dolgos ~ Dated: .~¢..~.d. I~1.~_~)E) ' ~esp~Onden~~t, CHADD RONK, Plaintiff/Petitioner RAYETTE I. SLOOP Defendent/Respondent IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT OF PENNSYLVANIA JUNIATA COUNTY BRANCH NO. 436 of 1997 RULE TO SHOW CAUSE AND NOW, this / ~'"~tday of ~)~.~/./ , 2001, upon consideration of the within Petition, a Rule is granted upon Rayette I. Sloop as to why the prayer of the Petition should not be granted. Rule returnable and hearing on the ~,~dayof (~t'O~-- ,2001, in Courtroom ~ ' at ~ ~(~) ~).M. BY THE COURT: CHADD RONK, Plaintiff/Petitioner RAYETTE I. SLOOP Defendent/Respondent IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT OF PENNSYLVANIA JUNIATA COUNTY BRANCH NO. 436 of 1997 PETITION FOR SPECIAL RELIEF AND NOW, Plaintiff/Petitioner Chadd Ronk, by and through his counsel, Judith F. Dolgos, seeks the following special relief pursuant to Pennsylvania Rule of Civil Proceedure 1915.13: 1. Petitioner is Chadd Ronk, Plaintiff in the above captioned matter. 2. Respondent is Rayette I. Sloop, Defendant in the above captioned matter. On August 27, 1999, after credible arugment on the matter of custody, this Honorable Court issued an Order of custody which details the primary and temporary custody of the children of Chadd Ronk and Rayette I. Sloop. On or about August 26, 2001, Respondent refused to produce the children for their period of custody with their Petitioner/father. As of August 31, 2001, Respondent has refused and continues to refuse to permit ordered temporary custody of Petitioner and has further refused any contact between Petitioner and his children by telephone. Petitioner has had substantial input into each child's life since their birth, and has a close and loving bond with each child. 7. Respondent's actions does not consider the needs of the children. 8. Respondent's actions has severely disrupted the daily lives of the children. Petitioner has been denied the comfort and compansionship of the children and they of his. 10. Respondent's actions are not in the best interest of the children and are contrary to the Order of custody issued by this Court. 11. Petitioner and his children will be irreprarably harmed should Respondent be permitted to continue to deny Pet;itioner the custody of his children. WHEREFORE, Petitioner respectfully requests the Court to order and direct Respondent to deliver the children into the custody of their father; that temporary custody of the children be awarded to Petitioner pending further Order from this Court; that Respondent be restrained from removing the children from the jurisdication of this Court; and other further relief as the Court deems appropriate. Respectfully submitted, or hnF. Dolgos, Esquire) Date: September 13, 2001 eylD~68738 PO Box 60809 Harrisburg, PA 17106 717 541-9660 I, CHADD RONK, certify that the statements made in the foregoing PLEADING, are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. ~4904, relating to unsworn falsification to authorities. CHADD RONK ,Juniata Ooun~ Prothonotary MIFFCINTOWN, PA CHADD RONK, Plaintiff/Respondent V. RAYETTE I. SLOOP Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT OF PENNSYLVANIA JUNIATA COUNTY BRANCH NO. 436 of 1997 CERTIFICATE OF SERVICE I, JUDITH DOLGOS, Esquire, Attorney for Plaintiff/Respondent, hereby certify that I have served, this day, the foregoing PRELIMINARY OBJECTION and RESPONDENTS RESPONDENT TO DEFENDANT/PETITIONER'S PETITION FOR CHANGE OF VENUE, by US Mail, First Class, postage pre-paid, addressed as follows: Ms. Rayette Sloop 428 Chestnut Street Mount Holly Springs, PA 17065 Date: September 18, 2001 By: /-'~ith F. Doigos, Esquire42 /_//Attorney ID# 68738 PO Box 60809 Harrisburg, PA 17106 717 541-9660 Juniata Count! Prothonotary MtFFLINTOWN, PA CHADD RONK, Plaintiff/Petitioner V. RAYETTE I. SLOOP Defendant/Respondent IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT OF PENNSYLVANIA JUNIATA COUNTY BRANCH NO. 436 of 1997 CERTIFICATE OF SERVICE I, JUDITH DOLGOS, Esquire, Attorney for Plaintiff/Respondent, hereby certify that I have served, this day, the foregoing PETITION FOR SPECIAL RELIEF, by US Mail, First Class, postage pre-paid, addressed as follows: THOMAS S. DIEHL, ESQUIRE MISLITSKY & DIEHL One West High Street Suite 208 Post Office Box 1290 Carlisle, PA 17013 Date: September 24, 2001 By: Igos~-ES&ire 0698738 Harrisburg, PA 17106 717 541-9660 ~'t~t~ SEP 2 § 200] Juniata Ccur~:~ MIFFLiN'I ©¢~,,i, ~ ',HADD E. RONK v. ',AYETTE I. (RONK) SLOOP : IN THE COURT OF COMMON PLEAS : OF THE 41ST JUDICIAL DISTRICT : OF PENNSYLVANIA : JUNIATA COUNTY BRANCH : NO. 436 of 1997 ORDER AND NOW, October 15, 2001, the Petition for Special Relief is Granted and the previous court order shall be enforced effective his weekend when dad's visitation shall recommence as per court ~rder. On the issue of change of venue, counsel has ten (10) days from this date within which to submit authorities, after which this Court will render its decision on the change of venue request. At this time neither party resides in Juniata County and mother and :he subject children have been residing in Cumberland County for Dad has been residing in Mifflin County a lpproximately two years. couple of months. Judith Dolgos, Esq. Thomas Diehl, Esq. File cc: BY THE COURT: C. ~GE CHADD E. RONK v. RAYETTE I. (RONK) SLOOP : IN THE COURT OF COMMON PLEAS : OF THE 41ST JUDICIAL DISTRICT : OF PENNSYLVANIA : JUNIATA COUNTY BRANCH : NO. 436 of 1997 ORDER AND NOW, October 31, 2001, upon review of the letter memorandums submitted by both parties, through counsel of record, on the issue of change of venue, IT IS HEREBY ORDERED AND DIRECTED that venue in this case is hereby transferred from Juniata County to Cumberland County, which is the present residence of the mother and two subject children and has been the residence of the children for the past two years, as per order of court dated August 27, 1999. It should also be noted that father now resides in Mifflin County. It should also be noted that the contempt petition has been ~esolved by order of court. The Prothonotary of Juniata County is hereby directed to certify the records and transfer the case to Cumberland County. BY THE COURT: Judith F. Dolgos, Esq. Thomas S. Diehl, Esq. Prothonotary-Cumb. Co. File cc: C. JOSEPH REHK~P,~ COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF HEALTH VITAL RECORDS ? DIVORCE Juniata ~ RECORD OF OR ANNULMENT (CHECK ONE} [-~ STATE FILE NUMBER STATE FILE OATE HUSBAND I Ch~dd Eric Ronk ! B.R*. 11/22/73 2. RES,OENCE ~o, o,,.o. ~.-,v. eo,o. ~ r,~ R.R.$1. BOX 331. Honey Grove, Jun~ata County OF~.,S ~ ~ ~ ~ ~ Construction 'worker WIFE Rmym~-t~- T ren~_ Rock~_nbmrrv BIRTH 5/15/74 - I~fe or £~,~-~. Counrryl 235 Baltimore St.. Mt. Holly Sprinqs, Cumberland Cty~ ~....~q~ [ ~ ~ ~ Factory worker Mifflin County, PA ' 17B. NUMBER OF OEPENOENT CHIL 18. PLAINTIFF OREN UNOER 18 2 HUSBAND~ September 3, 1998 TRANSCRIBING CLERK THIS ~^RR,A~E 11/27/93 O.~OR¢SO"AN"UL~ENT irretrievable breakdown TOV,T^LRECOROS September 4~ 1998 CHADD E. RONK V. RAYETTE I. (RONK) SLOOP : IN THE COURT OF COMMON PLEAS : OF THE 41ST JUDICIAL DISTRICT : OF PENNSYLVANIA : JUNIATA COUNTY BRANCH : NO. 436 of 1997 ORDER AND NOW, October 31, 2001, upon review of the letter memorandums submitted by both parties, through counsel of record, on the issue of change of venue, IT IS HEREBY ORDERED AND DIRECTED that venue in this case is hereby transferred from Juniata County to Cumberland County, which is the present residence of the mother and two subject children and has been the residence of the children for the past two years, as per order of court dated August 27, 1999. It should also be noted that father now resides in Mifflin County. It should also be noted that the contempt petition has been ~esolved by order of court. The Prothonotary of Juniata County is hereby directed to :ertify the records and transfer the case to Cumberland County. Judith F. Dolgos, Esq. Thomas S. Diehl, Esq. le onotary-Cumb. Co. Certifie~: A '[~ue Copy I ~ ¥~othonotar~ .... BY THE COURT: · JOSEPH REHK~ MISLITSKY AND DIEHL THOMAS S. DIEHL RICHARD p. MISLITSKy* KIMBERLy L. HOUGH LEGAL ASSISTANT KATHiE j. DiEHL LEGAL SECRETARy REPLy TO: CARLISLE ONE WEST HIGH STREET ~/~ SUITE 208 ~-~1~1 CARLSLE m~....P'O. BOX 1290 14 NO~TH MA~N STREET ~L~~ ~JMBERSBURG ~_ SUITE 550 (7~7) 261-O208 (7~ 7) 240-O893 ~ FACSIMILE October 25, 2001 Perry County Courthouse Center Square New Bloomfield, PA 17068 RE: Chadd E. Ronlt v. Rayette I. (Ronll) Sloop No. 436 of 1997 (Jnniata County) In Custody Memorandum of Rayette I. Sloop Dear Judge Rehkamp: Please accept this Memorandum on behalf of the Mother, Rayette I. Sloop, in the above- captioned matter. The issue at hand is whether Mother may have venue of this case transferred to .Cumberland County. The facts indicate that the prior Custody Order (for which change of venue is requested), dated August 27, 1999, provides primary, children to Rayette I. Sloop (hereinafter "M -" physical custody of the parties' two , 0th, e.r ). For an excess of two years Mother has resided with the children at her residence locatea m Mount Holly Springs, Cumberland County, Pennsylvania. Chadd E. Ronk (hereinafter "Father") had previously resided in Juniata County, however has moved to his current residence in approximately three months ago. McVeytown, Mifflin County, Pennsylvania During the parties' appearance before the Court on October 15, 2001, counsel for Father indicated that she was aware of a case on point in which it would be appropriate for Juniata County to retain jurisdiction. I, however, am not aware of any such case, and accordingly am arguing this matter directly from Pennsylvania Rules of Civil Procedure 1915.2, concerning venue in a custody action. It should be noted that Cumber/and County meets the necessary criteria for venue under several of the subsections of Rule 1915.2. This is specifically due to Mother residing in Cumber/and County in excess of the six months required for jurisdiction. Furthermore, it should be noted that it does not appear on the face of the relevant Rule that Juniata County would be an appropriate venue under any subsection of Rule 1915.2. This is due to the fact that neither of the children nor any of the persons a party to this case reside in Juniata County, and that there is no current action pending in Juniata County. FILE No. Ol !99 *CERTIFIED AS A CIVIL TRIAL ADVOCATE BY THE NATIONAL BOARD OF TRIAL ADVOCAcy A PENNSYLVANIA SUPREME COURT ACCREDITED AGENcy Page 2 October 25, 2001 Memorandum to Honorable C. Joseph Rehkamp re__2_ Ronk v. Sloop Although case law does give discretion to the Court on whether or not to retain venue, there must be a basis for exercising such discretion. In the immediate matter, Father has argued that transferring the case to Cumberland County would create an undue hardship on Father's witnesses. Mother, however, is unaware of what hardship Father is referring.- Specifically, as this is a custody matter, it is likely that most, if not all, witnesses would be testifying voluntarily (i.e. they have chosen to make themselves a part of the action and therefore would not incur any hardship by agreeing to be present at any subsequent Court proceeding). This is in contrast to other civil actions in which witnesses who have no relation to the parties could be subpoenaed contrary to their will to testify on behalf of one of the parties. Such is often the case in contract or employment litigation matters. The only foreseeable exception may be expert witnesses (i.e. custody evaluators), however it should be noted that such experts are typically chosen by mutual agreement of the parties, and it is the parties who typically travel to the expert witness' office in custody matters, and not the expert witness himself who would be inconvenienced by traveling. Ultimately, the appropriate remedy for Father's concerns is not the current objection to change of venue, but a timely objection to Mother's relocating with the children. Accordingly, Father's present concerns, if founded, should have been brought in the form of a relocation hearing two years ago. As the law is not generally agreeable to leaving matters open-ended, parties typically have a time limit for contesting relocations, hence the six-month deadline established in Pa.R.C.P. 1915.2(a)(1)(ii), as well as analogously the six-month standard in the Uniform Child Custody Jurisdiction Act, 23 Pa.C.S. §5341-5366. To now permit Father to object to the new location being inconvenient would open the proverbial "can of worms" for all relocation matters and leave an open-ended standard, which could be used to review relocations that have taken place over two years prior, such as in the instant matter. Lastly, it shoald be noted that the ~resent ar tun ' typical objection to relocation i tho, ...... ;~ g . ent ~s even more strained n ....,,v~, me person objecting to the than your case, Father) no longer resides in the county at issue, relocation (in the instant In sum, this is a fairly standard case in which Mother sought to initiate an action in a county, which given the above facts, can clearly exercise jurisdiction, and merely sought to go through the standard process of transferring venue to Cumberland County. As of yet, there has been no rational basis--in fact or law--for the Court to maintain jurisdiction in Juniata County in this matter. Page 3 October 25, 2001 Memorandum to Honorable C. Joseph Rehkamp re: Ronk v. Sloop Accordingly, Mother respectfully requests venue be appropriately transferred. Respectfully submitted, Thomas S. Diehl TSD/klh cc: Rayette I. Sloop Judith F. Dolgos, Esquire (via facsimile (717) 541-9663) *CERTIFIED AS A CIVIL TRIAL ADVOCATE BY THE NATIONAL BOARD OF TRIAL ADVOCACy A PENNSYLVANIA SUPREME COURT ACCREDITED AGENCY llllllTli TRANCES DOL60$ ' ATTOBliEY ItT lAW .~- _ ~ ~ ~isburg, PA 17106-0809 541-9660 ~ Fax 717 541-9663 ~ F. mai~ jcHAPS9 @ cs.com Phone 717 October 24, 2001 VIA FAX582-5466 The Honorable C. Joseph Rehkamp Perry county Courthouse New Bloomfield, PA 17068 IN RE: Ronk v. SloOp 436-'/997, Juniata County Dear Judge Rehkamp: Per your order of October 15, 2001, we submit the following on the issue of the Defendant's Petition for Change of Venue. The issue before the court is whether this court has broad discretion to grant or refuse a petition for change of venue. Most of the cases on point, deal with preliminary venue and not matters such as this where the court have previously heard testimony and drafted orders. Change of venue was originally governed by the Act of March 30, 1875. Under the Act, the legislature had set forth a list of mandatory and discertionary circumstances- The Act was repealed in 1978 and was replaced with 42 Pa. C.S. 5106. Much simpler in its text, the new law reads: "The power to change venue in civil and criminal by · June 27, 1978). The law makes no cases shall be vested in the courts, to be exercised in such manner as shall be provided or prescribed law. 42 Pa.C.S. 5106, (1976, July 9, P.L. 586, No. 142 2, effective ...... ,=r of venue. The attempt to set forth the terms under which the court may exercise ts discretion . ,,,o,,~.s Pennsylvania Supreme Court drafted pa.R.C.P. 1006, which prescribes when change of venue is allowed. Section (d) (1) of rule 1006 governs the Defendant's request for change of venue· Under section (d) (1), for the convenience of the parties and witnesses "the court may transfer an action to the appropriate court any other county where the action could originally have been brought"· of The use of the word may is significant. Both the Pennsylvania Supreme Court and the commonwealth Court have attributed a permissive or discretionary connotation to the legislature's use of 497 Pa. 551,442 A.2d 674 (1982); O'Neil v _ ,,.,~n', nc, fiti~n f rQEj~o~- - "~ "~a'"' in the new the word "may" in a statute. ~ zimmerman v O'Bannon, f aoo_e_aLd.eJ:~, 526 Pa. Pa. CmwItn.-luoo~_~ ~,,. inotheworu -' · Bo u h of Yardley 565 A.2d 502 ( · ~-,- ion of the ~5upreme ~,uu~,, ,,y .s , 64~°, ~4 A.2d 324 (1990)· It was the ,n,~,,t rule, to vest broad discretionary powers in the courts. · ' . the rule vests the trial judge with .... ~-* are the same, spectf?allY ......... ~,~nne of venue...and the Dst all of the cases on ~u, ot to rant a peTITion ~u~ ~,,, = 43 A!m. ........ in determining whether or n g Pa. ~LOb[oj~o. 416 149,205 A.2d consideraole Qiscr~uu- standard of review in one of abuse of discretion. (1964); p, Lo_e,.~_tJ/__~x P I~_~__C_o~. 341 Pa. Super. 71,491 A.2d 50 (1984); ~ ' hl,j.gbLC-Q. 315 Pa. Super 79,461 A.2d 805 (1983); D_au~ TUgS CD_. 240 Pa. Super. 527,359 The Honorable C. Joseph Rehkamp October 24, 2001 Page 2 · in the tria judge to determine whether to grant a ............ e vests considerable dlscret?n_ ...~ "~0 A 2d 549 (1960); I:Ja[na~v City_O/ A 2d 465 (l~J/t~)- ~'.~ '~ ,, ..... T~,nn~×. Inc. 339 I~a ooo, ,~ . p~tition for change o~' venue, r_j_u.u~- ~-'~'"~981); Daughhertv VJQ~n~ ,,C_o_. 240 Pa. Supe'r. 527, ~/_a,~.bJ/1.~, 291 Pa. Super. 137,435A.2d 606 Super. 58, 2~J8 A.~2d 903 (1972) .... the trial court, is vested 359 A.2d 465 (1976); ~r~rasi v~, 223 Pa. Ma.s.c,L~ass139aQ 689 in determining whether or not to grant petition for change of venue. with discretion 1997); I~/~at-aEc°rD'' 438 Pa. Super 231,652 A.2d 349 (1994). A.2d 314 (Pa. Super court must find that the transfer is more convenient for both In granting the petition, "the trial parties to the action or for the witnesses. -N~si v Fitti~. 434 Pa 133, 252 A.2d 700 (1969) (emphasis in original). The ends of justice are not sewed by allowing a suit to be litigated in a forum where, on balance, unnecessary hardship and inconvenience would be cast on one party without campensatingly fair convenience to the other parties and where suit might be more conveniently litigated in another forum available equally to both parties. D_a.tzg]Ae_d:~v t~Tug_s Co.. 240 Pa. Super. 527,359 A.2d 465 (1976). The current venue is equally convenient for both parties as it is approximately equidistant from both parties and their potential witnesses. This court is familiar with the matter. By moving this matter form its present forum, there is the potential for a need to restate previous testimony. There will absolutely be an increase in the cost of litigating any future actions because the parties would be required to make the court aware of past testimony. This would require the necessity to purchase the transcripts from the past hearings as well as the need to have the expert witness testify again. Should this be the case it is likely that the psychologist who testified previously would require meeting with the parties again, prior to any new testimony. This would be an additional expense to Mr. Ronk, respondent in this matter. The potential for unnecessary costs is great should the change be granted. Furthermore, Mrs. Sloop was in contempt of the existing order at the time that her counsel requested the change of venue. Should this court transfer venue to Cumberland County there is nothing · . order issued by this court, Mr. Ronk would be at the assure Mr. Ronk that his ex-wife will continue to comply with the existing order upon transfer. That tw°ould mean the should she once again wolate the almost eight weeks to get into the mercy of a much busier court system. The last violation took courtroom, and Mr. Ronk and his children were deprived of each others love and affection during that time. Once transferred to a new forum, Mr. Ronk could find himself waiting for twice as long before getting relief· In light of the information set forth herein, Plaintiff/Respondent Chadd Ronk, respectfully requests this court deny Defendant's request for a change of venue. CC: Thomas S. Diehl, Esquire Chadd Ronk Sincerely, MlSLITSKY AND DIEHL THOMAS S. DIEHL RICHARD P. MISLITSKY* KIMBERLY I. HOUGH LEGAL ASSISTANT KATHIE J. DIEHL LEGAL SECRETARY REPLY TO: CARLISLE Juniata County Court of Common Pleas Prothonotary's Office P.O. Box 68 Bridge & Main Streets Miffiintown, PA 17059 September 7, 2001 ONE WEST HIGH STREEt SUITE 208 P.O. Box ! 290 CARLISLe, PENNSYLVANIA 17013 (717) 240-0833 14 NORth MaIN STREet SUITE 550 CHAMBERSBURG, PENNSYLVANIA 17201 (717) 261 -O208 (717) 240-0893 -- facsimile FILE NO. O1199 RE: Chadd E. Ronk v. Rayette I. (Ronk) Sloop No. 436 of 1997 Dear Sir or Madam: Please find enclosed the original and two copies of the Petition for Change of Venue for the above-captioned matter. Kindly stamp these documents in and forward them to the appropriate Judge for review. I have also enclosed two self-addressed, stamped envelopes for your office to return a copy of the Petition to both Mr. Ronk and Attorney Diehl once an Order has been signed. If you have any questions concerning the above, please do not hesitate to contact me. Your assistance in this matter is greatly appreciated. Very truly yours, Legal Assistant Enclosures *CERTIFIED AS A CIVIL TRIAL ADVOCATE BY THE NATIONAl BOARD OF TRIAL ADVOCACY A PENNSYLVANia SUPREME COURT ACCREDITED AGENCY JUDITH FRANCES DOLGOS - ATTORNEY AT LAW PO,Box 60809 ~ Harrisburg PA 17106-0809 Phone 717 541-9660 ~ Fax 717 541-9663 ~ Email JCHAPS9 ~ cs.corn September 24. 2001 Prothonotary Juniata County Courthouse Bridge Street Mifflintown, PA 17059 RE: Ronk v. Sloop 436 of 1997 Dear Prothonotary: Enclosed please find the Certificate of Service for Mr. Ronk's Petition for Special Rehef. Please time stamp the documents and return the copies in the enclosed envelopes. Your assistance n th~s matter is greatly appreciated. Sincerely, /Dol(~os~~ JgDITH FRANCES DOLGOS - ATTORNEY AT LAW PO Box 60809 ~ Harrisburg, P,~, 17106-0809 Phone 717 541-9660 ~ Fax 717 541-9663 ~ Email JCHAPS9 @ cs.com September 18. 