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Home My WebLink About91-4011SHARON KEEFER Plaintiff DAWN STROCK and NORMAN KEEl:ER, JR. Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW NO. ~0[{CIVIL 1991 IN CUSTODY CUSTODY AND VISITATION AGREEMENT THIS AGREEMENT, made this ,~ ~7~-- day of 0~0/~e~' 1991, between Sharon Keefer (hereinafter "Grandmother"), and Defendants Dawn Strock (hereinafter "Mother) and Norman Keefer, Jr. (hereinafter "Father") concerns the custody and visitation of the child Justin Keefer. WHEREAS, all parties desire to enter into an agreement as to the custody of Justin Keefer and to have this agreement made an Order of Court, the parties agree to the following: 1. Justin Keefer. 2. Mother shall have reasonable periods of partial custody with Justin Keefer as mutually agreed to by the parties at a later date. 3. Mother shall keep the grandmother informed as to the whereabouts of Justin Keefer when the mother has partial custody. 4. Mother shall not drop Justin Keefer off at the home of the maternal grandparents without first notifying the grandmother. 5. Justin Keefer shall always have his own bed to sleep in. 6. Mother shall not be drunk or otherwise intoxicated when she has partial Grandmother shall have sole legal custody and primary physical custody of custody of Justin Keefer. 7. Mother shall drop Justin Keefer off at the mutually agreed to times and places. 8. Mother shall not take Justin Keefer outside the state. 9. Mother and father understand that the Family Law Clinic represents only the grandmother's interests in this matter. Dawn Strock Mother Norman Keefer Father Sharon Keefer Grandmother Lisa Newman Student Attorney THOMAS M. PLACE ROBERT E. RAINS LINDA E. FISHER Supervising Attorney FAMILY LAW CLINIC 150 S. College Carlisle, PA 17013 Approved and entered as an Order of Court. ~ A .~ J. SHARON KEEFER v. DAWN STROCK and NORMAN KEEFER, JR. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 4011 CIVIL 1991 IN CUSTODY PETITION POR PARTIAL CUSTODY 1. Petitioners are Sharon Keefer and Norman Keefer, Jr., grandmother and father of Christian Keefer who live at 934 Valley Road, Enola, Pennsylvania, 17025. 2. Respondent is Dawn Strock, mother of Christian Keefer who lives at 17 East Louther Street, 2nd floor, Carlisle, Pennsylvania, 17013. Christian Keefer was born July 28, 1986 out of wedlock. 4. Justin Keefer has lived with the following persons: July 1986 to July 1987 with parents and paternal grandparents in Harrisburg, PA July 1987 to January 1988 with parents and paternal grandparents in Mechanicsburg, PA January 1988 to Summer of 1989 with parents in Wertzville, PA Summer 1989 until February 1991 with parents in Boiling Springs February 1991 with paternal grandmother April 1991 with mother 5. christian visited with petitioners every weekend for over a year until June 1992, on birthdays, holidays and two weeks at Christmas. 6. The petitioners have been denied visits since June 1992. 7. Sharon Keefer was awarded sole legal custody and primary physical custody of Justin Keefer, brother of Christian by order of Court dated November 18, 1991. WHEREFORE, petitioners request partial custody of christian every weekend from Friday at 6:00 p.m. until Sunday at 6:00 p.m., two weeks in July and shared holidays. February /~, 1993 Respectfully submitted, ( _Fs~ances H. Del Duca ~-A~torney for Petitioners I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 10 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Dated: SHARON KEEFER :: :: V. DAWN STROCK and :: NORMAN KEEFER, JR. :: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 4011 CIVIL 1991 IN CUSTODY ORDER OF COURT consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, the conciliator, at 4th Floor, Cumbe~lDnd County Court House on the I~day of ~f~ 1993, at F~u~..M. 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. FOR THE COURT, By: C~stody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 717-240-6200 SHARON KEEFER ~ DAWN E. STROCK, and NORMAN D. KEEFER, Jr., Plaintiff Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 4011 CIVIL 1991 CUSTODY _.NOTICE ANDORDERTOAPPEAg~ Legal proceedings hawe been brought against you alleging you have wilfully disobeyed an order of court for partial custody and requesting modification of custody. If you wish to defend against the claim set forth in the 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 person before Hubert X. Gilroy, the conciliator, in the conference room on the 4th floor of the Omberland Coun~tzCourthouse on the 18th day of March, 199~3, at 8:30 a.m. 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 of court. YOU SHOULD TAKE THIS PAPER TO YOUR LAWxrI~R AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFPORD ONE, GO TO OR q~LEPHONE THE OFFICE SET FOR~ BEL/~ TO FIND OUT thlIERE YOU CAN GET LEGAL HELP. DAWN STROCK, NORMAN KEEFER, Plaintiff VS. Defendant AND NOW. this~day IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2512 CIVIL 1989 PROTECTION FROM ABUSE CUSTODY CUSTODY ORDER of February, 1991, upon consideration of the parties' Consent Agreement. the following Order is entered with regard to custodv of the parties' children, JUSTIN MATTHEW KEEFER and KRISTIN KEEFER. 1. The Plaintiff, hereinafter referred to as the mother, will have primary physical and legal custody of the children. The Oefendant, hereinafter referred to as the father, will have custody of the children at times which are mutually agreeable to the partial parties. 3. The mother will provide transportation of the children to ano from the father's residence. 4. Neither party shall do anything which may estrange the children from the other parent, or injure the opinion of the child(ren~ as to the other parent or which may hamper the free and natural development of the children's love or respect of the other parent. TMUE COpy F ..... HONt RECORD By the Court, Exhibit A SHARON KEEFER Plaintiff DAWN STROCK and NORMAN KEEFER, JR. Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW NO.q 0 ~ ICIViL 1991 IN CUSTODY CUSTODY AND VISITATION AGREEMENT THIS AGREEMENT, made this day of ~P~0e~' 1991, between Sharon Keefer (hereinafter "Grandmother"), and Defendants Dawn Strock (hereinafter "Mother) and Norman Keefer, Jr. (hereinafter "Father") concerns the custody and visitation of the child Justin Keefer. WHEREAS, all parties desire to enter into an agreement as to the custody of Justin Keefer and to have this agreement made an Order of Court, the parties agree to the following: 1. Grandmother shall have sole legal custody and primary physical custody of Justin Kee£er. 2. Mother shall have reasonable per/ods of partial custody with Justin Keefer as mutually agreed to by the parties at a later date. 3. Mother shall keep the grandmother informed as to the whereabouts of Justin Keefer when the mother has partial custody. 4. Mother shall not drop Justin Keefer off at the home of the maternal grandparents without first notifying the grandmother. 5. Justin Keefer shall always have his own bed to sleep in. 6. Mother shall not be drunk or otherwise intoxicated when she has partial Exhibit B custody of Justin Keefer. 7. Mother shall drop Justin Keefer off at the mutually agreed to times and places. 8. Mother shall not take Justin Keefer outside the state. 9. Mother and father understand that the Family Law Clinic represents only the grandmother's interests/n this matter. Dawn Strock Mother Norman Keefer Father Sharon Keefer Grandmother Lisa Newman Student Attorney THOMAS M. PLACE ROBERT E. RAINS LINDA E. FISHER Supervising Attorney FAMILY LAW CLINIC 150 S. College Carlisle, PA 17013 Approved and. entered as an Order of Court. Date: I I[/// 8/ q / TRUE COPY FROM RECORD In Tox~r~t who~ot, ! ~re ~ato ~.~ my fi,md APR 1993, SHARON KEEFER, Plaintiff V DAWN KEEFER and NORFa%N KEEFER, JR. Defendants :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVARIA :NO. 4011 - CIVIL - 1991 :CIVIL ACTION - CUSTODY AND NOW, this day of~_~w~'~ , 1993, the~&ttached Custody Conc~iator Report, directed as follows: upon consideration of it is ordered and 1. The Paternal Grandmother Sharon Keefer and the Father Norman Keefer, Jr. and the Mother Dawn Strock shall enjoy shared legal custody of Kristin E. Keefer, born June 22, 1986 and Justin M. Keefer, born July 28, 1987. 2. The Grandmother and the Father shall enjoy primary physical custody of Justin. 3. The Mother shall enjoy primary physical custody of Kristin. 4. Parties shall exchange physical custody of the minor children on alternating weekends from Friday at 6:00 p.m. until Sunday at 5:00 p.m. under a schedule whereby the children shall be together on each weekend. For the first two months, the alternating weekend schedule shall only be for one weekend per month, and thereafter shall alternate on consecutive weekends. 5. Neither party shall consume illegal drugs while they have custody of either of the minor children. 6. The party having the children for the weekend will provide the transportation and will remain in the car during the transfer of custody. 7. The parties will alternate holidays as follows: Easter, Memorial Day, Labor Day, Thanksgiving, and Christ- mas. The Mother will have both children from Christmas Eve, 1993 at 6:00 p.m. until Christmas Day at 11:00 a.m. The Father and Grandmother will have the children from 11:00 a.m. Christmas Day until December 26 at 11:00 a.m. This schedule for Christmas shall alternate each year thereafter. 8. The Mother shall have the children on Mother's Day, the Father shall have the children on Father's Day and the Grandmother shall have the children on Grandparent's Day, each period of time to be from 1:00 p.m. until 5:00 p.m.. 9. The parties will share the children's birthdays at times as agreed upon by the parties. 