The URL can be used to link to this page

Home My WebLink About01-2844RANDI A. LONG~ :: IN THE COURT OF COMMON PLEAS PlaintiFf' :: OF CUMBERLAND COUNTY :: PENNSYLVANIA, v. :: 9TM JUDICIAL DISTRICT CLARENCE S. LONG, III, :: No. 01-2844 DeFendant :: CIVIL ACTION - CUSTQDY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgement may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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 OFFICES SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. DAUPHIN COUNTY LAWYER REFERAL SERVICE 2 i 3 NORTH FRONT STREET HARRISBURG, PA 17101 (717) 232-7536 CENTRAL PENNSYLVANIA LEGAL SERVICES 213A NORTH FRONT STREET HARRISBURG, PA 17101 1-800-932-0356 RAND! A. LONG, :: [N THE COURT OF COMMON PLEAS Plaintiff :: OF CUMBERLAND COUNTY :: PENNSYLVANIA, v. :: 9TM JUDICIAL DISTRICT CLARENCE S. LONG, HI, :: No. 0 i-2844 Defendant :: CIVIL ACTION - CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER · NOW COMES, the Defendant, CLARENCE S. LONG, HI, pursuant to 1915· 1 et seq. of the Pennsylvania Rules of Civil Procedure to petition this Honorable Court for a change in the custody order entered in the above-captioned action· Defendant requests that this Honorable Court grant Defendant primary physical custody and shared legal custody of the minor children, Alexandria P. Long and Catelyn S. Long. In support of this petition, Defendant assert the following: 1. Defendant, CLARENCE S. LONG, III, (hereinafter Father) is an adult individual residing at 7081 Spring Road, Shermans Dale, Perry County, Pennsylvania. 2. Plaintiff, RANDI A. LONG, (hereinafter Mother) is an adult individual residing at 67 Country View Estate, Upper Frankford Township, Cumberland County, Pennsylvania· 3. The subject children of this action, ALEXANDRIA P. LONG was born February 10, 1992 and CATELYN S. LONG was born February 22, 2000. 4. A custody conciliation conference was held on May 17, 2001 in Attorney Dawn Sunday's Office. 5. A custody order was executed by the Honorable J. Wesley Oler, Jr. on June 21, 2001. A follow up conference was held in Attorney Sunday's office on October 23, 2001 and a custody order was executed by the Honorable J. Wesley Oler, Jr. on November 2, 2001. A true and correct copy ofthe Custody Conciliation Summary Report and Custody Order of November 2, 2001 are attached hereto and Marked Exhibit "A". 6. Since the entry ofthe within mentioned custody order, there has been a significant change of circumstances that directly and substantially impacts the parties' respective custody rights. These changes in circumstances are as follows: a.) Defendant believes that the minor children are not beJng properly cared for. b) The minor children are not being bathed properly or often and their appearance is unkempt. c) The minor child, Alexandria, has two incidents of lice infestation. d) Defendant believes that the minor children are not being fed properly and healthy. e) Alexandria's grades in school have plummeted and are now very poor. f) The teacher and counselor at the minor child's school have expressed concern to the Defendant over the minor child's appcarance,ability to perform in class and behavior. g) Defendant believes that the minor children do not have proper supervision or discipline. 7. The minor children are not presently being raised in a safe and stable environment. 8. Father is better able to provide a safe, stable and loving environment in which to raise the child. 9. Defendant seeks primary physical custody and shared legal custody of the minor children. 10. Defendant prays that this Honorable Court grant the relief requested because said reliefwill serve the best interest of the children. WHEREFORE, Defendant respeetfi~lly requests that this Honorable Court ~ant him primary physical custody and shared legal custody of the minor children, ALEXANDRIA P. LONG and CATELYN S. LONG. Respectfully submitted: / ~ttomey for Defendant Barbara L. Wevodau, Esquire Supreme Court I.D. No. 85673 P.O. Box 264 New Bloomfield, PA 17068 (7 ~ 7) SS2-SSS3 RANDI A. LONG~ :: IN THE COURT OF COMMON PLEAS Plaintiff :: OF CUMBERLAND COUNTY :: PENNSYLVANIA, V. :: 9TM JUDICIAL DISTRICT CLARENCE S. LONG, III, :: No. 01-2844 Defendant :: CIVIL ACTION - CUSTODY V~RIFICATION I verify that the statements made in the attached PETITION FOR MODIFICATION OF CUSTODY ORDER are true and correct. I understand that false statements herein are made subject to the penalties of ! 8 Pa.C.S. 4904 relating to unsworn falsification to authorities. Clarence S. Long, IH RANDI A. LONG. :: IN THE COURT OF COMMON PLEAS Plaintiff :: OF CUMBERLAND COUNTY :: PENNSYLVANIA, v. :: 9TM ~-DICIAL DISTRICT CLARENCE S. LONG, III, :: No. 01-2844 Defendant :: CIVIL ACTION - CUSTODY CERTIFICATE OF SERVICE l, Barbara L. Wevodau, Esquire, hereby certify that, on this date, a true and correct copy of the foregoing Petition for Modification of Custody was served upon Jane Alexander, Esquire, attorney for the Plaintiff, RANDI A. LONG, by mailing a certified tree copy via first class mail from the New Bloomfield Post Office, New Bloomfield, Pennsylvania to the following address: Jane M. Alexander, Esq. 148 S. Baltimore Street P.O. Box 421 Dillsburg, PA 17019-0421 R,.._~... _elct fully Submitted, f~t~o~n~y for Defendant Barbara L. Wevodau, Esq. Supreme Court ID# 85673 P.O. Box 264 New Bloomfield, PA 17068 (717) 582-8883 AMERICANS WITH DISABILITIES ACT OF 1990 The Cumberland County Court of Common Pleas 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 my 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 RANDI A. LONG, Plaintiff : OF CUMBERLAND COUNTY, PA. : : NO. VS. : CLARENCE S. LONG, III, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY ]~OTIC-F- TO DF. FEND 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 Judpjnent 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 Court House, One Courthouse Square, Carlisle, pennsylvania 17013. 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 : IN THE COURT OF COMMON PLEAS RANDI A. LONG, Plaintiff : OF CUMBERLAND COUNTY, PA. : : NO. VS. CLARENCE S. LONG, III, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion con prontitud. Se lc avisa que st no se defiende, el caso puede proceder sin usted y decrcw de divorcio o anulamiento pucde set emitido en su contra pot ia Corte. Una decision puedc tambien set emitida en su contra pot cuaiquier otra queja o compensacion reciamados pot el demandant. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimicnto irrep, arablc del matrhnonio, usted puede solicitar consejo matrimonial. Una lista de conse, leros matrimoniales esta disponible en la oficina del Prothonotry, en la Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DER.ECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 : IN THE COURT OF COMMON PLEAS RANDI A. LONG, Plaintiff : OF CUMBERLAND COUNTY, PA. : : NO. VS. : CLARENCE S. LONG, III, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY /".~)., _ . j ,200l, comes AND NOW, this ~~ay of _ ~ .