HomeMy WebLinkAbout10-1521FILED-UTICE
Frank C. Sluzis, Esquire ( THE PROTMTAR1(
Attorney I.D. No. 43829 1010 MAR -4 PM 12: 59
Scaringi & Scaringi, P.C.
2000 Linglestown Road, Suite 106 ;D. ",
Harrisburg, PA 17110 CUEJI?`.??`'"?° "? ?`,?+.,?.1t?'Y
(717)657-7770 PEf`JPvSYLV`IA
Attorney for Plaintiff
JEFFREY J. ZENDAL, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
. NO.: 2010- /5a V VI
ANGELA M. BRUNGARD, CIVIL ACTION -LAW
Defendant IN CUSTODY
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 the 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 the Cumberland County Courthouse, One Courthouse Square, Carlisle,
Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S 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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013-3308
(717)249-3166 SJGf ZiS
Cllr ;3
?? d3? ti0
Americans with Disabilities Act of 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact the Court Administrator's office at (717) 240-6200. 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 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. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166
Frank C. Sluzis, Esquire
Attorney ID# 43829
Scaringi & Scaringi, P.C.
2000 Linglestown Road, Suite 106
Harrisburg, PA 17110
717-657-7770
frankna,scaringi law.com
JEFFREY J. ZENDAL
Plaintiff
V.
ANGELA M. BRUNGARD
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2010- ` C
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY COMPLAINT
AND NOW, comes the Plaintiff, Jeffrey J. Zendal, by and through his attorney, Frank C.
Sluzis, Esquire and the law firm of Scaringi & Scaringi, P.C., who files this Custody Complaint
and avers as follows:
1. Plaintiff, Jeffrey J. Zendal, an adult individual, is the biological Father of the subject
minor child and currently resides at 13 Andes Drive, Mechanicsburg, Cumberland
County, Pennsylvania 17055.
2. Defendant, Angela M. Brungard, an adult individual, is the biological Mother of the
subject minor child and currently resides at 806 Grantham Road, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
3. The subject minor child is Jackson T. Brungard, born December 1, 2009.
4. Plaintiff seeks shared legal and shared physical custody of the subject minor child.
5. The subject minor child, Jackson T. Brungard, is presently in the partial physical
custody of Angela M. Brungard, 806 Grantham Road, Mechanicsburg, Pennsylvania,
17055.
6. During the child's lifetime, the subject minor child has resided with the following
persons and at the following addresses:
ADDRESSES
PERSONS
DATES
Jeffrey J. Zendal
13 Andes Drive
Mechanicsburg, PA 17055
Angela M. Brungard
806 Grantham Road
Mechanicsburg, PA 17055
December 2009-present
December 2009-present
7. The mother of the subject minor child is Angela M. Brungard, who resides at 806
Grantham Road, Mechanicsburg, Cumberland County, Pennsylvania 17055.
8. The father of the subject minor children is Jeffrey J. Zendal, who resides at 13 Andes
Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055.
9. The Plaintiff currently resides with the following persons:
NAME
Jackson T. Brungard
RELATIONSHIP
Child Age 3 months
10. The Defendant currently resides with the following persons:
NAME
Jackson T. Brungard
James Volpicelli
RELATIONSHIP
Child Age 3 months
Mother's Boyfriend
11. Plaintiff has not participated as a party or witness, or in any other capacity, in other
litigation concerning custody of the subject minor child in this or any other court.
Plaintiff has no information of a custody proceeding concerning the subject minor
child pending in a court of this Commonwealth. Plaintiff does not know of a person
not a party to the proceeding that has physical custody of the subject minor child or
claims to have custody or visitation rights with respect to the subject minor child.