10. Mother will enjoy a period of two weeks vacation during the summer months to coincide with her work vacation. Mother shall advise the Grandmother and Father at least thirty days in advance as to when this vacation shall take place. In the event that Mother's vacation conflicts with the vacation in the Grandmoth- er's household, the parties shall work out an arrangement whereby each of them shall have at least a one week period of time with the children in the summer during their scheduled vacation and the other to be during non-vacation time. 11. The parties by mutual agreement may vary the schedule at any time as they may agree. 12. The orders previously issued in this case at 4011 Civil 1991 and 2512 Civil 1989 are vacated. BY THE COURT: SHARON KEEFER, Plaintiff V DAWN STROCK and NORMAN KEEFER, JR. Defendants :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :NO. 4011 - CIVIL - 1991 : :CIVIL ACTION - CUSTODY : : PRIOR JUDGE ASSIGNED: HONORABLE GEORGE E. HOFFER CONCILIATION CONFERENCE SU~4~tY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Justin M. Keefer, born July 28, 1987 and Kristin E. Keefer, born June 22, 1986. 2. A Conciliation Conference was held on March 18, 1993 with the following individuals in attendance: Father Norm Keefer, Jr. who appeared with his counsel Frances DelDuca, Esquire, Mother Dawn Strock who appeared with her counsel Joan Carey, Esquire, of Legal Services and the Paternal Grandmother Sharon Keefer who appeared with her counsel Erik Lang of the Family Law Clinic. 3. The parties agreed to the attached. entry of an order in the form as Hu eft X. Ga roy/ Esquire Custody Conciliator SHARON KEEFER, Pet i t loner/Respondent DAWN E. STROCK, Respondent/Petitioner NORMAN D. KEEFER, Jr., Respondent : IN THE COURT OF CO~[MON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 91-4011 CIVIL TERM : CUSTODY PETITION FOR MODIFICATIO[j The petitioner, Dawn E. Strock, avers the following by and through her attorney, Joan Carey of Legal Services, Inc. 1. The petitioner is Dawn E. Strock ("the mother"), residing at 17 East Louther Street, 2nd Floor, Carlisle, Cumberland County, Pennsylvania. 2. The respondents are Sharon Keefer ("the grandmother") who resides at 934 Valley Road, Enota, Cumberland County, Pennsylvania, and Norman D. Keefer, Jr. ("the father") who resides at the Molly Pitcher Hotel, 13 South Hanover Street, Room 410, Carlisle, cumberland County, Pennsylvania. 3. The petitioner is the mother of Justin M. Keefer ("Justin") and Kristin E. Keefer ("Kristin"). 4. On February 22, 1991, the Court awarded the mother custody of both children through the mother's Protection From Abuse and Custody action against the father. See attached Exhibit A incorporated by reference. Pursuant to a Consent Agreement: signed by the parties on October 7, 1991, a custody order was entered by this Court on November 18, 1991, continuing custody of Kristin in the mother and granting the grandmother and the father primary custody of Justin with the mother having reasonable periods of partial custody as mutually agreed upon by the parties. See attached Exhibit B incorporated by reference. On March 17, 1993, the ~other filed a Petition for Contempt and Modification against the grandmother and father for consistently and wilfully obstructing her efforts to exercise periods of partial custody with Justin. This Court entered an Order on April 9, parties. 5. 1993, setting out a specific schedule for partial custody for the See attached Exhibit C incorporated by reference. On or about May 16, 1994, school administrators at East Pennsboro Elementary School[ contacted Cumberland County Children & Youth Services to report that 6 year-old Justin had 25 days of unexcused absence from school in the 1994 calendar year. 6. The Children & Youth caseworker investigating the school's allegations reported that the child's absences were not due to any illness that he had, but primaritly to the severity of the grandmother's illnesses with diabetes and cancer which rendered her physically unable to provide basic care to the child and get him up and ready for school. 7. The mother has concerns regarding the child's welfare if he continues to reside with the grandmother for reasons including: a) The child is not progressing developmentally according to his ability and age. b) The grandmother is not physically able at this time to provide care for the child, including assuring his attendance at school. c) The mother fears that the grandmother's environment adversely affects Justin since he is exposed to violent criminal activities of the grandmother's children (including the child's father) who are both defendants in a Protection From Abuse case filed by the grandmother and who both have a history of drug and alcohol abuse. 8. The mother, who has established a stable environment for herself and her daughter, Kristin, can best provide for the physical and emotional needs of Justin. 9. It is not in Just:in's best interest to be separated from his sibling. WHEREFORE~ the petitioner requests that the order of October 7, 1991, be modified to grant her primary custody of Justin M. Keefer and set forth a partial custody schedule for the grandmother. The petitioner further requests such other relief as may be proper. just and Respectfully submitted, 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 The above-.named petitioner, Dawn E. Strock, verifies that the statements made in the above Petition are true and correct. The plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Dawn E. Strock, Petitioner DAWN STROCK. NORMAN Plaintiff VS. Oefenoan~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2512 CIVIL 1989 PROTECTION FROM ABUSE CUSTODY ~u~TQDy ORDER AND NOW. tn~s ~ _~ cay of February, 1991. uDon consideration of tDe oar~les' Consent Agreement. the following Order is entered with regard to c=s;==~ ?~ the ;ar:]es' chlloren..JUSTIN MATTHEW rEEFER and KRISTIN KEEFEE. ;. The ~la~n[]ff. nere]nafcer referreo to as the mother, will have or-'mar'v onvs!ca! and :eaa] custody of the children. ~. -i~e gefeno~t, hereinafter referred:to as the father, will have car::a: :u~oov of the cn~iOren at t~me$ which are mutually agreeable ~o the c~rt:es. 3. The ~c~ner w~i] Drcv:oe ~ransoortatNon of the children to and from ~. Neither Dar~¥ sha}l ~o anv[hing which may e~tran~e :he children from %ne ~cner :arena. or ~n]ure t~e oo~nlon Of the fhild[ren) as to :he other oareH[ )r wnl,:n may hamoer ~he free and natural deveioDmen~ of the children's }ore or resDe¢c of %he other oarent. Bv the Court, ~orge E. Holler, J~'j-~y~' TRUE, COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of ~a~J Court at CarNsle, Pa. 'Prothonot*ary ~' Exhibit A SHARON KEEFER Plaintiff DAWN STROCK and NORMAN KEEFER, JR. Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ~01{CIVIL 1991 IN CUSTODY CUSTODY AND VISITATION AGREEMENT THIS AGREEMENT, made this day of ~'oOer" 1991, between Sharon Keefer (hereinafter "Grandmother"), and Defendants Dawn Strock (hereinafter "Mother) and Norman Keefer, Jr. (hereinafter "Father") concerns the custody and visitation of the child Justin Keefer. WHEREAS, all parties desire to enter into an agreement as to the custody of Justin Keefer and to have this agreement made an Order of Court, the parties agree to the following: 1. Grandmother shall have sole legal custody and primary physical custody of Justin Keefer. 2. Mother shall have reasonable periods of partial custody with Justin Keefer as mutually agreed to by the parties at a later date. 3. Mother shall keep the grandmother informed as to the whereabouts of Justin Keefer when the mother has partial custody, 4. Mother shall not drop Justin Keefer off at the home of the maternal grandparents without first notifying the grandmother. 5. Justin Keefer shall always have his own bed to sleep in. 6. Mother shall not be drunk or otherwise intoxicated when she has partial Exhibit B custody of Justin Keefer. 7. Mother shall drop Justin Keefer off at the mutually agreed to times and places. 8. Mother shall not take Justin Keefer outside the state. 9. Mother and father understand that the Family Law Clinic represents only the grandmother's interests in this matter. Dawn Strock Mother Norman Keefer Father Sharon Keefer Grandmother Lisa Newman Student Attorney THOMAS M. PLACE ROBERT E. RAINS LINDA E. FISHER Supervising Attorney FAMILY LAW CLINIC 150 S. College Carlisle, PA 17013 Exhibit B Date: ~ /I ~il~ApprOved and entered, as an Order of Court~~I~ Exhibit B APR 8 1993, SHARON KEEFER, Plaintiff V DAWN KEEFER and NORMAN KEEFER, JR. Defendants :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 4011 - CIVIL - 1991 :CIVIL ACTION - CUSTODY AND NOW, this day of~)~ , 1993, the attached Custody Conc~iator Report, directed as follows: upon consideration of it is ordered and 1. The Paternal Grandmother Sharon Keefer and the Father Norman Keefer, Jr. and the Mother Dawn Strock shall enjoy shared legal custody of Kristin E. Keefer, born June 22, 1986 and Justin M. Keefer, born July 28, 1987. 2. The Grandmother and the Father shall enjoy primary physical custody of Justin. 3. The Mother shall enjoy primary physical custody of Kristin. 4. Parties shall exchange physical custody of the minor children on alternating weekends from Friday at 6=00 p.m. until Sunday at 5=00 p.m. under a schedule whereby the children shall be together on each weekend. For the first two months, the alternating weekend schedule shall only be for one weekend per month, and thereafter shall alternate on consecutive weekends. 5. Neither party shall consume illegal drugs while they have custody of either of the minor children. 6. The party having the children for the weekend will provide the transportation and will remain in the car during the transfer of custody. 7. The parties will alternate holidays as follows= Easter, Memorial Day, Labor Day, Thanksgiving, and Christ- The Mother will have both children from Christmas Eve, 1993 at 6:00 p.m. until Christmas Day at 11:00 a.m. The Father and Grandmother will have the children from 11:00 a.m. Christmas Day until December 26 at 11=00 a.m. This schedule for Christmas shall alternate each year thereafter. Exhibit C 8. The Mother shall have the children on Mother's Day, the Father shall have the children on Father's Day and the Grandmother shall have the children on Grandparent's Day, each 9eriod of time to be from 1=00 p.m. until 5=00 p.m.. 9. The parties will share the children's birthdays at times as agreed upon by the parties. 