2001 Prothonotary Juniata County Courthouse Bddge Street Miffiintown. PA 17059 RE: Ronk v. Sloop 436 of 1997 Dear Prothonotary: Enclosed please find the Certificate of Service for Mr. Ronk's Preliminary Objections to the Petition for Change of Venue. Please time stamp the documents and return the copies m the enclosed envelopes. Your assistance in this matter is greatly appreciated. Sincerely, Parent Notification Waiver Student Name: of IEP Meeting Date: Within 10 days of the Multidisciplinary Evaluation (MDE) team meeting, the school district or intermediate unit will forward to you a typewritten copy of the Comprehensive Evaluation Report (CER). You have the right to review and study the written CER before attending thc Individualized Education Program (IEP) planning meeting. Within 30 calendar days following the Multidisciplinary Evaluation meeting, an Individualized Education Program (IEP) planning meeting will be held to review and discuss the written multidisciplinary 'report (CER) and decide if your child is exceptional and in need of special education services. If the IEP team decides your child is exceptional and in need of special education services, his/her IEP will be developed to meet your child's identified educational needs. You may elect to v~aivc the time period between the MDE meeting and thc IEP meeting and request that the IEP meeting be held at the conclusion of the MDE meeting. Please check your choice below. I want the IEP meeting to immediately follow the Multidisciplinary Evaluation (MDE) team meeting. · I understand that I will not have a typewritten copy of the multidisciplinary evaluation report/comprehensive evaluation report (CER) prior to the IEP meeting. · The "Invitation to Participate in the IEP Team Meeting" has been reviewed with me and I agree to participate in the IEP team meeting as proposed. (2) I want an IEP planning meeting separate from the Multidisciplinary Evaluation team meeting. Please contact me for a meeting time after I receive a typed copy of the CER report. ' ' ~/~rent(s)~ Signature Date Wit~e~s Date White - School District Yellow - Psychologist/Teacher Pink - Parent Goldenrod - IU Office TUSCARORA INTERMEDIATE UNIT EARLY INTERVENTION IN THE MULTIDISCIPLINARY EVALUATION/REEVALUATION Date,. PARTICIPATE Student Name: ~ EI-213 INVITATION TO MEETING Title Parent Agency Representative* MDT Representative Other, identify Other, identify If you would like additional personnel from the MAWA agency to attend this team meeting, you may call me and I will try to have that person attend. If this time, date or location is not convenient, please contact me as soon as possible so we can arrange another time and place which is convenient for you. If you have any questions or comments, please contact the person listed below: Name: ~'9~_/~ ~'-/~-~'~ j Phone Number: .~ _~.//"~~' ''''~°~ When the permission to evaluate/intent to reevaluate form was sent to you, a copy of the Not,ce ot Parents' Rights (EI-205) explaining your rights as a parent to protect your child was attached. You may wish to review this letter again. We will provide a copy of the Notice of Parents' Rights (EI-205) again when the notice of assignment is presented at the meeting. If you do not attend this team meeting, you will receive a notice before any significant changes are made regarding your child's education. (please check one) ~ I ~ill i~tter~d the ngiltidi/sciplinary evaluation/reevaluation meeting. ~//~o At,'c[esire//l~p~a~ticipate in the multidisciplinary evaluation/reevaluation meeting. ~_ .~~~.~.~__....~ --' Phone Number: Signature: We look forward to your participation. *The agency representative is an individual other than the teacher who is familiar with available placement options. **For children who are enrolled in a program. Please indicate whether you will or will not attend the meeting and return to contact person: (please check oneJ White - IU Office Yes, I will attend. No I cannot attend, please send a copy of the typed CER for my review. I would like to attend but need to reschedule. Call me at Phone Number The best time to call is , Day Time Yellow - Psychologist/Teacher Pink - Parent Goldenrod - Service Provider/Agency The following people are expected to attend: Name Complete Name of Parent Your child has been referred for a muitidisciplinary evaluation/reevaluation of his/her educational status. As part of the evaluation/reevaluation process, we are requesting a meeting with you as the parent/guardian and/or student, the professionals who have conducted the evaluation, and other knowledgeable persons. During this meeting, the results of the evaluations will be discussed. 'Recommendations will be made as to whether or not your child is, or continues to be, an exceptional student. Recommendations for your child's educational programming will also be presented. The results of this evaluation/reevaluation will be included in a Comprehensive Evaluation Report which will be drafted during the meeting. Your participation in this meeting is important. It will give you the opportunity to provide those in attendance with your insights. The meeting is scheduled.for Date: 'JoJq¢ , Time: ~g.'O[d t//Iq at Location: ~tt./t.~o.~,,~O~ -./~,~-n~' Yo~ may decide not to participate in this meeting. If you do not respond to this letter within 10 days, the meeting will be held in your absence. Yuscarora Intermediate Unit 11~ 2527 US Hw~ 522 South McV~town PA 17051-9717 E I- 2 1 1 ($14) 542-2501 · (717) 899-7143 EARLY INTERVENTION SCREENING REpoRT This report is to be sent to the agent referring the child for services following the completion of the screening. am of h. : Name of Parent(s): ~ ~----~--~-' Phone: ~/~,/~;7'.~.5/ ,~xT/ Mailing Address: ~ School District:~~~-~ Person & Agency who Referred Child: ~ ~ '~' (name) (agency) Reason Child was Referred: ~'-. ~' ~t.,~n '... 1 Staff Person(s) who Conducted the Screening & Completed this Report: Additional Person(s) to whom this Report should be Sent: (Release of information must be attached or in office file) ~ Date of Referral: ~~--~ Today's Date: Screening Tests Administered: Areas Screened: ~Social/Emotional [~ Cognitive (please check t/all) [~ Health [~ Motor Skills [~/ Language [~/ Functional Hearing ~/ Speech (articulation/fluency/voice) /Self Help Skills Functional Vision Recommendations: [] Development appears normal, no follow-up recommended at this time. [] Progress should be monitored and child should be screened again in months. ~ Child will be evaluated further to determine if developmental delays are present and the need for special education services will be decided by an Individual Educational Program (IEP) Team, to include the parents, at a future date. [] If further information about this child's program is needed, please contact the evaluator listed above or the Early Intervention Supervisor at the Tuscarora Intermediate Unit office. White - [U Office (copies of this report will be scnt by the El secretary to referral agent(s) listed above) Yellow - Teacher An Equal Rights and Opportunity Educational Service Agency' Pink - Parent TUSCARORA INTERMEDIATE UNIT EARLY INTERVENTION PROGRAM COMPREHENSIVE EVALUATION REPORT (CER) EI-214a [] Initial Evaluation [] Reevaluation Date: (Permission to Evaluate/Reevaluate): Date: Completion of MDE (last assessment): Child's Name: Christian Ronk Address: RR l, Box 331, Honey Grove, Pa. 17035 Parent(s)/Guardian Name: Cbacld Ronk School District: luniata County Other Info~a~ation (as needed):. 5/6/99 3/29/99 Date: CER: 5~6~99 Birthdate: 12/21/94 Phone: 717-734-3094 Reason for Referral Initial: Brief summary of how and why the child was referred. Reevaluation: Brief summary of how and why the child was referred for this evaluation (example: eligible for transition to school age, yearly evaluation). Christian was referred by his father, Chadd Ronk, due to concerns about his speech and language development. II. History A. Early Intervention History: Initial: Include an overview of medical, educational and social services that have been received. Reevaluation: Update any changes in the past year. Christian has had no previous therapies. EI-214b COMPREHENSIVE EVALUATION REPORT (continued) II. History (continued) B. Educational, Social and Physical History: Christian attends a day care setting every other week when he is living with his father. Two other preschoolers also are cared for in this setting, one of them being his two year old sister. The day care provider is a certified teacher with nine years of early education experience. Christian enjoys playing with other children and gets along well with them. His physical history is unremarkable. III. Information froTM the Family (parents or other persons with whom the child lives) A. Child's strengths and needs including physical condition, cultural and language considerations and adaptive behavior: Christian's father reports that Christian has good comprehension skills. He enjoys playing with other children and becomes friends easily. Motor skills are advanced. He is very observant and has good memory skills. He feels that his greatest need is articulation skills and having a stable living environment to maintain skills being taught. The father reports that he is concerned about weight loss during the week he is not with him (see attached weight report). The child is weighed by the caretaker, Catharine Zook. There are no cultural or language considerations. Christian's adaptive skills are fine. He is willing and able to do age appropriate self-help skills. He sometimes helps his sister with these skills. B. At the family's discretion, the family's perceived strengths and needs which will enhance the development of child: Christian's father believes that he needs a consistent environment so that Christian is able to learn the skills he needs for school readiness and to communicate at home and in the community. Mr. Ronk is very pleased with the loving, nurturing setting provided by Catharine Zook's day care. He also is pleased with the teaching she gives and her insights and expertise in this area. Christian also receives balanced, nutritional meals and shows adequate weight gain under her care. COMPREHENSIVE EVALUATION i~PORT (continued) IV. Summary of Findings A. Screening Results (if screening was not conducted, please note reason): t Screening Test Administered: 4113199 - First Step, TIU Developmental Record Further Further No,,lial Evaluation Normal Evaluation Needed Needed X Social/Emotional X Cognitive X Health X Motor Skills X Language X Functional Hearing X Speech X Self-Help Skills (articulation/fluency/ X Functional Vision voice) EI-214c B. For reevaluation, include review of current IEP (a single test may never be the sole factor in dete~'a~ining whether a young child is eligible): This was an initial evaluation for Christian Ronk. C. Developmental Assessment 1. Test Results (include date, procedure/test used, and testing results): Goldman Fristoe Test of Articulation - 4/15/99 Preschool Language Scale - 4/29/99 Battelle Developmental Inventory (Personal/Social Domain) - 5/6/99 Health Concerns - Interview - 5/6/99 EI-2Fkl COMPreHENSIVE EVALUATION REPORT (co~ued) IV. Summary of Findings (continued) C. Developmental Assessment (continued) Articulation Christian's speech is difficult to understand. His speech is characterized by omissions, substitutions and distortions. He has more difficulty with multisyllabic words. At times he avoids saying words that have certain consonant sounds in them. Language Christian's chronological age at the time of testing was 52 months. His receptive language score was 46 months. Expressive score was 30 months and total language score 38 months. His expressive and total language scores represent at least a twenty-five percent delay. Receptively he had difficulty with colors, quantity and time concepts as well as passive voice. Expressively Christian speaks in short two to three word phrases. He does not use plurals, possessives, pronouns, prepositions, auxiliaries, or answer "wh' questions appropriately. He cannot use basic sentence structure, even in repetition. His vocabulary is limited. Personal/So,iai Christian's chronological age is 52 months. He scored 40 months in this area. He was able to accomplish most items in the adult and peer interaction areas. He had more difficulty in the area of coping, such as following rules and sharing toys. Health Health concerns are being investigated by the family (see section HI). E1.214e ~ COMI;REHENSIVE EVALUATION REPORT (continued) IV. Summary of Findings (continued) Narrative (including, but not limited to, physical development, cognitive and sensory development, hearing problems, learning strengths and educational needs, language and speech development, social and emotional development, self-belp skills, health considerations): Christian's motor, self-help and cognitive skills are within age appropriate ranges. His vision and hearing are reported as nom~al. His receptive language is developmentally appropriate. Expressive skills fall below expected levels. His father has some bealth-related concerns (see section llI). His articulation is difficult to understand due to multiple errors and omissions and substitutions. He needs to develop more communication skills in order to be understood and to make his wants, needs and feelings known. Personal/social skills are borderline. Classroom placement would be recommend to help improve this area. D. Observations (infomiation from observations during doily activities such as play with other children and interaction with family members and/or other adults): Christian was initially reluctant to interact with the evaluator, but cooperated with activities with encouragement. He enjoys playing with adults and his sister and friend who stay at the babysitters with him. He communicates with them in short noun-verb phrases and gestures to be better understood. He needs to be encouraged to stay interested in learning activities long enough to finish the task. He will play for at least 20-30 minutes with high-interest toys. E. Area(s) of Delay Language Articulation Personal/Social E1-214~ ' COMP~EHENSIVE EVALUATION REPORT (continued) IV. Summary of Findings (continued) F. Skills needed by the child to function successfully in a variety of settings, including the home, school and community: Christian'S articulation and language skills need to improve in order for him to be better understood and to be able to make his wants, needs and feelings known. His personal/social skills are borderline. Classroom placement would be beneficial to improve such skills as turn-taking and sharing. Ve Recommendations A. Recommendations of Eligibility for EI Services and Programs.from the Annotated IEP: 1. X Team recommends eligibility for early intervention services. The following services or programs should be considered by the IEP team. 2. Team recommends continued eligibility (attach IEP). 3. Team does not recommend eligibility for early intervention services. Recommendations for follow-up activities (if any) are: Speech and language therapy Personal/social support Early Intervention classroom placement B. Recommended Services to Meet the Famdy Needs: The family feels that speech and language therapy should be provided on a weekly basis at the day care home. Early Intervention classroom placement will provide support for his personal/social skills and readiness skills, as well as to support the development of his communication. Fuscarora Intermediate Unit 2527 US Ht~ 522 South McVeytown PA 17051-9717 (814) 542-2501 · (717) 899-7143 Report Today's Date: Parent Evaluation/Re-evaluation Child's Name:, ~ Parent(s) Name: EI-207 Please give us some written information below about your child's strengths as well as describe your child's educational needs. This information will be considered by a team at an upcoming meeting to help make plans for your child's future educational progrsm. 1. Play and Preschool Skills. (How well does your child handle activities such as puzzles, recognizing colors, counting, etc.?): ~./..~ .~;//. /'i'~x~//zr~/.~z,~., 2. understand?).; ,, .. ) -/ 3. Social Skills (How does your child get along with friends and adults? How does your child 4. Develo. pmental Skills (How well does your child handle such activities as climbing, ~'~~ dressing, toileting, etc.?): 5. Please indicate any areas of family concern, such as community, health or social services, with which you would like help to meet the needs of your child. 6. Please list any additional services or programs you would like to have considered at this meeting for your child's program. Please tell us if you will be attending the meeting: ~ I will be attending the meeting as scheduled. [] I will not be attending the meeting. If you have any questions or concerns, please call the Tuscarora Inten~ediate Unit Early Intervention Program Supervisor at the TIU office (814-542-2501 or 717-899-?143). An Equal Rights and Opportunity Educational Service Agency FAX ($14) 542-256') · TDD (814) 542-2905 EI-214g COMPREHENSIVE EVALUATION REPORT (continued) MULTiDISCIPLINARY EVALUATION TEAM SIGNATURES: (Please indicate your agreement or disagreement with the conclusion or content of this report. If you disagree, please write the reasons for disagreement and attach them to this report.) Signature Title Date Agree Disagree Chadd Ronk Father 516199 X Michele Meiser Speech Therapist 5~6~99 X Catharine Zook Caretaker-Reg. Ed. Teacher 516199 X Diane Galbraith L~AJSupervisor 516199 X This report is a draft until a/l MDT members (including parents) have reviewed and signed the report. Any dissenting opinions must be included. Date CER Sent to Parents: 5/7/99 White - IU Office Yellow - Psychologist/Teacher Pink - Parent Goldenrod - Service Provider/Agency 3APITAL AREA NTEPJAEDIATE UNIT , ~chool Programs and Services 55 Miller Street, P.O. Box 489 ~ummerdale, PA 17093-0489 z 17-732-B400; Fax:. 717-732-8~, 14 I tq99 Screenin ort Date o,fBirth: I z..I '~'-' I ff.Y" .' --- - '~ Parent, Name: ~:~-tZ~ ~ ~.~_.,o-~ Chronological Age: ~eason for ReferS: , ~ Z ~ ' Tes~ Adm~stered:' D Brigance Preschool Screen for 3 and 4 Year Old Children or Kindergarten and First Grade (Br~gance): The Br~gance is administered to obtain infu~i~iation about a child's overall develo~mentai skills. Area~ tested on the $ and 4 Year old forms include language skills, motor skills, body awareness, visual discr~mlnaffon ability and general reasoning sIdll$. Areas tested on the K and & 1 for~ inchtde fan,rage skills, gross motor skills, .fine and visual motor skills, and concept knowledge. Score: Pass~ Fail Fiuhartv_ Preschool Speech and Language Screening Test The purpose of this screening test is to elicit reeponses from this Preschool child that indicate his or her vocabulary, articulation, and receptive and expressive language .performance Identification Pass.~ Fail. Articulation Pass. "Fail Comprehension Pass~t.-''''/ Fail Repetition Pass,~ Fail Developmental Indicators .for the Assessment Of Learning (DIAL-R) The DIAL-R is administered to assess a child's general moloric sldlls, concept awareness and language ability. It provides an ove-rvq~w of skills in comparison lo a large group of same age children. Motor Pass.~ Fat[ Concepts. Pass.~ Fail. E~ar/v sage Pass Fa.il creening Inventory - Revised ('ESI-R[ TI~e ESI-R is a devetopmenta! screenlng for children ages 3-6 years of age. It ~am?les perfo, mance i. n the areas of s?eech, tang, rage, cognition, perception, Pass., ,/ Fail Pass__ Fail.~ Could Not Test Could Not Test,__ Recommendations: [] Your child passed the screening and further evaluation and/or intervention is not warranted. [] Results from this screening indicate that your child's development is currently within normal limits. We recommend a re-screening in months to monitor continued development. We will call you to schedule the screening. [] Your c_}dld did not pass the hearing screening. Plfase contact Barb Kline at 732-8400 ext. 585 to schedule an Audiological EvaluaHon if you have concerns. 13 Your child did not pass the vision s~reening. It is suggested that you call your primary care physician or an eye spedalist for further information about a vision screening or'evaluation. ~ The results of this screening show that further evaluation is indicated. Please fill out the Preschool Referral Form and return it in the envelope provided. Assessment Specialist' (AIqTAL AREA NITEBNEBIATE WET School Pre)grams and Services 55 Miller Street P.O. Box 489 Summerdale. PA 17093-0489 717-732-8400; Fax 717-732-8414 ! 199 o EARLY INTERVENTION REFERRAL FORM Child' · Child's Social Security Number - 75 -/00 7 School District Where Child Lives: 30~.6k ~;d~l~n Parent/Guardian N~e(s): ~a'~L~ 31 p I Street Cft~ -' State Zip Does your child have a Medical Assistance (~1 card? If yes, please list the card n~er: Who should we call .to schedule the Evaluation Appointment? ~(~k~.~ .~_ I(~0~) Has your child been tested by another agency or specialist? Ye~ No ~ If yes, ~ere or ~o? Has your c~i..~d ever been enrolled by another agency or individual for Early Intervention? Yes No ~'If yes, Where or Who? Is the child still enrolled? What intervention service does your child receive? Do you have a caseworker? Yes No ~ If yes, write name and agency. Does your child attend any of the following? Nursery School __.Day Care Center Head Start __~ay Care in a home If you checked any of the above, please tell us where and how often? Name of child's physician: Physician address and/or phone: Name of other physicians who are caring for your child, if any: Where~did, you learn about the CAIU Preschool Program PLEASE TAKE A FEW MINUTES TO PROVIDE US WIT~ T~E FOLLOWING IN~O~/~ATION ABOUT YOUR CHILD ANT) FAMILY. WE WILL REVIEW THIS INFORMATION WIT}{ YOU AND ASK FOR MORE DETAILED INFORMATION AS PART OF THE EVALUATION. 1. Did you have any difficulties: before during~/ after the birth of this child' Yes.. No Check any of the following that apply: Prematurity How early? ~' Past due date ~ ~ow late? Long labor Difficult delivery ... Needed oxygen Jaundice (needed lights) RH incompatibility Adopted (do not k~ow history) Other Please explain: What was your child's birth weight? ~" 2. Did your child need special medical care following birth or during the first few months? Yes No....&-" If yes, please explain: 3. Please check if your child has a history of the following: __ Convulsion/seizures __ Pneumonia ~ Ear infections __ Asthma ~ Tonsillectomy __ Hernia repair ~ Allergies, if checked, what kind? Other, if checked, please explain. Has your Child ever been hospitalized due,to illness or accident~ ~Yes No Does your child have any continuing medical problems or special medical needs? Yes /No If yes, please explain: 5. 6. 7. Does your child currently take any medication? .. Yes ~No If yes, what medication and what dosage? Are you concerned that your child has problems hearing? Yes If yes, has hearing ever been tested? What were the results? 