12. The best interest and permanent welfare of the subject minor child will be served by
granting the relief requested because Plaintiff is the biological father of the subject
minor child and has been and continues to be an actively involved parent and
caretaker of the subject minor child and up until very recently enjoyed a shared
physical custody arrangement
13. Each parent whose parental rights to the subject minor child have not been terminated
and the persons who have physical custody of the subject minor has been named as
parties to this action. All other persons, named below, who are known to have a right
to custody or visitation of the subject minor child will be given notice of the
pendency of this action and the right to intervene: NONE
WHEREFORE, Plaintiff Jeffrey J. Zendal, respectfully requests this
Honorable Court grant to Plaintiff shared legal custody and shared physical custody of the
subject minor child.
VSluzis, C.
BDate:- y- ?0
Scaringi & Scaringi, P .C.
2000 Linglestown Road, Suite 106
Harrisburg, PA 17110
717-657-7770
frank scarin ilaw.com
By:
Megan E. Castor, Esquire
Attorney ID# 89939
Scaringi & Scaringi, P.C.
2000 Linglestown Road, Suite 106
Harrisburg, PA 17110
717-657-7770
megan ,scaringilaw.com
I verify that the facts set forth in the foregoing pleading are true and correct to the
best of my knowledge, information and belief.
I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. Section 4904, relating to unsworn falsification to authorities.
Date: 10
-3 1 b / /
JEFFREY J. ZENDAL IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
ANGELA M. BRUNGARD
DEFENDANT
2010-1521 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, March 10, 2010 _ 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 41h Floor, Cumberland County Courthouse, Carlisle Oil Tuesday, April 06, 2010 at 8:30 AM
..... _..... __ .......... --__ ..... . ...... ...... _ ....._.
tier a Pre-Hearings Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot he accomplished, to define and narrow the issues to he heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ ac uelrne M. Verne Es .
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTfI 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
FLE- 7 -i
`T THE '?.. ,mss r< }?
2010 MAR 12 AM 11, 00
JUN 0 7 2010
JEFFREY J. ZENDAL,
Plaintiff
V.
ANGELA M. BRUNGARD,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0.2010-1521
CIVIL ACTION -LAW
IN CUSTODY
ORDER OF COURT
Q
AND NOW, this y day of V G/ a! ~ , 2010, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Order of Court dated April 8, 2010 shall remain in full force and
effect with the following modifications.
2. Holidays:
A. Memorial Day, July 4th and Labor Day shall be shared 9:00 a.m. to
3:00 p.m. and 3:00 p.m. to 9:00 p.m. with the parent having overnight
physical custody on the day before the holiday having the earlier time.
B. Thanksgiving shall be divided 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to
9:00 p.m. with Mother having the earlier time in even numbered years and
the later time in odd numbered years and the Father having the earlier time
in odd numbered years and the later time in even numbered years.
C. Christmas/Hanukkah. Christmas shall be divided into two Blocks.
Block A is from 5:00 p.m. Christmas Eve to 5:00 p.m. Christmas Day and
Block B shall be from 5:00 p.m. Christmas Day to 5:00 p.m. on December
26. Mother shall always have Block A and Father shall always have
Block B. In addition, Father shall have physical custody from 7:30 p.m. to
8:30 p.m. for the days of Hanukkah that he does not already have physical
custody of the child. However, Father shall accommodate Mother's
Christmas Day plans by extending her time past 5:00 p.m.
D. Mother shall always have physical custody of the child on Easter from
9:00 a.m. to 9:00 p.m. In the event that Easter falls on Father's weekend,
Father shall have makeup time on the next weekend, 9:00 a.m. to 9:00
p.m.
3
E. Mother shall always have physical custody of the child on Mother's
Day from 9:00 a.m. to 9:00 p.m. Father shall always have physical custody
of the child on Father's Day from 9:00 a.m. to 9:00 p.m.
F. Child's Birthday. The child's birthday shall be shared and alternated
9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. with Father having
physical custody for the earlier time in even numbered years and the later
time in odd numbered years. Mother shall have the earlier time in odd
numbered years and the later time in even numbered years.
3. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY THE COURT,
Edward E Guido, J,
/cc: Frank C. Sluzis, Esquire, Counsel for Father
t/ Peter Russo, Esquire, Counsel for Mother ~? a :~:;
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JEFFREY J. ZENDAL, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V• : N0.2010-1521 CIVIL ACTION -LAW
ANGELA M. BRUNGARD, .
Defendant : IN CUSTODY
PRIOR JUDGE: Edward E. Guido, 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 Child who is the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Jackson T. Brungard December 1, 2009 shared
2. A Conciliation Conference was held in this matter on June 7, 2010, with
the following in attendance: The Father, Jeffrey J. Zendal, with his counsel, Frank C.
Sluzis, Esquire, and the Mother, Angela M. Brungard, with her counsel, Peter Russo,
Esquire.
3. The Honorable Edward E. Guido previously entered and Order of Court
dated Apri18, 2010 providing for shared legal custody and shared physical custody.
4. The parties agreed to an Order in the form as attached.
Date: ~ - 7 `/ 4 ~(.
ac line M. Verney, Esquire
Custody Conciliator
JEFFREY J. ZENDAL,
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: IN THE COURT OF COMMON PLEAS OF
: NO. 2010 -1521 CIVIL
ANGELA M. BRUNGARD, : CIVIL ACTION — LAW
Defendant : IN CHILD CUSTODY
Prior Judicial assignment: Edward E. Guido, Judge
Prior Conciliator: Jacqueline M. Verney, Esquire
FATHER'S PETITION FOR MODIFICATION OF CHILD CUSTODY
AND NOW, comes Plaintiff, Jeffrey J. Zendal, by and through his counsel, Linda A.
Clotfelter, who files this Petition to for Modification of Child Custody and in support thereof
respectfully states the following:
1. Petitioner is Jeffrey J. Zendal, (hereinafter "Father"), an adult individual who
resides at 13 Andes Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. Father's
Criminal Record Abuse History Verification is being filed concurrently with this Petition.
2. Respondent is Angela M. Brungard, (hereinafter "Mother"), an adult individual
who resides at 5 West Green Street, Shiremanstown, Cumberland County, Pennsylvania 17011.
3. The parties are the natural parents of three (3) children, namely, Jackson T.
Brungard, born in December 1, 2009 (age 5 years); Ava M. Brungard, born September 12, 2011
(age 3 years); and Kendall R. Brungard, born March 4, 2014 (age 9 months) (hereinafter the
"Children").
4. There are two prior Orders of Court in this case dated April 8, 2010 and June 8,
2010, granting the parties shared legal and physical custody of the parties' eldest child, Jackson,
using a 2-2-3 schedule. True and correct copies of the Orders are attached hereto collectively as
Exhibit "A" and are incorporated herein.
5. The parties have had two additional children out of wedlock since the entry of thecasug4 (,fid
prior Orders. I 3
C)� 3S71
1; 31500
6. Because Mother moved from the family residence on November 21, 2014, Father
now seeks to modify the prior Orders to include the two younger children and continue with
shared legal and physical custody of the Children as per the prior Orders.
7. Father also believes that the best interest and permanent welfare of the Children
will be served by granting the parties shared legal and physical custody for the following
reasons:
a. Father, who has in the last year been a stay-at-home Dad and the primary
caregiver of the parties' nine (9) month child while Mother worked, wishes to
continue to maximize the both parties' time with the Children in a way that meets
their work schedules once he finds full time employment.
b. Father is able to provide a stable, loving and nurturing environment for the
Children in the family home which is most familiar to them and there is no reason
to minimize either parent's time with the Children.
WHEREFORE, Father respectfully requests that this Court enter an Order awarding the
parties shared legal and physical custody of their three (3) children as per the prior Order of
Court entered in this case and granting such other relief as this Court deems just and proper.