~- ~-,'~-~- - Complaint upon a cause of action of which the following is a statement. 1. Plaintiff is Randi A. Long, 32 years of age, who currently resides at 6'/Country View Estate, Upper Frankford Township, Cumberland County, Newville, Pennsylvania, 17241. 2. Defendant is Clarence S. Long, III, 36 years of nge, who currently resides at '/081 Spring Road, P. O. Box 61, Sbermans Dale, Pennsylvania, 1'/090. 3. Plaintiff nnd Defendant hnve both resided in the Commonwealth of pennsylvania for at least six (6) months prior to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on November 28, 1992 in Carlisle, Pennsylvania. 5. There were two (2) children born between the parties, Alexandrea P. Long, age 9 years, born February 10, 1992 prior to marriage and Catelyn S. Long, age 1 year, born February 22, 2000 during the marriage. 6. There were no prior actions in divorce or annulment commenced by the parties. 7. The parties have not entered into a written agreement as to alimony, counsel fees, cost and property division. 8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. While the parties were domiciled within the Commonwealth of Pennsylvania, and through no fault of Plaintiff, the innocent and injured spouse, the Defendant, in violation of the marriage vows and the laws of the Commonwealth, has offered such indignities to the person of the Plaintiff as to render her condition intolerable and life burdensome. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. 10. The allegations of Paragraph one (1) through nine (9) are incorporated herein by reference and made a part hereof. 11. The marriage is irretrievably broken. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. 12. The allegations of Paragraph one (1) through nine (9) and Paragraphs ten (10) and eleven (11) are incorporated herein by reference and made a part hereof. 13. Plaintiff and Defendant have acquired property, both real and personal during marriage. 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. ' "e divide all WHEREFORE, Plaintiff requests your ttonoram Court to equitably marital property of whatsoever kind and wheresoever situate and for such further relief as the Court may deem equitable and just. .C,,_O_MPI-AINT FOR._C_USTODY 15. The Plaintiff seeks primary physical and joint legal custody of the following children, Aiexandrea P- Long, age 9 years, born February 10, 1992 and Catelyn S. Long, age I year, bom February 22, 2000. Long, was born between the parties prior to 16. The first child, Aiexandrea P. marriage and the second child, Catelyn S. Long, was born between the parties during this marriage. 17. The children are presently in the custody of the Plaintiff. 18. The children have resided with the Plaintiff and Defendant from 1995 to 1997 at 25 W. Big Spring Avenue, Apartment 1, Newville, PA. From 199'/to 1999 Plaintiff, Defendant and the children lived at 820 York Road, Carlisle, PA 17013. From April 16, 1999 to April 16, 2001 Plaintiff, Defendant and the children lived at 6'/Country View Estate, Newville, PA 17241. From April 16, 2001 to date Plaintiff and both children lived at 6'/Country View Estate, Newville, PA 17241. 19. The relationship of the Plaintiff to the children is that of natural mother. 20. The relationship of the Defendant to the children is that of natural father. 21. The Plaintiff has not participated as a party or as a witness, or in any other capacity, in other litigation concerning the custody of these children in this or any other Court. no information of a custody proceeding concerning the children 22. The Plaintiff has pending in any other court within this Commonwealth. 23. The Plaintiff knows of no other persons, not a party to these proceedings, who has visitation or custody rights with respect to the children. 24. The best interest and permanent welfare of the children will he served by granting the Plaintiff primarY physical custody and joint legal custody because with partial visitation to Defendant on the second weekend of each moth. The Plaintiff is able to provide the children with a good environment and proper care of the children and has, during the life of the children, been the primarY care giver particularly since the Defendant moved out. WHEREFORE, the Plaintiff requests your Honorable Court to grant her primary physical custody of the subject children with reasonable rights of visitation to the Defendant and that the Defendant shall not use alcoholic beverages when he has custody of the children and he shall not remove the children from the jurisdiction of the Pennsylvania Courts. Respectfully Submitted, /l~ne M~ Al~'xa~r, .~..s.~mre · ' ' Plamtm / ~torneY for theJ~ ( liD. No. 07355 i ~4g S. Baltimore Street ', oDillsburg, PA 17019 (717) 4324514 Verificati ~a I verity, thai the statements made in this Complainl in Divorce .'ire true and correct. I understand that false statemetlts herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: , / Randi A. Long COMMONWEALTH OF PENNSYLVANIA S.S COUNTY OF YORK Betbre nle. the undersigned officer, a Notary Public. n'~ and for the said Commonwealth and County. Personally appeared Randi A. Long who. being affirmed according to law, deposes and says thai the l~cts and matters set I~rth in the fi~rcgoi~g Complaint are true and correct to lhe best of her knowledge, intbrmation and belicl'. Randi A. Long Sworn to and subscribed belhre me this day of " ~ 2~)1 Notary Public ' Ii l'illl~ ill!l]~ ,, i :l' l. i :'. , RANDI A. LONG : IN THE COURT OF COMMON PLEAS OF PLAINTIFF V. : CUMBERLAND COUNTY, PENNSYLVANIA CLARENCE S. LONG, III DEFENDANT : 01-2844 CIVIL ACTION LAW IN CUSTODY AND NOW. Thursday, May 17, 2001 . upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear betbre Dawn S. Sunday, Esq. . the conciliator, at 39 West Main Street, M,,~h.n~e_tburg' PA 17055 on Tuesday, June 12, 2001 at 11:30 a.m. for a Pre-Hearing Custody Conference. At such conference, an;ffort 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/ Dawn S. .qu,,day. Esa. ~ 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 bearing. 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 RANDI A. LONG, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PA : VS. : NO. 01-2844 CIVIL TERM : CLARENCE S. LONG, Ill, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY AFFIDAVIT OF SF. RVICI~ AND NOW, this of appeared Jane M Alexander, Esouire whn ...... '? · t'~'-i ,2001 personally ~ ...... ~wcars accoraing~to law, that a true and correct copy of a COMPLAINT IN DIVORCE AND CUSTODY was caused to be served by certified mail with return receipt requested upon the said, Clarence S. Long, Ill 7081 Spring Road P. O. Box 61 Shermans Dale, PA 17090 on MaY_J_7.~!0~ by leaving the same at the Dilisburg Post Office with postage pre-paid thereon as evidenced by the mailing receipt and return receipt hereto attahced and made a part hereof. ,../ /Attorney I.D. #07355 · ' / 148 S. Baltimore Street ~J Diilsburg, PA 17019-O421 (717) 432-4514 Sworn and subscribed before me this ,~7..,~'~ day of ~,'~J,~'~ ,2001. Notary i lio/ ' I ~.,."