8. Are you worried that your child has problems seeing? Yes /No If yes, has your child ever been seen by an eye doctor? If yes, who and what were the results? 9. Circle the word that best describes your child's health. EXCELLENT ~ FAIR POOR 10. At what age, IN MONTHS, did your child accomplish the following? Sitting ~o7 ~ ~nu~h& Check here if child has not accomplished Crawling ~Jgt~OnJ'4~% Walking ~ 1~ ~on I"h~ Toilet training __i~kJ_~:n~h% 11. Place a check next to those your child has accomplished. Feeds self with help ~ Feeds self without help, uses silverware ~.---- Takes clothes off ~ Helps put clothes on Dresses self with little need for help 12. 13. At that age, If your child Yes IN MONTHS, did your child start to: Use Sentences is t~lking, ca~family members understand most of what she/he says? FAMILY, INFORMATION, Highest level of education: Lives with child? [-- Yes e~t~J~ Higheet level of education: Work phone: g~ .~ {.~No Lives with child~ ~ YeS Please list any brothers and sisters below: N~e ~ex Date of Birth Lives in child's home~ Age: ~ ' ' - /2_ Do other people live in child's home? Please list name and relationship to the child. ~-~c~eo~d L. %loop 3%ep PLEASE COMPLETE THIS CHECKLIST TO HELP US KNOW YOUR CHILD BETTER. Place a check next to any of the following that describe concerns you have about your child's development. - Behavior concerns: tantrums; iS not able to accept limits; resists rules or refuses to follow rules. Emotional concerns: has recently shown a sudden change in personality. Socialization concerns: does not play well with other children; has difficulty separating from parent(s); will not work in a group; is left out of peer group activities. ~Speech/Language concerns: speech is hard to understand; poor language structure or often needs to have directions repeated. Self-help concerns: toileting, feeding, or dressing problems. L'~ttentional concerns: short attention span; changes activities a lot or has a hard time keeping self busy and out of trouble. Developmental delays: does not seem to be learning at an average rate; needs a lot of help to learn new skills or is delayed accomplishing milestones such as walking. Motor concerns: clumsy; poor control of body movement; has trouble with stacking, puzzles, drawing. Hearing concerns= television. __Vision concerns= __ Sensory concerns: COMMENTS asks you to repeat or talk louder; turns up volume on tapes or eyes turn in; eyes turn out, or squints. sensitive to touch, haircuts, loud noises. Rev 8/8/95 :APJTAL AREA ~ERUEDU~TE UNIT -hool Program,s and Services Miller Street, PoO. Box 489 dmmerdale. PA 170930489 7-732-8400; Fa~c 717-732-8414 PERMISSION TO EVALUATE/REEVALUATE Date, ~-//7//~'~ EARLY INTERVENTION Child's' Name~/~'~.S~.~.<. ~L'2~"'~./L-- Date of Birth. /2/~/,~/ Name and Address of Parent, Dear ~ . ~ ~-p , Your child ~as been referred for sn initial evaluation for the followi~ The MAWA agency requests your consent to conduct a Mulitidisciplinary Evaluation (MDE). We must have your written consent before we can begin. As a parent, you are a member of the multidisciplinary team. You are entitled to participate in all meetings concerning this evaluation. During the evaluation process you may also provide written comments. The team will review your child's educational needs and strengths as shown by performance levels, assessment results, observations and information from you, Attached is a list of the specific types of tests and procedures that will be used and a description of each: The evaluation is proposed for the following date(s):. f~lowing The MAWA agency is reason(s): planning a reevalua Jori of your Child for the The MAWA agency requests your cons, must have your written consent before please be aware that after reasonal response, we are permitted by parent, you are a member of th participate in all meetings co ~g this conduct this ~. We reevaluation can However, pts, if we h. received your with ... ation. As a You are entitled to reevaluation process you also nrovia-. During the ~r.e.vi_e~w yo..ur ch. ild's curreo and ;d,,,,~,=.'---,x uy eoucatlonal I:'erf< a"nlevels -..~-="u--'~x?eecl.s. and. stren tbs a ..... JnformatJo ~,,, ........ . , =~rn.en~ r -~.~,- -~ .g. , s shown n,,,,,,, ),u, .o11 in ,~ft~ioenSo~e .... ~, ooserva[io procedures that ,,o~..~ _~j s_a?st o.f .. e specific t es of ns and ,-o=,~ .~,u each:YP tests and The ~luafion is proposed.~r the following date(s):__ · , The mu. ltidisciplinary team will .child s educational nro~ra,-,..,~-, ...,__..prepare recommendation ar ' . - · . .,:- u ,,, .=..u wne[ner your child is eli ible s reg .ding you, be eligible, for special education and related service.~ ~g- -. '-°.r con. bnues to MDE will be contained in a Comprehensive Evaluation Report (CER) and will -. ~le Ilnolngs I'rom the be the basis for developing the IEP. The CER is to be delivered to you within 60 days of receipt of your written consent to evaluate or reevaluate. Please read the enclosed Procedural Safeguards Notice, which includes parent resources such as state or local advocacy organizations. You may contact me if you have any questions or concerns about the evaluation or if you need the services of a translator or an interpreter. Contact PersonL~s,~ ¢, ~ -- ~'"~'~'~'~'~'~Position ~ -73 ~ -~/co _Phone__ DIRECTI,ONS FO.R .PARENTS..- Please check the appropriate item(s), sign eno return this Torm to the person below. [y~] I give consent to begin the proposed !nitial evaluation. [ ] I give consent to begin the proposed reevaluation. [ ] Please contact me. I am not ready to give consent at this time and would like to talk about this. [ ] I do not give consent to the proposed initial evaluation or reevaluation. Please do not begin the process. [ ] ! object to the proposed initial evaluation or reevaluation; however, I would like to schedule: [ ] An Informal meeting [ ] A prehearing conference' [ ] Mediation* [ ] Due Process Hearing' · The enclosed Procedural Safeguards Notice provides information on these options..I have receiv~ed a,copy and I understand the content of the Procedural Safeguards Notice. ~,~.,~. Parent's initials Your family may have strengths and needs which would be helpful to consider as part of the multidisciplinary evaluation in order to enhance the development of your child. Yes, I wish to share such information. ~ ,,~. ~. Parent's initials No, I do not wish to share such information. Parent's initials The CER may in. clude a statement of your family's strenn~h- needs.and services recommended to meet those need~'.= .... and Yes, I give permission for the CER to include such information. ~ .,~. ~. No, I do not wish the CER to include, suc~ information. Parent's initials Pare.hr(s) Signature_/~~~). ~~ Pa~en,', initials MAWA Agency Contact~~_~ ~/~z.?~ "732 -~4/'C"D,,~.~_.~ 732-8400 ext. CAIU Preschool MDE Outcomes and Recommendations £valuator(~): '20 ~ or 1-800-244-2425 ¥I · STREE~THS/~EF.~S strengths and needs: l)ste of .Birth:' C.A.. ~ yrs. ~ =os.. ~on~hs: has demonstrated the follo~'lng ¥II. A. B. The team reco:=ends *ligibility for .early intervention services. It is the recommendation of this team that is not eligible for early intervention services at this time. It is reco=mended that this child continues to be eligible for early intervention services (I£P will be developed). The teem recommends referral to the School District for placement consideration. (See attached The }~DE team recommends the folloving: A. Battelle Developmental ~nventor~ Personal-~ocial (parent response) Adaptive (parent response) Gross ~otor Tine Hotor Receptive ~xpressiv i ion ~ears~ eot in Months Auditory ~o~prehe~sion L~'x~*A~.C~ Verbal Co::unica~ion Arizona Proficienc~ Scele .~PS Score (.o7 s7 aEOTE ..... Test items ~'ere adzinistered according to test standardization require=ants and reflect Your child's responses in this setting on this da)', Test items ~ere unable to be administered accordln~ to test ~a~dardization requirements, Any scores reflect your child's responses this setting on this day and are ~stlmates. D. Other Tests/Observations of Behavior and Play/Coe~ents: Name of Participant Tuscarora Intermediate Unit 11 2527 US Hwy 522 South McVeytown PA 17051-9717 (814) 542-2501 · (717) 899-7143 Early Intervention Individualized Education Child's Name: ~. ' Reevaluation Date: Birthdatc: .,/,~.,/,~//~:f/' Date Plan Developed: Parent/Guardian/Surrogate: ff~~.. ~ Address: /~/~/4~--~/ ~~,~./~ District of Residence: ~~ Eligible to Tr~sition to School: Ye~ Child is Signature (~gnatur~ mai~s att~da~, ROt ~ EI-217a Program Child's SSN or ID4: Home School: .~ _,~_.~ IEP Reviewmevision Date: Relationship to Child Parents have a right to request mediation of a prehearing conference and a right to a due process hearing. More information included in the attached procedural safeguards notice. I have received a copy of and understand the Procedural Safeguards Notice: ~/a Parent's Initials Parent(s) wishes to include family services: Yes _X No ~f-~--~Initial Projected Date Projected Agency Address & of Initiation Duration of Direct Service Family Services Phone No. of Service Service or Referral Exit Criteria: When IEP team determines child is no longer eligible for services. This includes when a child is able to function for a six month period within appropriate developmental and intellectual levels without supplemental aids or services. When the child has reached the age of beginners; when the child's family removes the child from services. White - School District Yellow - Psychologist~Feachnr Pin~ - Patent Goldenrod - IU Office An Equal Rights and Opportunity Educational Service Agency EI-217c EARLY INTERVENTION INDIVIDUALIZED EDUCATION PROGRAM' ¢co,um~,~) Child's Name: ~ Special Considerations the IEP Team Must Address Before Developing the IEP (each question must be answered) A. Is the child blind or visually impaired? ~ NO B. Is the child deaf or hard of hearing? C. Does the child exhibit behaviors that impede his/her learning or that of others? D. Does the child have limited English proficiency? E. Does the child have communication needs? F. Does the child require assistive technology devices and services? YES - Team mu~t provide instruction in Braille and use of Braille Braille/based on the child's current and future reading and writing needs and will be included in the development of the IEP. YES - Team does not need m address the need for Braille/Braille instruction based on the child's current and future reading and writing skills and needs. YES - Team must address the child's language and communication needs, opportunities for direct communication with peers and professionals in the child's language and communication mode, academic level, and full range of needs including opportunities for direct instruction in the child's language and communication mode in the development of the IEP. YES - Team must develop strategies including positive behavior interventions and supports in the IEP. YES - Team must address the language needs of the child in the development of the IEP. YES - Team must address the communication needs of the child in the development of the lEI YES - Team must address the child's assistive technology needs in the development of the IE1- (Any item, piece of equipment or product system, whether acquired commercially off the shelf, modified, or customized, that is used to increase, maintain or improve functional capabilities of a child with a disability.) G. Does the child have any health concerns? H. Does the child need transition to school age services? While - School Districl Yellow - PaychologistfFeacher YES (If YES, team must address intervention strategies needed to support the child's participation in programs and services.) YES - The child is within one year of transition. Team must discuss transition and develop transition goals and objectives. Pink - Parent Goldettrod - IU Office 'EARLY INTERVENTION INDIVIDUALIZED EDUCATION PROGRAM Child's Name: EI-217d Present Levels of Performance Describe the eligible young child's present levels of performance (include functional information on strengths and needs): With parental consent, describe what the family perceives as their strengths and needs as they re~,l~e .to ,the/goals ,of the child. What ar~e thc family's priorities for the child.? ~ , How does the eligible young child's disability affect the child's participation in the general education curriculum and/or appropriate, activities? White - IU Office Yellow - Teacher Pink - Parent Goldenrod - Service Provider/Agency EARLY INTERVENTION INDIVIDUALIZED EDUCATION PROGRAM (continued) Child's Name: ~ EI-217e Benchmarks/Short-term Measprable Objectives (expected level Annual Goal of achievement, evaluation schedule, method of evaluation) White - School District Yellow ~sychologist/Teacher Pink - Parent Date & Result of Review Goldenrod - IU Office 'EARDY INTERVENTION INDIVIDUALIZED EDUCATION PROGRAM Child's Name: _~.~_ ~~"~,~t,/ ~ Measurable Annual Goal Benchmarks/Short-term Objectives (expected level of achievement, evaluation schedule~ method of evaluation) EI-217e Date & Result of Review White - School District Yellow - Psychologist/Teacher Pink - Parent Goldenrod - IU Office " EI-217e EARLY INTER--ON INDIVIDUAg.V'2~n EDUCATION PROGRAM em#fred; Measurnble Annual Goal Benchmarks/Short-Mm ObJectives (expected level of achievement, evaluation schedule? method of evaluation) mmsition inf~m~rlrm with a rcprese~m~ from t~ school disuict 2. Th~ early ~on staff will .~...~ inforrn~rlon and support to th~ child's family as tlmy prepare for trnn~!fion. 3. Th~ early ~fion ~ will · e d~ve.,lopn~nt of aplropriam ~ to assu~ a smooth mmsition for the chilc~ 4. Th~ early in2~mlfion staff and school I~l~trJct will ~ snd comm~nienM regularly ,'hsring th~ transition process. -~, The child will successfi~y transition from early intervention to school-age program. Date & Result of Review EARLY INTERVENTION INDIVIDUALIZED EDUCATION Child's Name: PROGRAM EI.217f Specially-Designed Instruction, Special Adaptations, Strategies (Needed to ad,vance appropriately toward attaining annual goals and to be involved and progress in the general curriculum and/or appropriate activities.) 1. Specially-Designed Instruction How are content, method and materials being modi~ to. meet. the eligible young child's needs? z. Keiateu 'Services - what supportive serviceg'~ are required to assist the eligible young child to benefit from or gain access to special education? (For example, OT, PT, transportation) 3. Supplementary'Aids & Services - What aids, services and supports are required to ensure the eligible young child meaningful participation to the maximum extent appropriate with non-eligible children? 4. Supports What training and/or materials will be provided for program personnel in order to allow the child to participate or progress in the general curriculum or appropriate activities? 5. Least Restrictive Environment - Explain to what extent, if any, the eligible young child will not participate with non-eligible children. 6. Progress Reporting - Explain how the program will report progress toward annual goals to parents and how often. White - School District Yellow - Psychologist/Teacher Pink - Parent Goldenrod - IU Office Tuscarora Intermediate Unit 11 2527 US HR 522 Sout~ McVeytown PA 17051-9717 (814) 542-2501 · (717) 899-7143 EI-218a EARLY INTERVENTION NOTICE OF RECOMMENDED ASSIGNMENT Child's Name: ' ' Date: __~__~__~__~ This notice describes recommendations or proposed changes regarding your child's educational program as a result of the recent Individualized Education Program (IEP) meeting or your request. The assignment recommended for your child is: ~__ This assignment was recommended after a review of the attached options, which were used to assist in identifying the services that will meet your child's needs. 1. I~ Your child should begin to receive early intervention services. The MAWA agency will not proceed without your approval of this recommendation (the IEP is attached). 2. D 4. D Your child's early intervention placement or services should be changed as noted in the IEP. The MAWA agency will proceed with this change unless you notify us, within 10 days, of your written disapproval (the IEP is attached). Your child is no longer in need of early intervention services because he/she has met exit criteria. We recommend current early intervention services be discontinued. The MAWA agency will proceed with this change unless you notify us, within 10 days, of your written disapproval. All early intervention services provided by the MAWA agency will be discontinued by the beginning of the coming school term. Education services will become the responsibility of the school district. You will be provided assistance with this transition. 5. [] 6. [] Your child is not eligible to receive early intervention services. The MAWA agency is refusing your request to initiate or change your child's: [] Identification [] Evaluation [] Educational Placement [] Provision of a Free Appropriate Public Education The reason and basis for this refusal are: MAWA Agency{,~h~ef Executive Officer Signature White - School District ~ Yellow - Psychologist/Teacher Ping - Parent An Equal Ri§hts and O;3portuni',? Educational Service Agency,, Date Goldemod - [U Office EARLY INTERVENTION NOTICE OF RECOMMENDED ASSIGNMENT EI-218b You have certain rights which are described in the attached Procedural Safeguards Notice. Please carefully read the information. If you need more information, you may contact: -// Nan~ / Position Date Directions for Parents: Please check one of the options below, sign this form, and return it within 10 days to the person listed above. .~' I approve this recommendation [] I do not approve this recommendation My reason for disapproval is: I request: [] A Prehearing Conference* [] Mediation* [] Due Process Hearing* *The attached Procedural Safeguards Notice provides information on these options. received a copy and I understand the content of the Procedural Safeguards Notice. I have Parent's Initials Parent's Signature Date Daytime Phone White - School District Yellow - Psychologist/Teacher Pink - Parent Goldenrod - IU Office Tuscarora Intermediate Unit 11 2527 US Hwy 522 South McVeytown PA 17051-9717 (814) 542-2501 · (717) 899-7143 OPTIONS CONSIDERED (Early Intervention) EI-218c Child's Name: ~--~~ The following options were considered in descending order when recommending placement for your child, except for the alternative relating to services and programs provided in the home. Services in the home may be the least restrictive early intervention program for an eligible young child. · Regular preschool program or class for the entire program day with supportive intervention. · Regular preschool program or class for all or most of the program day with supplemental intervention. · Specialized setting for most or all of the program day, with non-eligible young children. · Specialized setting for part of the day, with some programming provided in the regular preschool program or class and opportunities for participation with non-eligible young children in play or other activities. · Services and programs provided in the home, including services which are provided in conjunction with services provided in another setting. · Specialized setting, including the following: approved private school residential school or facility approved out-of-state program Reasons for the recommendations (include evaluation procedures, reports and other factors used in making the recommendations): ~t[ Refer to most recent CER for specific details. [] Other Reasons why the above recommendation is appropriate and why it represents the least restrictive environment in which your child's needs can be met: 1~. The rEP can best be implemented in this setting. [] Other Reasons why the options that were considered, but not recommended, are inappropriate or do not represent the least restrictive environment in which your child's needs can be met: ~ Other options provide more extensive or restrictive services as indicated on the needs listed on the CER. [] Other Goldenrod - Fa' Office White - School District Yellow - PsychologistYTeacher Pink - Parent Tuscarora Intermediate Unit 11 · 2527 US Hwy 522 South McVeytown PA 17051-9717 (814) 542-2501 · (717) 899-7143 INVITATION TO PARTICIPATE IN THE IEP TEAM MEETING Child's Name: El-Z16a Date: __n~_~__~__ (Nan~ of Parent) (Address of Parent) (Address of Parent) We would like you to participate in an individualized education program team meeting. The purpose of this meeting is to: (The MAWA Agency is to check all that apply) [e''/ Discuss the results and recommendations of the multidisciplinary evaluation and make a determination if your child is in need of special education. If it is determined that your child is eligible, an Individualized Education Program (IEP) will be developed at the meeting. Discuss your child's current IEP to review and revise it as needed. Develop and/or review a statement of your child's need for transition services. We are also inviting representative(s) from the following agency or agencies to attend: The team meeting has been scheduled for this location: ~~ ~/ ~ at the following date and time: ~0">/~-~/~'~ ~ ~'~-'~-~.~a.-~7 ~ If this time, date or location axe not convenient, please contact me as soon as possible so we can arrange a time and place which are mutually convenient. // / Name &/rifle ' - Phone Number ' l~ate The following people are expected to attend the meeting for your child: NAIVIE _//~,~'~/_/~)'9 ,,~ ROLE* NAIVIE ~'~? )~ ~- ~'qJZ~/,"2~'- - ',J~ ROLE* ,,'",,"2, ROLE* NAME ROLE* NAME White - IU Office ROLE* Yellow - Psychologist/Teacher Pink - Parent Goldenrod - Service Provider/Agency INVITATION TO PARTICIPATE IN THE IEP TEAM MEETING EI-216b *This denotes this person's involvement in your child's IEP development. 