Date: 1))
Respectfully submitted,
LAW FIRM OF LINDA A. CLOTFELTER
da A. Clotfelter, Esquire
orney ID No. 72963
76 Market Street, Suite 100
Camp Hill, PA 17011
(717) 796-1930 telephone
(717) 796-1933 facsimile
Attorney for Petitioner
JEFFREY J. ZENDAL, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 2010 -1521 CIVIL
ANGELA M. BRUNGARD, : CIVIL ACTION — LAW
Defendant : IN CHILD CUSTODY
VERIFICATION
I, JEFFREY J. ZENDAL, verify that the statements in the foregoing FATHER'S
PETITION FOR MODIFICATION OF CHILD CUSTODY ORDER are true and correct to the
best of my knowledge, information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to
authorities.
Date: %a"//z/V
JEFF R I, J. KENDAL, Plaintiff
APR 0s2010
JEFFREY J. ZENDAL, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
ANGELA M. BRUNGARD
: NO. 2010-1521
Defendant : IN CUSTODY
ORDER OF COURT
AND NOW, this / day of, 2010, upon
consideration of the attached Custody Concili tion Report, it is ordered and directed as
follows:
CIVIL ACTION - LAW
111 Tr•
cr.
C7+
1. The Father, Jeffrey J. Zendal and the Mother, Angela M. Brungard, shall
have shared legal custody of Jackson T. Brungard, born December 1, 2009. Each parent
shall have an equal right, to be exercised jointly with the other parent, to make all major
non -emergency decisions affecting the Child's general well-being including, but not
limited to, all decisions regarding his health, education and religion. Pursuant to the
terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information
pertaining to the child including, but not limited to medical, dental, religious or school
records, the residence address of the child and the other parent. To the extent one parent
has possession of any such records or information, that parent shall be required to share
the same, or copies thereof, with the other parent within such reasonable time as to make
the records and information of reasonable use to the other parent. Both parents shall be
entitled to full participation in all educational and medical/treatment planning meetings
and evaluations with regard to the minor child. Bach parent shall be entitled to full and
complete information from any physician, dentist, teacher or authority and copies of any
reports given to them as parents including, but not limited to: medical records, birth
certificates, school or educational attendance records or report cards. Additionally, each
parent shall be entitled to receive copies of any notices which come from school with
regard to school pictures, extracurricular activities, children's parties, musical
presentations, back -to -school nights, and the like.
2. The parents shall have shared physical custody on the following schedule:
A. Father shall have physical custody of the child every Monday
beginning at 7:30 p.m. to Wednesday morning at 9:30 a.m. and
alternating weekends beginning April 9, 2010, Friday at 7:30 p.m. to
Monday at 9:30 a.m.
B. Mother shall have physical custody of the child every Wednesday
from 9:30 a.m. to Friday at 7:30 p.m. and alternating weekends from
Friday at 7:30 p.m. to Monda at 7:30 •.m.
i
3. Mother shall have physical custody of the child while Father is working.
4. Mother shall have physicalcustody of the child on Mother's Day from
9:30 a.m. to 7:30 p.m.
5. Father shall be responsible for all transportation.
6. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control. Another
Custody Conciliation Conference is scheduled for June 7, 2010 at 8:30 a.m.
BY THE CO
ii,',,i)
C. Sluzis, Esquire, Counsel for Father
Peter Russo, Esquire, Counsel for Mother
q/q//6
J.
JUN 0 7 2010
JEFFREY J. ZENDAL, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2010-1521 CIVIL ACTION - LAW
ANGELA M. BRUNGARD,
Defendant : IN CUSTODY
QRDER OF COURT
AND NOW, this 5til day of 1J A/ L. , 2010, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Order of Court dated April 8, 2010 shall remain in full force and
effect with the following modifications.
2. Holidays:
A. Memorial Day, July 4th and Labor Day shall be shared 9:00 a.m. to
3:00 p.m. and 3:00 p.m. to 9:00 p.m. with the parent having overnight
physical custody on the day before the holiday having the earlier time.
B. Thanksgiving shall be divided 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to
9:00 p.m. with Mother having the earlier time in even numbered years and
the later time in odd numbered years and the Father having the earlier time
in odd numbered years and the later time in even numbered years.