10. Mother will enjoy a period of two weeks vacation during the s-mmer months to coincide with her work vacation. Mother shall advise the Grandmother and Father at least thirty days in advance as to when this vacation shall take place. In the event that Mother's vacation conflicts with the vacation in the Grandmoth- er's household, the parties shall work out an arrangement whereby each of them shall have at least a one week period of time with the children in the Sl,mmer during their scheduled vacation and the other to be during non-vacation time. 11. The parties by mutual agreement may vary the schedule at any time as they may agree. 12. The orders previously issued in this case at 4011 Civil 1991 and 2512 Civil 1989 are vacated. BY THE COURT: Exhibit C SHARON KEHFHR, Plaintiff V DAWN STROCK and NORMAN KEEFER, JR. Defendants :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :NO. 4011 - CIVIL - 1991 :CIVIL ACTION - CUSTODY : PRIOR JUDGE ASSIGNED: HONORABLE GEORGE E. HOFFER CONCILIATION CONFERENCE SUM~%~Y ~EPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Justin M. Keefer, born July 28, 1987 and Kristin E. Keefer, born June 22, 1986. 2. A Conciliation Conference was held on March 18, 1993 with the following individuals in attendance: Father Norm Keefer, Jr. who appeared with his counsel Frances DelDuca, Esquire, Mother Dawn Strock who appeared with her counsel Joan Carey, Esquire, of Legal Services and the Paternal Grandmother Sharon Keefer who appeared with her counsel Hrik Lang of the Family Law Clinic. attached. The parties agreed to the entry of an order in the form as Hubert X. Gl.l.r.oy./ Esquire Custody Conc~li&tor Exhibit C SHARON KEEFER ~ P I a int i f f/Respondent Vo DAWN E. STROCK, Defendant/Petitioner NORMAN D. KEEFER, Jr., Defendant/Respondent IN THE COURT OF COI~qON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 4011 CIVIL 1991 : : CUSTODY PETITION FOR CON'rI21~ AND MODIFICATION The petitioner, Dawn E. Strock. avers the following by and through her attorney, Joan Carey of Legal Services, Inc. 1. The petitioner is Dawn E. Strock ("the mother"), residing at 17 East Louther Street, 2nd Floor, Carlisle, Cumberland County, Pennsylvania. 2. The respondents are Sharon Keefer ("the grandmother") and Norman D. Keefer, Jr. ("the father"), who reside at 934 Valley Road, Enola, Cumberland County, Pennsylvania. 3. The petitioner is the mother of Justin M. Keefer ("Justin") and Kristin E. Keefer ("Kristin"). 4. On February 22, 1991, the Court awarded the mother custody of both children (See attached Exhibit A incorporated by reference.) Pursuant to a Consent Agreement a custody order was entered by this court on November 18, 1991, granting the mother partial custody of Justin M. Keefer and the grandmother primary physical reference). 5. Since custody of Justin (see attached Exhibit B incorporated by the entry of the custody order of November 18, 1991, the grandmother and father have consistently and wilfully obstructed the mother's efforts at exercising periods of partial custody with Justin M. Keefer by denying her access to the child whenever she attempted to schedule visits. 6. In or about January, 1993, the grandmother and father wilfully failed Exhibit C to return Kristin to the mother pursuant to this Court's Order of February 22. 1991. The mother contacted the East Pennsboro Police Department who assisted her in getting the child from the grandmother and father. 7. It is not in the children's best interest to be separated from each other or to be denied reasonsble contact with the mother. 8. The mother requests a specific partial custody schedule for Justin including weekends, holidays, extended periods in the summer and other times that can be agreed upon. WHEREFORE. the petitioner requests that the respondents contempt of cou:rt. The petitioner further requests that the order of October 7, modified to grant her specific periods of partial custody. In addition, the petitioner requests any other relief which is just and proper. be found in 1991, be Respectfully submitted. ,~dan C'arey, Attorne~or Petitioner LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 Exhibit C SHARON KEEFER, Petitioner/Respondent DAWN E. STROCK, Respondent/Petitioner NORMAN D. KEEFER, Jr., Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 91-4011 CIVIL TERM : CUSTODY ORDER OF COURT AND NOW, this ~%day of ._~ , 1994, upon consideration of the attached complaint, it is h~i~re_~.[.~ed that the parties and their respective counsel appear befor bert X. Gilroy, Esq:,/Samuel L. ~des, Esq. on the ~ day of - ~ 1994, at [O[~m., on th loor of the Cumber ~y Courthouse~t the law offices of ~des, Vaughn & Bangs, 525 North 12th Street, Lemoyne, Cumberland County, Pennsylvania, for a Pre-Hearing Custody ~nference. 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 tem~rary order. Failure to appear conference may provide grounds for entry of a tem~rary or permanent at the order. For the Court, Custody Conci 1 iator YO~ SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOq' A~TORD O~E, GO TO OR TELEPHO~ THE OFFICE SET !~ORTH BELOW TO FIND Otrr WHERE YO0 CAN GET I~ HELP. , COURT ADMINISTRATOR, 4TH FLOOR ~¢klMBERL~ ~U~ COURTHOUSE jcP~LISL~, P~VANIA 17013 TELEPHONE: (717) 240-6200 SHARON KEEFER, Plaintiff/Petitioner V. ' .. DAWN E. STROCK, : Respondent/Defendant : NORMAN D. KEEFER, JR. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 91-4011 CIVIL TERM CUSTODY PETITION FOR SPECIAL RELIEF 1. Petitioner is Sharon Keefer, who currently resides at 934 Valley Road, Enola, Cumberland County, Pennsylvania. 2. Respondent is Dawn E. Strock, who resides at 17 East Louther Street, Second Floor, Carlisle, Cumberland County, Pennsylvania. 3. Petitioner is the grandmother of Justin M. Keefer, born July 28, 1987, and Kristin E. Keefer, born June 22, 1988. Respondent is the mother of said children. 4. On April 9, 1993, after a conciliation, the Court entered an Order giving the captioned parties shared legal custody of Kristin E. Keefer and Justin M. Keefer, giving to Petitioner and Norman Keefer, Jr., her son, primary physical custody of Justin, and to Respondent, primary physical custody of Kristin. A copy of the Court's Order of April 9, 1993 is attached hereto as Exhibit "A". 5. Respondent has filed a Petition for Modification, and a conciliation before Hubert X. Gilroy, Esquire is set for September 29, 1994 at 10:30 a.m. 6. Pursuant to agreement of the parties, said children have been in the physical custody of Petitioner for a week ending August 19, 1994. 7. During that week, Kristin has described to Petitioner molestation by a visitor in Dawn Strock's home at a time when Dawn Strock was in the home and had left the child unintended with the perpetrator. Kristin described the perpetrator placing his hands in her underpants and fondling her. 8. Petitioner has brought Kristin to Cumberland County Children and Youth Services which has no jurisdiction over the abuse since it was not performed by a member of Respondent's household. Cumberland County Children and Youth Service referred Petitioner to the Carlisle Police Department. 9. 10. Detective Fortes of the Carlisle Police Department is investigating the abuse. During the past week, both children have described to Petitioner extensive drug use in the Respondent's household, including the smoking of a material which the children described as looking like tobacco and the placing of "white stuff= in a black instrument which is then smoked. This activity has also been reported to the Carlisle Police Department. 11. Petitioner avers that Kristin has expressed her desire not to return to Respondent's home for fear of injury since she states that she told Respondent about the abuse and Respondent did nothing in response. 12. Petitioner requests this Court enter a Temporary Order, pending the conciliation set for September 29, 1994, providing temporary physical custody of Justin Keefer and Kristin Keefer to her with such times of visitation with Respondent as can be arranged in a neutral environment such as Petitioner's home or a public place. FLOWER, MORGENTHAL FLOWER & LINDSAY Attorneys for Plaintiff/Petitioner By: ~ ,' . ' Esquire 11 East High Street Carlls/e, PA 17013 (717) 243-5513 2 VERIFICATION i, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. SHARON KEEFEN, Plaintiff V DAWN KEEFER and NORMAN KEEFER, JR. Defendants :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 4011 - CIVIL - 1991 :CIVIL ACTION - CUSTODY : : ORDER AND NOW, thzs ¥ day of [£{.v~J~ , 1993, u.pon consideration of the attached Custody Conc~li~/tor Report: it Ks ordered and directed as follows: 1. The Paternal Grandmother Sharon Keefer and the Father Norman Keefer, Jr. and the Mother Dawn Strock shall enjoy shared legal custody of Kristin E. Keefer, born June 22, 1986 and Justin M. Keefer, born July 28, 1987. 2. The Grandmother and the Father shall enjoy primary physical custody of Justin. 3. The Mother shall enjoy primary physical custody of Kristin. 4. Parties shall exchange physical custody of the minor children on alternating weekends from Friday at 6:00 p.m. until Sunday at 5:00 p.m. under a schedule whereby the children shall be together on each weekend. For the first two months, the alternating weekend schedule shall only be for one weekend per month, and thereafter shall alternate on consecutive weekends. 5. Neither party shall consume illegal drugs while they have custody of either of the minor children. 6. The party having the children for the %;eekend wi!l provide the transportation and will remain in the car during the transfer of custody. 