Loading...
HomeMy WebLinkAbout04-3477 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04 - 3'f77 l2ju~L'-r~ CIVIL ACTION - LAW CUSTODY BRENDA K. BROWNEWELL, Plaintiff vs. MARK D. ISENBERG, Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is BRENDA K. BROWNEWELL, residing at 61 Partridge Circle, Carlisle, Cumberland County, pennsylvania 17013. 2. The Defendant is Mark D. Isenberg, residing at 752 petersburg Road, Carlisle, Cumberland County, pennsylvania 17013. 3. Plaintiff seeks custody of the following child: NAME PRESENT ADDRESS Taylore M. Brownewell 752 Petersburg Rd. Carlisle, PA 17013 The child was not born out of wedlock. AGE 4 (dob 1/14/00) The child is presently in the custody of Defendant who resides at 752 Petersburg Road, Carlisle, Cumberland County, Pennsylvania 17013. Since birth, the child has resided with the following persons at the following addresses: PERSON ADDRESS Plaintiff & Defendant 216 Hill Street, Mt. Holly Springs, PA 17065 Plaintiff & Defendant 752 Petersburg Road Carlisle, PA 17013 Plaintiff 61 Partridge Circle Carlisle, PA 17013 Defendant 752 Petersburg Road Carlisle, PA 17013 DATE Birth - 8/02 8/02 - 8/03 8/03 - 6/1/04 6/1/04 - Present IV ~ "IQ.. - fI:. ..... [, 9 r.' ....... 1::. CI1 (.. _.~. - ,'I t tJ () , - -..,'" w .'---' . ,<J ~ ~ 1J ---', ~ ; --.J -. - ~ L) '- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04 - JLf77 l2iu~L'-r~ CIVIL ACTION - LAW CUSTODY BRENDA K. BROWNEWELL, Plaintiff vs. MARK D. ISENBERG, Defendant COMPLAINT FOR CUSTODY 1. The Plaintiff is BRENDA K. BROWNEWELL, residing at 61 Partridge Circle, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Mark D. Isenberg, residing at 752 Petersburg Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the following child: NAME PRESENT ADDRESS Taylore M. Brownewell 752 Petersburg Rd. Carlisle, PA 17013 The child was not born out of wedlock. AGE 4 (dob 1/14/00) The child is presently in the custody of Defendant who resides at 752 Petersburg Road, Carlisle, Cumberland County, Pennsylvania 17013. Since birth, the child has resided with the following persons at the following addresses: PERSON ADDRESS Plaintiff & Defendant 216 Hill Street, Mt. Holly Springs, PA 17065 Plaintiff & Defendant 752 Petersburg Road Carlisle, PA 17013 Plaintiff 61 Partridge Circle Carlisle, PA 17013 Defendant 752 Petersburg Road Carlisle, PA 17013 DATE Birth - S/02 S/02 - S/03 S/03 - 6/1/04 6/1/04 - Present The mother of the child, Plaintiff Brenda K. Brownewell, is currently residing at 61 partridge Circle, Carlisle, Cumberland County, Pennsylvania 17013. She is married to Defendant. The father of the child, Defendant Mark D. Isenberg, is currently residing at 752 Petersburg Road, Carlisle, Cumberland County, Pennsylvania 17013. He is married to Plaintiff. 4. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with her mother and other daughter Amber A-M Brownewell. 5. The relationship of Defendant to the child is that of father. The Defendant currently resides with his mother and the subject child. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the said child. 7. The best interests and permanent welfare of the subject child will be served by granting Plaintiff primary physical custody of her because she has been and is the more nurturing parent during the child's life, can better provide for her needs and is better able than Defendant not to put their child in the middle of disagreements between them. 8. Each parent whose parental rights to the children has not been terminated and the persons who have physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff requests the Court to grant her custody of the children the subject hereof. DATED: 6-29-04 Respectfully Submitted: ~~(i( HERSCHEL LOCK, ESQUIRE ATTORNEY FOR PLAINTIFF 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 VBRIFICATIO~ I verify that the statements made ~n the foregoing are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. section 4904 relating to unsworn falsification to authorities. DATED: 6-29-04 trZL,fLtI#:Cr< ~/U I( IA{ ~ jBRENDA K.' B~~ELL N (::J "'IQ. 