'Examples: regular education teacher, local education agency representative, etc. If you would' like additional personnel from the MAWA Agency to attend this team meeting, or if you have any questions or comments, please contact me. Further, please be advised that you may bring other people to the meeting who have knowledge or special expertise regarding your child. Attached to this invitation is a copy of the "Procedural Safeguards Notice" describing your rights and procedural safeguards under State and Federal Law. We are requesting that you respond to this invitation by checking the appropriate option below, and returning this form to thc school district (by mail or in person) as soon as possible. will attend the IEP meeting as scheduled.' I wil not attend the IEP meeting. I wish to attend an IEP meeting, but this time and/or location is not convenient. Please contact me to make alternative arrangements. Parent Signature Date White - Utl Office Yellow - Psychologist/Teacher Pink - Parent Goldenrod - Service Provider/Agency CAPITAL AREA INTERMEDIATE UNiT Servln.q School Districts in Dauphin~ Cumberland~ Perry~ and Northern York Counties School Programs and Services · 55 Miller Slreel · P.O. Box 489 · Summerdale, PA 17093-0489 Phone 717-732-8400; Fax 717-732-8414; TDD 717-732-8422 COMPREHENSIVE EVALUATION REPORT INITIAL EVALUATION REEVALUATION DATE:Signature of Parental Permission to Evaluate: DATE:Notification of Reevalualion Senl: DATE:CER: CHILD'S NAME: CHILD'S ADDRESS: TELEPHONE #: PARENT(S) NAME: DOB: STUDENT #: SCHOOL DISTRICT: Christian Ronk 58 Mountain Street Mt. Holly Springs, Pa. 17065 486-0082 Rayette Sloop 12/21/94 163-75-1007 South Middletown REASON FOR REFERRAl: 5/4/99 5/4/99 INTERMEDIATE UNIT STAFF IN CHARGE OF COORDINATING THIS REPORT: Lisa Brittingham Christian, age 4 years, 5 months, was referred to the CAIU Preschool Program Io determine eligibility for Early Intervention services under Depadment of Education Guidelines. Primary concerns are his expressive language and his articulation skills. II. HISTORY: Early Intervention History: Christian has nol received early inlervention services. .Educational, Social and Physical History: Christian was accompanied to the evaluation by his mother, Rayette Sloop, who provided the medical and developmental informalion repoded here. Also in altendance were his slepfalher and his sister. Prenatal History: Bidh History: Medical History: Family History: Vision: Hearing: No concerns noted. No concerns noted. No concerns noted. Christian's molher had remedial math and remedial reading in school. No concerns noted. No concerns noted. Developmental History: °An Equal Opportunity Employer · Christian Ronk Comprehensive Evaluation Repod Page: 2 DOE: 5/4/99 II1. IV. Molor: Self Help: Communication: Peer Interaction: Play: Self Regulation/Behavior: Learning Related to Peers: Primary Medical Provider: Daycare/Nursery School: Motor mileslones occurred at typical times. No concerns were holed with his motor skills. No concerns noted. Speech milestones are significantly delayed. Christian began lo use words at 3 years of age. He does not yet speak in sentences. Christian's mother has been concerned about his speech since he was 3 years old. She described his speech development as very slow. Mrs. Sloop is concerned about Christian's peer inleractions, since he has limited oppodunity to play with other children. No concerns noted. No concerns noted. Mrs. Sloop was not sure if Christian was learning like his peers. No primary provider Christian does not attend any nursery school. INFORMATION FROM THE FAMILY (Parents or other persons with whom the child lives): A. Child's strenqths and needs includinq physical condition, cultural and lanquaqe considerations and adaptive behavior. English is spoken in lhe home and there were no stated cultural considerations. Christian's slrengths are his ability to say some words clearly, to point to communicate, to take others to what he wants and Io make noises in his play. His need is his pronunciation skills and to put words together in sentences. At the family's discretion, the family's perceived strenqths and needs which will enhance the development of the child. Mrs. Sloop did not padicipate in the CAIU Family Needs Survey. SUMMARY OF FINDINGS: A. Screeninq Results: Co Christian was screened on 2/23/99 using the Early Screeninq Inventory-Revised and the Fluhady Preschool Speech and Lanquaqe Screeninq Test. He failed the ESI-R and failed the identification and articulation sublests on the Fluhadv. Areas of concern included his expressive language, vocabulary, lenglh of utterance and adiculation. Chrislian was referred for fudher lesting. For reevaluation, include review of current IEP: Not applicable. Developmental Assessment: 1 .Test Results: Date 5/4/99 Evaluation Tools/Procedures Preschool Lanquaqe Scale-3 (PLS-3): The PLS-3 is adminislered !o obtain information aboul a child's overall language functioning in lwo areas: Auditory Comprehension and Expressive Communicalion. Audilory Comprehension refers Io lhe child's ability to understand spoken language and Expressive Communication refers to lhe abilily Io use spoken language. - Lisa Brittingham, CCC-SLP 5/4/99 Arizona Adiculation Proficiency Scale (AAPS): The AAPS was designed to provide a measure of adiculalory proficiency in children aged 1 1/2 through an Ronk .,prehensive Evalualion Repod Page: 3 DOE: 5/4/99 514199 514199 5199 2/23/99 2/23/99 13 years. The A, APS provides informalion on the child's level of correcl articulation, level of inlelligibility and developmental age of articulatory proficiency. Lisa Briltingham, CCC-SLP _Oral Motor Exam_: The structure and function of the articulators are examined to delermine strenglh and range of molion of Ihe Iongue, lips, jaw, cheeks and velum. The ability Io coordinate oral and speech movements is also examined. Feeding and swallowing issues may also be explored. - Lisa Britlingham, CCC-SLP ~: A sample of the child's speech and language is collecled to assess overall skills including: grammar and synlax, lenglh of utterance, vocabu an/, intelligibility, pragmatic skills (including initiating conversation and maintaining conversation, eye conlact, approprialeness of conversation, etc.) and range ot communicalive intents (e.g. expressing wants and needs, commenting, asking questions, etc.). This is done in as naturalislic a setting as possible and in a range of settings where possible. - Lisa Briltingham, CCC-SLP _Review of evaluation results bva psycholoqisl: A CAIU psychologist reviews evalualion results and recommendalions in order to help determine if there is a need for fudher evaluation and Io verify lhal lhe child's eligibility for early intervenlion has been appropriately determined. The psychologist reviewing the evaluation information will sign the signature page. F~luharty Preschool Speech and Lanquaqe Screeninq Test: The purpose of this screening lesi is Io elicil responses from lhis preschool child lhat indicale his or her vocabulary, adiculal on, and receplive and expressive language performance. Carol Sharp .Early Screeninq Inventory-Revised (ESI-R): The E__Si-R is a developmental screening for children ages 3-6 years of age. I! samples performance in the areas of speech, language, cogn lion, perceplion, gross and fine motor coordination. Carol Sharp AAPS-2 CA: 4 years, 5 monlhs Based on standardized tests a 25% delay would be an age equivalenl score of 3 years, 4 monlhs. Test items were administered according 1o lest slandardizalion requirements and reflecl your child's responses in this selling on this day. ?LS-3: Domain: Audilory Comprehension Expressive Communication 4 years, 2 months 2 years, 6 months Slandard Score 37 Standard Score: 98 67 2.Narrative includin but not limited to h sicaldevelo merit co nitive and sensor develo men! hearin roblems learnin stren tbs and educational needs lan ua e and s each develo ment social and emotional develo ment self-hal skills health Lea___rninq Skill~ss Domain Allending Skills: Christian was able 1o sit and allend Io lhe lesling with no difficulty. Christian Ronk Comprehensive Evaluation Repod Page: 4 DOE: 5/4/99 Follow Directions: Eye Conlact: Need for Cues/Types of Cues: Interesl in Test Activities: Motor Domain Gross Molor Skills: Fine Molor Skills: Visual Molor Skills: Sensorimotor Processing: Communication Domair~ Language Comprehension: Language Expression: Adiculation: Christian followed a variely of 1-2-step directions. Age appropriale. Christian did not appear Io need any extra cueing in order to understand the language used with him today. Age appropriale. Not formally assessed Gross motor skills found to be age appropriate on his original screening. Not formally assessed. Fine motor skills found 1o be age appropriate on his original screening. No concerns noted. No concerns noted. Comprehension of language is age appropriate. Christian passed all of the items given at his age level on the PLS-3 and ~,4 of the items given at lhe 4 years, 6 month to 4 years, 11 month level. He appeared to understand all of the language used with him today. Language expression is significantly delayed. Chrislian achieved a standard score of 67 with an age equivalent of 2 years, 6 months on the PLS-3. An average standard score on this test ranges between 85 and 115. Strengths and weaknesses found on lhe PLS- 3 were: STRENGTHS NEEDS Answers When questions Completes analogies Tells functions of objects uses plurals uses verb + produces basic sentences Analysis of a language sample revealed that Christian spoke in 1-4-word utterances. Mean length of ulterance in words was 2.08. A typical mean length of utterance for a 4-V2 year old ranges between 4 Io 5 words. A grammatical analysis of Christian's speech was unable to be done due to his poor speech intelligibility. It was holed lhat Christian demonstraled a very limiled expressive vocabulary and lhe majority of his understandable speech consisted of nouns, some verbs and Ihe word "no". Christian often used noises, pointing and some gestures Io communicate rather than words. His mother repoded that they do hear words "out of the blue" and that Christian gets fruslrated when others do not understand him. Christian is demonstraling a moderate to severe delay in his articulation. Administration of the AAPS-2 revealed the following errors: INITIAL FINAL p/f omission/m I/i (y) Ill w/I omission/n pw/pl omission/g an Ronk ,~prehensive Evaluation Report Page: 5 DOE: 514199 b/v omission/ng d/voiced Ih omission/Id d (j)/voiceless th t/ch ch/sh L/voiceless th w/z t/sh t/s omission/z t/st t/s k/st omission/ts k/ks Many of Christian's productions were repetitions, as he did nol know the words to say. He did know some of the vocabulary on the test and he would occasionally say an associated word, for example, "eal" for the word "cake". Oral Motor Skills: Pragmatics: Errors increased in spontaneous speech, Overall intelligibility of speech was significantly reduced. Many produclions of sounds that Christian was able to repeal or to say spontaneously deteriorated when he attempted to speak in a longer utterance. Christian was stimulable to correct some sounds in isolation. Christian was able to imitate various oral motor movements as long as no sound needed to be imitated. Oral motor movements appeared to be adequate for speech production. Christian was able lo initiate and maintain a conversation. Coqnitive Domain Play Level: Verbal Problem Solving: Concept Development: Memory: Christian demonstrated good pretend play during this evaluation. Christian's poor speech intelligibility impacted on his ability to answer questions. Comprehension of language concepts appears age appropriate. Christian was able to repeat 2 digits on his original screening. Social-Emotional Domain Interactions with People: Interaclions with Objects: Interactions with Environment: Adaptability: Age appropriate. Age appropriate, Age appropriate. Christian adapted to the testing environment with no difficulty. 3.Information from other evaluations: No other evaluations were used to write this repod. Do Observations (Information from Observations durinq daily activities such as play with other children and interaction with family members and/or other adults): Christian was observed in this setting only. Area of Delay: Christian Ronk Page: 6 Comprehensive Evaluation Repod DOE: 5/4/99 Fo Christian is exhibiting a delay in his articulation and expressive language. .Skills needed by the child to function successfully in a variety of settin~s, including the home~ school, and community: ' ' - STRENGTHS: Receptive language Fine/gross motor skills Play skills Cooperation Attention Oral motor skills Stimulable to correct sounds NEEDS: Adiculation Overall speech intelligibilily Expressive language Putting together sentences Vocabulary (expressive) RECOMMENDATIONS: A. Recommendations of Eliqibility for El Services and Proqrams: 1. X Team recommends eligibility for early intervention services. 2. [] It is the recommendation of Ibis learn that Ihis child is not eligible for early intervention services at this time. 3. [] It is recommended that this child continue to be eligible for early intervention se~'ices (IEP will be day eloped). 4. [] Team recommends referral to school districl for placement consideration (see attached IEP). 5. X The MDE team recommends the following: It is recommended that Christian qualifies for Early Intervention services according to Stale slandards and regulations in the areas of speech and language. .Recommended Services to meet the family's need~: No services were needed at this time. cc: Keyslone Legal Services, Inc., Douglas Hearn .,an Ronk ,nprehensive Evalualion Repod Page: 7 DOE: 5/4/g9 MULTIDISCIPLINARY EVALUATION TEAM SIGNATURES (Please indicate your agreement or disagreement with lhe conclusion or conlent of this repot1. If you disagree, please wrile the reasons for disagreement and attach them to this report.) .,n SIG NATI, zfI::I E TITLE DATE AGREE DISAGREE / Parent' .~ ' ' · This repod is a drafl unlil aI. JI MDT members (including parents) have reviewed and signed the repod. Any dissenling opinions must be included. Dissenling opinions must be relurned within 5 days of receiving this repod. MDE conferences must include parenls unless parents decline padicipalion. · p · arenls wdl receive a copy of the final repod along with a summary of its conlents. _T..im eline sj (date CER sent to parenl) MDE or reevaluation compleled within 45 calendar days upon receiving parental permission Ior initial or reevaluation. CER or reevaluation report shall be completed 10 calendar days alter completion o~ the MDE. Wilhln 5 calendar days after its completion and al least 10 school days prior to the IEP meeting, typewritten copies of the evaluation or reevalualion report shall be delivered to the MAWA agency end Io the parent. CAPITAL AREA INTEP~ ED{AlrE UNI'r School Programs and Sewlces 55 Miller Street, P.O, Box 489 Summerdale, PA 17093-0489 717-732-8400; Fax: 717-732-8414 Screening Report Oateo,fBirth: /z../~-,Iq~ , , . Oateo£Screening: P,~",nt s Na~ne: ~ /Z~,~. ~.(.~ Chronological Age, Reason for Reread: Tes~dm~steredd Bri~_ance Preschool Screen for 3 and 4 Year Old Childrenor Kindergarten and First Grad. {Brigance): The Brlgance is adminlstered to obtain informah'on about a child's overall devel~mentai skills. Area. d tested on the 3 and 4 Year old forms include language skills, motor skills, body awareness, visual discriminaffon abilib,d and general reasoning skills. Areas tested on the K and & 1 forms include langwage skills, gross motor skills, ~ne and tdsual molor skills, and concept knowledge. Score: Pass Fa:fi__ Fluhart¥ Preschool Speech and Langua£e Screening Test The purpose of this screening test is to elicit responses from this preschool child that indicate his ~r her vocabulary, articulation, and receptive and expressive language performance Identification Pass Fail Articulation Pass Fail -- Comprehension Pass ~ Fail-- Repetition Pass Fail [] D~evelopmental Indicators.For the Assessment of Learning (D]AL-R~ The DIAL-R is admlnlst~re8 to assess a child's general motoric skills, conce~t awareness and language alHlity. It provides an overview of skills in comparison to a large group o]same age children. Motor Pass FaJ_t__ Concepts. Pass Fail sage Pass Fall creening Inventorg - Revised (ESI-R~ 3he ESI-R is a developmental screeMng for children ages 3-6 years o/age. It sam?les per/o,t~ance i. n the areas of speech, language, coguiHon, perception, gross and J~ne motor coardinaHon. Pass~ Pass_ ~/' Fail., Vision Scre~in : Pass_ Fail Could Not Test, .Comments: Recommendations: Your child passed the screening and further evaluation and/or intervention is not warranted. Results from this screening indicate that your child's development is currently within normal limits. We recommend a re-screening in_ months to monitor continued development. We will call you to schedule the screening. Your child did not pass the hearing screening. Pl6ase contact Barb Kline at 732-8400 ext. 585 to schedule an Audiological Evaluation if you have concerns. Your child did not pass the ~islon c~reening. It is suggested that you call your primary care physician or an eye specialist for further information about a vision screening or ~valuation. The results of this screening show that further evaluation is indicated. Please fill out the Preschool Referral Form and return it in the envelope provided. Assessment Specialist/ CAPITAL AREA ki~i~NEB, IA'rl IIII!! School Programs and Services 55 Miller Street PO, Sox 489 Summerdale. PA 17093-0489 717-732-8400; Fax 717-732-8414 MAR EARLY INTERVENTION REFERRAL FO~ Parent/Guardian Name(s): ~'~O.~I~(~L-/i~.~ StOOp Child's Address: ,Z~'~ ~K~aun~{/'n 5'~J"~.'l~ Child's Social Security Number l[,l~3 - 75 -I00 1 School District Where Child Lives: ~O~6~ ~]~dcJlcbn /o2- / - ?q C i't ~/ -' State Zip Does your child have a Medical Assistance (~) card? If yes, please list the card n~er: Who should we call to schedule the Evaluation Appointment? ~(~\%~.~f~ %loop Wher~an we call this person between 8:30 ~ and 4:00 PM Monday - Friday? WHY ~ YOU REFERRING THIS CHILD FOR ~ALUATION' ~U'in~ Ha~ your child been tested by another agency or ~pectalist? Ye~ No ~ I[ yes, ~ere or ~o? ,, Has your c~i.~d ever been enrolled by another agency or individual for Early Intervention? Yes No ~If yes, where or Who? Is the child still enrolled? What intervention service does your child receive? ~ Do you have a caseworker? Yes No -- If yes, write name and agency. Does your child attend any of the following? Nursery School , Day Care Center Head Start Day Care in a home If you checked any of the above, please tell us where and how often? Name of child's physician: ~O~9 Physician address and/or phone: --~ Name of other physicians who are caring for your child, if any: where, did, you learn about the CAIU Preschool Program I PLEASE TAKE A FEW MINUTES TO PROVIDE US WITH THE FOLLOWING INFORMATION ABOUT YOUR CHILD AND FAMILY. WE WILL REVIEW THIS INFORMATION WITH YOU AND ASK FOR MORE DETAILED INFORMATION AS PART OF THE EVALUATION. 1. Did you have any difficulties: before during~/ after the birth of this child? Yes No Check any of the following that apply~ Prematurity __ How early? ~" Past due date ~L~ ~ow late? Long labor Difficult delivery Needed oxygen Jaundice (needed lights) RH incompatibility Adopted (do not know history) Other Please explain: What was your child's birth weight? ~" Did your child need special medical care following birth or during the first few months? Yes__ No ~ If yes, please explain: 3. Please check if your child has a history of the following: __ Convulsion/seizures __ Pneumonia __ Ear infections __ Asthma __ Tonsillectomy __ Hernia repair Allergies, if checked, what kind? Other, if checked, please explain. 4. Has your child ever been hospitalized due,to illness or accident? ~Yes If yes, explain ~ ~'x~{~ Dad ~'~%u~c~d ~ C¼~cco~l ira ~o~l~' ~ 5. Does your child have any continuing medical problems or ~pecial medical needs? __Yes /No If yes, please explain: __No 6. Does your child currently take any medication? Yes ~No If yes, what medication and what dosage? 7. Are you concerned that your child has problems hearing? Yes ~/No If yes, has hearing ever been tested? What were the results? Are you worried that your child has problems seeing? __ Yes /No If yes, has your child ever been seen by an eye doctor? If yes, who and what were the results? 10. 11. Circle the word that best describes your child's health. EXCELLENT ~ FAIR POOR At what age, IN MONTHS, did your child accomplish the following? Sitting ~o~nu~}h& Check here if child has not accomplished Crawling IO,~Oa H~\ Toilet training l~ ~on~ Place a check next to those your child has accomplished. Feeds self with help Feeds sel£ without help, uses silverware Takes clothes off Helps put clothes on Dresses self with little need for help 12. 13. At that age, IN MONTHS, did your child start to: - ~ Use words >~7~,~~ L--'- Phrases / ' - / Sentences ~ . .