7. The parties will alternate holidays as follows: Easter, Memorial Day, Labor Day, Thanksgiving, and Christ- m~s, The Mother will have both children from Christmas Eve, 1993 at 6:00 p.m. until Christmas Day at 11:00 a.m. The Father and Grandmother will have the children from 11:00 a.m. Christmas Day until December 26 at 11:00 a.m. This schedule for Christmas shall alternate each year thereafter. EXHIBIT "A" 8. The Mother shall have the children on Mother's Day, the Father shall have the children on Father's Day and the Grandmother shall have the children on Grandparent's Day, each period of time to be from 1=00 p.m. until 5=00 p.m.. 9. The parties will share the children's birthdays at times as agreed upon by the parties. 10. Mother will enjoy a period of two weeks vacation during the e,,mmer months to coincide with her work vacation. Mother shall, advise the Grandmother and Father at least thirty days in advanbe as to when this vacation shall take place. In the event that Mother's vacation conflicts with the vacation in the Gran~mcth- er's household, the parties shall work out an arrangement whereby each of them shall have at least a one week period of time with the children in the s,,mmer during their scheduled vacation and the other to be during non-vacation time. 11. The parties by mutual agreement may vary the schedule at any time as they may agree. 12. The orders previously issued in this case at 4011 Civil 1991 and 2512 Civil 1989 are vacated. BY THE COURT: George E. Holler , u EXHIBIT "A" SHARON KE~-FER, Plaintiff V DAWN STROCK and NORMAN KEEFER, JR. Defendants :iN TH~ COURT OF COMMON P?.~S OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 4011 - CML - 1991 :CIVIL ACTION - CUSTODY PRIOR ~uuG~ ASSIGNED= EONORABLE G~ORG~ CONCILIATION IN ACCORDANCE WITH CUMBERLAND COUNT~RULE OF CML PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator su~ts the following report= 1. The pertinent information pertaining to the =hildren who are the subject of this litigation is as follows: Justin M. Keefer, born July 28, 1987 and Kristin E. Keefer, born June 22, 1986. 2. A Conciliation Conference was held on M~ch 18, 1993 with the following individuals in attendance: Father Norm Keefer, Jr. who appeared with hie counsel Frances DelDuca, Esquire, Mother Dawn Strock who appeared with her counsel Joan Cerey, Esquire, of Legal Services and the Paternal Grandmother Sharon Keefer who appeared with her counsel Brik Lang of the Family Law Clinic. 3. The par~ies agreed to the entry of an order in the form as attached. Eubert X. Gi.J~ .oy./~squire Custody Conciliar or EXHIBIT "A" SHARON KEEFER, : Plaintiff/Petitioner : : V. : DAWN E. STROCK, : Respondent/Defendant : NORMAN D. KEEFER, JR. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 91-4011 CIVIL TERM CUSTODY ORDER OF COURT NOW thisI I~L dayof Au(3ust ,1994, after a meeting in chambers with counsel for the parties, and it appearing that a conciliation in the captioned case is set for September 29, 1994, pending further Order of Court as a result of said conciliation, Petitioner Sharon Keefer shall have primary physical custody of the children Justin M. Keefer and Kristin E. Keefer, with times of visitation to Respondent Dawn E. Stro.ckt aa ea~ I~c ..... =, ...... "--' By the Court, SHARON KEEFER, Plaintiff/Petitioner DAWN E. STROCK, : NORMAN D. KEEFER, JR. : Respondent/Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 91-4011 CIVIL TERM CUSTODY PETITION FOR MODIFICATION NOW comes Sharon L. Keefer by and through her attorneys, FLOWER, MORGENTHAL, FLOWER & LINDSAY, and petitions this Honorable Court as follows: 1. Petitioner is Sharon L. Keefer, who resides at 934 Valley Road, Enola, Cumberland County, Pennsylvania. 2. The Respondents are Dawn E. Stock, who resides at 17 East Louther Street, Second Floor, Carlisle, Cumberland County, Pennsylvania; and Norman D. Keefer, Jr., whose last known address was 34 South Main Street, Marysville, Perry County, Pennsylvania. 3. Petitioner is the grandmother of Justin M. Keefer, born July 26, 1987, and Kristin E. Keefer, born June 22, 1986. 4. Respondents are the parents of said children. 5. On or about April 9, 1993, after a conciliation, the Court entered an Order giving the captioned parties shared legal custody of Kristin E. Keefer and Justin M. Keefer, giving to Petitioner and Respondent Norman Keefer, Jr., her son, primary physical custody of Justin, and to Respondent Dawn E. Strock primary physical custody of Kristin. A copy of the Court's Order of April 9, 1993 is attached hereto as Exhibit "A". 6. Since the entry of the Court's Order of April 9, 1993, Petitioner has filed a protection from abuse action in Cumberland County, Pennsylvania, to No. 94-3284 Civil Term, the Defendants of said action being Norman Keefer, Jr. and Jeffrey Keefer, her sons. By Order of Court of June 27, 1994, a copy of which is attached hereto is Exhibit "B", the Court excluded Norman Keefer, Jr. from Petitioner's home. 7. On August 18, 1994, Petitioner filed a Petition for Special Relief in the captioned case seeking temporary custody of the referenced children because: A. Kristin reported to Petitioner that she had been molested by a visitor in Respondent Dawn Strock's home at a time when Dawn Strock was in the home and had left the child unattended with the perpetrator; B. Kristin and Justin report to Petitioner behavior which indicates that marijuana and cocaine are smoked in Respondent Dawn Strock's home. 8. In Response to the Petition of August 18, 1994, the Court entered an Order, a copy attached hereto as Exhibit "C", giving pdmary physical custody of both children to Petitioner with periods of partial custody to Respondent Dawn Strock as set out on the Court's earlier Order of April 9, 1993. 9. Upon information and belief, Respondent Dawn Strock was advised of the sexual abuse of her child and failed to obtain a medical examination of said child or to report the abuse to the police. 10. Petitioner believes and therefore avers that the best interest and permanent welfare of the children will be served by providing to her physical custody of said children because: 2 VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Sharon K~fer 4 APR $ /993 SHARON KEEFER ~ Plaintiff V DAWN KEEFER and NORMAN KEEFER, JR. Defendants :IN TEE COURT OF COMMON Pn~AS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 4011 - CIVIL - 1991 : :CIVIL ACTION - CUSTODY : ORDER AND NOW, thls ~ day of ~t~J~ , 1993, upon consideration of the attached Custody Conciliator Report, it is ordered and directed as follows~ 1. The Paternal Grandmother Sharon Keefer and the Father Norman Keefer, Jr. and the Mother Dawn Strock shall enjoy shared legal custody of Kristin E. Keefer, born June 22, 1986 and Justin M. Keefer, born July 28, 1987. 2. The Grandmother and the Father shall enjoy primary physical custody of Justin. 3. The Mother shall enjoy primary physical custody of Kristin. 4. Parties shall exchange physical custody of the minor children on alternating weekends from Friday at 6:00 p.m. until Sunday at 5:00 p.m. under a schedule whereby the children shall be together on each weekend. For the first two months, the alternating weekend schedule shall only be for one weekend per month, and thereafter shall alternate on consecutive weekends. 5. Neither party shall consume illegal drugs while they have custody of either of the minor children. 6. The party having the children for the waak~nd will ~rovlde the transportation and will remain in the car during the transfer of custody. 7. The parties will alternate holidays as follows: Easter, Memorial Day, Labor Day, Thanksgiving, and Christ- The Mother will have both children from Christmas Eve, 1993 at 6:00 p.m. until Christmas Day at 11:00 a.m. The Father and Grandmother will have the children from 11:00 a.m. Christmas Day until December 26 at 11=00 a.m. This schedule for Christmas shall alternate each year thereafter. EXHIBIT 8. The Mother shall have the children on Mother's Day, the Father shall have the children on Father's Day and the Grandmother shall have the children on Grandparent's Day, each period of t{me to be from 1=00 p.m. until 5=00 p.m.. 9. The parties will share the children's birthdays at times as agreed upon by the parties. 10. Mother will enjoy a period of two weeks vacation during the snm~er months to coincide with her work vacation. Mother shall, advise the Grandmother and Father at least thirty days in advance as to when this vacation shall take place. In the event that Mother's vacation conflicts with the vacation in the Grandmoth- er's household, the parties shall work out an arrangement whereby each of them shall have at least a one week period of time with the children in the s-mmer during their scheduled vacation and the other to be during non-vacation time. 11. The parties by mutual agreement may vary the schedule at any time as they may agree. 12. The orders previously issued in this case at 4011 Civil 1991 and 2512 Civil 1989 are vacated. BY THE COURT= George EZ Holler ~ NORMAN D. KEEFER and SHARON L. KEEFER, Plaintiffs V. NORMAN KEEFER, JR. and JEFFREY KEEFER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-3284 CIVIL TERM PROTECTION FROM ABUSE ORDER OF COURT AND NOW this c~'7~ day of ~--~rt ~ ,1994, the Defendant, Norman Keefer, Jr., having failed to appear and after testimony presented by the Plaintiff Sharon L. Keefer, Plaintiff Sharon L. Keefer is in immediate and present danger of abuse from Norman Keefer, Jr., Norman Keefer, Jr. is enjoined from physically abusing Sharon L. Keefer, or placing her in fear of abuse. Norman Keefer, Jr. is ordered to refrain from having any contact with Sharon L. Keefer, from harassing her or from coming to her residence at 935 Valley Road, Enola, Cumberland County, Pennsylvania. This Order shall remain in effect for one year from the date hereof. The Enola Police Department shall be provided with a copy of this Order by attorneys for Plaintiffs. This Order shall be enforced by any law enforcement agency where a violation occurs by arrest for indirect criminal contempt without a warrant upon a probable cause that this Order has been violated, whether or not the violation is committed in the presence of the Police Officer. In the event that an arrest is made under this section, the Defendants shall be taken without unnecessary delay before the Court that issued the Order. When that Court is unavailable, the Defendants shall be arraigned before the appropriate District Justice. By the Court, G~6rge E. Hoffer, EXHIBIT Jo SHARON KEEFER, Plaintiff/Petitioner DAWN E. STROCK, Respondent/Defendant NORMAN D. KEEFER, JR. IN THE'. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAI CIVIL ACTION - LAW NO. 91-4011 CIVIL TERM CUSTODY ORDER OF COURT / NOW this ! ~ ~ day of Auc~ust , 1994, after a meeting in chamb with counset for the parties, and it appearing that a conciliation in the captioned case is set September 29, 1994, pending further Order of Court as a ~result of said conciliation, Petitio Sharon Keefer shall have primary physical custody of the children Justin M. Keefer and Kristir Keefer, with times of visitation to Respondent Dawn E. Strock a3 eer~rbo"at'taf~ed~m-a~rt~ By the Gourt, EXHIBIT c:!wp5 l~cji\keefer.pet 4433-94-01 SHARON KEEFER, Plaintiff/Petitioner DAWN E. STROCK, : NORMAN D. KEEFER, JR. : Respondent/Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 91-4011 CIVIL TERM CUSTODY ORDER OF COURT AND now, this ~ day of .'~-..'~l-em/~¢,' , 1994, upon consideration of the attached Petition, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esquire, the conciliator, on the 29th day of September, 1994, at 10:30 a.m., on the 4th floor of the Cumberland County Court House, Carlisle, Pennsylvania, for a 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 t~e heard by the court, and to enter into a temporary order. All children age five or older ~ ~so be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. : ............... ~'~ ....... Fo~;"~he COUrt, 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. Office of the Court Administrator Courthouse, 4th Floor Carlisle, Pennsylvania 17013 (717) 240-6200 SHARON KEW. FER, Plaintiff V DAWN E. STROCK AND NORMAN D. KEEFER, JR., Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :NO. 4011 - CIVIL - 1991 : : :CIVIL ACTION - CUSTODY PRIOR JUDGE: JUDGE GEORGE E. HOFFER CONCILIATION CONFERENCE SUMNARE REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Justin M. Keefer, born July 28, 1987, and Kristin E. Keefer, born June 22, 1986. 2. A Conciliation Conference was held on September 29, 1994, with the following individuals in attendance: The Paternal Grandmother, Sharon Keefer, with her counsel, Carol J. Lindsay, Esquire, and the Mother, Dawn E. Strock, with her counsel, Joan Carey of Legal Services. Even though the Father was served with notice of the Hearing, the Father did not attend. This case was before the Custody Conciliator in April of 1993, at which time an agreement was reached whereby the Paternal Grandmother had custody of one child and the Mother had custody of the other child. Since that time, there have been a number of incidents. In August of 1994, Judge Hoffer issued an Order transferring custody of both children to the Paternal Grandmother. This was based upon testimony that there was illegal drug use taking place in the Mother's home. The Paternal Grandmother has serious concerns about the Mother's parenting ability. She alleges that the Mother is engaged in illegal drug use and that the Mother did not adequately respond to allegations of sexual abuse made by the child. The Mother suggests that the Paternal Grandmother is not properly taking care of the children. She cites that one child missed 25 days of school last year when the child was with the Paternal Grandmother. She also suggests that the child is not developing in accordance with his age. Essentially, the Paternal Grandmother wants the Custody Order to remain the same whereby the Paternal Grandmother has the children with the Mother having custody on every other weekend. The Mother desires primary physical custody, but admits that she is not in a position to seek primary physical custody because of her current drug counseling. The case is not ripe for a Hearing. It would certainly benefit the Paternal Grandmother to proceed at this time with a Hearing. However, the Conciliator notes that the Paternal Grandmother currently has primary physical custody of the minor child and that she should not be prejudiced in any way by a further delay in this case. DATE The Conciliator recommends an Order in the form as attached. Cus~tcdy C~or Hubert~X. Gi oy, Esquire OOT SHARON KEEFER, Plaintiff V DAWN E. STROCK AND NORMAN D. KEEFER, JR., Defendant AND NOW, this __ day of , 1994, of the attached Custody CdT~iliation Report, directed as follows: :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA 1991 :NO. 4011 - CIVIL - ~ : : :CIVIL ACTION - CUSTODY upon consideration it is ordered and This Court's Order of August 18, 1994 is affirmed such that the Paternal Grandmother, Sharon Keefer, and the Mother, Dawn E. Strock shall enjoy shared legal custody of Justin M. Keefer and Kristin E. Keefer. The Paternal Grandmother shall have primary physical custody of both minor children. The Mother shall have temporary physical custody on alternating weekends under the prior schedule arranged between the parties. 3. The parties will meet again for another Conciliation Conference on December 15, 1994, at 8:30 A.M. In the event that the Mother arranges for counseling sessions involving her and the two minor children and such sessions do not require any monetary contribution from the Paternal Grandmother, the Paternal Grandmother shall cooperate in those sessions to allow the two children to attend any counseling sessions that are scheduled. CC: BY THE COU? T, Joan Carey-Legal Services ¢ ~:~-j t,~' , ~I~U SHARON KEEFER, Plaintiff v DAWN E. STROCKAND NORMAN D. KEEFER, JR., Defendants :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :NO. 4011 - CIVIL - 1994 : : : :CIVIL ACTION - CUSTODY PRIOR JUDGE: JUDGE GEORGE E. HOFFER CONCILIATION CONFERENCE SU~qARYREPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Justin M. Keel·r, born July 23, 1987, and Kristin E. Keefer, born June 22, 1986. 2. A Conciliation Conference was held on December 15, 1994, with the following individuals in attendance: The Paternal Grandmother, Sharon Keefer, with her counsel, Carol J. Lindsay, Esquire, and the Mother, Dawn E. Strock, with her counsel, Joan Carey of Legal Services. e The Father is not involved in the proceedings and has not been involved in the custody or care of the children for a number of years· In April of 1993, an agreement on custody was reached whereby the Paternal Grandmother had custody of one child and the Mother had custody of another child. Since that time, there have been a number of proceedings including a Court Hearing in Auqust of 1994 at which time Judge Holler issued an Order transferring custody of both children to the Paternal Grandmother. The Mother now seeks custody of both children. The Mother is pregnant and scheduled to deliver in February of 1995. The Mother lives with her boyfriend in the Carlisle area. The Paternal Grandmother lives in East Pennsboro and the children are currently attending school in the East Pennsboro School District. DEC 2 1 SHARON KEEFER, Plaintiff v DAWN E. STROCK, AND NORMAN KEEFER, JR., Defendants :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :NO. 4011 - CIVIL - 1991 : : : :CIVIL ACTION - CUSTODY COURT ORDER AND NOW, this ay of 1994, upon consideration of the attached Custody Condiliation Report, it is ordered and directed as follows: A Hearing is scheduled in C~o~troom No. ]_of~the Cumberland County Courthouse on the ~/. day o{ ~ , 1995 at /o.~/9~. at which time t~-~lmony will k~ taken in the above case. At this Hearing, the Mother, Dawn E. Strock, shall be the moving party and shall proceed initially with testimony. Counsel for both parties shall file with the court and opposing counsel a memorandum at least ten days prior to the Hearing date. This memorandum shall include a list of witnesses that party will call to testify along with a summary of the anticipated testimony of each respective witness· The memorandum shall also include a summary of the procedural history of this case and a summary of that party's position with respect to custody. In the event Mother files of record any pleadings raising the issue of whether the Paternal Grandmother has standing to seek custody in this matter, this memorandum shall also address the law with respect to that issue. 2. Pending further Order of this Court, this Court's prior Order of August 18, 1994 and the Order of October 14, 1994 shall remain in effect. 3. For the Christmas 1994 holiday, the Paternal Grandmothem Shall have physical custody on Christmas Eve and Christmas morning with the Mother enjoying physical custody from 1 P.M. on:' Christmas Day through 7 P.M. on December 26. cc: ~ N/~ C 3 R T , JuG~' ~~ Holler Joan Car. ey, Esquire Carol Llndsay, Esquire~ SHARON KEEFER, Plaintiff DAWN E. STROCK, : NORMAN D. KEEFER, JR. : Defendant .' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'W, PENNSYLVANIA CIVIL ACTION - LAW NO. 91-4011 CIVIL TERM CUSTODY PETITIONER is Carol J. Lindsay, Esquire. RESPONDENT is Sharon Keefer, Plaintiff above. PETITION TO WITHDRAW AS COUNSEL NOW comes Carol J. Lindsay, Esquire, counsel for Plaintiff above, and petitions this Honorable Court as follows: 1. On or about August 12, 1994, Respondent and her husband, Norman D. Keefer, sought representation from Petitioner and her law firm with regard to a protection from abuse action against her sons. 2. Subsequent thereto, Respondent and her husband sought representation with regard to the custody of their grandchildren, Justin M. Keefer and Kristine Keefer. 3. As a part of said representation, Petitioner attended two conciliation conferences with Respondent; one on October 14, 1994, and the other on December 15, 1994. At the December conciliation, a hearing was set before this Honorable Court on April 3, 1995 at 10:00 a.m. 4. Subsequent to the December conciliation, a check tendered prior to the conciliation for counsel fees in the amount of $610.00 was returned, the check having been drawn on an account closed on August 31, 1993, over a year earlier. 5. On December 27, 1994, Petitioner sent to Respondent a photocopy of the returned check and a request for payment. A copy of the December 27, 1994 letter is attached hereto as Exhibit "A". 6. In addition, on December 27, 1994, Petitioner wrote to Respondent advising her of the hearing date, and requesting that she contact Petitioner to prepare a witness list and make appropriate financial arrangements for the up-coming hearing. 7. On or about March 13, 1995, not having heard from Respondent, Petitioner called Respondent and spoke to her husband, reminding him of the unpaid legal bills, and the need to prepare for a hearing. Petitioner asked that Respondent contact her. 8. Respondent has not telephoned or written to Petitioner. Upon information and belief, Respondent was hospitalized for a period of time, but she is presently not hospitalized, and is not cooperating in the preparation of her case which is schedule for hearing on April 3, 1995. 9. Without the cooperation of Respondent, and in the light of the bad check which was tendered for legal fees, Petitioner can no longer represent Respondent. 10. The Defendant in the custody action is represented by Legal Services, which does not object to a short continuance to permit Respondent to obtain new counsel. WHEREFORE, Petitioner prays this Honorable Court to issue a Rule upon Respondent to show cause why Petitioner should not be permitted to withdraw as her counsel and for a continuance of the hearing scheduled for April 3, 1995 so that Respondent may obtain new counsel. FLOWER, MORGENTHAL FLOWER & LINDSAY By: ~CaroliD Cf 44693 & Li~n(~say, Esquire 11 East High Street Carlisle, PA 17013 (717) 243-5513 2 VERIFICATION i, the undersigned, hereby verify that the statements made herein are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. 3 EXHIBIT "A" IAW OFFICr~ FLOWER, MORGENTHAL, FLOWER & L1NDSAY 11 EAST HIGH STIt~:~i' CARLISLE, PENNSYLVANIA 17013-3016 .tAMES D. PLOWER ROGER M. MORGENTHAL JAMF-.q D. FLOW~P., Jl~ CAROL J'. LINDSAY Ms. Sharon L. Keefer 934 Valley Road Enola, PA 17025-1541 (7~7) 24.~SS~ FA~ 017) 24~-r~Io December 27, 1994 BI~I,~CH & MORGI~VlI-'IAL MORGElVlHAL & FLOWER Dear Sharon: I enclose a photocopy of the check which you tendered to our Firm on an account which apparently was closed on August 31, 1993. I expect this was an oversight. Please forward us a check in the amount of $617.50 (the or/g/na/amount of SEYO. O0 plus a $7.50 bank service charge) on your new account. Very truly yours, FLOWER, MORGENTHAL, FLOWER & UNDSAY CJL\tjb Enclosure Carol J. Lindsay OZl LAW OPFIC~ EAST HIG~ S'I~I.* CA~T.T-~R.E, PENNSYLVANIA 17013-3016 JA.MP-,S D. FI.,OWHR ROOHE. M. SAMP. S D. FLOWEI~ J~ CAROL J. LINDSAY ("z*x~) ~,q,~ ('z:tT) 24.~.6sxo December 27, 1994 Bi~.r~ & MORGI~'IIL~ 0~-~,~) MOR~BI~I~'~L & PLOWBR Ms. Sharon L. Keefer 934 Valley Road Enola, PA 17025-1541 Dear Sharon: I enclose the Court Order of December 22, 1994 indicating that a hearing will be held on April 3, 1995 at 10:00 a.m. regarding custody of Justin and Kristin. To prepare for the hearing, we will need to put together a list of witnesses. We will also need to make appropriate financial arrangements for the payment of fees prior to the hearing. Please give my office a call to arrange a time to discuss both the witnesses and the anticipated fees. Very truly yours, FLOWER, MORGENTHAL, FLOWER & UNDSAY CdL\~b Enclosure Carol J. Lindsay SHARON KEEFER, Plaintiff/Petitioner DAWN E. STROCK, : NORMAN D. KEEFER, JR. : Respondent/Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 91-4011 CIVIL TERM CUSTODY ORDER OF COURT AND now, this day of/,,,~,., ~ ,1995, upon consideration of the within Petition, a Rule is issued upon Respondent, Sharon Keefer, to show cause why, if any, Carol J. Lindsay, Esquire, should not be permitted to withdraw as her counsel. RULE returnable days from the date of service hereof. The hearing schedule for April 3, 1995 is continued generally to be reset at the request of the parties set out in the caption. By the COUrt, SHARON KEEFER, Plaintiff vs. DAWN KEEFER and NORMAN KEEFER, JR. Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 4011 CIVIL 1991 CIVIL ACTION--LAW CUSTODY PREACIPE TO WITHDRAW APPEARANCE Please withdraw my appearance on behalf of Defendant Dawn Keefer. Legal Services, Inc. Carey, Esquir~ Please Keefer. PREACIPE TO ENTER APPEARANCE enter my appearance on behalf of Defendant Dawn Jam~. Jones, Es~Ti~ 401 East Louther Street Carlisle, PA 17013 (717) 240-0296 SHARON KEEFER, Vm DAWN E. STROCK, NORMAN D. KEEFER, JR. Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNIY, PENNSYLVANIA CIVIL ACTION - LAW NO. 91-4011 CIVIL TERM CUSTODY MOTION FOR RULE ABSOLUTE NOW comes Carol J. Undsay, Esquire, counsel for Plaintiff above and moves this Honorable Court as follows: 1. On Ma~ch 30, 1995, upon consideration of a Petition to Withdraw as Counsel, this Honorable Court issued a Rule upon Sharon Keefer to show cause why Petitioner should not be permitted to withdraw as counsel. The Rule is returnable five days from the date of service. A copy of the Court's Order and the accompanying Petition is attached hereto as Exhibit "A". 2. The Court's Order was served upon the Respondent on March 31, 1995. A copy of the transmittal letter is attached hereto as Exhibit "B". 3. Respondent has not answered the Rule. WHEREFORE, Petitioner prays this Honorable Court to make the Rule absolute permitting Petitioner to withdraw as counsel for Sharon Keefer. FLOWER, MORGENTHAL FLOWER & MNDSAY 11 East High Street Carlisle, PA 17013 (717) 243-5513 VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. L/~a~l J. Unds'ay Date: ~J/~2~/(~'--~ EXHIBIT "A" SHARON KEEFER, Plaintiff/Petitioner VJ DAWN E, STROCK, : NORMAN D. KEEFER, JR, : Respondent/Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 91-4011 CIVIL TERM CUSTODY ORDER OF COURT AND now, thTs .3o ~ day of '-Y)q ~ ,1995, upon consideration of the within Petition, a Rule is issued upon Respondent, Sharon Keefer, to show cause why, if any, Carol J. Lindsay, Esquire, should not be permitted to withdraw as her counsel. RULE returnable .5- days from the date of service hereof. The hearing schedule for April 3, 1995 is continued generally to be reset at the request of the parties set out in the caption. By the Court, SHARON KEEFER, DAWN E. STROCK, NORMAN D. KEEFER, JR. Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 91.-4011 CIVIL TERM CUSTODY PETITIONER is Carol J. Lindsay, Esquire. RESPONDENT is Sharon Keefer, Plaintiff above. PETITION TO WITHDRAW AS COUNSEL NOW comes Carol J. Undsay, Esquire, counsel for Plaim;ff above, and petitions this Honorable Court as follows: 1. On or about August 12, 1994, Respondent and her husband, Norman D. Keefer, sought representation from Petitioner and her law firm with regard to a protection from abuse action against her sons. 2. Subsequent thereto, Respondent and her husband sought representation with regard to the custody of their grandchildren, Justin M. Keefer and Kristine Keefer. 3. As a part of said representation, Petitioner attended two conciliation conferences with Respondent; one on October 14, 1994, and the other on December 15, 1994. At the December conciliation, a hearing was set before this Honorable Court on ApriJ 3, 1995 at 10:00 a.m. 4. Subsequent to the December conciliation, a check tendered prior to the conciliation for counsel fees in the amount of $610.00 was returned, the check having been drawn on an account closed on August 31, 1993, over a year earlier. 5. On December 27, 1994, Petitioner sent to Respondent a photocopy of the returned check and a request for payment. A copy of the December 27, 1994 letter is attached hereto as Exhibit "A". 6. In addition, on December 27, 1994, Petitioner wrote to Respondent advising her of the hearing date, and requesting that she contact Petitioner to prepare a witness list and make appropriate financial arrangements for the up-coming hearing. 7. On or about March 13, 1995, not having heard from Respondent, Petitioner called Respondent and spoke to her husband, reminding him of the unpaid legal bills, and the need to prepare for a hearing. Petitioner asked that Respondent contact her. 8. Respondent has not telephoned or written to Petitioner. Upon information and belief, Respondent was hospitalized for a period of time, but she is presently not hospitalized, and is not cooperating in the preparation of her case which is schedule for hearing on April 3, 1995. 9. Without the cooperation of Respondent, and in the light of the bad check which was tendered for legal fees, Petitioner can no Jonger represent Respondent. 10. The Defendant in the custody action is represented by Legal Services, which does not object to a short continuance to permit Respondent to obtain new counsel. WHEREFORE, Petitioner prays this Honorable Court to issue a Rule upon Respondent to show cause why Petitioner should not be permitted to withdraw as her counsel and for a continuance of the hearing scheduled for April 3, 1995 so that Respondent may obtain new counsel. FLOWER, MORGENTHAL FLOWER & LINDSAY By: ID ~ , ,B93- 11 East High Street Carlisle, PA 17013 (717) 243-5513 2 VERIFICATION i, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Carol ;J. Llndsay, Esquire Date: ~ ~) 3 EXHIBIT "A" FLOWHR, MOR~, FLOWHR & LINDSAY 11 HAST HIGH STI~I~T CA~t.t-~.r~ PI~NSYLVANIA 1701!5-3016 CAROL $. LIND~AY Ms. Sharon L. Keefer 934 Valley Road Enola, PA 17025-1541 December 27, 1994 MORGI~NTHAL ~ FLOWI~R Dear Sharon: I enclose a photocopy of the check which you tendered to our Rrm on an account which apparently-was closed on August 31, 1993. I expect this wes an oversight. Please forward us a check in the amount of $617.50 (the or/g/nal amount of $610.00 p/us a ~ 7. 50 ban£ service charge) on your new account. Very truly yours, R.0WER, MORGENTHAL, FLOWER & LINDSAY C~JL~tjb Enclosure Carol J. Lindsay CAROL £ L/NDSAY 1! EAST HFm' STI~[ CA~r~T.~:~-,, PIth'SYLVANIA 17013-~016 ('AD ~ PA~ (~7) 2a3~1o December 27, 1994 MORG~rI"HAL & PLOW~lt Ms. Sharon L Keefer 934 Valley Road Enola, PA 17025-1541 Dear Sharon: I enclose the Cour~ Order of December 22, 1994 indicating that a hearing will be held on April 3, 1995 at 10:00 a.m. regarding custody of Justin and Kriatin. To prepare for the hearing, we will need to put together a list of witnesses. We will also need to make appropriate financial arrangements for the payment of fees prior to the hearing. Please give my office a call to arrange a time to discuss both the witnesses and the anticipated fees. Very truly yours, FLOWER, MORGENTHAL, FLOWER & UNDSAY CJL~tjb Enclosure Carol J. Undsay EXHIBIT "B" LAW OFFICI~ ~, PENN~J'LVANIA JAM~S D. FLOWER ROGER M. MOROI~i~-IAL SAMES D. FLOWEI~ ~1~ CAROL J, LIND~AY March 31, 1995 I~,t~H & MORGEN'ITIAL (~-~) MORGI/~IrI-IAL · FLOWER Sharon L. Keefer 934 Valley Road Enola, PA 17025 Dear Mrs. Keefer: I enclose for ~ervice the Court Order dated March 30, 1995. Very truly yours, FLOWER~f;~RGEN~TH~I~ FLOWER & UNDSAY Carol J. CJL~tjb Enclosure SHARON KEEFER, Plaintiff DAWN E. STROCK, : NORMAN D. KEEFER, JR. : Defendant .' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 91-4011 CIVIL TERM CUSTODY CERTIFICATE OF SERVICE / AND now, this c~- i day of /,ff- ,1995, I, Carol J. Lindsay, Esquire, V of the law firm of FLOWER, MORGENTHAL, FLOWER & LINDSAY Attorneys, hereby certify that I served the within Motion for Rule Absolute this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Sharon Keefer 934 Valley Road Enola, PA 17025 Joan Carey, Esquire LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 FLOWER, MORGENTHAL FLOWER & LINDSAY By: ID # 44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 SHARON KEEFER, Plaintiff Ve DAWN E. STROCK, NORMAN D. KEEFER, JR. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT~, PENNSYLVANIA CIVIL ACTION - LAW NO. 91-4011 CIVIL TERM CUSTODY AND now this ORDER OF CrUdRT ~195, upon consideration day of ~ of the within Motion for a Rule Absolute, said Motion is granted. Carol J. Lindsay, esquire is permitted to withdraw as attorney for Sharon Keefer. By the Court, 0 0 0 oF-:,, ~ SHARON KEEFER, PLAINTIFF DAWN E. STROCK and NORMAN KEEFER, JR. DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 4011 CIVIL 1991 CIVIL ACTION--LAW CUSTODY Keefer. 3. Grandmother shall ten Keefer until June 10, have primary physical custody of Kris- 1995, at which time Mother shall have primary physical custody of her. 4. Grandmother and Mother shall have partial physical custo- dy and visitation with the children on alternating weekends from Friday at 6:00 p.m. to Sunday at 5:00 p.m. such that the children will be together each weekend during those periods of partial physical custody and at other times as agreed between the par- ties. ~F%~ORDER OF C~URT AND upon consideration of the within Custody Stipu{~ion and Agreement, it is hereby ordered as follows: 1. The parties shall have shared legal custody of the chil- dren, meaning that they shall share the legal right to make major decisions affecting the best interest of the children and all of the major matters related to the children, including, but not limited to, medical, religious and educational decisions. 2. Grandmother shall have primary physical custody of Justin 4. Each party shall have primary physical custody of both period during the children's summer fourteen days notice is provided to same or similar provision. children during a two week vacation provided at least the other party. 5. All other periods of partial physical custody shall be provided as set forth in prior orders of court. 6. Neither party shall consume non-prescribed controlled substances while they have custody of either of the children. 7. Neither party shall do anything which may estrange the children from the other party or injure the opinion of the chil- dren as to the other party, or which may hamper the free and natural development of the children's love and affection for the other party. 9, The failure to either party to insist on strict perform- ance of the provisions of this stipulation and agreement shall not be construed as a waiver of any subsequent default of the SHARON KEEFER, PLAINTIFF DAWN E. STROCK and NORMAN KEEFER, JR. DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 4011 CIVIL 1991 CIVIL ACTION--LAW CUSTODY Made this Sharon Keefer, after "Mother"; WHEREAS the Keefer, born June CUSTODY STIPULATION AND AGREEMENT 77'~ day of /~}~ , 1995 by and between hereinafter "Grandmother" and Dawn Strock, herein- parties have two children, namely Kristin E. 22, 1986, and Justin M. Keefer, born July 28, 1987, hereinafter "children"; and WHEREAS, the parties wish to enter into an agreement rela- tive to custody, partial custody and visitation of the children; and WHEREAS, the children have resided in Cumberland County, Pennsylvania for at court jurisdiction. NOW THEREFORE, least the last six months, thus giving this in consideration of the mutual covenants, promises and agreements as hereinafter set forth, the parties agree as follows: 1. The parties shall have shared legal custody dren, meaning that they shall share the legal right decisions affecting the best interest of the the major matters related to the children, of the chil- to make major children and all of including, but not limited to, 2. Keefer. 3. medical, religious and educational decisions. Grandmother shall have primary physical custody of Justin Grandmother shall have primary physical custody of Kris- ten Keefer until June 10, 1995, at which time Mother shall have primary physical custody of her. 4. Grandmother and Mother shall have partial physical custo- dy and visitation with the children on alternating weekends from Friday at 6:00 p.mo to Sunday at 5:00 p.m. such that the children will be together each weekend during those periods of partial physical custody and at ties. 4. Each party shall children during a two week vacation provided at least the other party. other times as agreed between the par- have primary physical custody of both period during the children's summer fourteen days notice is provided to 5. All other periods of partial physical custody shall be provided as set forth in prior orders of court. 6. Neither party shall consume non-prescribed controlled substances while they have custody of either of the children. 7. Neither party has the intention to pursue custody of the child in the custody of the other party absent a change in circumstances. 8. Neither party shall do anything which may children significant estrange the from the other party or injure the opinion of the chil- dren as to the other party, or which may hamper the free and natural development of the children's love and affection for the other party. 9. The failure to either party to insist on strict perform- ance of the provisions of this stipulation and agreement shall not be construed as a waiver same or similar provision. 10. The parties agree and of any subsequent default of the desire that this stipulation and agreement be made an Order of Court of the Court of Common Pleas of Cumberland County, Pennsylvania. 11. This Stipulation and Agreement shall become an Order of Court with the Court of Common Pleas of Cumberland County, enter- ing said Order and retaining jurisdiction should either party desire or require modification of said order. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. WITNESS: Dawn Strock SHARON KEEFER, Plaintiff/Petitioner DAWN E. STROCK, Respondent/Defendant NORMAN D. KEEFER, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW No. 91 -- 4011 Civil Term CUSTODY ................. PETITION FOR EMERGENCY RELIEF AND MODIFICATION TO THE HONORABLE, THE JUDGES OF THE SAID COURT: Now Comes Sharon Keefer by her attorneys Walz & Walz and respectfuly represents: 1. Petitioner is Sharon Keefer, an adult individual currently residing at 216 North Front Street, Liverpool, (Perry County) Pennsylvania; she is the paternal grandmother of the children who are the subjects of this Petition. 2. Respondent Dawn E. Strock is an adult individual whose last known address and presumed present whereabouts is 47 Walnut Street, Carlisle (Cumberland County) Pennsylvania; she is the mother of the children who are the subjects of this Petition. 3. Respondent Norman D. Keefer, Jr., is an adult individual whose last known address and presumed present whereabouts is 1032 State Road, Duncannon, Pennsylvania; he is the father of the children who are the subjects of this Petition. 4. The subject children are Kristen E. Keefer, born June 22, 1986, now age 11, and Justin M. Keefer, born July 28, 1987, now age 9. 5. By virtue of prior Orders of This Honorable Court, Petitioner Sharon Keefer has had shared legal custody of Kristen and Justin. 6. By virtue of said Orders, Petitioner Sharon Keefer has also had primary physical custody of Justin, and Respondent Dawn E. Strock has had primary physical custody of Kristen; each has had alternating-weekend visitation. 7. According to the terms of said prior Orders (and in accord with Pennsylvania statutes) "Neither party shall consume illegal drugs while they have custody of either of the minor children." Petitioner believes, and therefore avers, that Respondent Dawn E. Strock and/or others at her residence, have used marijuana, cocaine and/or crack cocaine while subject child Kristin has been living her residence, and while Justin has been visiting there. 9. Petitioner believes, and therefore further avers, that the subject children, Kristin E. Keefer and Justin M. Kkeefer. have been subjected to other various and sundry improper influences and experiences which are detr'unental and deleterious to their proper physical, mental and emotional development. 