'i ::::: "It 0 r,_) ,--_: "- 1::. CI) c ~ " tl - (} , -,-,;q t w ...- )---- ~ ~ V \.<'J .-c-' , p:: - ; -..J - ".- ~ ,~ ~ , BRENDA K, BROWNEWELL PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 04-3477 CIVIL ACTION LAW MARK D. ISENBERG DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, July 22, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, AUl(ust 18, 2004 at 8:30 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 conrt 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 hearinl(. FOR THE COURT, By: Isl Dawn S. Sunday. Fsq. Custody Conciliator mhc The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of I990. 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 P MER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,,~ k ~ ~ ~ h~'e-e'L . h ;g ~ ~u, ./>C? -ec.{" ~-fI:P /!- ~ ~t7 C?? fit::? '~'L. LS :\ '/7 Yi" \lU~Z vv .1,1 .'* ' MARK D. ISENBERG, Plaintiff IN THE COURT OF COMMON PLEAS OF? CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BRENDA BROWNEWELL, 04-3332 CIVIL TERM Defendant IN CUSTODY ***************************************** BRENDA BROWNEWELL, Plaintiff IN THE COURT OF COMMON PLEAS OF? CUMBERLAND COUNTY, PENNSYLVANIA v. MARK D. ISENBERG, Defendant CIVIL ACTION - LAW 04-3477 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this 7th day of April, 2005, upon consideration of the complaints for custody filed by the parties with respect to their child, Taylore L. Brownewell (date of birth January 14, 2000), and following an initial period of hearing held on this date at which Dr. Arnold T. Shienvold, custody evaluator and psychologist, completed his testimony and his report was admitted into evidence, and at which both parties testified briefly without prejudice to the right to be recalled and subjected to further direct and cross-examination, it is ordered and directed pending further order of court as follows: 1. Legal custody of the child shall be shared by the parties; 2. Physical custody of the child shall be shared by the parties with the mother having the child on Monday and Tuesday with overnights, and the father having the child on Wednesday and Thursday with overnights, and the parties alternating weekends; 3. The child shall be enrolled in the South Middleton School District; 4. Nothing herein is intended to preclude the parties from deviating from the terms of this order by mutual agreement; 5. After December 25, 2005, the Court will entertain 2005 Af;; 12 10: t~8 " . . . .~ upon motion by either party a request to modify the terms of this order based upon circumstances as they exist at that time; and 6. Further hearing in these matters is scheduled for Wednesday, July 27, 2005, at 9:30 a.m., and Thursday July 28, 2005, at 9:30 a.m. Neither party has requested that the notes of testimony from today's hearing be transcribed. By the Court, ~ia P. Cognetti, Esquire 210 Grandview Avenue Ste. 102 Camp Hill, PA 17011 For Mark D. Isenberg ~rschel Lock, Esquire 3107 North Front Street Harrisburg, PA 17110-1310 For Brenda Brownewell Pcb V ~ ~ 04 -I'd- -05 MARK D. ISENBERG, Plaintiff v. BRENDA BROWNEWELL, Defendant IN THE COURT OF COMMON PLEAS OF? CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 04-3332 CIVIL TERM IN CUSTODY ***************************************** BRENDA BROWNEWELL, Plaintiff v. MARK D. ISENBERG, Defendant IN THE COURT OF COMMON PLEAS OF? CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 04-3477 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this 7th day of April, 2005, the action at No. 04-3477 Civil Term is hereby consolidated with the action at No. 04-3332 Civil Term, for purposes of the hearing being held on this and subsequent dates, the Plaintiff shall continue to be designated as Mark D. Isenberg on the exhibits, and the issues raised in both parties' complaints for primary custody will be deemed encompassed by the hearing. ~ria P. Cognetti, Esquire 210 Grandview Avenue Ste. 102 Camp Hill, PA 17011 For Mark D. Isenberg ~schel Lock, Esquire 3107 North Front Street Harrisburg, PA 17110-1310 For Brenda Brownewell pcb By the Court, td- Wesley 0 ~~~ .