C. Christmas/Hanukkah. Christmas shall be divided into two Blocks.
Block A is from 5:00 p.m. Christmas Eve to 5:00 p.m. Christmas Day and
Block B shall be from 5:00 p.m. Christmas Day to 5:00 p.m. on December
26. Mother shall always have Block A and Father shall always have
Block B. In addition, Father shall have physical custody from 7:30 p.m. to
8:30 p.m. for the days of Hanukkah that he does not already have physical
custody of the child. However, Father shall accommodate Mother's
Christmas Day plans by extending her time past 5:00 p.m.
D. Mbther shall always have physical custody of the child on Easter from
9:00 a.m. to 9:00 p.m. In the event that Easter falls on Father's weekend,
Father shall have makeup time on the next weekend, 9:00 a.m. to 9:00
p.m.
E. Mother shall always have physical custody of the child on Mother's
Day from 9:00 a.m. to 9:00 p.m. Father shall always have physical custody
of the child on Father's Day from 9:00 a.m. to 9:00 p.m.
F. Child's Birthday. The child's birthday shall be shared and alternated
9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. with Father having
physical custody for the earlier time in even numbered years and the later
time in odd numbered years. Mother shall have the earlier time in odd
numbered years and the later time in even numbered years.
3. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY THE COURT,
Edward E Guido,
✓cc: Frank C. Sluzis, Esquire, Counsel for Father
I/ Peter Russo, Esquire, Counsel for Mother
cq4.04 ,„, tek//4
JEFFREY J. ZENDAL, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 2010 -1521 CIVIL
ANGELA M. BRUNGARD, : CIVIL ACTION — LAW
Defendant : IN CHILD CUSTODY
yy CERTIFICATE OF SERVICE
AND NOW, this A9 Ly of December, 2014, the undersigned hereby certifies that a true
and correct copy of the Father's Petition for Modification of Child Custody Order and two (2)
Criminal/Abuse Affidavits upon the interested parties by United States First Class Mail, postage
prepaid, addressed as follows:
Dated: 0) /14 4CJ /Pi
Peter J. Russo, Esquire
5006 E. Trindle Road, Suite 203
Mechanicsburg, PA 17050
Respectfully submitted,
LAW FIRM OF LINDA A. CLOTFELTER
a A. Clotfelter, Esquire
rney ID No. 72963
6 Market Street, Suite 100
Camp Hill, PA 17011
(717) 796-1930
Attorney for Plaintiff
JEFFREY J. ZENDAL,
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA[
vs. : NO. 2010 -1521 CIVIL
ANGELA M. BRUNGARD, : CIVIL ACTION — LAW
Defendant : IN CHILD CUSTODY
: IN THE COURT OF COMMON PLEAS OF
CRIMINAL RECORD / ABUSE HISTORY VERIFICATION
I, JEFFREY J. ZENDAL, hereby swear or affirm, subject to penalties of law including 18
Pa.C.S. § 4904 relating to unsworn falsification, to authorities that:
1. Unless indicated by my checking the box next to a crime below, neither I nor any
other member of my household have been convicted or pled guilty or pled no contest or was
adjudicated delinquent where the record is publicly available pursuant to the Juvenile Act, 42
Pa.C.S. §6307 to any of the following crimes in Pennsylvania or a substantially equivalent crime
in any other jurisdiction, including pending charges:
Check
all that
apply
Crime
❑ 18 Pa.C.S. Ch. 25 (relating to
criminal homicide)
O 18 Pa.C.S. §2702 (relating to
aggravated assault)
O 18 Pa.C.S. §2706 (relating to
terroristic threats)
Self Other Date of Sentence
household conviction,
member guilty plea, no
contest plea or
pending
charges
❑ ❑
O 0
0 0
0
El 18 Pa.C.S. §2709.1 (relating to
stalking)
El 18 Pa.C.S. §2901 (relating to
kidnapping)
El 18 Pa.C.S. §2902 (relating to
unlawful restraint)
O 18 Pa.C.S. §2903 (relating to
false imprisonment)
18 Pa.C.S. §2910 (relating to
luring a child into a motor
vehicle or structure)
O 18 Pa.C.S. §3121 (relating to
rape)
O 18 Pa.C.S. §3122.1 (relating to
statutory sexual assault)
18 Pa.C.S. §3123 (relating to
involuntary deviate sexual
intercourse)
O 18 Pa.C.S. §3124.1 (relating to
sexual assault)
18 Pa.C.S. §3125 (relating to
aggravated indecent assault)
18 Pa.C.S. §3126 (relating to