10. Petitioner therefore avers that it would be in the best interest and welfare of said children to have their permanent, pr'unary custody placed in Petitioner, for the following reasons: A. Petitioner is providing a drug-free environment, which Respondent Dawn Strock has failed and/or neglected to provide, despite the mandates of Pennsylvania law and prior Orders of Your Honorable Court; B. Petitioner will continue to provide a loving, caring, safe and nurturing environment to both children. WHEREFORE, Petitioner prays Your Honorable Court to forthwith Order that custody of the said Kristen E. Keefer and Justin M. Keefer be placed with Petitioner Sharon Keefer pending further Order of this Court. Respectfully Submitted, WALZ & WALZ Shaubut C. Walz, III I.D. No 15277 341 Market Street Newport, PA 17074 (717) 567-6993 VERIFICATION I, Sharon Keefer, verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: Plaintiff COURT' :IN TItE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :CIVIL ACTION - LAW : :NO./401'1 czvz.r., .z_.o 9' i : CUSTODY/VIST. TATION AND NOW, this~ (date) '?. ~'-~? , upon consideration of the attached complaint, it is hereby directed that ~he parties and their respective counsel appear before ~)~ff~ (~'~\'~4,~ ~-.~ , , the conciliator, at ~.~)~%. on the ~ day of Oa390f.,~. ' , 19 ~. 1~, for a Preheating Cub~d~ 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 fnto a temporary order. Either part3; may bring the child who is the subject of this custody action to the conference, but the child/children's attendance is not mandatory. Failure to appear'at the conference 'may provide grounds for entry of a tempo, rary or permanent order. FOR THE COURT: YOU SHOULD TAK~' THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TF. nW. PHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE PA 1 7013 (71 7)240-6200 !i[tMtt?:I,H ANL~ County, Pennsylvania, who being duly sworn upon ~'rR~lCb; ~AWN ~ the dcieod~nt, st ip~),~ HOURS, on the 22nd day ,nf July lg~TI at 4'7 WALNUT CARLI~LT., PA lv~13 ,CUMB~L,AND Cour]ty, ?ennsylvania, by handing to DAWN STROCb.' a true and attested copy of the ~Ot{DI'.'R LIP' COURT together w~th CLISTUDY O~DER AND PETi'IfON FOR ~M~SR~3KNCY AND MO0 fP' [CA'f t ON the same t~me directing Her_ attention to the contents thereof. ~6heri££'s Costs: Docketing l~.~0 Surcharge 2,00 Thomas l{line, Sheriff ~-WA[.Z AND WAI.Z 07/23/1997 by SHARON KEEFER, Plaintiff V DAWN E. STROCK, Defendant NORMAN D. KEEFER, JR. Prior Judge: George E. :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :CIVIL ACTION - LAW : :NO: 91 - 4011 CIVIL TERM : :IN CUSTODY Hoffer CONCILIATION CON~u~ENCE SUF~/~%RYREPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the children who are the subject of this litigation is as follows: Kristen E. Keefer, born June 22, 1986, and Justin M. Keefer, born July 28, 1987. 2. A Conciliation Conference was held on October 2, 1997, with the following individuals in attendance: The Paternal Grandmother, Sharon Keefer, and the Father, Norman D. Keefer, Jr. The Mother, Dawn E. Strock, did not appear. The Grandmother related that she understood that Dawn knew there was a hearing scheduled and that she deliberately did not attend the Conciliation Conference. Before the Court is a Petition for Emergency Relief and Modification of an existing Custody Order. The Grandmother relates that she has had custody of the two minor children since June of this year· Prior to that, she had custody of Justin since Justin was born. Kristen had lived with the Mother for approximately two years prior to June of this year, but had also resided with the Paternal Grandmother for a number of years prior to that time. The Paternal Grandmother said she took custody of both minor children because she felt the situation with the minor children living with the Mother was rather questionable. The Father is in agreement with the Paternal Grandmother having custody of the minor children. 4. The Conciliator recommends an Order in the form as attached. DA TE ~~o~squire 0 8 997 SHARON KEEFER, Plaintiff V DAWN E. STROCK, Defendant NORMAN D. KEEFER, JR. :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :CIVIL ACTION - LAW : :NO: 91 - 4011 CIVIL TERM : :IN CUSTODY Cu ~ COURT ORDER AND NOW, this __ day of October, 1997, upon the attached stody Conciliation Report, it directed as follows: consideration of is ordered and i. The prior orders of Court issued in this matter are vacated. e The Paternal Grandmother, Sharon Keefer, shall enjoy legal and physical custody of Kristen E. Keefer, born June 22, 1986, and Justin M. Keefer, born July 28, 1987. ® The Father, Norman D. Keefer, Jr., shall enjoy periods of temporary physical custody with the minor children at such times and under such circumstances that the parties may agree. The Mother, Dawn E. Strock, shall enjoy periods of temporary physical custody with the minor children at such times and under such circumstances that the parties may agree. The Order is entered pursuant to the attached Custody Conciliation Conference and it is noted that the Mother was not present at the Conciliation Conference. In the event the Mother desires to have this Order modified, she may petition the Court to have the case again scheduled before the Custody Conciliator at which time Mother may raise all issues including standing of the Paternal Grandmother to claim custody· cc: Sharon Keefer 216 North Front Street Liverpool, PA 17045 court, 1032 State Road Duncannon, PA 17020 Dawn E. Strock 47 Walnut Street Carlisle, PA 17013 Samuel L. Andes, Esquire 525 North Twelfth Street P. O. Box 168 Lemoyne, PA 17043 SHARON KEEFER, Plaintiff DAWN E. STROCK and NORMAN D. KEEFER, JR. Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION--LAW NO. 91-4011 CIVILTERM IN CUSTODY PETITION FOR MODIFICATION OF A PART/AL CUSTODY OR VISITATION ORDER 1. The petition of Dawn E. Strock respectfully represents that on October 9, 1997 an Order of Court was entered for partial custody, a tree and correct copy of which is hereby attached. 2. The Order should be modified because paternal grandmother Sharon Keefer has made arbitrary and conflicting decisions in regard to the contact of the Petitioner with her two children. WHEREFORE, Petitioner requests that the Court modify the existing Order for Partial Custody because it will be in the best interest of the children. Respectfully submitted, ttorney for Petitioner 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date Dawn E. Strock 0 8 ,997 SHARON KEEFER, Plaintiff V DAWN E. STROCK, Defendant NORI4AND. KEEFER, JR. :IN THE COURT OY CO~IMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :NO: 91 4011 CIVIL TERM :IN CUSTODY COURT ORDER AND NOW, this day of October, 1997, upon the attached Custody Conciliation Report, it directed as follows: consideration of is ordered and 1. The prior orders of Court issued in this matter are vacated. e The Paternal Grandmother, Sharon Keefer, shall enjoy legal and physical custody of Kristen E. Keefer, born June 22, 1986, and Justin M. Keefer, born July 28, 1987. The Father, Norman D. Keefer, Jr., shall enjoy periods of temporary physical custody with the minor children at such times and under such circumstances that the parties may agree. The Mother, Dawn E. Strock, shall enjoy periods of temporary physical custody with the minor children at such times and under such circumstances that the parties may agree. e CC: The Order is entered pursuant to the attached Custody Conciliation Conference and it is noted that the Mother was not present at the Conciliation Conference· In the event the Mother desires to have this Order modified, she may petition the Court to have the case again scheduled before the Custody Conciliator at which time Mother may raise all issues including standing of the Paternal Grandmother to claim custody. Sharon Keefer 216 North Front Street Liverpool, PA 17045 /,COURT, r No~r, Jr. 1032 State Road Duncannon, PA 17020 Dawn E. Strock 47 Walnut Street Carlisle, PA 17013 Samuel L. Andes, Esquire 525 North Twelfth Street P. O. Box 168 Lemoyne, PA 17043 SHARON KEEFER PLAINTIFF V. DAWN E. STROCK & NORMAN D. KEFFER, JR. DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 91-4011 CIVIL ACTION LAW CUSTODY ORDER OF COURT AND NOW, this 27th day of July ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on the 12th day of October ,2000, 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. FOR THECOURT, By: /s/ Hubert X. Gilroy, Custody Conciliato'b~ The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 SHARON KEEFER, Plaintiff V DAWN E. STROCK and NORMAN D. KEEFER, Jr., Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 914011 CML IN CUSTODY Prior Judge: George E. Hoffer CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the children who are the subject of this litigation is as follows: Kristen E. Keefer, bom June 22, 1986 and Justin M. Keefer, bom July 28, 1987. A Conciliation Conference was held on November 16, 2000, with the following individuals in attendance: The Mother, Dawn E. Strock, with her counsel, James Jones, Esquire. The Paternal Grandmother, Sharon Keefer, did not attend. The Father, Norman D. Keefer, Jr. is incarcerated and was not present. Mother tells the Conciliator that she is seeing the minor children on alternating weekends in accordance with the existing Order and that she desires to continue with that visitation arrangement. She indicates that she believes the Paternal Grandmother is also in agreement with that arrangement. 4. The Conciliator recommends the entry of an order in the form as attached. SHARON KEEFER, Plaintiff V DAWN E. STROCK and NORMAN D. KEEFER, Jr., Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 914011 CIVIL 1N CUSTODY COURT ORDER AND NOW, this ~D'~ day of fi~ot~r, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. This Court's prior Order of October 9, 1997 and October 17, 2000 shall remain in effect such that the Paternal Grandmother, Sharon Keefer, shall continue to enjoy custody of the minor children Kristen E. Keefer, bom June 22, 1986 and Justin M. Keefer, born July 28, 1987. 2. The Mother, Dawn E. Strock, shall continue to enjoy alternating weekend custody in accordance with Paragraph 2 of the October 17, 2000 Order. CC.' James K. Jones, Esquire Samuel L. Andes, Esquire Sharon Keefer 553 North Enola Drive Enola, PA 17025 BY THE COURT,