{ ,oS O~/\~ MARK D. ISENBERG, Plaintiff IN THE COURT OF COMMON PLEAS OF? CUMBERLAND COUNTY, PENNSYLVANIA v. BRENDA BROWNEWELL, Defendant CIVIL ACTION - LAW 04-3332 CIVIL TERM IN CUSTODY ***************************************** BRENDA BROWNEWELL, Plaintiff IN THE COURT OF COMMON PLEAS OF? CUMBERLAND COUNTY, PENNSYLVANIA v. MARK D. ISENBERG, Defendant CIVIL ACTION - LAW 04-3477 CIVIL TERM IN CUSTODY PARTIAL TRANSCRIPT OF PROCEEDINGS Proceedings held before the HONORABLE J. WESLEY OLER, JR., J., Cumberland County Courthouse, Carlisle, Pennsylvania, On April 7, 2005, In Courtroom Number 1. APPEARANCES: Maria P. Cognetti, Esquire For Mark D. Isenberg Herschel Lock, Esquire For Brenda Brownewell 1 ll:l :01 ~'\ (~ C!r!"i7 . ,,~'v j'('! ,. 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 MARK D. ISENBERG, having been duly sworn, testified as follows: DIRECT EXAMINATION BY MS. COGNETTI: Q Sir, I have three questions for you this afternoon. Would you state your name, please? Mark Daniel Isenberg. You are probably going to have to stay close to the that she doesn't lose the beginning of every sentence, A Q mike so okay? A Q A Q Okay. Mark, you go by Danny, is that correct? That is correct. Danny, could you tell the Court what kind of parent you think you are for Taylore? A I think I am a very good parent for Taylore. I think that she needs to have strong values instilled in her while she is young. She needs to have a stable environment. I don't think she should be moved around. And I feel that I can do that for her. Sorry, could you get closer to the mike. MR. LOCK: BY MS. COGNETTI: Q Why do you feel that you are the better primary custodial parent? A Well, as I said, I feel that there is things that 2 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 should be taught to a child when they are young so that they grow up -- as they grow, it is built into their nature and it becomes routine, habit. And it is no longer hard to force them to do something then too, you know, if it is instilled in them when they are young. Q Why are you the better person? A Well, I feel that Brenda was late on correcting Amber, disciplining her for her grades, leaving her off of punishment early before she brought her grades up, and some other things, basically. MS. COGNETTI: Cross. CROSS-EXAMINATION BY MR. LOCK: Q Mr. Isenberg, let me ask you a couple of questions. I believe you indicated you think you are a good parent? A Yes, I do. Q Do you believe your wife is a good parent? A I believe she loves her child dearly, yes. Q Strong values, you believe in them from what you correct? said, A Yes. Q Do you believe she does, she, Brenda? A Yes. Q You said you wanted to be the primary custodial 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 parent so you could teach the child certain things while she is young. What sort of things are you referring to? A Things, a routine, habits, homework, school comes before play. If she doesn't do good in school, there is consequences that she is going to suffer. If she suffers those consequences, they will be the full consequence until they do not -- until she does bring her grades up. About going to school on time, not being late. Q Well, Taylore isn't in school yet, is she? A Yes, she is. Q Where is she? A She is at the Church of the Brother, she goes to day school for two days a week now. Q She is not in public school, is she? A No, sir. MR. LOCK: I have nothing, Your Honor. THE COURT: Okay. Ms. Cognetti, anything further 18 of this witness? 19 MS. COGNETTI: No, Your Honor. Do you care to ask 20 the witness any questions? 