?. reminder,. _Na]my pllblo I / .._ _~,.au~g Bom, York (2mjb; RANDI A. LONG. : IN THE COURT OF COMMON PI.EAS Plainliff : OF CUMBERLAND COLIN'FY. PA VS. : NO. 01-2844 CIVIL TERM CLARENCE S. LONG. Iii. : CIVIL ACTION - LAW Defcndan~ : IN DIVORCE AND CUSTODY Bo~, ~his ~_~_~a¥ of ~ ~___~__~_~t 2001, u~ coflsi~eratzofl ~11 ~ ~ ~ ~ ~,=~ 22, ~' ~' z~[--' -~"h~ ~ ~ exe~{8~ 3oz~zy ~<~' ~,~ g~al ~jo= ~en~ ~,~v. J~ 17, ~1 at. 3.~ p.m~ ..... ~_ FairYs ~si~n~ ~ to .... er t~ Father ~ ......... ~ . t wi~ t~ ~il~n, 6. ~e ~er ~ll ~i~ ~~ti~ for ex--es ~ S~ ~ ~ Mo~ ~1 ~i~ tr~tim ~t~ ~ ~t~- . ~ a ~lor tl ~tlfy ~e ~r ~. ~e ~er ~1 ~ Y ....... ~ ~nter to ~le 1915.3-8, the undersigned CustOdy ConciliatOr submits tb~ following report: .... =nent fnformation concerning the O~ildren who are the 1. ~ne ~=.~.-. . . - =ollows: subjects of this l~t~atlO~ ~s a~ ~ A~exanc~a P* ~ ~el~uaL-~ ].0~ 1992 Ca~e~n S. Long ~ebL'uaw 22, 2000 ~o~eF 2. A ~l~a~ ~n~e~ ~s held ~ ~ ~2, ~, ~ ~ ~oll~i~ ~ivi~ls ~ a~e~ce: ~ ~, ~ A. L~, ~ he~ ~, ~ ~. ~e~, ~' ~ ~e ~a~e~, ~ S. ~, ~' 2. ~e ~es ~ ~o ~W o~ ~ ~e~ ~ ~e ~ ~ a~a~* --Date Custody Conciliator RANDI A. LONG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : 01-2844 CIVIL ACTION LAW : CLARENCE S. LONG, III, : Defendant : IN CUSTODY ORDER OF COURT AND NOW, this '~ ~ ~ day of ~ ~ x~ t~ --/oc] , 2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated June 21, 2001 is vacated and replaced with this Order. 2. The Mother, Randi A. Long, and the Father, Clarence S. Long, IIl, shall have shared legal custody of Alexandria P. Long, born February 10, 1992, and Catelyn S. Long, born February 22, 2000. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 3. The Mother shall have primary physical custody of the Child~n. 4. The Father shall have partial physical custody of the Children on alternating weekends from Friday at 7:00 p.m. (when the Father shall pick up the Children at dance class), through Sunday at 6:00 p.m., beginning October 26, 2001. 5. The parties shall share or alternate having custody ofthe Children on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from 9:00 a.m. until 8:30 p.m. on Christmas Eve, and Segment B, which shall run from 8:30 p.m. on Christmas Eve through 8:30 p.m. on Christmas Day. In odd numbered years, the Mother shall have custody during Segment A and the Father shall have custody during Segment B. In even numbered years, the Father shall have custody during Segment A and the Mother shall have custody during Segment B. B. THANKSGIVING: The Thanksgiving holiday shall be divided into Segment A, which shall run from 9:00 a.m. until 8:30 p.m. on Thanksgiving Day and Segment B, which shall run from Thanksgiving Day at 8:30 p.m. through the Friday following Thanksgiving at 8:30 p.m. In odd numbered years, the Mother shall have custody during Segment A and the Father shall have custody during Segment B. In even numbered years, the Father shall have custody during Segment A and the Mother shall have custody during Segment B. C. EASTER: The party who has custody of the Children under the regular custody schedule on Easter shall have custody on the holiday. D. MEMORIAL DAY/LABOR DAV: The Father shall have custody of the Children every year for the Memorial Day holiday from Sunday at 8:00 p.m. through Memorial Day at 7:00 p.m. The Mother shall have custody of the Children every year for the Labor Day holiday from Sunday evening at 8:00 p.m. through Labor Day at 7:00 p.m. E. INDEPENDENCE DAY: The Independence holiday shall run from 9:00 a.m. on July 4th through 9:00 a.m. on July 5th. The Mother shall have custody over the holiday in even numbered years and the Father shall have custody in odd numbered years. F. MOTHER'S DAY/FATHER,S DAY: The Mother shall have custody of the Children every year on Mother's Day from 9:00 a.m. until 6:00 p.m. and the Father shall have custody of the Children every year on Father's Day from 9:00 a.m. until 6:00 p.m. G. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 6. The Father shall be entitled to have custody of the ' . school break for two non-consecutive wee , .; C.hlldren every year dunng the summed, er ks upon providing a~ least 30 days advance notice to th Mother. In the event either party intends to take the Children on vacation, that party shall provide advance notice to the other party of the address and telephone number where the Children can be contacted. 7. Unless otherwise agreed between the parties, the Father shall provide all transportation for exchanges of custody to and from the Mother's residence, with the exception of the exchanges of custody on Fridays, when the Father shall pick up the Children at dance class. 8. The Father shall ensure that the Mother has a current work telephone number and home telephone number where the Father can be contacted in the event of an emergency or to discuss issues relating to the Children. 9. The parties shall communicate directly with each other concerning issues affecting the Children without the involvement of or interference by third parties. 10. Neither party shall consume alcohol to the point of intoxication during his or her periods of custody. Each party shall ensure that third parties having contact with the Children comply with this provision during his or her periods of custody. 11. Neither party shall take the Children to a tatoo parlor for extended periods of time during his or her periods of custody. 12. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this Provision. 13. 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, · ~esley Oler, SrFj --""'~-~ ,, cc'..lane M. Alexander, l~squire - Counsel for Mother Daniel McGuire, Esquire- Counsel for Father ~ ~,,~J~ /I-(,-o/ RANDI A. LONG, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : VS. : 01-2844 CIVIL ACTION LAW : CLARENCE S. LONG, III, : Defendant : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr. CUSTODY CONCILIATION SUMMARY REPOR IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. as follows:The pertinent information concerning the Children who are the subjects of this litigation is NAME DATE OF BIRTH ~CURRENTLY IN CUSTODY OF Alexandria E. Long February I 0, 1992 Mother Catelyn S. Long February 22, 2000 Mother 2. A Conciliation Conference was held on October 23, 2001, with the following individuals in attendance: The Mother, Randi A. Long, with her counsel, Jane M. Alexander, Esquire, and the Father, Clarence S. Long, III, with his counsel, Daniel McGuire, Esquire. 3. The parties agreed to entry ofan Order in the form as attached. Date awn S. Sunday, EsquireS/' Custody Conciliator RANDI A. LONG : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA v. 01-1844 CIVIL ACTION LAW CLARENCE S. LONG, III : DEFENDANT : IN CUSTODY AND NOW, Thursday, May 16, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. S..nda~,, Esq. , the conciliator, at 39 West Main Street, M~h..;*~h~rg, PA 17055 on Thursday, May 30, 2002 at 10:00 AM for a Pre=Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or pli rd by th if this cannot be accom shed, to define and narrow the issues to be hea e 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 ali existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: I~1 Dawn $..