~----~h~ld doesn't talk If your child is ~alking, can f~ily m~ers undmrst~d most of what Yes ~No F~ILY I~O~TIO~ Age: . ~q ' ,ighest level of education I~ Age: ~ ~e: _ : H~ghest level of education: Work phone: ~q. Please li~t any brothers and ~i~ter~ below: N~e Sex Date o~ Birth Lives i~ child'~ home~ Do other people live in child's home? Please list name and relationship to the child. PLEASE COMPLETE THIS CHECKLIST TO HELP US KNOW YOUR CHILD BETTER. PJace a check next ~o any of the following that describe concerns you have about your child's development. Behavior concerns: tantrums; iS not able to accept limits; resists rules or refuses to follow rules. ~ Emotional concerns: has recently shown a sudden change in personality. ~ Socialization concerns: does not play well with other children; has difficulty separating from parent(s); will not work in a group; is left out of peer group activities. ~Speech/Language concerns: speech is hard to understand; poor language structure or often needs to have directions repeated. ~ Self-help concerns: toileting, feeding, or dressing problems. ~"~ttentional concerns: short attention span; changes activities a lot or ha~ a hard time keeping self busy and out of trouble. Developmental delays: does not seem to be learning at an average rate; nc~eds a lot of help to learn new skills or is delayed accomplishing milestones such as walking. Motor concerns: clumsy; poor control of body movement; has trouble with stacking, puzzles, drawing. Hearing concerns: television. ~ Vision concerns: Sensory concerns: CO~{ENTS: asks you to repeat or talk louder; turns up volume on tapes or eyes turn in; eyes turn out, or squints. sensitive to touch, haircuts, loud noises. Rev 8/8/95 AIU :APJTAL AREA ~EPJ, IED[ATE UNIT 'hool Programs and Services Miller Street, P.O. Box 489 ummerdale, PA 170930489 7-732-8400; Fax: 717-732-8414 PERMISSION TO EVALUATE/REEVALUATE EARLY INTERVENTION Date ~-./~7//~ Child's Name. Name and Dear ~-'P~/'TL'/L' Date of Birth /2//~ Address of Parent ¢ .Your child has been referred for an Initial evaluation for the following reason(s): The MAWA agency requests your consent to conduct a Mulitidisciplinary Evaluation (MDE). We must have your written consent before we can begin. As a parent, you are a member of the multidisciplinary team. You are entitled to participate in all meetings concerning this evaluation. During the evaluation process you may also provide written comments. The team will review your child's educational needs and strengths as shown by performance levels, assessment results, observations and information from you. Attached is a list of the specific types of tests and procedures that will be used and a description of each: The evaluation is proposed for the follo~ing date(s):. The MAWA agency is planning a reevalua ion of your child for the f~llowing reason(s): The MAWA agency requests your conser conduct this ree must have your written consent before reevaluation can please be aware that after reasona; if we response, we are permitted by Iai proceed with the parent, you are a member of' sciplinary tea participate in all meetings co g this reevalu reevaluation process you also provide writt review your child's curre by educational information from procedures that 3. We lin. However, received your ation. As a You are entitled to During the -=hts. The team will and educationa and strengths, as shown levels, assessm results, observations and ~g is a list ofspecific types of tests and used and a desci of each: The uation is proposed~r the following date(s):_ The multidJsciplinary team wiJJ prepare recommendations regarding your child's educational program and whether your child is eligible, or continues to be eligible, for special education and related services. The findings from the MDE will be contained in a Comprehensive Evaluation Report (CER) and will be the basis for developing the IEP. The CER is to be delivered to you within 60 days of receipt of your written consent to evaluate or reevaluate. Please read the enclosed Procedural Safeguards Notice, which includes parent resources such as state or local advocacy organizations. You may contact me if you have any questions or concerns about the evaluation or if you need the services of a translator or an interpreter. Contact Pers°n.l'~ z~'~'~'~':Pos~tion ~ c ~-. -7~ -~lco /~vc.. ' Phone DIRECTIONS FOR PARENTS: Please check the appropriate item(s), sign and return this form to the person below. [y~'] I give consent to begin the proposed !nitial evaluation. [ ] I give consent to begin the proposed reevaluation. [ ] Please contact me. I am not ready to give consent at this time and would like to talk about this· [ ] I do not give consent to the proposed initial evaluation or reevaluation. Please do not begin the process. [ ] I object to the proposed initial evaluation or reevaluation; however, I would like to schedule: [ ] An informal meeting [ ] A preheating conference* [ ] Mediation' [ ] Due Process Hearing' · The enclosed Procedural Safeguards Notice provides information on these options..I have receiv~e~l a~opy and ! understand the content of the Procedural Safeguards Notice.. ~. ~. Parent's initials Your family may have strengths and needs which would be helpful to consider as part of the multidisciplinary evaluation in order to enhance the development of your child. Yes, I wish to share such information. _~ ,~. ~. Parent's initials No, I do not wish to share such information. Parent's initials The CER may Include a statement of your family's strengths and needs and services recommended to meet those needs. Yes, I give permission for the CER to include such information. · Parent's initials No, I do not wish the CER to include such information. Parent(s) Signature_/"/~.<~_.~),_~). ~._~ Pa-rent's initials MAWA Agency Contact:_'~/')f~ ~, CAIU Preschool MDE Outcomes and Recommendations Date of Birth: 732-8400 ext. -20 ~.. or 1-800-244-2425 C.A.: Z/ )'rs. Months: Svaluatoris): has demonstrated the following strengths and needs: VlI. A. B. REOO.-~fE,-.h'D^TIO.~ OF ELI6IBILITY The teas reco:~ends eligibility for early intervention services. It is the recommendation of this team that is not elilible for early intervention services at this time. It is recommended that this child continues to be eligible for early intervention services (I£P ~111 be developed). The team recommends referral to the School District for placement consideration. {See sttached I£P.} The I~DE team recommends the following: EESULTS: Battelle Developmemtal Inventory Personal-Social /parent response) Adaptive (parent response) Gross Motor Fine Hotor ~ecFptive [omou rears, ~eonth$ months nt ia Hontbs Verbal ¢om:unicet ion C. Arizona Proficiency Scale Age Equi%'alent or SS .L~PS Score ~;OTE . ..... Test items ~'ere administered according to test standardization require:ents and reflect Tour child's responses in this setting on this day. Test items ~ere unable to be administered accordtn~ to test standardization requirements. Any scores reflect your child's responses ~n this settin~ on this day and are ~stimates. D. Other Tests/Observations of Behavior and Play/Co.ants: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CHADD E. RONK V. RAYETTE I. RONK 1 : IN THE COURT OF COMMON PLEAS : 41ST JUDICIAL DISTRICT : OF PENNSYLVANIA : JUNIATA COUNTY BRANCH : NO. 436 OF 1997 TRANSCRIPT OF PROCEEDINGS CUSTODY HEARING BEFORE: DATE: PLACE: C. JOSEPH REHKAMP., JUDGE SEPTEMBER 28, 1998 JUNIATA COUNTY COURTHOUSE MIFFLINTOWN, PENNSYLVANIA APPEARANCES: BARRON&ZIMMERMAN BY: DAVID BARRON, ESQUIRE FOR - CHADD RONK KEYSTONE LEGAL SERVICES BY: DOUGLAS HEARN, ESQUIRE FOR - RAYETTE RONK VERONICA RHEAM (717) 582-7109 OERI'IFI'ED ORiGILI A! 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 JERRY E. BOYER BY: MR. BARRON BY: MR. HEARN CHADD RONK BY: MR. BARRON BY: MR. HEARN RAYETTE RONK BY: MR. HEARN BY: MR. BARRON PLAINTIFFS: No. 1 Document INDEX TO WITNESSES DIRECT CROSS REDIRECT RECROSS 12 17 -- 22 -- 21 -- INDEX TO EXHIBITS PRODUCED & MARKED ADMITTED 4 -- 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. BARRON: If I may, Your Honor, we're here before you on Civil Action No. 436 of 1997 Chadd E. Ronk versus Rayette I. Ronk. And by order dated July 30 by this court it was ordered and directed that we have a supplemental hearing regarding the parties two minor children, Christian and Josie. Josie is almost four years old and Josie will be -- excuse me, Christian is almost four years old and Josie will be almost two years old coming this December. Both were born in December. With stipulation and agreement by opposing counsel, who is here also today, Mr. Jerry Boyer prepared an evaluation that was, I believe, submitted to the court also. It's the evaluation of the parties, Mr. Sloop and the two minor children, and it's dated July 20 of 1998. We would ask that that be admitted into evidence. Of course, there will be brief testimony from Mr. Boyer and brief testimony from Mr. Ronk. THE COURT: I don't have it with me. If it was reviewed by me back then, it may have been. MR. BARRON: I don't have an extra copy. Do you have an extra copy? With that in mind, I don't know if opposing counsel has any preliminary. But with that in mind, I would call Mr. Boyer to the stand. MR. HEARN: Nothing preliminarily. MR. BARRON: Mr. Boyer, please take the stand. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Plaintiff's Exhibit No. 1 was produced and marked for identification.) DIRECT EXAMINATION BY MR. BARRON: Q Mr. Boyer, please state your name for the record. A Jerry E. Boyer. Q And your business address, please. A I'm a psychologist. I have a private practice at 223 East Third Street, Lewistown, Pennsylvania. Q How long have you been a psychologist? A Been working as a psychologist since 1967. I've been licensed for private practice since 1978. I've been a member of the medical staff at Lewistown Hospital since 1985. Q You've been licensed in the State of Pennsylvania? A That's correct. MR. BARRON: I would offer him as an expert in psychology at this point. MR. HEARN: MR. BARRON: BY MR. BARRON: Q 20, 1998. No objection. Thank you. Mr. Boyer, you prepared an evaluation dated July Is that correct? 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A That's correct. Q And is that dealing with Chadd and Rayette Ronk and their children? That's correct. I would offer -- can you tell me what this is, A please? A That's a copy of the report that I forwarded to Judge Rehkamp. Q correct? A And this is the exhibit marked Pl. Is that That's correct. MR. BARRON: I'd like to admit this into evidence if that's okay. MR. HEARN: MR. BARRON: Honor? No objection. May I approach the bench, Your THE COURT: Yes. BY MR. BARRON: Q Mr. Boyer, can you sum up your conclusions and recommendations regarding your evaluation? A Certainly. I spent eleven and a half hours in face to face contact with Mrs. Ronk, Mr. Ronk and Mr. Sloop. The evaluation consisted of personal interviews and psychological testing. As a result of that process, I arrived at the following conclusions and made the following 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 recommendations. At the time that I felt that the evidence was in favor of Mrs. Ronk having primary physical custody of the children when Mr. Ronk returned to full-time employment. At that time, Mr. Ronk was unemployed, receiving unemployment compensation and had not yet returned to work. For that period of time that he was unemployed, I recommended that they share custody with the time spent with each parent being approximately equal with the children. There was nothing in the profile of either of the three adults that would preclude them from being adequate parents. Of the two natural parents, Mr. Ronk is certainly the more emotionally stable, the more mature and is all together a decent hard working man. However, the nature of his job, and I understand that he has changed jobs since then, but, at the time, it was the nature of his job and his need to rely on other caregivers that made it very difficult for me to recommend that he be the primary custodial parent simply because of time factors. At the same time I felt that if Mrs. Ronk did not follow through with her promise to be a full-time stay at home mother, that that recommendation should be reconsidered. While Mrs. Ronk certainly has some underlying characterological traits that are worrisome, I 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 was giving her the benefit of the doubt in chalking up some of those problems that she's had to the history and some problems with impulse control to family and situational factors. I felt that her match with Mr. Sloop might, in fact, be workable and that the age difference between the two might be of some benefit to her. However, I felt that her functioning as a primary custodial parent had to be dependent on her striving to achieve some stability in her life. And if the pattern of her behavior that she has demonstrated over the last several years should continue, then I recommended that a transfer of custody immediately go to Mr. Ronk. Mr. Ronk if primary custody is given to Mrs. Ronk, it really is in the best interest of the children that Mr. Ronk not be relegated to just a weekend father status. He has many positive qualities that it would be not in the children's best interest to be limited to contact with him. I understand that his job situation has changed to some extent. And.if he has more time available and is spending less time on the road, then I think I would be inclined to recommend some sort of joint custodial arrangement. Q Do you know what type of joint -- I mean, I understand the parties have maybe an hour and a half away 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 by car. What could you propose as far as a joint custody, every other week? I know the children are four and two. They're not yet in school yet. But when they do become in school, it's a year or two down the road. A I understand that. When the children reach school age, then it becomes more of a problem, because they need to have someplace as a primary domicile. I hesitate to see the children splitting up one week here, one week there. I think I would be more inclined to recommend that the children be located in one domicile primarily with the other parent be given liberal visitations, weekends, evenings, holidays. Q Your conclusions were made in light of the fact that Mrs. Ronk and Mr. Sloop are 20 years apart in age. Is that correct? A That's correct. Q And also that Mr. Sloop had two felonies in the past. Is that correct? A That's correct. Q If I were to tell you that Mrs. Ronk is now remarried. For instance, if they got divorced early in September and now remarried, would that have any bearing on what your findings would be or conclusions? A I don't think so. Q What if Chadd, Mr. Ronk, were to work only 15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 minutes away from his house, work 7 a.m. to 3 p.m. Monday through Friday, would that have any bearing on your findings right now? A Well, given the age of the children, Mr. Ronk would still need to have someone functioning as a baby-sitter, you know, during the day. And I think if Mrs. Ronk is available to be a full-time mother, it would be very difficult to reconunend that the children be in the care of a baby-sitter rather than with their mother. Q How about if the children were in school? A If the children were in school, that might be a different story. MR. BARRON: Nothing further, Your Honor, with Mr. Boyer. CROSS-EXAMINATION BY MR. HEARN: Q practice? A Mr. Boyer, what's the primary area of your I'm a general psychologist. I've -- for a long time I was the only psychologist in private practice in Lewistown area so my practice became very general. However, I've done child custody evaluations for Mifflin, Juniata, Huntingdon, Perry, Snyder County Courts and average about 1 a month for the last 20 years or so. Q You said you administered some personality tests 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 or psychological tests to the three people involved here? A That's correct. Q What tests did you give them? A I administered the Minnesota Multiphasic Personality Inventory in an effort to gather some objective data regarding their personality structure and to look at any underlying clinical -- anything clinical that might be of some significance. Q And that was the original MMPI not the MMPI II? A That was the original MMPI. That's correct. Q I was just curious. Am I correct in assuming that that test was not designed for evaluations for divorce or custody purposes? A That's correct. Q I had a couple questions about some of your statements in the evaluation itself. This should be just a couple minutes. One other question I had, did you give the parties any IQ tests? A No, I didn't. Q Because I noticed at several points in the evaluation that you were making judgements as to the range of intelligence. A That's correct. I did. Q Did you base those on the MMPI? 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 A No. No. I based that on my clinical impressions of the interaction with the individuals. Q On Page 7 of the test of the evaluation, you stated that Mr. Ronk is or he appeared to be moderately anxious and at least mildly depressed. Is that also based on your personal impression of looking at him or -- A Part of the clinical interview involves a mental status examination which includes developing some subjective impressions about the person's affect and about the person's mood. And those statements reflect a moderately anxious, mildly depressed reflects my clinical impression of him as he was being interviewed. Q And your general conclusion was that if Mrs. Ronk is not working, it'd be better for the children -- it'd be in the best interest of the children to be with their mother? A That was my conclusion at the time, yes. MR. HEARN: MR. BARRON: THE COURT: No further questions, Your Honor. No redirect, Your Honor. You may step down. You may be excused, I guess, unless there's an objection. MR. HEARN: MR. BARRON: THE COURT: MR. BARRON: No objection. No objection, Your Honor. Okay. Thank you. I call to the stand Chadd Ronk. 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 CHADD RONK. called as a witness, having been duly sworn, was examined and testified as follows: THE COURT: Be seated. BY MR. BARRON: Q A Q A Q DIRECT EXAMINATION Please state your name, Chadd. Chadd E. Ronk. And where do you live? I live in Honey Grove, Pennsylvania. And you're the plaintiff in this action against your ex-wife I believe? A That's correct. Q When were you and her divorced? A I received the papers and it said September 3rd. Q Of what year? A Of '98. Q Do you know if she's remarried since then? A I do not know a hundred percent sure. I had a witness that seen a wedding band. Q Back in October, do you recall being here in court testifying regarding the custody of your children? A Yes, I do. Where were you working back then? I was working for Hempt Brothers in Carlisle. How far of a drive was that? 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A around 6 to 6. Q How about on the weekends? weekends? A That was about an hour drive, 48 miles. And what were your hours? How often a week? Oh, I was working roughly a 12-hour shift say Did you work the Once in a while I'd work a Saturday. Where are you working now? I work for Jay Fulkroad & Son in McAlisterville. Do you have set hours when you work for him? Yes, I do. I was able to set my own schedule. And what hours are they? They're from 7 a.m. to 3 p.m. How far is the commute or the drive from your trailer to work? A I'd say the longest would be around 25 minutes, and I'm only 10 minutes away from the children from their caretaker. Q A October 21st, Where is that? It's in Mifflintown. So you travel across Mifflintown to get to work? Yes, I do. How long have you had your two children now? I've had them almost a year. I think it was somewhere around that date when -- that we 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 split up that she left. Q Did you allow your wife to have liberal summer vacation with the children? A Yes, I did. Q How long was that? A It was for two weeks. Q Two weeks together or just one? A Yeah, two weeks with the children alone. Q Do you know where they went? A They did say that they went to a couple different places. I know they went to a zoo. I think it was out of state. I think it might have been Maryland, but they went a couple different places. Q A 50 miles. Q Is that one way? A That's one way, yes. Q There was an incident regarding your license. Do you have a current Pennsylvania license right now? A I receive my license this coming Thursday, How far away does Rayette live from you? I'd say a good hour and a half. It would be over October. Q A related situation. 1st of Why did you not have your license? I lost my license for six months due to health I had a seizure in April. 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q What year? Of '98. Who said you couldn't drive? Department of Transportation. Do you take medicine for that? Yes, I do. But you're getting it back two days from now? Yes. MR. BARRON: Nothing further, Your Honor. CROSS-EXAMINATION BY MR. HEARN: Q Mr. Ronk, when you had that seizure in April, do you remember the exact date of that seizure? A I know it was in the end of April. I think it might have been the 23rd. I'm not a hundred percent sure on that. Q Do you remember testifying in this court on the 23rd, the 23rd of April, 19987 A That must have been the day, yes. Q Did you have the seizure that same day? A I had the seizure before that. I had the seizure about three weeks before that so it had to have been the beginning of April then. Q Do you remember testifying back in April and me asking you if you had epilepsy? 15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes, I do. Q And do you remember testifying that you had been receiving doctor's care? A Yes, I do. Q But you also testified that you were not taking medication at that time? A I was not -- there was a time that I did not take medication for a few months and that was before that we were separated, but I was back on medication at that time, yes. seizure? A Q A And when you testified, you had already had the Yes, I did. Had you already lost your license? No, I did not. There was something -- I don't know what it was, but I was not notified until two months after the seizure. Q How did the Department of Transportation find out about your seizure? A From workmens' comp. I had the seizure at work, and it was on file at workmens' comp. And workmens' comp. supposedly reported it to the Department of Transportation. Q And you testified just now that you're working at a Jay Fulkroad & Sons in McAlisterville? A That's correct. 