21 THE COURT: No, I don't believe so. Thank you, you 22 may step down. 23 24 25 4 1 BRENDA K. BROWNEWELL, 2 having been duly sworn, testified as follows: 3 DIRECT EXAMINATION 4 BY MR. LOCK: 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Brenda, would you give the Court your full name? Brenda K. Brownewell. You are the Defendant in the action that was Q A Q brought today to No. 04-3332, A That is correct. Q As far as your daughter, Taylore, would you tell correct? Judge Oler what kind of parent you think you are for the child? A I think I am a good parent. I have been very involved with Taylore. I feel I am the nuturing parent, I have been since the day she was born. There was scheduling for her. The bad times, the play times, the activity times, the holiday things with people, with family, I kept that close connection. I was very involved with Taylore. Taylore and I are very close, and we have a very good relationship. Q Why do you feel you are the better custodial parent to Taylore than Mr. Isenberg? I have been the nuturing parent for Taylore. A I can keep separate my personal -- my relationship with Mark Starner, and my relationship with Mark Isenberg and my work separate from the needs of Taylore. I can give her, just as any other mother, a good mother can give the proper care. I take good 5 1 2 3 4 5 6 care of her and I am there for her. Q You said that you were the primary nurturing parent. What do you mean by that? A Knowing the needs of Taylore, knowing what she needs and how she needs to be taken care of and what is 7 important for her as a child to grow. MR. LOCK: That would be all, Your Honor. 8 9 10 THE COURT: Ms. Cognetti? CROSS-EXAMINATION 11 12 BY MS. COGNETTI: Q Can I call you Brenda? 13 A Yes. 14 Q Brenda, you said we have a good relationship, 15 16 meanlng you and Tay1ore, correct? A Yes. 17 Do you acknowledge that she has a really good Q 18 relationship with her dad as well? A Q A Q her dad? A Q 6 1 question that -- I was trying to keep up so I think I did -- 2 that you could give her proper care? 3 A Yes. 4 5 6 7 8 9 10 11 12 13 14 And that I think you said I am there for her? Q A Correct. Q Would you agree either from what you see or from what you have heard from Dr. Shienvo1d that in the last six to nlne months that Danny has also given her proper care? A Yes. Q And that he has been there for her as well as you have? A Yes. MS. COGNETTI: That is all I have, Your Honor. THE COURT: Okay, Mr. Lock, anything further of 15 this witness? 16 MR. LOCK: No, Your Honor, thank you. 17 THE COURT: You may step down, thank you. 18 Mr. Lock, did you want to move for admission of Dr. Shienvold's 19 report? 20 MR. LOCK: Yes, I would ask that that be admitted, 21 marked as Defendant's Exhibit 1, please. 22 MS. COGNETTI: No objection, Your Honor. 23 THE COURT: All right. Defendant's Exhibit 1 is 24 admitted. Do counsel wish to make brief closing arguments at 25 this point in the case with the understanding that I would be 7 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 under some sort of temporary order at the conclusion of the argument? HR. LOCK: THE COURT: HR. LOCK: I would like to if I may. All right, go ahead. Your Honor, I realize this is an interim step on the prelude to an interim order. I would respectfully suggest that it is good both parents love the child and the child loves both parents. On the other hand, at least all the primary testimony today that is in Dr. Shienvold's report, there are anger issues that Hr. Isenberg is facing, which I believe the totality of Exhibit 1, Dr. Shienvold's report, as well as his testimony on direct and cross-examination, indicate that not only exists but it might be incorrect to impact upon the child. Fortunately, he says it is not lost, the child is doing well. However, given what he said also and realizing this is just an interim step, I respectfully suggest it might be prudent, given the history of this case, to move slowly and keep an eye on that anger, the impact the anger has on custody, which isn't to say Mr. Isenberg doesn't love the child and vice versa, for the protection of the child, given the history of the case. Thank you. THE COURT: Hs. Cognetti. MS. COGNETTI: Thank you, Your Honor. I am not sure that I understood Hr. Lock's last reference to protection 8 1 of the child because I don't think we have heard anything 2 today, including mostly what we have heard from Dr. Shienvold, 3 about the child needing protection from either of these 4 parents. 