¢,,,,,l~_y. Esq, ~ko 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 A'I'TORNEY AT ONCE. IF YOU DO NOT HAVE AN ATFORNEY 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 RANDI A. LONG, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA ,' VS, : 01-2844 CIVIL ACTION LAW : CLARENCE S. LONG, III : Defendant : IN CUSTODY ORDER OF COURT AND NOW, thia Z'"~ day of ~ ~l , 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The prior Order of this Court dated November 2, 2001 shall continue in effect. 2. Based on representations and documentation presented by the Mother at the Conciliation Conference and the fact that the Father was not in attendance, the Father's Petition for Modification is dismissed. BY THE COURT, cc: Barbara L. Wcvodau, Esquire- Counsel for Father Jane M. Alexander, Esquire-Counsel for Mother RANDI A. LONG, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : 01-2844 CIVIL ACTION LAW : CLARENCE S. LONG, III, : Defendant : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr. 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 Alexandrea P. Long February 10, 1992 Mother Catelyn S. Long February 22, 2000 Mother 2. A Conciliation Conference was held on June 26, 2002, with the following individuals in attendance: The Mother, Randi A. Long, with her counsel, Jane M. Alexander, Esquire, and the Father's counsel, Barbara L. Wevodau, Esquire. The Father, Clarence S. Long, III, who filed this Petition for Modification, did not attend the Conference for reasons unknown to his counsel. 3. The issues raised by the Father in his Petition were discussed at the Conference and the Mother offered documentation from Alexandrea's school, physician and counselor in direct response to the Father's allegations. 4. As the Father did not attend the Conference, no further Order addressing the custody arrangements is necessary at this time except to dismiss the Father's Petition for Modification, if deemed necessary by the Court. Date Dawn S. Sunday, Esquire Custody Conciliator RANDI A. LONG, :: IN THE COURT OF COMMON PLEAS Plaintiff :: OF CUMBERLAND COUNTY, PA :: v. :: NO. 01-2844 CIVIL TERM CLARENCE S. LONG, Ill, :: Defendant :: IN CUSTODY PRAECIPE TO ENTER APPEARANCE AND NOW, Barbara L. Wevodau, Esquire, hereby enters her appearance for the Defendant in the above-captioned case· Date:~,~~ · · IN THE COURT OF COMMON PLEAS RANDI A. LONG, .. Plaintiff :: OF CUMBERLAND COUNTY, PA · · NO. 01-2844 CIVIL TERM ... CLARENCE S. LONG, IH, :: Defendant :: IN CUSTODY PRAECIPE TO ENTER APPEARANCE AND NOW, Barbara L. Wevodau, Esquire, hereby enters her appearance in thc above-captioned case. E q. RANDI A. LONG, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : CLARENCE S. LONG, : III, : Defendant : NO. 01-2844 CIVIL TERM IN RE: PLAINTIFF'S EMERGENCY PETITION FOR SPECIAL RELIEF AND PETITION FOR CIVIL CONTEMPT ORDER OF COURT AND NOW, this 1~t day of April, 2003, upon consideration of the attached letter from Barbara Wevodau, Esq., attorney for Defendant, the hearing previously scheduled for April 3, 2003, is rescheduled to Thursday, June 26, 2003, at 10:45 a. m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, / J. ,Wesley Oler,"Jr., n J. Jane M. Alexander, Esq. 148 S. Baltimore Street Dillsburg, PA 17019 Attorney for Plaintiff Babara Wevodau, Esq. ~ /tvt~-~t ~g. 0 ~- 0-~ 26 E. Main Street (~W'-" ' P.O. Box 459 New Bloomfield, PA 17068 Attorney for Defendant .3 7[75827697 ELIZA))EI'H P QUIGLEY PAGE 82 Sent Vm Fax Only (717) 240-6~62 FlonoF~ble L Wesley 03er, ~. Cure.land CO~ C~ R~: ~ v. L~ No. 01-28~ D~ lu~ Olcr, M~ 31~ 2003 I received a ~ c~ of~e Peblon tm 3p~l Ke~ECon~ ~m A~y N~. U~n~, I ~ ~ ~Y c~ti~ s~d m P~ c~ Co~ m ,~ 3r~ ~t 9:00 ~.m. I ~ve s~k~ ~ A~ ~ ~d ~d ~e ~. Mr. ~nS ~ m~ ~ ~ ~ Ms. L~. l ~ m~es~ ~st ~ ~t A~ ~det ~t nm ~e ~ ms~. ~ you ~ yo~ ~id~ of my ~eq~st. co: Snne Alexnnder, Esq. ~NDI A. LONG, : IN THE COURT OF CO~ON PLEAS OF Plaintiff/Petitioner: CUMBERLAND COUNTY, PENNSYLVANIA : V. : : CLARENCE S. LONG, III, : CIVIL ACTION - LAW Defendant/Respondent: NO. 01-2844 CIVIL TE~ ORDER OF COURT AND NOW, this 26th day of June, 2003, upon consideration of the Emergency Petition for Special Relief and Petition for Civil Contempt in the above-captioned matter and following a hearing, the Court finds that the Defendant has at least in a technical sense intentionally, voluntarily, and willfully failed to comply with the order of court herein, and he is consequently adjudicated in contempt. The sanction of the Court is that the Plaintiff be compensated in terms of lost time with the parties' child, A~exandria P. Long (date of birth February 10, 1992) in the amount of two and a half days, said period to be selected at Plaintiff's option, and that Defendant pay to Plaintiff the sum of $50.00 for filing fees and $200.00 for attorney's fees. The parties are a~onished to follow the terms of the order hereafter. By the Court, ~~ ~Wesley O e~'~Jr'' J] ~ne M. Alexander, Esquire For the Plaintiff ~arbara L. Wevodau, Esquire For the Defendant :lfh IN THE COURT OF COMMON PLEAS OF CUMBERLAND, PENNSYLVANIA RAND! A. LONG, : CIVIL ACTION - LAW Plaintiff/Petitioner : : VS. : NO. 01-2844 : CLARENCE S. LONG, IIL : Defendant/Respondent : IN CUSTODY EMERGENCY PETITION FOR SPECIAL REI.IEF .AND PETITION FOR CIVIL CONTEMPT TO, ,T. th s of . -003 comestbe Plaintiff/Petitioner. Randi A. Long. by and through her a~tton(ey. Jane M. Alexander. Esquire, who respectfully represents: [. Plaintiff/Petitioner, Randi A. Long, is the natural mother of two (2) minor children. Alexandria P. Long. born Februa~. 10, 1992 and Catelyn S. Long. born FebruaD, 22, 2000. 2. Defendant/Respondent, Clarence S. Long, III, is the natural father of the said two (2) minor children. 3. That on November 2, 200 I. Judge J. Wesley Oler, Jr. entered an order awarding Plaintiff/Petitioner primary physical custody of the children, Alexandria P. Long and Catelyn S. Long. A true and correct copy of the order marked Exhibit "A" is at~ached hereto and made a part hereof. 4. Defendant/Respondent filed a Petition for Modification of the custody order May 2002. A conciliation conference was held on June 26, 2002 before Dawn S. Sunday, Esquire. His petition was dismissed. A copy of Conciliation Summary Report marked Exhibit "B" is attached hereto and made a hereot; 5. Defendant/Respondent has willfully failed to abide by the order in that he did not return his daughter. Alexandria, to the Plaintiff/Petitioner on Sunday'. March 23. ~-003 in compliance with paragraph 4 of said order. 6. Defendant/Respondent, based on allegations of abuse made by Alexandria against PlaintiflTPetitioner. reported the ab[,se to Children and Youth Services of Perry County on Marcl~ 2 I, 2003. The allegations were investigated by Children and Youth Services on March ~-2, 2003 by Jeff Wickard of the Cumberland County Children and Youth Services. 