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q What are you doing for them? I'm a plant manager. Are you driving any vehicles for them? No, I don't. When Mrs. Ronk had the children with her for two weeks this suA,~er, did you volunteer to let her have those two weeks or was it her request that initiated that? A She asked if I could have -- or if she could have I agreed the children for two weeks and I accepted that. to it. MR. HEARN: MR. BARRON: THE COURT: MR. BARRON: MR. HEARN: No further questions, Your Honor. No redirect, Your Honor. You may step down. That's all I have, Your Honor. Your Honor, we'd call Rayette Ronk to the stand. RAYETTE RONK, called as a witness, having been duly sworn, was examined and testified as follows: THE COURT: You may be seated. BY MR. HEARN: DIRECT EXAMINATION Q Ms. Ronk, would you state your full name for the record, please? A Rayette I. Ronk. And I'm sure you remember testifying in the same 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 courtroom back in April. A Q Ronk? A Q A Q Is that right? Yes. At that time, you were still married to Chadd Yes. Are you still married to him now? No, sir. And that divorce came through he testified the 3rd of September. A Yes. That's when I received paperwork. Q About three weeks ago? A Um-hum. Q Have you remarried since then? A No. Q Are you engaged to be married? A Yes, sir. Q To whom. are you engaged to be married? A Mr. Harold Sloop. Q How long have you and Mr. Sloop been together? A It will be a year next month. Q And would you say -- how would you -- how does Mr. Sloop -- how is your relationship with Mr. Sloop affected your life in the past year? A It's given me a better perspective on life. I'm happier. I see things better than I did before. I'm not 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in a hole. Q A Q I can do what I want, and I'm not trapped. Have you set a date to be married? No. When you testified last spring, you were not working at that time? That's right. Are you working now? No. A Do you have plans to go back to work? No. Are you and Mr. Sloop able to make ends meet financially so that you don't need to work? A Yes, sir. Q When you testified back in April, you were living in a trailer in Cumberland County. Is that correct? A Yes. Q And are you still living in that trailer? A We're going to be there until next month. Mr. Sloop and I found a three bedroom house. It has -- there's kids around. There's a trailer court right down below us. We're going in to sign on the lease this Thursday and putting $500.00 down. And the people that's in it right now will be out by the end of next month and we're moving in then. Q And you say it's a three bedroom house? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A What is it like? A It's on a back street. riffraff is. It's a quiet -- Q Yes. Tell me a little bit about the neighborhood. It's not where all the What town is it in? It's in Mount Holy Springs. I'm sorry. And does it have a yard? Yes, it has a nice backyard. It's really -- it's enough room for the kids to play. Q Can you tell me a little bit about what you and the children did when you had them for two weeks? A Well, we went to a zoo in Maryland. They had such a good time. They were petting goats, and they saw this big turtle. And then we went to Col. Denning. Q That's a state park? A Yes. It has a play area and then it has where you can go swla~ing. The nice wa£,, days we went swimming because it was fun. We took them to Laurel Lake. It's up by Mount Holly Springs. And we went to -- we took them to see the fireworks in Harrisburg. To my knowledge, that was the first time they ever saw really big fireworks. Q was that on Labor Day? A Yeah. They just clapped, and they really had a good old time. And we went to Boiling Springs. They have 2O 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 a whole bunch of ducks and geese there. We went to feed them on a couple of nights. They enjoyed feeding the ducks and watching them fly into the water and diving for food. cross. MR. HEARN: MR. BARRON: BY MR. BARRON: I have nothing further, Your Honor. If I may, Your Honor, just brief on CROSS-EXAMINATION Q Rayette, do you have any photographs of where you're going to be living next month? A No, not yet. Q How far is your new place next month to where you're living right now? A It takes -- it cuts out a mountain. It probably takes about -- it takes six minutes to get from where I'm living at now to get to there. Q In a car? A Yes. Four or five miles? A Yes. Q Last April at the hearing that you testified of this year, you had quit your work a week prior to that hearing, isn't that right? A Yes, sir. Where were you working? 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Carlisle. Q weekend? A Q A Q I was working at Ross. It's a distribution in Have you been seeing your children every other Yes, sir. And every Wednesday night? Yes. More or less. I have nothing further. MR. HEARN: One clarification. REDIRECT EXAMINATION BY MR. HEARN: Q Is this new place closer than your old place Mr. Ronk's place? A It takes out about five mile so he won't be driving the mountain. Q It's about six minutes closer, is it? A Yes. MR. HEARN: No, nothing further, Your Honor. MR. BARRON: THE COURT: MR. HEARN: MR. BARRON: THE COURT: MR. BARRON: ~O No recross, Your Honor. You may step down. Nothing further, Your Honor. Nothing on rebuttal, Your Honor~ Any argument? I don't believe so, Your Honor, unless you want something filed. 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: make oral argument? see counsel in chambers before we adjourn. All right. Court's in recess. counsel. concluded.) It's up to you. No? Do you want to You may. If you don't, I'd like to I'd like to see (Whereupon, at 1:20 p.m., the hearing was 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I hereby certify that the proceedings and evidence are contained fully and accurately in the notes taken by me during the hearing of the within cause, and that this is a true and correct transcript of the same. V~'I%ONICA L.%R~EAM ' TM Court Rep0~ter The foregoing certification does not apply to.~ any reproduction of the same by and means unless under the ;"~! direct control and/or supervision of the certifying reporter. ~ VERONICA L. RHEAM RD 1 BOX 124-A SHERMANS DALE, PA 17090 (717) 582-7109 24 VERONICA RHEAM (717) 582-7109 RAYETTE I. (RONK) SLOOP, Plaintiff/Petitioner CHADD E. RONK, Defendant/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - CUSTODY : NO. 2001- ~?a~CIVIL TERM : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY 1. The Petitioner is the above-named Plaintiff, Rayette I. Sloop, an adult individual currently residing at 428 Chestnut Street, Mount Holly Springs, Cumberland County, Pennsylvania 17013. 2. The Respondent is the above-named Defendant, Chadd E. Ronk, an adult individual currently residing at R.R. #4 Box 937, Mifflintown, Mifflin County, Pennsylvania 17059. 3. The parties are the natural parents of the children Christian Robert Ronk, bom December 21, 1994; and Josie May Ronk, bom December 5, 1996. The children were bom in wedlock. 4. Juniata County, docketed at No. 436 of 1997. A copy of the Order is attached hereto and incorporated herein by reference as Exhibit "A." 5. There have been no additional actions relative to custody of the within named children in any jurisdiction to the Petitioner's knowledge. 6. Since the entry of the Court's Order of August 27, 1999, the children have primarily resided with the Petitioner. The parties are currently subject to a Custody Order dated August 27, 1999, of follows: Among the reasons why the Petitioner desires to modify the existing Order are as (a) The Court's Order of August 27, 1999 requires the parties to equally share transportation; (b) Respondent has relocated two times in the last three years with each residence being farther away than the other, which has substantially increased the Petitioner's distance in which to travel and caused undue difficulties in transporting the children; (c) The current Order grants two weeks of summer vacation to the Respondent without regard to whether Respondent spends that time with the children. (a) Petitioner does not work and is always available to care for the children, she desires that daycare of the children be kept to a minimum. 8. The natural mother of the children is Rayette I. Sloop. She is married. 9. The natural father of the children is Chadd E. Ronk. He is divorce. 10. The relationship of the Petitioner to the children is that of natural mother. The natural mother currently resides with the children, and her husband, Harold Sloop. I 1. The relationship of the Respondent to the children is that of natural father. The natural father currently resides alone. 12. The Petitioner has not participated as a party or a witness in any other capacity in litigation concerning the children. 13. Petitioner has no information of any custody proceeding concerning the children pending in any Court of this Commonwealth. 14. The children's best interest and permanent welfare would be significantly improved by modifying the existing Custody Order for the following reasons: (a) Modifying the transportation provision would not unduly burden the Respondent and would address the Respondent's relocations; (b) Modifying the Order so that the parties have fewer exchanges of longer durations would prevent unnecessary travel for the children; and (c) Modifying the summer schedule so that Respondent is still be able to exercise vacation time with the children, while limiting the time that the children would spend in daycare. 15. Petitioner does not know of any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. WHEREFORE, Petitioner requests your Honorable Court to grant her request to enter an Order scheduling a Custody Conciliation regarding the custody modification. Respectfully submitted, Thomas S. Diehl, Esquire Attorney for Plaintiff/Petitioner One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. RAyI3~FE i. SLOOP, Plaintif~Petitioner EXHIBIT A ~mn-[,7-99 1~:11 ~yS~Om~ Legal Services 814-228-9504 P.02 CHADD ~. RONK IN THE COURT OF COMMON OF T~E 41~T JUDICIAL DISTRICT OF PENNSYLVANIA : JUNIATA COUNTY BRANCH RAYETTE I. (RONK) S~OOP : NO. 436 Of 1997 O~R D g R AND NOW, August 27, 1999, this Court having entertained argument on the issue of temporary custody of father, IT IS HEREBY ORDERED AND DIRECTED that tg~..~rties shall enjoy e ehare~ legal custody arrangement, with primary - physical custody awarded to mother, subject ~o and visitation rights in father, as follows= Pot ~he months of September through May, lecher shell have, commencing in September, two (2) weekends out of the month, ~eing the seoond and fo~tb weekends, which weekends are defined as from Friday at 6:00 P.M. until Sunday a= 6:00 P.M. and then father would have the children on ~he second, fourth and fifth weekends of the month of October and then alternating ~hereafter with two (2) weekends the following month and three (3) weekends the month thereafter and, if there is only four weekends in a particular month that father has t~ree weekends, it should be the la$~ three (3) weekends of the month: ~emporacy custody un~il Father shall have three yea~ from December 25=h a~ 3:00 P.M.; (3) days following Chris,mas 3:00 P.M. until December 28th The par:ies Shall share Thamksgiving and Easter at times to be de:ermined by the parties and alternating o:her - 1 ~he ¢aaaonable holidays; ,. DurinG the summer month~ of June, July and A~S~, each party shall have two (2) week block~ wi~h the Children and alternating during the summer months; receiving party shall provide ~=ans~orta~ion: and tallghone contact shall be allowed by the non-custodiai BY THE COURT: ~glas Hearn, Esq., True Copy ~ 2 RAYETTE I. (RONK) SLOOP PLAINTIFF IN THE coURT OF coMMON PLEAS OF CUMBERLAND couNTY, PENNSYLVANIA : 01-6989 CIVIL ACTION LAW CHADD E. RONK DEFENDANT : IN cUSTODY AND NOW, ~December 21, 2001 ., upon consideration of the attached Complaint, it is hereby directed that parties and their respectwe counsel appear before ~cq~eline M. Ve~ the conciliator, d Count Courthouse, Carlisle on Wednesday, January 2~, 2002 at 3:30 PM - ~*~ ~ r Cumberlan ~-~ ..... - - ~-~ *~-~ ~ .... s in disnute; or at. 4tll I~ loor, ~uu ~ - .... an effort will be maae to resotw [~ ......e L for a Pre-Hearing Custody Conference. At such comerettu*, if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, 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 heating or business before the court. You must attend the scheduled conference or hearing. IF YOU DO NOT YOU sHOULD TAKE THIS pAPER TO YoUR ATTORNEY AT ONCE. ONE, GO TO OR TELEPHONE THE OFFICE SET HAVE AN ATTORNEY OR CANNOT AFFORDcAN GET LEGAL HELP. FORTH BELOW TO FIND OUT WHERE YOU Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 FEB 0 q zOOZLd RAYETTE I. (RONK) SLOOP, Plaintiff V. CHADD E. RONK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ._ : CIVIL ACTION - LAW : : NO. 2001-6989 CIVIL TERM : : IN CUSTODY ORDER OF COURT ANDNOW, this IZ~ dayof !'-~' '*~'t ,2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. / , of the Cumberland ~C, ounty Court House, on the//~_~ day of ~ ,2002, at ~ :SE) o clock, /~. M., at which time testimony will/be taken. For purposes ofthis'He~ng, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the following shall remain in effect: 3. The Order of Court dated August 27, 1999, shall remain in full force and effect except for the following modifications: 4. For the summer of 2002 only, Father shall have partial physical custody of the Children from June 6, 2002 or one day after the last day of school, until June 16, 2002. Mother shall have physical custody of the Children from June 16, 2002 until July 19, 2002. Thereafter, Father shall have physical custody of the Children from July 19, 2002 until August 23, 2002, when the Children will be returned to the Mother and the regular non-summer schedule shall resume. During each parent's five week summer block of time, the non-custodial parent shall enjoy alternating weekends with the Children on the usual weekend schedule. 5. Transportation shall be shared such that Mother shall be responsible for one round trip per month, which shall occur on the first exchange of every month. BY THE COURT, cc: Thomas S. Diehl, Esquire, counsel for Mother Judith Dolgas, Esquire, counsel for Father FEB 0 "/ZO0 RAYETTE I. (RONK) SLOOP, Plaintiff V. CHADD E. RONK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2001-6989 CIVIL TERM : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits thc following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Christian Robert Ronk Josie May Ronk December 21, 1994 December 5, 1996 Mother Mother 2. A Conciliation Conference was held February 6, 2002, with the following individuals in attendance: The Mother, Rayette I. Sloop, with her counsel, Thomas S. Diehl, Esquire, and the Father, Chadd E. Ronk, with his counsel, Judith Dolgos, Esquire. 3. The Honorable C. Joseph Rehkamp of the Court of Common Pleas of Juniata County previously entered an Order on August 27, 1999. On October 31, 2001, Judge Rehkamp transferred venue of the matter to Cumberland County. The Order of August 27, 1999 granted shared legal custody with Mother having primary physical custody. Father has periods of partial custody two to three weekends per month. The summer schedule is shared physical custody on a two week on/two week off arrangement. Transportation is shared with the receiving party providing transportation. 4. Mother's position on custody is as follows: she seeks to change the summer schedule claiming that one of the children should attend the Camp Read-A-Lot, five week program offered by Carlisle School District from June 17 to July 18, 2002. Mother suggests Father receive only one week during the summer and his usual alternating weekends. Mother also requests that Father do all of the transportation. A round trip drive is approximately 3 hours. 5. Father's position on custody is as follows: he is willing to accommodate the hfld s summer reading program, and ~s in favor of the Order recommended by the Conciliator. Father is willing to reduce Mother's transportation responsibility to one round trip per month. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and granting the parents shared legal custody, Mother primary physical custody and amending the prior Order regarding the summer of 2002 only and reducing Mother's transportation responsibility. It is expected that the Hearing will require one half day. Date ~ine M. Vemey, Esquire 2 Custody Conciliator RAYETTE I. SLOOP, : Plaintiff, Respondent : V. : CHADD E. RONK, : Defendant, Petitioner : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001-6989 CIVIL TERM IN CUSTODY PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY ORDER The Petition of CHADD E. RONK, respectfully represents: 1. That on February 12, 2002, Judge Wesley Oler, Jr., entered an Order awarding Petitioner partial custody of the minor children Christian Robert Ronk and Josie May Ronk. A true and correct copy of the order is attached to this petition. (Attachment A) 2. Respondent has willfully failed to abide by the order in that she refused to comply with paragraph 5 of the order, thereby causing father to miss his period of partial custody the weekend of March 8, 2002. 3. This is the second time Respondent has been in violation of an Order relating to the partial custody of the minor children. 4. Petitioner filed a Petition for Special Relief on September 14, 2001, alleging Respondent had refused to produce the minor children for visitation for the period of August 26, 2001 up until the date of a hearing set by the Court of October 15, 2001. 5. The Court granted Petitioner's Petition for Special Relief. A true and correct copy is attached to this petition. (Attachment B) 6. Respondent has since filed a Petition for Modification of Custody with this Court, a hearing is set for April 11, 2002. 7. Respondent continues to put her interests and convienence before that of her children by refusing to comply with orders of this court and of the court of Juniata County. 8. Respondent's Petition for Modification should be denied since she is in contempt of an Order of this Court. 8. Primary physical custody of the minor children should be amended, granting primary physical custody to Petitioner who has consistently been in compliance with all orders of this court and the previous court in Juniata County. WHEREFORE, Petitioner requests that Respondent be held in contempt of court, that primary physical custody be awarded to Petitioner/Father and in addition, that Respondent be ordered to pay Petitioner's attorney fees in the amount of $250.00. Respectfully submitted: I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S ~ 4904 relating to unsworn, falsifications to aJ~oritJes DATE -- CHADD E. RONK Exhibit A FEB O~ 2002~O' RAYETTE I. (RONK) SLOOP, Plaintiff V. CHADD E. RONK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001-6989 CIVIL TERM IN CUSTODY ORDER OFCOURT AND NOW, this /~ ~ day of ~,~ ........ 2002, upon consideration of the attached Custody Conciliation t~eport, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. [ , of the Cumberland County Court House, on the //6- day Of ~)t~,,'z ,2002, at o'clock,/~ . M., at which time testimony will b'~ taken. For purposes of this Hearing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of wimesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the following shall remain in effect: 3. The Order of Court dated August 27, 1999, shall remain in full force and effect except for the following modifications: 4. For the summer of 2002 only, Father Shall have partial physical custody of the Children from June 6, 2002 or one day after the last day of school, until June 16, 2002. Mother shall have physical custody of the Children from June 16, 2002 until July 19, 2002. Thereafter, Father shall have physical custody of the Children from July 19, 2002 until August 23, 2002, when the Children will be returned to' the Mother and Ce regular non-summer schedule shall resume. During each parent's five Week summe'r· block ofthne, the non-custodial parent shall enjoy alternating weekends with the Children on the usual weekend schedule. 5. Transportation shall be shared such that Mother shall be responsible for one round trip per month, which shall occur on the first exchange of every month. BY THECOURT, cc: Thomas S. Diehl, Esquire, counsel for Mother Judith Dolgas, Esquire, counsel for Father Exhibit B UHADD E. RONK ~AYETTE I. (RONK) SLOOP IN THE COURT OF COMMON PLEAS OF THE 41ST JUDICIAL DISTRICT OF PENNSYLVANIA JUNIATA COUNTY BRANCH NO. 436 of 1997 ORDER '.- AND .NOW, October 15, 2001, the Petition for Special Relief is :ranted and the previous court order shall be enforced effective' this weekend when dad's visitation shall recommence as per court urder. On the issue of change of venue, COUnsel has ten (10) days from this date within which to submit authorities, after which this 2Ourt will render its decision on the change of venue request. Atl :his time neither party resides in Juniata County and mother and subject children have been residing in Cumberland County for approximately two years. Dad has been residing in Mifflin County a couple of months. ~udith Dolgos, Esq. Thomas Diehl, Esq. Pile BY THE COURT: RAYETTE I. SLOOP : PLAINTIFF : V. IN THE cOURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-6989 CIVIL ACTION LAW CHADD E. RONK DEFENDANT : 1N CUSTODY AND NOW, Tuesday, March 19, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland Count), Courthouse, Carlisle on Wednesday, April 17, 2002 at 2:30 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. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry ora 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/ Jacaueline M. Vernev. Esa. ~ A ^ ~ Custody Conciliator ' 0r- ' 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 CHADD E. RONK, : Plaintiff : V. RAYETTE I. (RONK) SLOOP, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-6989 CIVIL TERM ORDER OF COURT AND NOW, this 11th day of April, 2002, upon consideration of the Petition for Modification of Custody filed by Defendant mother, with respect to the parties' children, Christian Robert Ronk (d.o.b. December 21, 1994) and Josie May Ronk (d.o.b. December 5, 1996), and following a hearing held on this date, the terms of custody contained in the order of court dated February 12, 2002, are entered as a permanent order of court. ~th Dolgas, Esq. //2409 Beech Street Harrisburg, PA 17110 Aa~h~o~n~mey for Plaintiff as S. Diehl, Esq. One West High Street Suite 208 P.O. Box 1290 Carlisle, PA 17013 Attorney for Defendant BY THE COURT, / ~]Wesley 0 ,~., · O :rc VINVA'!A8NNfld 01:1 I~d I ltld~20 APR 1 8 ZOOZ._ RAYETTE I. (RONK) SLOOP, Plaintiff V. CHADD E. RONK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. : CIVIL ACTION - LAW : : NO. 2001-6989 CIVIL TERM : : IN CUSTODY ORDER OF COURT follows: ,2002, upon it is ordered and directed as 1. Mother, Rayette I. Sloop, willfully and intentionally violated Paragraph 5 of the Order &Court of February 12, 2002, requiring her to transport the children on the first weekend visit with Father in March, 2002. 2. Mother is hereby found in Contempt of Court for violation of Paragraph 5 of the Order of Court of February 12, 2002 as affirmed by the Order of April 11, 2002. 