indecent assault)
O 18 Pa.C.S. §3127 (relating to
indecent exposure)
O 0
O 0
18 Pa.C.S. §3129 (relating to
sexual intercourse with animal)
18 Pa.C.S. §3130 (relating to
conduct relating to sex offenders)
18 Pa.C.S. §3301 (relating to
arson and related offenses)
O 18 Pa.C.S. §4302 (relating to
incest)
El 18 Pa.C.S. §4303 (relating to
concealing death of child)
18 Pa.C.S. §4304 (relating to
endangering welfare of children)
18 Pa.C.S. §4305 (relating to
dealing in infant children)
El 18 Pa.C.S. §5902(b) (relating to
prostitution and related offenses)
O 18 Pa.C.S. §5903(c) or (d)
(relating to obscene and other
sexual materials and
performances)
18 Pa.C.S. §6301 (relating to
corruption of minors)
O 18 Pa.C.S. §6312 (relating to
sexual abuse of children)
18 Pa.C.S. §6318 (relating to
unlawful contact with minor)
O 0
O 0
O 0
O 0
O 0
O 0
O 0
O 0
O 0
18 Pa.C.S. §6320 (relating to
sexual exploitation of children)
O 23 Pa.C.S. § 6114 (relating to
contempt for violation of
protection order or agreement)
O Driving under the influence of
drugs or alcohol
O 0
O 0
O 0
Manufacture, sale, delivery, 0
holding, offering for sale or
possession of any controlled
substance or other drug or device
2. Unless indicated by my checking the box next to an item below, neither I nor any
other member of my household have a history of violent or abusive conduct including the
following:
Check Self Other Date
all that household
apply member
El A finding of abuse by a Children & Youth 0 0
Agency or similar agency in Pennsylvania
or similar statute in another jurisdiction
Abusive conduct as defined under the
Protection from Abuse Act in
Pennsylvania or similar statute in another
jurisdiction
0 Other: 0 0
3. Please list any evaluation, counseling or other treatment received following
conviction or finding of abuse:
4. If any conviction above applies to a household member, not a party, state that
person's name, date of birth and relationship to the child.
5. If you are aware that the other party or members of the other party's household
has or have a criminal/abuse history, please explain:
I verify that the information above is true and correct to the best of my knowledge,
information or belief. I understand that false statements herein are made subject to the penalties
of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
K
JEFFREY J. ZEAI,
JEFFREY J. ZENDAL
PLAINTIFF
ANGELA M. BRUNGARD
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVAN1
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2010-1521 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Monday, January 05, 2015 , 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 County Courthouse, Carlisle on Wednesday, January 21, 2015 10:30 AM
for a Pre -Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this
cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure
to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief
orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
You must file with the Court a verification regarding any criminal record or abuse history regarding you and
anyone living in your household on or before the initial in-person contact with the court (including, but not limited to,
a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition.
No party may make a change in the residence of any child which significantly impairs the ability of the other party
to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and
Pa.R.C.P. No. 1915.17 regarding relocation.
FOR THE COURT,
By: /s/ Jacqueline M. Verney, Esq.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with
Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled
individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior
to any hearing or business before the court. You must attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN
ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
Ct;pi' Aca,.e0'
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Cumberland County Bar Association.
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166