7. After the investigation Plaintiff/Petitioner was requested to allow Alexandria to remain with Defenda,~t/Respondent until close of school, March 24, 2002 in order to allow the paper work to be completed. She agreed. 8. Defendan'dRespondent was advised that Alexandria should be put in her school on Monday and returned to Plaintiff/Petitioner Monday evening. Defendant did not put Alexandria in school nor return her to Plaintiff/Petitioner. 9. Det'endant/Respondent signed a Protection From Abuse Petition on March 24, 2003 which was filed on March 25, 2003 in the Court of Common Pleas of Perry Counb' to No. 03-278 even though he was advised the changes were not "tbund." A cop)' of said Petition marked Exhibit "C" is attached hereto and made a pan hereol: I 0. The Court declined to sign the temporal. Protection from Abuse Order and schedule a hearing lbr April 9, 2003. Therefore custody remains with Plaintiff/Petitioner. I I. Defendant/Respondent has not returned Alexandria to Plaintiff/Petitioner nor has Alexandria been in school. 12. Defendant/Respondent was in the office of'the Cumberland County Children and Youth on Wednesday March 26. 2003 and was advised that the), found no basis for his not returning Alexandria to Plaintiff/Petitioner. ~t'HEREf'ORE, Plaintiff/Petitioner request your Honorable Court that Defendant/Respondent be held in contempt of court. .4ND FURTH£RMORE, Plaintiff/Petitioner is respectfidly requesting that her daugbter. Alexandria. be returned to her immediately and that the Defendant/Respondent be orden~l to pay' all counsel fees and costs incurred by Plaintiff/Petitioner in regard to this action and should any fines be levied against Plaintiff/Petitioner because of Alexandria's non-attendance at school Defendant/ Respondent shall be liable for paymen! of said fines. Resl~ctfullv submitted, / All~/rncv I'or Plainlil't' ! /' Atlj~rm..~. I.D. #0735.~ S l~altimor~ Stn.'et I, ~flls'~rg. pA 17019-O421 x /~7171432-4514 VERIFICATION ! veri~- that the statements made in this Petition are true and comeet. I understand that ~'alse statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. · / Ran~'i A. Ldng .:' RANDI A.I.(-)NG, IN TIlE COURT OF COMMON PI,EA$ OF I'l;unlilr CUMBERLANI) ('OtINTY, PI!NNSYI.VANIA vs. 01-2844 CIVIL ACTION I.AW £.'LAI(EN(.'I..' ,',;. L(JNt.i, III, I)urend:ml : IN CUSTODY ORDER OF COURT ANI) NOW, Ihis .J.,,.,.~ day or ~w~...~,-.---- , 2(.)01, upon considcralion el'thc allached Custody Conciliation Report, it is orde~d and directed as follows: I. Thc prior Order orthis Cou~ dated June 2 I, 2001 is vacated and replaced wilh Ihis Order. 2. Thc Molhcr, Rundi A. Long, and the Father, Clarence S. Long, III, shall huvc shared legal custody oF Alexandria P. Long, bom February 10, 1992, and Catelyn S. Long, horn Fei)ri ary 22, 2~ff). Each parent shall have an equal right, to be exe~ised .jointly with Ihe olhcr parent, Io make all nmjor non-emergency decisions u~ecting Ihe Child~n's general well-being including, hut not limiled to, all decisions rcgardin~ their health, education and religion. Pursuant Io Iht terms or this paragruph, each parcnl shall hc cnliflcd Io all r~ords and info,alien pc~aining Io Iht Children inclading, but not limilcd Io, school and medical records and in,om]alien. 3. The Molhcr shall huve prin]ary physical custody o~the Children. 4. The F;~lhcr shull huve pa,ial ph~ical custody of the Children on allemaling weekends from Friday at 7:00 p.m. (when Iht Falhcr shall pick up Ihe Child~n al dance class), Ihrongh Sanday al 6:00 p.m., hcginning Octobcr 26, 2001. 5. The I)arlies shldl sharc or allemate having custody o~lhc Child~=n on holidays as follows: fi. ~llRIS'rMfi~: The Chrislmas holiday shall be dividcd inlo Scgmcnl A, which shall nm Ihm~ ~J:lll) a.ln. unlil 8:30 p.m. m~ Chrislma~ ~ve, ~md Scgm~'nl R. which slmll run Ii'om 8:.~0 p.m. on Christmas Eve Ihroush 8:30 p.m. on Clu'islmus Day. In odd nnmh~r~d years, Ih~ Molhcr shall huvc cnslody dnring Scgmcnt A and Iht Falhvr shall have cush~dy during Scgmcnl B. In even numbered yearn, the Falher shall have cuslody during Segmenl A and thc Molhcr shall have custody during Se~en{ B. B. 'FIIANKSGIVING: The Thanksgiving holiday shall be divided inlo Scsmcnl A, which shall run fi'om 9:00 a.m. unlil 8:30 p.m. on Thanksgiving Day and Scgmeul B, which shall run Ihm] Thanksgiving Day at 8:30 p.m. Ihrough Ih= Friduy tblh~wing Thanksgiving al p.m. In odd numhcrcd years, the Molher shall havc cuslody daring Sugm~nl A and Father shall have custody during Segment B. In even numbcrcd years, Ihc Fqthcr shall havc cpslt~dy dL~riq§ ~cgnlcltl A and the Mothcr shall havc custody during Scgmcnl C. ~AS'I'ER: Thc parly who has cuslody o[ thc Children under thc regular ct~slody schedule on I~astcr shall have cuslody on the holiday. D. hII~MOI{IAL DAY/LABOR DAY: The Father shall have custody o1' Ihc Children c¥cry year ~ur the Memorial Day holiday ~mm Sunday at 8:00 p.m. Ihmugh Memorial Day al 7:~() i~.m. Thc Molhcr shall huve custody o[tbc Chilth'cu every your I~r Iht I.ahm' I)a~y holiday ~mm Sunday evening at 8:00 p.m. through Labor Day al 7:00 p.m. ~. INDI~PENI)ENCE DAY: Thc Independence holiday shall run [rom 9:00 u.m. ou July 4d' through 9:()0 a.m. on July 5~h. The Mother shall have custody over Iht holiday in cvcu mmlbcrcd ycal's and thc Father shall have custody ill odd ntllnbcrcd yearn. F. MOTIIER'S DAY/FATIIER'S DAY: Thc Mother shall have custody of Lhc C'hildrcn every your on MoLher's Day rmnl 9:00 a.m. unli] 6:00 p.m. and Iht I':alher shall have cuslody or tile Children every year on Falber's Day ~ro]11 9:00 a.m. uulil G:()(j p.m. G. Thc holiday cuslody schedule shall supemmle and lake precedence ()vcr Iht regular cuslotly schcdtllc. (~. The Fulhcr shall be enLitlcd Io have custody or Ihe Cbildren evcry year durin~ Lhc summcr sc]mol break fi~r two non-cons~ulive weeks upon ~mvidin~ al least 30 days advance nolicc Io Iht ~olhcr. lu Ibc event eilher pa~y intends lo take the Chi]d~n on vacaLion, IhaL pa~y shall provide advance m~Licc Io Iht olher parly or Ihe address and telephone nnmher where Ibc Children can be COlllaCl~d. ?. Unless olherwise a~reed between the pa~ies, Ibe Falber shall provide all Irausporlalion exchanges ~r cuslody (o and from (he ~oLher's ~sidence, wilh Ihe exception L,r thc exc]mn~es custody on Fridays, whcn Ibc Father shall pick up Ihe Children 8t dance class. ~. Thc ];alh~r SJlull ellSLl~ Iha[ the ~olller has a cu~enl work telephone nUlllher mid boule IcIcphonc numbcr whcre (he Falhcr can be contacted ill Ihe event o[ an c]11cr~cncy or Lo discuss issues rc]aLin~ (~ lhc Chikh'cn. ~). Thc parlies shall communicme dimclly with each oLhcr couccmin~ issues ar~cc(in~ Iht Children wilheul II~e invelvemem oror interre~nce by Lbi~l pu~ies. 10. ~cilher parly shall consume alcohol Lo Lhe poinl or intoxication durin~ his or hcr periods cuslody. ~a~h parLy shall ensu~ Iha[ third pa~ies havin~ conlacl ~iLh II~e Children comply will~ Lhis provision durin~ his or her periods orcus&ody. I]. ~cilhcr parly shall lake Ihe Child~n te 8 18loo parlor rot cxlcmlcd pcri~d~ ~r lime dnriu~ 12. Neither pqrty shall cio or say anything which may estran§e Ihe Chih. lrcn Ii'on1 Ih¢ other pm'cai, iltjm't: thc ~qsislion esi' the Childron as to the olhcr parent, or hamper Ibc free ami n:ittlrql dc¥chqmJ~..~ll isl'thc L'hllth'cl~'s ItJvc alld respect Ibr thc other pureqt. Itt)Ih pm'lies shall Ct,sLIS'C Ih:il Ihird putties hqving contuel with the C'lfildren comply with Ibis provision. 13. This Order is enlered pursuant to an agreement ot' the parties al a Custody Conciliation Conlbrcnce. The purlies may modify the provisions o£this Order by mutual consent. In the uhseqce of mutual consent, the lerms of Ibis Order shall control. BY THE COURT, cc: J:mc M. Alcxandcr, I~scluire _ Counsel For Mother I')qniel McCitlirc, F'squire - C'ot~nsel for Father I{^NI)I ^. I.( )N(;, IN TIlE COUX. T OF COMMON I'LF. AS OF I'hli,lil'£ ClfMFIF. RI.AND (~OI JN'I'Y. I'FNN~YI.VANI^ Ys. 01-2844 CIVIl. ACTION I.AW r.;I.ARENCI,.' S, LON(;, III, : l)elbmhml : IN CUSTODY I{IO1( ,IUI)(,I,..I. Wesley Oler, Jr. CUSTODY CONCILIATION SUMI¥1ARY REPORT IN A(?C'(}I{I}ANCE WITII CUMBERLAND COUNTY I{UI,F. OF CIVIl, I'I{OCI,;I)UEI~. 1915.3-8, the undersigned Cuslody Concilialor submits Ihe ~ollowing rcporl: I. Thc I~cl'lilletll inlbl'malion co.coming thc Children who are die sahjccls of Ihis liligation is ~ls ~A~II,: I)AI~ OF BIRTII ~UIIIIEN'ri.Y IN CUS'I'OI)Y OF AIc.xandria I~. I.ml~ February I O, 1992 Molhcr C'alelyn S. I.on8 Fchraary 22, 2000 Molhcr 2. A (?oncilialion (~onrcrence wns held on Oclol)¢r 23, 2001, wi[h Ihe Following individuals in ~dlendance: The Mother, Rundi A. ~ng, wilh her counsel, Jane M. Alexander, Esquire, nnd Ihe Falher, Clarence S. I.on~, Ill, with his counsel, Daniel McGuire, Esquire. 3. Thc i)arlics agrced to cntry ornn Order in Ihe form ns altached. -_ I)ale Dawn S. Sunday, ES(luire~ Cuslody Concilialor RANDI A. LONG, IN THE COURT OF ('(.)I~IKII~ I'1 I.'..\S t)l.' Plainti£f CUMBERLAND COUNTY, PI!NN.~YI.VANIA vs. 01-2844 CIVIL At'TI()N I...\W CLARENCE S. LONG, III. Dcfi:ndant IN CUSTODY PItlOR .JUl)GE: J. Wesley Oler, Jr. CUSTODY CONCII,IATION SUI~II~iARY i~.EI'OICI' IN ACCORDANCE WITll CUIViBERLAND COUNTY I~,UI.E tll,' (:IVII. PROCEDURE 1915.3-8. Iht undcrsigncd Custody Conciliator submils thc Ibl .wi.? rcp.r~: I. Thc pcrtincut inlbrmtdion concerning the Children who are Ille subjects ,,1' Ih~n liliu;tliun as Iblloxvs: ~A~.II,] DA]If OF BIWrll ~UlOiEN'I'LY IN (.'US'I'( ~1}~' Alcxandrca p. Long February 10. 1992 Mothcr Culclyn S. Long I~'cbnu~ry 22. 2000 Molhcr 2. A Conciliation Coulbrcncc was held on June 26, 2002, with Iht Ihlh~xvi.~ md~xiduals attcndance: The Mother, Randi A. Long, with her counsel, Jane M. Alexander. l~squi~c, and Falhcr's couuscl, Barbara 1.. Wcvodau. Esquirc. The Futher, Clarence S. .. .~ n:.. III. x~h. filed this Petition Ibr Modilicalion. did nol allcml the Conl~rence lbr ~asons unknoxvu t~ his 3. The issues raised by thc Father in his P~tition were discussed ut thc ~',,,l~'rc,cc a,d thc Mother offend documemalion Ii'om Alexandrca's school, physician and c~)tlllsch)r m dh'cot to thc Father's allegations. 4. As Ihe Father did not altcnd Ihe Confe~nce, no further Order addressinu thc ctlstodv arrangements is necessa~ at this time except to dismiss the Father's Pclition Ibr M~dilication, (1' dcemcd necessary by the Court. Date Dawn S. Sunday, Esquirc~--;~ ......... Custody Couciliator RANDI ^. I.(~N(~, I'l.,,hll IN THE COURT OF COMMON Iq.,I:'AS OF ~'11MIIFPI AHII f't, IH'Fy. I'I:NNgYI.VANIA vs. 01-2844 CIVIL ACTION LAW ('I.AREN{ '1'~ ~. I.ONG. III I k'fendanl ~ CUSTODY ORDER OF COURT ANI) NOW, Ibis ,2~,s,I day of ~___~,/.. ,-- . ............... 2002, ur)on cc~nsMcralion ol'lhu altached Cuslody Concilialiol] Repo~ ~1 is ordered and directed as I~)Jlows: I. Thc prior Order of dfis Courl dated November 2, 2001 shall conlinuc in cl'lbct. 2. li;~scd t~n representations and documentation presented by the blolller al thc Conciliation ( '~nlbrence ami file Ihcl I}1111 Ibc Father was nol in allendanee, Ihe Father's I'etilion for Modilicalion is dJsJ fisscd BY THE COL~WI'. y 'OICI', .Ir, j, ct:: Ilarh.'u'a I.. Wcvodau, I'.'sqtlire .. Cotlnscl for Falller .I;1~.. [~1..'\lexa,hlcr. I!squi,'c £'ounscI Ibr Mother CLARENCE S. LONG, III on :IN THE COURT OF COMMON PLEAS behalf of minor children, :OF THE 41s'r JUDICIAL DISTRICT ('ATEI,YN S. I,ONG, :OF PENNSYI,VANIA - :PERRY COUNTY BRANCH ALEXANDREA P. LONG :NO. 03-278 ¥. :P.F.A. RANDI A. L(kNG ORDER AND NOW, March 25, 2003, the Court having received an ex parte request for an Order, the Court declin~ to sign such Order, but schedules a hearing on the issue of whether or not a Protection From Abuse Order should issue for Wednesday, April 9, 2003, at 8:30 a.m. in Courtroom # 2, Perry County Courthouse, New Bloomfield, Pennsylvania, at which time both the plaintiff and defendant shall be present for a hearing. Service of this Order shall be by the Sheriff of Perry County.. Cc: Plaintiff ~efendant Domestic Violence ' Sheriff " PS P Local Police ~ ' .~ ' i RTIFIED ,'[ UE COPY '/ DEPUTY PROTH{JI OTARY Clarence S. Long I!I on behalf of minor children, : IN THE COURT OF COMMON Catelyn S. Long, Alexandrea P. Long : PLEAS FOR THE 41ST : JUDICIAL DISTRICT PERRY Plaintiff : COUNTY, PENNSYLVANIA .- ; V. : i No. O3- 2?$ Randi A. Long : Defendant i CIVIL ACTION - LAW i PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. Any protection order granted by a court may be considered in subsequent proceedings under Title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes, including child custody proceedings under Chapter 53 (relating to custody). A .hca ng on the matter ~ scheduled for the ~at . c,, in Couruoo~. You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Under federal law, 18. U.S.C. §2265, this Order is enforceable anywhere in the United States. If you travel outside of ibc state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act. 18 U.S.C. §2262. Violation of this Order may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. In addition, if you are subject to a FINAL PROTECTION ORDER, you may be prohibited from possessing, transporting, or accepting a firearm under the 1994 Amendment to the federal Gun Control Act, I g U.S.C. §922 (d) and (g). SENT YOU AT THE HEARING. THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU. 