3. A fine of $500.00 is hereby imposed on Mother for violation of said Orders. Within thirty days of this Order, Mother shall pay $250.00 to Father as reimbursement for legal fees incurred in the filing of the Petition for Contempt. Mother is further ordered to pay $250.00 to the Prothonotary of Cumberland County. Failure to pay said fine within 30 days from the date of this Order may result in another finding of Contempt of Court. BY THE COURT, Vesley Oler, ~ cc:)l~aomas S. Diehl, Esquire, counsel for Mother ,judith Dolgas, Esquire, counsel for Father VlNYAq,Lb~N':Jd RAYETTE I. (RONK) SLOOP, Plaintiff V. CHADD E. RONK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2001-6989 CIVIL TERM : : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. CUSTODY CONCII,IATION 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 conceming the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Christian Robert Ronk Josie May Ronk December 21, 1994 December 5, 1996 Mother Mother 2. A Conciliation Conference was held April 17, 2002, with the following individuals in attendance: The Mother, Rayette I. Sloop, with her counsel, Thomas S. Diehl, Esquire, and the Father, Chadd E. Ronk, with his counsel, Judith Dolgos, Esquire. 3. The Honorable J. Wesley Oler, Jr. entered an Order on February 12, 2002 following a Conciliation Conference. Pursuant to the Order of February 12, 2002, Mother, inter alia, was to provide transportation on the first exchange of every month (Paragraph 5). On April 11, 2002, Judge Oler, after hearing, confirmed the February 12, 2002 Order of Court. 4. Mother failed to transport the children on the first exchange in March, 2002 in violation of the February 12, 2002. 5. Father requested Mother be found in Contempt of the Order of February 12, 2002 and the Order of April 11, 2002 which confirmed the Order of February 12, 2002. In addition, Father requested reimbursement of counsel fees in the amount of $250.00. He also requested primary physical custody be transferred to him. 6. Mother admitted not transporting the children on the weekend in question basing her refusal on her disagreement with the provision requiring her to share transportation. Mother claimed that she did own a vehicle, although her husband owns at least two vehicles. She indicated that her husband did not permit her to take the vehicle out of the county. (This information was not presented at the prior Conciliation conference when the shared transportation requirement was imposed.) Mother further argued that the children did not want to visit with their Father and disputed the summer schedule included in the February 12, 2002 Order and affirmed by the Order of April 11, 2002, after hearing. She showed old pictures of bruises on one child which was not at issue at the current Conciliation conference or the prior Conciliation conference. 7. Mother was advised that the Conciliator intended to recommend a finding of Contempt of the Orders of February 12, 2002 and April 11, 2002 and suggest a fine of $500.00. Mother was offered the option of purging the fine by agreeing to transport the children on Father's next two weekend visits, but she refused. Mother left the Conciliation conference prior to its conclusion. Counsel for Mother later notified the Conciliator that Mother did not request a hearing on the matter of the finding of Contempt and imposition of the fine. 8. The Conciliator recommends an Order in the form as attached finding Mother in Contempt of Court for violation of the February 12, and April 11, 2002 Orders and fining Mother $500.00; $250.00 payable to Father as reimbursement for legal fees and $250.00 payable to the Prothonotary of Cumberland County. Date Custody Conciliator CHADD E. RONK, Plaintiff RAYETTE I. SLOOP, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2001-6989 CIVIL TERM CIVIL ACTION - LAW CHILD CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW comes Plaintiff, CHADD E. RONK, and by and through his attorney, Judith F. Dolgos, Esquire, moves this Honorable Court to modify the existing child custody order, and in so asking represents the following: 1. Plaintiff is Chadd E. Ronk, an adult individual currently residing at 6328 SR 103 South, McVeytown, Mifflin County, McVeytown, Pennsylvania 17051. 2. Defendant is Rayette I. Sloop, an adult individual currently residing at 428 Chestnut Street, Mount Holly Springs, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of the children Christian Robert Ronk, age 7, born December 21, 1994; and Josie May Ronk, age 5, born December 5, 1996. The children were born in wedlock. 4. The parties are currently subject to a Juniata County Custody Order dated August 27, 1999, (Exhibit A hereto) and a Modification Order dated February 12, 2002, (Exhibit B hereto) which was confirmed and made permanent by Order dated April 11, 2002, (Exhibit C hereto). 5. There have been no additional actions relative to the custody of the within named children in any jurisdiction to the Plaintiff's knowledge. 6. Since the entry of the Court's Order of August 27, 1999, the children have primarily resided with the Defendant. 7. Among the reasons that the Plaintiff wishes to modify the existing Order are as follows: (a) During the 1999 custody hearing in Juniata County, there was testimony by a competent psychologist that Plaintiff was the more desirable parent, but that Plaintiffs work schedule and the age of the children made Defendant the better choice because of her intention to by a "stay at home" mom. (b) That same psychologist testified that plaintiff should be granted generous access to the children, which Defendant has tried on many occasions to block, including her refusal to permit the children to see their father for most of the summer of 2001; (c) Defendant has been found in contempt by this Court for refusing to comply with aspects of the current modification to the Custody Order, by refusing to provide transportation for the children; (d) Defendant has made threats to Plaintiff regarding her control over the children and her intention to make sure that the children will "hate" him or "fear" him; (e) Defendant's actions while at custody conciliations have made it clear to Plaintiff that Defendant is not providing a stable and loving home for his children and that his relationship with his children as well as their well being is at risk: and (f) Certain concerns that the August 1999 Court had regarding the children's ages and father's work schedule have resolved making father the more desirable parent to be granted primary physical custody. 9. 10. 11. The relationship of the Plaintiff to the children is that of natural father. Plaintiff is not remarried. The relationship of Defendant to the children is that of natural mother. Defendant is remarried to Harold Sloop. 12. Plaintiff has not participated as a party or a witness in any other capacity in litigation concerning the children. 13. Plaintiff has no information regarding any custody proceeding concerning the children pending in any other Court of this Commonwealth. 14. The children's best interest and welfare would be significantly improved by modifying the existing Custody Order for the following reasons: (a) (b) Plaintiff has been and remains the more desirable custodial parent; The children will be able to attend school full-time in the fall of 2002 and father is able to modify his work schedule to be with children most of the time that they are not in school; (c) Defendant's homes proximity to many of his relatives makes using non family baby sitters unnecessary. 15. Plaintiff does not know of any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. WHEREFORE, Plaintiff request your Honorable Court to grant him primary custody and to enter an Order scheduling a Custody Conciliation regarding this request for modification of custody. Respectfully submitted, Dated: By: Judi~F. Dolgos, EsqUire // Attq~hey for Plaintiff, Chadd ~ Ronk ID No. 68738 PO Box 60809 Harrisburg, PA 17106-0809 (717) 541-9660 I, Chadd E. Ronk, certify that the statements made in the foresoin§ Petition for Modification of Child Custody, are true and correct to the best of my knowledse and belief. understand that false statements herein are made subject to the penalties of ~.8 Pa. C.S.A. 4904, relatin8 to unsworn falsification to authorities. Dated: ~ Cz .~.2. L"~__~..~/J~ ~ Chadd E."'Ron k CERTIFICATE OF SERVICE I, Judith F. Dolgos, Esquire, attorney for Chadd E. Ronk, hereby certify that I have served the foregoing Petition for Modification of Child Custody by placing a true and correct copy of the same in the U S Mail, First Class, postage pre-paid addressed as follows: Rayette I. Sloop 428 Chestnut Street Mount Holly Springs, PA 17013 Date: J~h ~. Dolg°s / ~ttorney for Plaintiff Exhibit A FAX NO. : 717-240-0B93 Jan. tH~ COURT Of COMMON ~UNZATA COUNTy ~ANC~ 436 Of 1~7 ars defined ss £rom ~ida¥ at 6:00 P.M. un,il Sunday ac 6:00 P-~. and ~hen father voul~ have ~he children on ~he second, alternating thereafter with two (2) weekends ~he ~cllow£ng mon=h and =brae ¢3) ~eeken~s the month ~hereafCe= and/ me · ia only ~ouc wee~end8 i~ a Particular month thac ~a~her Father shall have :h~ee (3~ days following C'he/~:~a3 ' The Pa~ies ~hall share Thanksgiving and ~aa%er ac :£~ ~o se dece~mlned ~y ~he Da=ties and a!~er~a~in~ ocher and a~er~a~in~ du~ing ~he eummer mofl~hs; Pa~mn:. CC= BY TB~ CO~T: ~)~f~g 1 as HeaL*n, file Exhibit B I~YETTE I. (RONK) SLOOP, Plaintiff CHADD E. RONK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2001-6989 CIVIL TERM : IN CUSTODY ,ORDER OF COURT · . AND NOW, this /~z~ day of ~,~ consmeration of the attach2,J r~,,~^.~_ ,~ :;.'":'.'~'~ ,2002, upon fbllows: ,,,~ ,.,-o~uuy ~oncmanon ~xeport, it is ordered and directed as 1. A Hearing is sched~uled in Court Room No. [ , of the Cumberland ounty Court House, on the j/~ day of ~,;~, " ,2002, at C'cl°ck, &_.. M., at which time testimony will l:(d taken. For purposes of this Hearing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify, at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the following shall remain in effect: 3. The Order of Court dated August 27, 1999, shall remain in full force and effect except for the following modifications: 4. For the summer of 2002 only, Father Shall have partial physical custody of the Children from June 6, 2002 or one day after the last day of school, until June 16, 2002. Mother shall have physical custody of the Children from June 16, 2002 ua~til July 19, 2002. Thereafter, Father shall have physical custody of the Children from July 19, 2002 until August 23, 2002, when the Children will be returned to ~l~e Mother and the. regular non-summer schedule shall resume. During each parent's five week scanme-r. block of time, the non-custodial parent shall enjoy alternating weekends with the Children on the usual weekend schedule. 5. Transportation shall be shared such that Mother shall be responsible for one round trip per month, which shall occur on the first exchange of every month. BY THE COURT, cc: Thomas S. Diehl, Esquire, counsel for Mother Judith Dolgas, Esquire, counsel for Father Exhibit C CHADD IE. RONK, · Plaintiff . RAYETTE I. (RONK) : SLOOP, : Defendant . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTy, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-6989 CIVIL TERM ORDER OF COURT AND NOW, this 11th day of April, 2002, upon consideration of the Petition Modification of Custody filed by Defendant mother, with respect to the part/es' children, Christian Robert Ronk (d.o.b. December 21, 1994) and Josie Ma), Ronk (d.o.b. December 5, 1996), and/b/lowing a hearing hetd on this date, the terms of custody contained in tile order of COUrt dated February 12, 2002, are ent'ered as a permanent order ol~court. BY THE COURT, J~,dith Dolgas, Esq ~409 Beech Street ' Harrisburg, PA 17110 Attorney tbr Plaintiff Thomas S. Diehl, Esq. One West High Street Suite 208 P.O. Box 1290 Carlisle, PA 17013 Attorney for Defendant CHADD E. RONK : PLAINTIFF : : V. : 01=6989 : RAYETTE I. SLOOP DEFENDANT : IN CUSTODY : ORDER OF COURT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW AND NOW, Wednesday, June 12, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before JaequeHne M. Verney, Esq. , the conciliator, at 4thFloor, Cumberland County Courthouse, Carlisle on Tuesday, July l6, 2002 at 1:30 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. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ [acaueline M. Vernev. Esa. ~ ' ' Custody Conciliat'o} '/J 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 RAYETTE I. SLOOP, Plaintiff CHADD E. RONK, Defendant JUL !F~O02 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2001-6989 CIVIL TERM : : IN CUSTODY ORDER OF COURT AND NOW, this I a~ day of 4 ~o { ~1 ,2002, upon consideration of the attached Custody Conciliation Rgport, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. / ., of the Cumberland County Court House, on the~,~¥,eb~ day of~,Z~:ffa~ _, 2002, at ,/:,~E) o'clock, ~0. M., at which time testimony will be taken. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the following shall remain in effect: 3. The Orders of Court dated August 27, 1999, February 12, 2002 and April 11, 2002 shall remain in full force. BY THE COURT, / cc: Judith Dolgas, Esquire, Counsel for Fath~ ' - ' Rayette I. Sloop, pro se 428 Chestnut Street Mt. Holly Springs, PA 17065 ~.~. RAYETTE I. SLOOP, Plaintiff V. CHADD E. RONK, Defendant : IN THE COURT OF COMMON PLEd/~-OI~'~002 : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2001-6989 CIVIL TERM : : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. 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 Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Christian Robert Ronk Josie May Ronk December 21, 1994 Mother December 5, 1996 Mother 2. A Conciliation Conference was held July 16, 2002, with the following individuals in attendance: The Mother, Rayette I. Sloop, pro se, and the Father, Chadd E. Ronk, with his counsel, Judith Dolgos, Esquire. 3. The Honorable C. Joseph Rehkamp of the Court of Common Pleas of Juniata County previously entered an Order on August 27, 1999. On October 31,2001, Judge Rehkamp transferred venue of the matter to Cumberland County. The Order of August 27, 1999 granted shared legal custody with Mother having primary physical custody. Father has periods of partial custody two to three weekends per month. The summer schedule is shared physical custody on a two week on/two week off arrangement. Transportation is shared with the receiving party providing transportation. The Honorable J. Wesley Oler, Jr. entered an Order dated February 12, 2002, changing the summer schedule. Said February 12, 2002 Order was confirmed by an Order dated April 11, 2002, following a hearing. Thereafter, Mother was found in contempt of the Orders of February 12, 2002 and April 11, 2002 for failure to transport the Children pursuant to the Orders. 4. Father has filed a Petition to Modify the prior Orders, seeking primary physical custody of the Children. 4. Mother appeared at the Conciliation Conference with her husband and the Children. She refused to attend the Conciliation Conference without the presence of her Husband and the Children. Mother requested a hearing on the Petition for Modification, but did not provide any reason therefore. 5. Father's position on custody is as follows: He is seeking primary physical custody of the Children believing the Mother is unstable and has alienated the Children against him. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and continuing the present Orders. It is expected that the Hearing will require one half day. Date ~cq~eline M. Vemey, Esquire Custody Conciliator CHADD E. RONK, : Plaintiff : : V. : : RAYETTE SLOOP, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-6989 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY IN RE: PETITION FOR MODIFICATION QRDER OF COUR~ AND NOW, this 24th day of October, 2002, upon consideration of the petition of the father for a modification of custody with respect to the parties' children, and pursuant to an agreement of the parties, and in response to a motion for appointment of an attorney to represent the minor children, filed on behalf of the mother, the motion is granted, and Samuel L. Andes, Esquire, of Lemoyne, Cumberland County, Pennsylvania, is appointed by the Court to represent the minor children. Both parents and any step-parents are directed to cooperate with Mr. Andes in his performance of his duties as attorney for the children. Pursuant to further agreement of the parties, the hearing in this matter is continued until Thursday, January 16, 2003, at 9:30 a.m. Pending further order of Court, the existing custody order shall remain in full force and effect. By the Court, Judith F. Dolgos, Esquire 4409 North Front Street Harrisburg, PA 17110 For the Plaintiff Rayette Sloop, Pro Se 428 Chestnut Street Mt. Holly Springs, PA Samuel L-~des, Esquire For the minor children 17065 :mae CHADD E. RONK, Plaintiff RAYETTE I. SLOOP, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-6989 CIVIL TERM ORDER OF COURT AND NOW, this 29th day of October, 2002, it is ordered and directed that Arnold Shienvold, Ph.D, psychologist, be appointed in the above matter for purposes of a custody evaluation and testimony at the hearing scheduled for January 16, 2003. The parties are hereby directed to cooperate fully with Dr. Shienvold in his scheduling of appointments for purposes of this evaluation. The court has authorized a payment of $1,000.00 for payment to Dr. Shienvold for these purposes. BY THE COURT, , ., / / / / , , / , / // . /¢(."'"-*./"x _~-xtb.J esley oli~r~r., ' · Judith Dolgas, Esq. 2409 Beech Street Harrisburg, PA 17110 Attorney for Plaintiff Rayette Sloop 428 Chestnut Street Mt. Holly Springs, PA 17065 Defendant, Pro Se Samuel L. Andes, Esq. 525 N. 12th Street Lemoyne, PA 17043 Attorney for the Minor Children Arnold ~thienvold, Ph.D. 2151 Linglestown Road Harrisburg, PA 17110 :rc CHADD E. RONK, Plaintiff RAYETTE I. SLOOP, Defendant IN THE COURT OF COMMON PLEAS CUMBERI;.AND COUNTY, PENNSYLVANIA No. 2001.~$989 CIVIL ACTION. LAW CHILD CUSTODY MOTION FOR SEQUESTER OF WITNI::SSE~ AND NOW comes Plaintiff, Chadd E. Ronk, and by and through his attomey, Judith F. Dolgos, files this Motion and in support thereof offers as follows: 1. The parties to this matter are the natural parents of the minor children, Christian Ronk and Josie May Ronk, ages 8 and 6 respectively. 2. A headng into the primary custody of the minor children is scheduled before this court on January 16, 2003, at 9:30 AM. 3. Plaintiff respectfully requests that all witnesses, in this matter be ordered sequestered dudng the headng. 4. Plaintiff anticipates calling Susan Ronk, Paternal Gnandmother to the children, Crystal Ronk, Paternal Aunt to the children and Harold Sloop, Step-father to the children as factual witnesses. 5. Defendant has not provided a list of witnesses as required by this court,, but it is anticipated that this court will make a determination as to who the witnesses are at the time of the headng, prior to a final ruling on this matter. WHEREFORE, Plaintiff respectfully requests this Honorabl,e Court to order witnesses sequestered in the matter before the court. Date: January 9, 2003 Respectfully Submitt .~~,~ Harrisburg, PA 17106-0809 717 541-9660 CERTIFICATE OF SERVICE I, Judith F. Dotgos, Esquire, attorney for Chadd E. Ronk, hereby certify that I have served the foregoing MOTION, by placing a true and correct copy of the samE; in the U S Mail, First Class, postage pre-paid addressed as follows: RAYETTE I. SLOOP 428 CHESTNUT STREET MOUNT HOLLY SPRINGS, PA 1'?013 Date: January 9, 2003 SAMUEL L. ANDES, ESQUIRE 525 N. TWENTIETH STREET LEMO/,~PA 17043 ~ F. Dolgos '~'' ' CHAD E. RONK, Plaintiff Vo RAYETTE SLOOP, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-6989 CIVIL TERM ORDER OF COURT AND NOW, this 21st day of January, 2003, upon consideration of Plaintiff's Petition for Modification of Custody, with respect to the parties' children, Christian Robert Ronk (d.o.b. December 21, 1994) and Josie May Ronk (d.o.b. December 5, 1996), following a hearing held on January 16, 2003, and based upon the court's view as to the best interests of the children, it is ordered and directed as follows: 1. Legal custody of the children shall be shared by the parties; 2. Primary physical custody of the children shall be in Defendant, the mother. 3. Partial or temporary physical custody of the children shall be in Plaintiff, the father, at the following times: a. During the school year, (1) For three consecutive weekends out of four, from Friday at 6:00 p.m. until Sunday at 6:00 p.m.; provided, that where the following Monday is a national holiday the father's period of partial or temporary custody shall extend until Monday at 6:00 p.m.; (2) During any spring or Easter recess, from the first day of the recess at 6:00 p.m. until the last day of the recess at 6:00 p.m. b. During the summer, for four consecutive weeks at the beginning of the summer and for four consecutive weeks at the end of the summer. 4. Notwithstanding the foregoing, Defendant mother shall have physical custody of the children during each period of Christmas vacation until Christmas Day at 3:00 p.m., and Plaintiff father shall have physical custody of the children from Christmas Day at 3:00 p.m. until the day preceding resumption of school at 3:00 p.m. 5. For purposes of this order, school recesses and vacations shall include weekends. 6. Transportation for custody exchanges shall be shared by the parties, with Defendant mother being responsible for one round trip out of every three throughout the year and with Plaintiff father being responsible for the remaining round trips. 7. Defendant mother shall, within three weeks of the date of this order, begin individual counseling to deal with her problems with "moods" and for the purpose of learning better anger management. 8. Neither parent shall disparage the other in the presence of the children. 9. Nothing herein is intended to preclude the parties from deviating from the terms of this order by mutual agreement. BY THE COURT, q3/esleyO , ., . Judith F. Dolgos, Esq. I~ P.O. Box 60809 Harrisburg, PA~ 17106-0809 Attorney for Plaintiff Rayette I. Sloop 428 Chestnut Street Mt. Holly Springs, PA 17065 Defendant, Pro Se Samuel L. Andes, Esq. 525 N. 12th Street Lemoyne, PA 17043 Attorney for Minor Children :rc RAYETTE I. SLOOP, Plaintiff, Respondent CHADD E. RONK, Defendant, Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001.6989 CIVIL TERM IN CUSTODY PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY ORDER The Petition of CHADD E. RONK, respectfully represents- 1. That on January 21, 2003, Judge Wesley Oler, Jr., entered an Order awarding Petitioner partial custody of the minor children Christian Robert Ronk and Josie May Ronk. A true and correct copy of the order is attached to this petition. (Attachment A) 2. Respondent has willfully failed to abide by the order in that she refused to comply with paragraph 3(a) of the order, thereby causing father to miss his period of partial custody the w~ekends of February 21, 2003 and February 28, 2003. 