5 I think we have heard a lot, even in their very 6 brief comments, that in spite of their kind of joint anger, 7 mutual anger or individual anger, I think that deep down they 8 both somewhere think highly of each other and know that they 9 are both decent parents. 10 I would focus the Court in the interim on two 11 things. We heard a lot about anger, we heard a lot about Mr. 12 Isenberg being angry, and I guess I keep thinking that if my 13 spouse ended up being engaged to my best friend/boss I probably 14 would be angry. The real test will be how Mr. Isenberg 15 continues to deal with his anger. 16 We heard from Dr. Shienvold that way before that 17 evaluation ever started Mr. Isenberg had put himself in 18 counseling, in this courtroom, in this kind of work, this is a 19 good thing. So we know that there are some steps there, only 20 time will tell, but Mr. Isenberg did that on his own. 21 On the other hand, we have the other competing 22 anger going on that perhaps didn't get quite as much play but 23 Ms. Brown is angry at Mr. Isenberg for taking or keeping her 24 child and now would appear to want to punish him for that by 25 ignoring the clear relationship between he and his daughter and 9 1 wanting to take this child away from him in a sense that would 2 appear to be to get back. 3 I think on an interim basis the Court should focus 4 on what is going on right now today, and that would be the 5 status quo, however we got there. I heard three things from 6 Dr. Shienvold, and I made a point of writing them down because 7 I thought they were so key: This child shows no signs of 8 alienation, there are no problems with Taylore -- those were 9 his words -- and Taylore is very well adjusted. To me that 10 says Taylore is doing good in the current situation, and then lIon an interim basis we should leave it at that. 12 THE COURT: Very good, thank you, we will take a 13 brief recess. I will look at Dr. Shienvold's report and come 14 back into court and I will enter a temporary order. 15 (Recess.) 16 THE COURT: We will enter this order, AND NOW, this 17 7th day of April, 2005, upon consideration of the complaints 18 for custody filed by the parties with respect to their child, 19 Taylore L. Brownewell (date of birth January 14, 2000), and 20 following an initial period of hearing held on this date at 21 which Dr. Arnold T. Shienvold, custody evaluator and 22 psychologist, completed his testimony and his report was 23 admitted into evidence, and at which both parties testified 24 briefly without prejudice to the right to be recalled and 25 subjected to further direct and cross-examination, it is 10 1 ordered and directed pending further order of court as follows: 2 1. Legal custody of the child shall be shared by 3 the parties; 4 2. Physical custody of the child shall be shared 5 by the parties with the mother having the child on Monday and 6 Tuesday with overnights, and the father having the child on 7 Wednesday and Thursday with overnights, and the parties S alternating weekends; 9 3. The child shall be enrolled in the South 10 Middleton School District; 11 4. Nothing herein is intended to preclude the 12 parties from deviating from the terms of this order by mutual 13 agreement; 14 5. After December 25, 2005, the Court will 15 entertain upon motion by either party a request to modify the 16 terms of this order based upon circumstances as they exist at 17 that time; and IS 6. Further hearing in these matters is scheduled 19 for Wednesday, July 27, 2005, at 9:30 a.m., and Thursday July 20 2S, 2005, at 9:30 a.m. 21 Neither party has requested the notes of testimony 22 from today's hearing to be transcribed. 23 Court is adjourned. 24 25 11 CERTIFICATION I hereby certify that the proceedings are contained fully and accurately in the notes taken by me on the above cause and that this is a correct transcript of same. '" . C /) / Y""f7T '-, - ;,' - - 'J a..lcUi'\ cL .' j) a /1/{o'j patricia C. Barrett Official Stenographer - ----- ---- ------ - - -- --- The foregoing record of the proceedings on the hearing of the within matter is hereby approved and directed to be filed. fv1-vJ, \1 2~(, Date 0l? J Wesley 12