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. IF YOU CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE. Coun .ty Lawyer Referral Service PA LAWYER REFERAL SERVICE 1-800-692-737:5 100 PINE STREET, PO BOX 166, HARRISBURG, PA 17108 PFAD Number: FJ1646779U Clarence S. Long Ill on behalf of minor : IN THE COURT OF COMMON children, Catelyn S. Long, Alexandreu P. Long : PLEAS FOR THE 41ST : JUDICIAL DISTRICT PERRY Plaintiff : COUNTY, PENNSYLVANIA : : v. : No. : Randi A. Long : CIVIL ACTION - LAW : PROTECTION FROM ABUSE Defendant : PETITION FOR PROTECTION FROM ABUSE Plaintiff's name is: Clarence S. Long Ill 2. I, ('the Filer), am filing this Petition: - as Parent of minor Plaintiff(s) · . Filer's Name is: Clarence S. Long Flier s Address is: 7081 Spring Rd.., Shermans Dale, PA 17090 5. Name(s} of ALL person(s), including minor children, who seek protection from abuse. a. Catelyn S. Long b. Alexnndrea P. Long 6. PlaintiWs Address is: 117 Steelstown Rd., Newville, PA 17:141 7. Defendant's Name is: Randi A. Long 8. Defendant is believed to live at the following address: · 117 Steeistown Rd., Newville, PA 17241 O. Dcfimdanl's Social Sem,rity Number is: OlliMlO-(lilllO 10. Defendant's Date of Birth is: · ~'~-'~? 30, 1969 11. Defenm~_-.?s Place of employment is: Cz :nputer Learning Network, Meehancisburg, PA 12. Det~p,d:.r: is an adult. 13. The ~:-.i .'.nship between the Plaintiff`and the Defendant is: · ";7 .',.use P::r :nts of the same children 14. The Pi::!:-r~if'and the Defendant been involved in the following court actions: ~. Support F. Custody 15. Other c-.-':~ils of the court action are: ~' "~'2 Cum berland Custody order- Defendant was awarded primary physical custody :...~ Plaintiff given every other weekend visitation. 2002 Support hearing at C'-,mberland County Domestic Relations. 16. The de:":.::ciant has not been involved in a criminal court action. 17. Plaintii'? '.nd Defendant are the parents of the following minor child/rea: . Catelyn S. Long Age:3 Child's address is: 117 Steelstown Rd., Newviile, PA 17241 · :. Alexandrea P. Long Age: 1 ! Child's address is: 117 Steeistown Rd., Newville, PA 17241 18. There '"~ an existing court order regarding the custody of the PlaintilTs and Defendant,s minor children. The terms of the order are: 2002 Cumberland Custody order- Defendant awarded primary physical custody and Plaintiff given every other weekend visitation. Coumy: Cumberland .~lnle: PA i 9. Plaimi'T !s seeking an Order of child custody as part of this petition. The fel!ewing is a list of the children and where they have live for the past 5 years: · :.. Catelyn S. Long For the past 5 years, this child has lived with: 2001-present: 117 Steelstown Rd., Newville, PA 1'7241 1998-2001:67 Country View Estates, Newville, PA 17241 Alexandria P. Long For the past 5 years, this child has lived with: 2001-present: 117 Steelstown Rd., Newville, PA 17241 1998-2001:67 Country View Estates, Newville, PA 17241 ' ~ong : .'. The f.~.c:s of the most recent incident of abuse are as follows: On a~.:.:~ Wednesday, March 19, 2003 at approximately 6:00PM locati=.~: .~ 17 Steelstown Rd., Newville, PA 17241 The De.*b~.dant and her two children, ages 11 and 3, were watching a movie. The girls got into an a. rgumer.~ and the three-year-old slapped her older sister. The · · sister's mouth shut. The D _ older starer briefly held her younger cf. became angry and held her eleven-year-old daughter*s mouth shut and sl.~l.?ped her repeatedly in the face. The eleven-year-old ran hack into her bedroom crying. The Def. foltowed and grabbed the minor child around her neck and punched her in her face. The Def. proeee~e.] to slap her in her face again, foUowed by punching the child in her shoulder. The three- year-o::~ -~ried to intervene on her sister*s behalf. The Def. turned her rage on the three-year-old and slapped her several times in the face. The n~f yelled at her. eleven.~year-old daughter to pack her ba~... ~he told her to get out of bet house right now. The minor chdd packed her bags and called ~er friend to see if she could spend the night. When the minor child came into the living room wi*.h her backpack, the Def. changed her mind and told her that she was just trying to get through +.o her. On Fr.;d_~y March 21 2003 when the Plaintiff picked up his two daughters for a sebeduled weekend vi.sit, 9e ]?rned of the abuse.against his daughters from his oldest eleven- wnat e?..t ha ened. T ' :_ . · year old who re orted ... ~ha,~ o,o. _i_p_pet ~. :he P. la.!ntiffobserved, hght bruise mar, on his dan, er', left oho~ .Fi._ .. ........ 0., s cpurteu To ncr luloer that her nose . . oht ......... ~,,..nc. , hurt. The Plaint,fY called Perry County Children & ... Youth =',nd reported the incident to a caseworker. A caseworker came to the residnee on Saturday. March 22 2003 and interviewed the oldest child. The caseworker also took three pictures of the ' child's ~See. The Plaintiffwas referred to Domestic ¥iolenee Services. . ...... .; ~ .. -' PHor iP.::i~ents of abuse that the Defendant has committed against Plaintiffor the minor c]~ild)~en.' (includim~ any threats, injuries, or incidents of stalking) are as tbllows: During me first week of March 2003 (minor child ean't recall exaet date), the Defendant threw her minor child who is 11, against their refrigerator so that the ehild*s head smacked against it. The child nl.~o sustained pain in her arm when it hit the handle of the refrigerator door. The Def. also slapped the child ac~;k~s her face. The child reported this incident to her father's girlfriend, who in tu .r~., informed the~ ! · later that same night. The Plaintitv---,- ......... , ,, ,, ~l,-,~c to me cnnu s prin. cip. al and gm(lance counselor on Monday March 10 2003 because the child had reported the incident] to these parties as well. On TIntr~d:ly Fehrnnry 20 2fl03, the Def. lost her temper with her children while tryJnl~ to get them into the ear. The Def. repeatedly hit her three-year-old daughter in her face once she got her into the ear sent. The eleven-year-old ran around to the front of the ear and tried to lock it to keep her mother out. The Def. got into the ear before the doors could be locked. Once in the ear, the Def. slapped her eleven- year- old repeatedly aeross her faee. The minor eleven=year-old daughter reported this incident to her school guldnnee counselor. The Plainti..ffis eoneerned for the safety and welfare ofhis two minor children and ' requests rehef from the court throw-a, o o ..... .. ...... ' at this time parties, s.. - -, u[~ctmn vrom Anuse oraer on behalf of the minor 22. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Newport PSP 23. There is an immediate and present danger of further abuse from the Defendant. 24. Plaintiff is asking the court to ~ exclude the Defendant from the following residence: 7081 Spring Rd., Shermans Dale, PA 17090 (No eviction. Plaintiffand Defendnnt do not li~,e together). Owned By: Carol Dieffenderfer 25. FOR TIlE REASONS SET FORTlt ABOVE, I REQIJEST TIlAT THE COURT ENTER A O 'ER.'nd A O ,ER T.AT WO ,.D DO a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiffand/or minor child/rea in any place where Plaintiffmay be found. b. 'E"~t/exclude Defendant from Plaintiffs residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. e. Award Plaintifftemporary custody of the minor child/ran and place the following restrictions on contact between Defendant and child/ran: No contact until court date at which time parties can agree on an arrangement. d. Prohibit Defendant from having any contact with Plaintiffand/or minor child/rea, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiff's school, business, or place of employment, except as the court may find necessary with respect to pnnial custody and/or visitation with the minor child/mn. e. Prohibit Defendant from having any contact with Plaintiff's relatives and Plaintiff's children listed in this petition, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/rea. Order the police or other law enforcement agency to serve the Deti~ndant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. VERIFICATION I veri~y that I am the petitioner as designated in the present action and that the thcts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements axe made subject to the Penalties of 18 Pa. C.S. §4904, relating to unsworn thlsification to authorities Clarence S. Long III on behalf of minor : IN THE COURT OF COMMON children, Catelyn S. Long, Alexandrea P. Long : PLEAS FOR THE 41ST : JUDICIAL DISTRICT PERRY Plaintiff : COUNTY, PENNSYLVANIA : No. Randi A. Long : : CIVIL ACTION - LAW Defendant i PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Randi A. Long Defendant's Date of Birth is: July 30, 1969 [3"-~'endant's Social Security Number is: 000-004)000 ?':.~me(s) of All protected persons, including Plaimiffand minor children: I. Catelyn S. Long 2. Alexandrea p. Long · ~-~,~D NOW, on 25th Day of Maroh, 2003 upon consideration of the attached P~.'tition for Protection from Abuse, the court hereby enters the following Temporary O~..'ter: Plaintiff's request for a temporary protection order is granted. 1. Defendant shah not abuse, harass, stalk or threaten any of the above persons in ".ny place where they might be found. 2. Defendant shall be ~ excluded from the residence at: 7081 Spring Rd., Shermans Dale, PA 17090 (No evietiun. Plaintiffand Defendant do not live together). :~r any other permanent or temporary residence where Plaintiff or any other person protected under this Order may live. Plaintiffis granted exclusive possession of the residence. Defendant shall have no right or privilege to enter or be present on the premises of Plaintiff or any other person protected under this Order. 3. Except for such contact with the minor child/ten as may be permitted under paragraph 5 of this Order, Defendant is prohibited from having ANY CONTACT with Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiffs school, business, or place of employment. Defendant is specifically ordered to stay away from the following iocations for the duration of this order. ' Newville Elementary School 4, ?-xcept for such comact with the minor child/ren as may be permitted under paragraph $ of this Order, Defendant shall not contact Plainti~ or any other :~,'r.;,,. i~n.,-,.~nl .n,'ler Ihi.~ Order. by lelephnne nr by nny miler mennr;, inch,din/:,. :brough third persons. $. ?ending the outcome of Ibc final hearing in this matter, Plalntiffis awarded 'empomry custody of the following minor child/mn: I. Catelyn S. Long 2. Alexandria p. Long ~ntil the final hearing, all contact between Defendant and the child/ren shall be ~!mited to the following: No contact until court date at which time parties eau agree on an '~rrangement. The local law enforcement agency in the jurisdiction where the child/ten are :neared shall ensure that the child/res are placed in the care and control of the 'qaintiff in accordance with the terms of this Order. Fhe following additional relief is granted: - Def_e.nd.a.n.t is pr.o. hibited from having any contact with Plai ' · and Plamtafl's ehddren listed :- -~: ..... ntfl~s relatives · al! tllla pel'lglOn~ except as the con 3eeessary w~th resneet to .~a-,~*. ...... ~ ........ rt may find · .:hild/ren. ~ ~. · a.m. ~uamuy ann/or vts~mt~on w~th the minor ?..~ certified copy of this Order shall be provided to the police department where ?laintiff resides and any other agency specified hercafier: N'ewpor~ PSP ~. Fhe sheri£f; police or other law enforcement agencies are directed to serve the Del'endant with a copy of the Petition, any Order issued, and the Order for Hearing without Prepayment of costs. The Petitioner will inform the designated ~U~tnhOri .fy of any addresses, other than the Defendant's residence, where Defendant be served. The Prothonotary is directed to file this Petition and Order without ~repayment of costs. 9. THIS ORDER SUPERSEDES ANY PRIOR ORDER RELATING TO CHILD CUSTODY l'} THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for ip. direc.t criminal contempt, which is punishable by a fine of up to $1,000.00 and/or uf~ ~,~ ~ax months in.jail. 23 Pa.C.S. §6114. Consent of the Plnintifftn Defendant's r~:'~m to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that pu.~ose. 23 Pa.C.S. §hi 13. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. §§2261- NOTICE TO LAW ENFORCEMENT OFFICIALS T':is Order shall be enforced by the police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the d:!'endant may be located. If defendant violates Paragraphs I through 5 of this Crier, defendant shall be arrested on the charge of Indirect Criminal Contempt. An a.-.'=st tbr violation of this Order may be made without warrant, based solely on prcbable cause, whether or not the violation is committed in the presence of law e',~breement. S~d~sequent to an arrest, the law enforcement officer shall seize all weapons used or trreatened to be used during the violation of this Order OR during prior incidents of ai'ase. Weapons must forthwith be delivered to the Sheriff's office of the county x;'~ich issued this Order, which office shall maintain possession of the weapons until fi-:.'~her Order of this court, unless the weapon/s are evidence of a crime, in which c:..;e, they shall remain with the law enforcement agency whose officer made the a.~'. 2St. ~Y_THECOURT Judge Date Dis,*:ibution to: PLAINTIFF DEFENDANT LOCAL POLICE STA ".'E POLICE SHERIFF DOK{ESTIC V'~ ~,LENCE FIIC IN THE COURT OF COMMON PLEAS OF CUMBERLAND, PENNSYLVANIA RANDI A. LONG, : CIVIL ACTION - LAW Plaintiff/Petitioner : : VS. : NO. 01-2844 CLARENCE S. LONG, III, : Defendant/Respondent : IN CUSTODY NOTICE AND ORDER TO APPEAR Legal proceodings have been brought against you alleging you have willfiflly disobeyed an order of court for custody and visitatiou. If you wish to defend against the claim set forth in thc following pages, you may but are not required to file in writing with the court your defenses or objections. Whether or not you file in writing with the court your defenses or objections, you must appear in Courtroom..~ ~. I , Cumberland Count' Court House, I Courthouse Square, Carlisle. PA 17013. IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST. If the court finds that you have willfully failed to comply with its order for custody and visitation, you may be found to be in contempt of court and committed to jail, fined or both. 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. Curoberland County Bar Association 2 Liberty Avenue Carlisle. PA 17013 (717) 249-3166 BY THE COURT: Judge