3. Respondent has willfully failed to abide by the order further by refusing to comply with paragraph 6 of the order relevant to the transportation of the children. 4. This is the third time Respondent has been in violation of an Order relating to the partial custody of the minor children. 5. Petitioner filed a Petition for Special Relief on September 14, 2001, alleging Respondent had refused to produce the minor children for visitation for the period! of August 26, 2001 up until the date of a hearing set by the Court of October 15, 2001. 6. The Court granted Petitioner's Petition for Special Relief. A true and correct copy is attached to this petition. (Attachment B). 7. Respondent is currently in contempt of the order referred to in paragraph 6 above in that she has not made any attempt to pay the fines levied therein. 8. Respondent additionally has provided not proof that she is in compliance with paragraph 7 of the order of January 21, 2003, which requires mother to begin cc,Jnseling for her 'moods" and "anger management". 8. Respondent continues to put her interests and convienence before that of her children by refusing to comply with orders of this court and of the court of Juniata County. 9. Petitioner is filing with this Petition a Petition for Modification of Child Custody. 10. Said Petition for Modification of Child Custody is predicated on the recommendation of two previous custody psychological evaluations which recommend that continued interference by mother in father's relationship with the children should result in a change in primary custody. 9. Pdmary physical custody of the minor children should be amended, granting primary physical custody to Petitioner who has consistently been in compliance with all orders of this court and the previous court in Juniata County. WHEREFORE, Petitioner requests that Respondent be held in contempt of court, that primary physical custody be awarded to Petitioner/Father and in addition, that Respondent be ordered to pay Petitioner's attorney fees in the amount of $500.00 in addition to the $500.00 awarded on April 22, 2002. it is further requested that this court find the ongoing contempt of the April 22, 2002 order to be willful and apply any action available to the court pursuant to Pa. Rule 1915.14. Date: Respectfully submitted: Ju I F. Dolg°s " ' d Attorney for the Petitioner FROM :KRAMERS FAX NO. :7175419665 Feb. 56 200~ 10:15AM P2 I, Chadd E. Ronk, certifY that the statements made in tile fore~oJnl~ PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF CUSTODY ORDER, are true and correct to the best of my knowlec~e and belief. ! understand that false statements herein are made subject to the penalties of ][8 Pa. C.S.A. [4904, relatinl~ to unsworn falsification to au~oritJes. Chadd E. Ronk - --- EXHIBIT A CHAD E. RONK, Plaintiff Vo RAYETTE SLOOP, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND cOUlee, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-6989 CIVIL TERM ORDER OF COURT AND NOW, this 21st day of January, 2003, upen consideration of Plaintiff's Petition for Modification of Custody, with respect to the parties' children, Christian Robert Ronk (d.o.b. December 21, 1994) and' Josie May Ronk (d.o.b. December 5, 1996), following a hearing held on January 16, 2003, and based upon the court's view as to the best interests of the children, it is ordered and directed as fellows: 1. Legal custody of the children shall be. shared by the parties; 2. Primary physical custody of the children shall be in Defendant, the mother. 3. Partial or temporary physical custody of the children shall be in Plaintiff, the father, at the following times: a. During the school year, (1) For three consecutive weekends out of four, from Friday at 6:00 p.m. until Sunday at 6:00 p,m.; provided, ~that where the :following Monday is a national holiday the father's period of partial or temporary custody shall extend until Monday at 6:00 p.m.; (2) During any spring or Easter recess, from the first day of the recess at 6:00 p.m. until the last day of the recess at 6:00 p.m. b. During the summer, for four consecutive weeks at the beginning of the summer and for four consecutive weeks at the end of the summer. 4. Notwithstanding the foregoing, Defendant mother shall have physical custody of the children during each period of Christmas vacation until Christmas Day at 3:00 p.m., and[ Plaintiff father shall have physical custody of the children from. Christmas Day at 3:00 p.m. until the day.preceding resumption of school at. 3:00 p.m. 5. For purposes of this order, school recesses and vacations shall include weekends.. 6. Transportation for custody exchanges shall be shared by the parties, with Defendant mother being responsible for one round trip out of every three throughout the year and with Plaintiff father being responsible for the remaining round trips. 7. Defendant mother shall, within three weeks of the date of this order, begin individual counseling to deal with her problems with "moods" and for the purpose of learning better anger management. 8. Neither parent shall disparage the other in the presence of the children. 9. Nothing herein is intended to preclude the parties from deviating from the terms of this order by mutual agreement. BY THE COURT, 1, /~ .~ //7/ Judith F. Dolgos, Esq. P.O. Box 6'0809 Harrisburg, PA~ 17106-0809 Attorney for Plaintiff EXHIBIT B IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001-6989 CIVIL TERM IN CUSTODY ORDER OF COURT consideration of tl~ ~ Cus~od~ Condliali~n ~ it h o~ and d~d ~ follows: 1, Moiher, Rayet~ I. Sloop, willfully and inMntionally violated Para,apb 5 of the Order of Court of Fel~uar~ 12, 2002, r~luiring h~r to uar~pon tl~ dt/kiren on the first weekend visit with Father in Mar~h, 2002, 2. Motlzr is hereby found in Contompt of Court for viola~n of Paragraph of thc Order of Cour~ of February 12, 2002 as affirmed by tl~ Order of April 11, 2002. 3. A fm~ of $~00.00 is horeby imposed on Mother for violationof said Orders. Within thirty days of this Ordcr. Mother shall pay $250.00 to Fathex as teimbursemont for logal fees im'urred in thc filing of the Petition for Conmmp~. Mother is further ordor~ to pa~ $2S0.00 to xl~ Prothonotary of Cumb~lmd County. Failure to. pay said fmc within 30 day~ from th~ date of this Order may re, su~ in anofl~r finding of Contempt of Court. BY THE COURT., V~I~ Olaf, ~ t,...,j. e~:~om, as S. Di,0hl. Esquiro, oo-an~l .tor Mother //udith Dolgas, Esquire. oouns~l for Fatl~ CERTIFICATE OF SERVICE I, Judith F. Dolgo$, Esquire, attorney for Chadd E. Ronk, hereby certify that I have served the foregoing PETITION, by placing a true and correct copy of the same in the U $ Mail, First Class, postage pre-paid addressed as follows: RAYETTE I. SLOOP 428 CHESTNUT STREET MOUNT HOLLY SPRINGS, PA 17013 Date: By: RAYETTE I. SLOOP, Plaintiff, Respondent Vj' CHADD E. RONK, Defendant, Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001 .-6989 CIVIL TERM IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW comes Plaintiff/Petitioner CHADD E. RONK, ,and by and through his attorney, Judith F. Dolgos, Esquire, moves this Honorable Court to modify the existing child custody order, and in so asking represents the following: 1. Petitioner is Chadd E. Ronk, an adult individual currently residing at 6328 SR 103 South, McVeytown, Mifflin County, Pennsylvania 1 7051. 2. Respondent is Rayette I. Sloop, an adult individtJal currently residing at 428 Chestnut Street, Mount Holly Springs, Cumberland County, Pennsylvania 1 7013. 3. The parties are the natural parents of the children Christian Robert Ronk, age 8, born December 21, 1994; and Josie May Ronk, age 6, born De4:ember 5, 1996. The children were born in wedlock. 4. The parties are currently subject to an order of'this court dated January 21, 2003, a copy of which is attached hereto and made a part hereof at Exhibit A. 5. There were previous actions in custody in Juniata County prior to the change of venue granted to the defendant in this matter. All relevant filings are on file with this court. 6. Since the entry of the Court's order of January 21,2003, the children have been in the primary custody of the defendant. ?. The reasons that the Plaintiff wishes to modify the existing order are as follows: a. Respondent has willfull)f/failed to abide by tile order in that she refused to / comply with paragraph 3(a) of the order, therel~ causing father to miss his period of partial custody the weekends of February 21, 2003 and February 28, 2003. b. Respondent has willfully failed to abide by the order further by refusing to comply with paragraph 6 of the order relevant to the transportation of the children. c. Respondent has informed Petitioner that the Court order grants him too much time with the children and has insisted that Petitioner follow a schedule setforth by herself instead. d. Defendant's actions are interfering with ~the Petitioner's relationship with the minor children and is contrary to the order of the court. 8. Under direct testimony and in a report written to this Court, Arnold T. Shienvold, Ph.D., stated that Ms. Sloop was in need a individual counseling to deal with are problems associated with "moods" and for the purpose of learning better anger management. Dr. Shienvold further stated that" If Ms. Sloop does not participate in the recommended counseling and i£she does not encourage the relationship between the children and Mr. Ronk, the Court should reconsider the custodial arrangement and shift pr/mary physical custody to father. [emphasis added] 9. Despite the admonishment of Dr. Shienvold and of this Court, this .is the third time that Defendant/Respondent is in non-compliance with a court order regarding the custody or transportation of the children. 10. The Respondent is currently under contempt o~ an order by this Court dated April 22, 2002. Respondent has failed to pay the fine in accordance with paragraph 3 of said order. A copy of the order is attached hereto and made a part hereof at Exhibit B. 11. Petitioner has not received any confirmation of !Defendant's compliance with paragraph 5 of the January 21,2003 Order regarding psychological counseling. 12. Plaintiff is not remarried. 13. Defendant is remarried to Harold Sloop. 14. Plaintiff has not participated as a party or a witness in any other capacity in litigation concerning the children. 15. Plaintiff has no information regarding any custody proceeding concerning the children pending in any other Court of this Commonwealth. 16. Petitioner does not know of any person not a party to these proceedings who claims to have custody or visitation rights with respect to the children. 17. The children's best interest and welfare would be significantly improved by modifying the existing custody to shift primary physical custody to Petitioner. WHEREFORE, Plaintiff/Petitioner requests your Honorable Court to grant him primary custody, or in the alternative enter an Order scheduling a Custody Conciliation regarding this request for modification of custody. Respectfully submitted, Attorney for Plaintiff, Chadd E. Ronk ID 68738 PO Box 60809 Harrisburg, PA 17106-0809 717 541-9660 FROM :KRAMERS FAX NO. :7175419865 F~b. 26 2005 10:15AM P5 l, Chad~E:..ReRk,. cerfify*tha~.the, statements mad~:~--fl~fere~ob~--l~--T'~-tON .FGR MOOIFICATtON OF CHILO CUSTODY, are true and correct to the best of my knowiedge and belief. I understand that false statements herein are made subject to '~he penalties of 18 Pa. C.S,A. [ 4904, ~relating to unswor~ falsification to authorities. -Chadd E- Ronk ' EXHIBIT A CHAD E. RONK, . Plaintiff · RAYETTE SLOOP, - Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND C01YNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-6989 CIVIL TEPdVl ORDER OF COURT AND NOW, this 21st day of January, 2003, upon consideration of Plaintiff's Petition for Modification of Custody, with respect to the parties' children, Christian Robert Ronk (d.o.b. December 21, 1994) andJosie May Ronk (d.o.b. December 5, 1996), following a hearing held on January 16, 2003, and based upon the court's view as to the best interests of the children, it is ordered and directed as follows: 1. Legal custody of the children shall be. shared by the parties; 2. Primary physical custody of the children shall be in Defendant, the mother. 3. Partial or temporary physical custody of the children shall be in Plaintiff, the father, at the following times: a. During the school year, (1) For three consecutive weekends out of four, from Friday at 6:00 p.m. until Sunday at 6:00 p.m.; provided, .that where the :following Monday is a national holiday the father's period ~ of partial or temporary custody shall extend until Monday at 6:00 P.m.; (2) During any spring or Easter recess, from the first day of the recess at 6:00 :p.m. until the last day of the recess at 6:00 p.m. b. During the summer, for four consecutive weeks at the beginning of the summer and for four consecutive weeks at the end of the summer. 4. Notwithstanding the foregoing, Defendant mother shall have physical custody of the children during each ]period of Christmas vacation until Christmas Day at 3:00 p.m., and Plaintiff father shall have physical custody of the children from, Christmas Day at 3:00 p.m. until the day.preceding resumption of school at 3:00 p.m. 5. For purposes of this order, school recesses and vacations shall include weekends. 6. Transportation for custody exchanges shall be shared'by the parties, with Defendant mother being resp6nsible for one round trip out of every three throughout the year and with Plaintiff father being responsible for the remaining round trips. 7. Defendant mother shall, within three weeks of the date of this order, begin individual counseling to deal with her problems with "moods" and for the purpose of learning better anger management. 8. Neither parent shall disparage the other irt the presence of the children. 9. Nothing herein is intended to preclude the parties from deviating from the terms of this order by mutual agreement. BY THE COURT,, Vesley Oler,Z~',~ - ~:i' Judith F. Dolgos, Esq. P.O. Box 60809 Harrisburg, PA~ 17106-0809 Attorney for Plaintiff EXHIBIT B RAYETTE L (RONIO SLOOP, V. CRADD E. RONK. Defcud~m IN THE COURT 01~ COMMON PLI~ OF CUMBERLAND COUNTY, PENNSYLVANIA CIV~ ACTION - LAW NO. 2001-6989 CIVIL TERM IN CUSTODY ORDER OF COURT I., Mother, Rayette I. Sloop, willfully a~d intentionally violated Pm'a~aph of the Order of Court of February 12, 2002, r~quiring her to transport th~ ch/ldren on the first weekend visit.with Father in Mm'ch, 2002. . 2. Mother is hereby found hi Contempt of Court for violation of Paragraph of thc Order of'Cour~ of February 12, 2002 am afl'mued by the Order of Apr/{ ! 1, 2002. 3. A fine of $$00,00 is hereby hnpas~d on Mother for viohuion of said Orders. With/n thirty days of this Order, Mo/her shall pay $2~0.00 to Father as reimbursemon! for legal fees incurred in thc filing of the Petition for ContainS. Mother is further ordered to pay $250.00 to fl~e Prothonotary of Cumberlaud County, Failure to. pay t~/d frae within 30 days from Contempt of Court. ~ da~e of this Order ma)- rest{It in another finding of CERTIFICATE OF SERVICE I, Judith F. Doigos, Esquire, attorney for Chadd E. Ronk, hereby certify that I have served the foregoing PETITION, by placing a true and correct copy of the same in the U S Mail, First Class, postage pre-paid addressed as follows: RAYETTE I. SLOOP 428 CHESTNUT STREET MOUNT HOLLY SPRINGS, PA 17013 Date: Judi~ F. D°lgo~ / C) ' Attorney for Plaintiff, Chadd E. Ronk ID 68738 PO Box 60809 Harrisburg, PA 17'106-0809 7] 7 541-966O CHADD E. RONK, Plaintiff V. RAYETTE I. SLOOP, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 2001-6989 CIVIL TERM CIVIL ACTION - FAMILY DIVISION CUSTODY PETITION FOR CUSTODY AND NOW, comes Plaintiff CHADD E. RONK, and by his attorney, Judith F. Dolgos, respectfully represents as follows: 1. Plainti~t, CHADD E. RONK, is an adult individual sui iuds, residing at 6328 SR 103 South, McVeytown, Pennsylvania, 17051. 2. Defendant, RAYETTE I. SLOOP, is an adtdt individual sui iuris, residing at 428 Chestnut Street, Mount Holly Springs, Cumberland County, Pennsylvania. 3. Plaintiff artd defertdant have been bonafide residents of this Commonwealth for at least six (6) months immediately previous Io the filing of this Petition. 4. Plaintiff requests an award of legal custody and pdmary physical custody of the minor children, Christian Robert Ronk, age 8, bom December 21, 1994 and Josie May Ronk, age 6, born December 5, 1996. 5. The children are presently in the physical custody of the plaintiff. 6. The mother of the child is Rayette I. Sloop, defendant in the instant action. 7. The father of the child is Chadd E. Ronk, ptaintitf in the instant action. 8. The children are currently subject to a custody order dated January 21, 2003. 9. No person(s) not a party to this transaction, are known to the plaintiff to have had physical custody or claims to custody or visitation with regard to the said minor child. 10. The best interest and permaae~t we{fare of the said children will be served by 10. The best interest and permanent welfare c,f the said children will be served by granting legal custody and primary physical custody to plaintiff, because of numerous benefits to the child which would result from this ongoing stable relationship and the care and love that would be provided to them. 11. Each parent whose parental rights to the c~,~ild have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests this Honorable Court to enter an Order granting legal and primary physical custody of the minor children Christian Robert Ronk and Josie May Ronk to plaintiff. / By: Respectfully submitted, · h F. Dolgos, Esq~re omey ID 68738 P.C). Box 60809 Harrisburg, PA 17106-0809 (71 7) 541-9660 Attorney for Plaintiff VERIFICATION relating to unsworn falsifications to authorities. Dated: ~-,~- 3- ~)~.~ I verify that the statements made in this Petition for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4901 VERIFICATION I verify that the statements made in this Petition for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. CS ~4901 relating to unsworn falsifications to authorities. Rayette I. Sloop CHADD E. RONK, Plaintiff RAYETTE I. SLOOP, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 2001-6989 CIVIL TERM CIVIL AC'I'ION - FAMILY DIVISION CUSTODY JOINDER FOR CUSTODY AND NOW, comes Defendant, RAYETTE I. SLOOP, and respectfully represents as follows: 1. The address of defendant is 428 Chestnut Street, Mount Holly Springs, Carlisle, Cumberland County, Pennsylvania. Ronk. Defendant is the mother of the minor children, Christian Robert Ronk and Josie May 3. Plaintiff is the father of the minor children, Christian Robert Ronk and Josie May Ronk. 4. Defendant has reviewed plaintiff's Petition for legal custody and primary physical custody of the said minor children and joins in plaintiff's request that primary physical custody of, Christian Robert Ronk and dosie May Ronk be with the plaintiff.. 5. Plaintiff and defendant agree that such custody arrangement is in the best interest of the minor children. WHEREFORE, Defendant RAYETTE I. SLOOP, joins with plaintiff in requesting this Honorable Court grant the p/aintiff hereto lega! and primary physical custody of minor children~hri ls~ Robert Ronk ~AYE~ I. SLOOP ~ CHADD E. RONK, Plaintiff RAYETTE I. SLOOP, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 2001-6989 CIVIL TERM CIVIL ACTION. FAMILY DIVISION CUSTODY PETITION FOR WITHDRAWAL OF ACTION TO THE PROTHONOTARY: Please withdraw the following Petitions on behalf of Plaintiff Chadd E. Ronk: 1. Petition for Modification of Custody Order entered March 3, 2003, and; 2. Petition for Civil Contempt for Disobedience of Custody Order entered March 3, 2003. The parties to this matter have reached an agreement as to the custody of the minor children outside of court action. Their agreements are contained within a Joinder Agreement filed with this Petition. Date: March 5, 2003 Respectfully :submitted, Harrisburg, PA 17106 717 541-9660 CERTIFICATE OF SERVICE I, Judith F. Dolgce, Esquire, attorney for Chadd E. Ronk, hereby certify that I have served the foregoing Petition, by placing a true and correct copy of the same in the U S Mail, First Class, postage pre-paid addressed as follows: RAYETTE I. SLOOP 428 CHESTNUT STREET MOUNT HOLLY SPRINGS, PA 17013 Date: March 5, 2003 By: ~fomey for Plaintiff CHADD E. RONK PLAINTIFF RAYETTE I. SLOOP DEFENDANT IN THE COURT OF ~OMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-6989 CIVIL ACTION LAW IN C'USTODY ORDER OF COURT AND NOW, Thursday, March 13, 2003 ~ upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jaequeline M. Verney, Esq. , the conciliator, at 4th Floor, C,mberland County Courthouse, Carlisle on Thursday, April 03, 2003 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and-to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE CO'URT~ By: /s/ Jacqueline M. Vern~, Esq. Custody Conciiliator The Court of Common Pleas of Cumberland County is requiired 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 bel:'ore 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 ATTOR2CEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU' CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 CHADD E. RONK, Plaintiff Vo RAYETTE I. SLOOP, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 200~1-6989 CIV;L TERM CIVIL ACTION - FAMILY DIVISION CUSTODY ORDER OF COURT A. .oW, ~ ~/~j~a~l~ ~ ~ .~ , 2003, ,frei consideration of the Plaintiff's Petition for Custody, it is hereby ordered and decreed that Plain{~, Chadd E. Ronk, is granted legal and primary physical custody of the minor children, Christian Robert Ronk and Josie May Ronk, as agreed to between the parties. BY THE COURT: