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HomeMy WebLinkAbout04-3818JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 0q - 30 TIMOTHY SCOTT DISBROW, CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELEGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 JEHAN SAMIR DISBROW, Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0C/- Gc,iL CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff is Jehan Samir Disbrow, an adult individual currently residing at 1888 Douglas Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 2. The Defendant is Timothy Scott Disbrow, an adult individual residing at 74 Prospect Drive, Carlisle, Cumberland County, Pennsylvania. 17013. :3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania, for a period in excess of six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 26, 2000, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. This action is not collusive. 7. Plaintiff and Defendant separated on or about July 20, 2004. 8. The causes of action and sections of the Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c) -The marriage of the parties is irretrievably broken. B. Section 3301(d) - The marriage of the parties is irretrievably broken. The parties separated on or about July 20, 2004. C. Section 3301(a)(6) -The Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and her life burdensome. 9. Plaintiff and Defendant have one child under the age of eighteen, namely Damian Fredrick Disbrow, born January 1, 2001. 10. Plaintiff has been advised of the availability of marriage counseling and understands that she may request that her spouse and she participate in counseling. 11. Plaintiff does not request that the Court require that her spouse and she participate in counseling prior to a divorce decree being handed down by this Court. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter a final decree in divorce. COUNTI EOUITABLE DISTRIBUTION 12, Paragraphs one through eleven are incorporated herein by reference. 13. During their marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Sections 3501 et.sea. of the Divorce Code of 1980. WHEREFORE, Plaintiff respectfully requests this Honorable Court equitably distribute all marital property, both real and personal, owned by the parties. COUNT II ALIMONY 14. Paragraphs one through thirteen are incorporated herein by reference. 15. Plaintiff lacks sufficient property to provide for her reasonable needs. 16. Plaintiff is unable to sufficiently support herself through appropriate employment. 17. Defendant has sufficient income and assets to provide continuing and indefinite support for the Plaintiff. WHEREFORE, Plaintiff requests this Honorable Court compel the Defendant to pay alimony to the Plaintiff. COUNT III ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES 18. Paragraphs one through seventeen are incorporated herein by reference. 19. By reason of the institution of the action to the above term and number, Plaintiff will be and has been put to considerable expense in the preparation of her case, in the employment of counsel, and the payment of costs. 20. Plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litigation and is unable to appropriately maintain herself during the pendency of this action. 21. The Plaintiff s income is not sufficient to provide for her reasonable needs and pay her attorney's fees and the costs of this litigation. 22. The Defendant has adequate earnings to provide support for the Plaintiff and to pay her counsel fees, costs and expenses. WHEREFORE, Plaintiff respectfully requests this Honorable Court compel the Defendant to pay alimony pendente lite as well as pay the Plaintiff s counsel fees, costs and expenses. COUNT IV CHILD CUSTODY 23. Paragraphs one through twenty-two are incorporated herein by reference. 24. The subject child is Damian Fredrick Disbrow, born January 1, 2001. 25. The relationship of the Plaintiff to the subject minor child is that of natural mother. 26. The relationship of the Defendant to the subject minor child is that of natural father. 27. The minor child has resided at the following addresses, in the custody of the following individuals: a. From birth until July 20, 2004 - the subject minor child resided at 74 Prospect Drive, Carlisle, Cumberland County, Pennsylvania in the care and custody of the Plaintiff and Defendant, b. From July 20, 2004 to present - the subject minor child resides at 1888 Douglas Drive, Carlisle, Cumberland County, Pennsylvania in the care and custody of the Plaintiff, as well as with maternal grandmother and grandfather, Josetta Ibrahim and Samir Ibrahim, and maternal aunt, Yasmin Ibrahim. 28. There have been no prior actions for custody of the subject minor child in this or any other jurisdiction. 29. The Plaintiff is not aware of the existence of any other individuals who have any type of claim whatsoever regarding the custody of the subject minor child. 30. The Plaintiff believes and therefore avers that she is much better able to meet the needs of the subject minor child than the Defendant. 31. The Plaintiff believes and therefore avers that it is in the best interest of the subject minor child that he be placed in her legal and physical custody. WHEREFORE, Plaintiff requests this Honorable Court award her custody of the subject minor child. Date: / 1` C110 Respectfully submitted, THE LAW OFFICES OF SILLIK REINHOLD ?J Kristin R. Reinho , Esquire 5922 Linglestown Road Harrisburg, PA 17112 (717) 671-1500 I.D. No. 57911 Attorney for Jehan Samir Disbrow AFFIDAVIT I,(-kk A S. Dk5h ?[DU), hereby certify that the aforegoing is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to unsworn falsifications to authorities. Dated: 7/a9/?1 p C o O ?_.? ? v w p? G? 7EHAN SAMIR DISBROW IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. 04-3818 CIVIL ACTION LAW TIMOTHY SCOTT DISBROW IN CUS'T'ODY DEFENDANT ORDER OF COURT AND NOW, Wednesday August 11, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator, at 301 Market Street Lemoyne PA 17043 on Thursday., September 16, 2004 at 1:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Melissa P Gr e ,, mhc Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR T ELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 1.7013 Telephone (717) 249-3166 of 0•!/.? ow., ? lkv Ao 1, 3 y 31-111 JO JEHAN SAMIR DISBROW, PLAINTIFF V. TIMOTHY SCOTT DISBROW, DEFENDANT COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 04-3818 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE PRAF IP TO N R APPEARANCE Please enter my appearance on behalf of Defendant, Timothy Scott Disbrow. lam c5rc;ZD J? David P. Perkins, Esquire Attorney ID No. 34342 7 Irvine Row Carlisle, PA 17013 (717) 240-0100 1 fl' ":, G _ ?`_7 JEHAN SAMIR DISBROW, Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3818 CIVIL, TERM CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, David Perkins, Esquire, attorney for Timothy Scott Disbrow, Defendant, hereby certify that I accept service on his behalf of a Complaint in Divorce as well as Order of Court scheduling a Custody Conciliation Conference for September 16, 2004, at 1:00 p.m. relative to the above-captioned matter on or about Au 6 u-TV I ?Q! > 2004, by first-class mail, postage prepaid. I hereby certify that the aforegoing is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Date: Aucoa t ?? 2?w David Perkins, Esquire A,b+-N iONO. 32{311? /"•? N ?` fi S" ' ? _ i l I JI . ?_. i.. ?f _.? ??,: ?r 1. ? 1 ? L SEP 2 7 2004 V//? JEHAN SAMIR DISBROW, Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3818 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this day of September, 2004, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. The following Order shall replace any Orders previously entered with respect to custody docketed to the PFA at No. 04-3748. 2. Legal Custody. The parties, Jehan Samir Disbrow and Timothy Scott Disbrow, shall have shared legal custody of the minor child, Damian Frederick Disbrow, born January 1, 2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody. Mother shall have primary physical custody of the minor child subject to Father's rights of partial custody which shall be arranged as follows: A. Commencing September 18, 2004, from Saturday at 9:00 a.m. until Monday at 7:00 p.m. each week. B. Commencing September 22, 2004, each Wednesday from 5:00 P.M. to 9:00 P.M. NO. 04-3818 CIVIL TERM 3. Transportation and Custody Exchanges. Except for the 5:00 p.m. Wednesday exchanges, the custodial exchanges shall occur at the Carlisle Police Station. At the time of the custodial exchange, the adults shall stay in the car and allow the child to walk the short distance between the vehicles. Father may not participate: in the custodial exchanges at the Carlisle Police Station for the duration of the Protection from Abuse Order. However, at the beginning of Father's period of custody on Wednesday evenings, he may pickup the child at the Magic Years Daycare Center. 4. Father shall have the child bathed and ready for bed when the child is returned to Mother at 9:00 p.m. on Wednesday evenings. 5. Either party may petition to modify this Order in the event of a change of one of their work schedules. 6. Both parents shall establish a no-conflict zone for their children and refrain from making derogatory comments about the other parent in the presence or earshot of the children and, to the extent possible, shall prevent third parties from making such comments in the presence or earshot of the children. 7. The parties agree that the child will not be subject to physical discipline. 8. Holidays. The following holiday schedule shall supersede the regular schedule: A. Child's Birthday. The parties will share time with the child on his birthday (January 1°ach year. B. Christmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 24`h at Noon until December 25` at 2:00 p.m. Segment B shall be from December 25`h at 2:00 p.m. until December 26`h at 6:00 p.m. In even-numbered years, Father shall have Segment A and Mother shall have Segment B. In odd-numbered years, Mother shall have Segment A and Father shall have Segment B. C. Alternating Holidays. The parties will alternate the following holidays: Easter, Memorial Day, Labor Day and Thanksgiving. The custodial period for these holidays shall be from 6:00 p.m. the day before the holiday until 6:00 p.m. the day of the holiday. The alternating schedule shall commence with Mother having the Thanksgiving holiday in 2004. NO. 04-3818 CIVIL TERM matter. D. Mother's Day / Father's Day. Mother will have custody for Mother's Day and Father will have custody for Father's Day. The custodial period for these holidays shall be from 6:00 p.m. the day before the holiday until 7:00 p.m. the day of the holiday. E. Ramadan. Mother shall be entitled to have custodial periods on the first and last days of Ramadan. According to the Islamic Society of North America, the first day of fasting for Ramadan 2004 is expected to be October 16, 2004. Therefore, Mother will have custody of the child for the first day of Ramadan from 9:00 a.m. to 8:00 p.m. On the last day of Ramadan when the ending of fasting is celebrated by feast, Mother shall have custody for this holiday from 9:00 a.m. to 8:00 p.m. Father shall be entitled to makeup time for the Ramadan holiday on the following two dates in 2004: On Monday, October 18, 2004, Father's custodial period will extend from 7:00 p.m. until the following morning at 8:00 a.m. On November 26, 2004, Father's weekend period of custody will begin on Friday morning at 9:00 a.m. rather than Saturday morning at 9:00 a.m. 9. Cumberland County Court of Common Pled wi retain jurisdiction of this BY THE COUR Dist: Kristin R. Reinhold, Esquire, 5922 Linglestown Road, Harrisburg, PA 17112 David P. Perkins, Esquire, 7 Irvine Row, Carlisle, PA 17013 J. ???.?, r rr f,S??.C-'-,?n ?? /)t??? ??,, .?+.? ?fd1?.iG?. ? OS ??S ?dQl ?u?.t ? , ?;?`'yi' ??77 ? ?'0 JEHAN SAMIR DISBROW, Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3818 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Damian Frederick Disbrow January 1, 2001 Mother 2. The parties' first Custody Conciliation Conference was held on September 16, 2004 following Mother's filing of a Complaint in Divorce with a Count for Custody on August 4, 2004. Present for the conference were: the Mother, Jehan Samir Disbrow, and her counsel, Kristin R. Reinhold, Esquire; the Father, Timothy Scott Disbrow, and his counsel, David P. Perkins, Esquire. In addition, there is a Protection from Abuse Order docketed to No. 04-3748. At the hearing set on the Temporary Protection from Abuse Order, the parties worked out a temporary custody plan which was dictated into the record in proceedings before Judge Hess on August 9, 2004. The intent of the custody arrangement made on August 4th was that it be a temporary arrangement intended to be in place only pending the Custody Conciliation. At that time, the parties also agreed to continue the PFA generally. Therefore, there was no finding of abuse made at that hearing before Judge Hess. 3. The parties reached an at agreement in the for Order as attached. 1 Melissa Peel Greevy, Esquir Custody Conciliator :235769 JEHAN SAMIR DISBROW, Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3818 CIVIL ACTION -LAW IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, x prior to the entry of a Final Decree in Divorce or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of Jehan Samir Ibrahim, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 704. Date: /.? ?C:41 ?_ '1t??-- J an Samir Disbrow ;han/Seamir Ibrahim COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN On the day of 2004, before me, a notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto hand and o cial seal. NOTARIAL SEAL Notary Public Rm" Dmisbach. Notary Publk Lo" Put= Twp» Dsiq+hia t1o ? My t' +*aion Expim Nov. 30, 2006 1 \ ? r r 1 4?1 9 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF (now JEHAN SAMIR IBRAHIM) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. TIMOTHY SCOTT DISBROW, Defendant : CIVIL ACTION - LAW : NO. 2004 - 3818 CIVIL TERM : IN DIVORCE PRAECIPE FOR WITHDRAW AND ENTRY OF APPEARANCE OF COUNSEL OF RECORD TO THE PROTHONOTARY: Please withdraw the appearance of DAVID P. PERKINS, ESQUIRE, as attorney of record for Defendant, TIMOTHY SCOTT DISBROW, in this matter. u- 12 , 2008 '??),?A (?-? a?? DAVID P. PERKINS, ESQUIRE 4 JAMES CIRCLE SHIPPENSBURG, PA 17257 717-532-9537 SUPREME COURT I.D. NO. 34342 Please enter the appearance of NATHAN C. WOLF, ESQUIRE, as attorney for the Defendant in this matter. ?? , 2008 AT OLF, ESQUIRE WOL WOLF 10 West High Street Carlisle, PA 17013-2922 717-241-4436 SUPREME COURT ID #87380 r-7 r+a Tz e„? a r NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR DEFENDANT JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF (now JEHAN SAMIR IBRAHIM) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant : CIVIL ACTION - LAW : NO. 2004 - 3818 CIVIL TERM : IN DIVORCE CERTIFICATE OF SERVICE I, Nathan C. Wolf, Esquire, attorney for defendant, do hereby certify that I have served a copy of the foregoing Praecipe for Withdraw and Entry of Appearance of Counsel of Record upon the following individuals by postage prepaid mail, addressed as follows: Counsel of Record for the Plaintiff. Kristin R. Reinhold, Esquire 5922 Linglestown Road Harrisburg, PA 17112 JULY 18, 2008 Jehan Samir Ibrahim 1888 Douglas Drive Carlisle, PA 17013 717-241-4436 SUPREME COURT ID NO. 87380 Carlisle, PA 17013 Z7 c, NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF (now JEHAN SAMIR IBRAHIM) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant : CIVIL ACTION - LAW : NO. 2004 - 3818 CIVIL TERM : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about August 4, 2004 and served upon defendant on August 18, 2004 (see acceptance of service filed August 18, 2004). 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. l (o , 2008 < __ an Samir Ibrahim Pn cx? IT-i r Gi n NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF (now JEHAN SAMIR IBRAHIM) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. TIMOTHY SCOTT DISBROW, Defendant : CIVIL ACTION - LAW NO. 2004 - 3818 CIVIL TERM IN DIVORCE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. 2008 L - ` an Samir Ibrahim - 6 vt Z lu ? ? ? # f 1 ? t'''ry) d _ NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 97380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF (now JEHAN SAMIR IBRAHIM) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant : CIVIL ACTION - LAW : NO. 2004 - 3818 CIVIL TERM : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about August 4, 2004 and served upon defendant on August 18, 2004 (see affidavit of service filed August 18, 2004). 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unworn falsification to authorities. C , 2008 T. colt Disbrow 9A r r l c o t ,.. ,.r ?k1 c y, NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR DEFENDANT JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF (now JEHAN SAMIR IBRAHIM) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff _ V. TIMOTHY SCOTT DISBROW, Defendant : CIVIL ACTION - LAW : NO. 2004 - 3818 CIVIL TERM : IN DIVORCE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and con-ect. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. 2008 T. Scott Disbrow C"'? . ;?. ,, ?;, -?, > .. -.,. , ..? ? {{ro" ?'?'A ."'4. NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF (now JEHAN SAMIR IBRAHIM) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant : CIVIL ACTION - LAW : NO. 2004 - 3818 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about August 14, 2004, defendant was served with a copy of the divorce complaint through counsel. (See Acceptance of Service previously filed, August 18, 2004.) 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: September 16, 2008 By the defendant: September 16, 2008 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: NIA. (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: NIA. 4. Related claims pending: None 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: NIA.. (b) Date plaintiff's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: September 17, 2008 Date defendant's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary. September 17, 2008 October 20, 2008 NAT C. WOLF Attorney for Defendant ;-? ,-, ?_ ?? ,.,``? ,,i ` mod w ? .4 ?6 `? , 4 ,.a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. JEHAN SAMIR DISBRO (now JEHAN SAMIR IBRAHI" VERSUS TIMOTHY SCOTT DISBROW 2004 3818 DECREE IN DIVORCE AND NOW, IT IS ORDERED AND JEHAN SAMIR DISBROW (now JEHAN SAMIR IBRAH lvV DECREED THAT , PLAINTIFF, AN D TIMOTHY SCOTT DISBROW ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONR PROTHONOTARY NO. o?y,,`''?';` ? ?- o/ .?Q.£? Gf . , e,, "; ?`? ,, NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR DEFENDANT JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF (now JEHAN SAMIR IBRAHIM) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant CIVIL ACTION - LAW NO. 2004 - 3818 CIVIL TERM IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW comes the Petitioner, Timothy Scott Disbrow, by and through his attorney, Nathan C. Wolf, Esquire, and files this petition for modification of custody, respectfully representing as follows: 1. The plaintiff/respondent is Jehan Samir Ibrahim, formerly Jehan Samir Disbrow, an adult individual residing at 1404 Bradley Drive, Apartment B-112, Carlisle (North Middleton Township, Cumberland Count, Pennsylvania 17013. 2. The defendant/petitioner is Timothy Scott Disbrow, an adult individual who resides at 461 Petersburg Road, Carlisle (South Middleton Township, Cumberland Count Pennsylvania 17015. 3. The plaintiff and defendant are the natural parents of one minor child, namely: N= Present Residence Damian Fredrick Disbrow 1404 Bradley Drive, Apt B-112 8 years Carlisle, PA 17013 D.O.B. 1/1/2001 4. The child is presently the subject of an Order for Custody issued September 30, 2004 by the Honorable Edgar B. Bayley, providing for shared legal custody and primary physical custody of the child to Mother with Father having periods of partial physical custody. A true and correct copy of the order of which modification is sought is attached hereto as Exhibit "A." 5. The parties have been operating under an oral agreement which provides Father with custody of the child from Monday after school until Tuesday night at 8:30, Friday after school until Sunday night at 8:30 and in the following week Wednesday after school until Thursday at 8:30. Said schedule corresponded with Father's work schedule as Father is employed as an emergency dispatcher with Cumberland County Communications. 6. Father has resided at his current residence since October 2008 with his fiance, Christy Bitner. Previously Father had resided at 74 Prospect Drive, Carlisle (Middlesex Township) for nine years prior to his current residence. 7. Mother has resided at her current residence since approximately July 2004 with her paramour Robert Leach. 8. Father seeks a modification of custody based upon developments that have occurred since the issuance of said custody orders. 9. On days when Mother has custody of the child, the child has missed approximately 12 days of school, and has been tardy to school on 16 days. 10. Of the above-mentioned absences, the child was sent home from school on one occasion, all other absences were a result of Mother's failure to send the child to school. 11. On days when the Father has had custody of the child, the child has not been either absent or tardy. 12. Mother often sends notes into the school indicating that the child is ill or has suffered a fever, but when Father has picked up the child the same afternoon, the child has appeared without any indication of illness and Mother has failed to ever provide any medication or care instructions from a physician. 13. On at least two occasions, Mother has informed the school that the child has been tardy due to medical appointments, however, the child was taken to those treatment providers (namely an eye doctor and a dentist) by Father at such times to avoid any school absence. 14. Father provides medical insurance for the child through his employment and has received neither bills for the patient contribution nor explanation of benefits from such services being provided. 15. Moreover, Father is aware of several police incidents which occurred at Mother's residence within the past year, one of which was on or about March 16, 2008 at which time the child was present during a home invasion and violent exchange between Mother's paramour and an individual who broke into the home and initiated a fight over a disputed drug transaction. 16. Likewise, the child was present at an incident which occurred on or about September 7, 2008 during which Mother's paramour was engaged in a violent incident with Mother's sister, Yasmin Ibrahim, at which time the police intervention was required. 17. Mother is unstable, has been neglecting the child's medical and dental care including not ensuring the child has his necessary immunizations. 18. Father has recently attempted to ensure that the child has had appropriate medical care, dental care and vision care when it became apparent that Mother had neglected to ensure that the child's needs were being met.. 19. Father believes that Mother's paramour and possibly Mother are engaged in the abuse of drugs, including marijuana, and unlawfully obtained prescription medication. 20. On more than one occasion, Father has picked up the child and has detected the odor of burnt marijuana and observed Mother with slow slurred speech, staggered gait and glassy bloodshot eyes, which Father believed presented as the classic signs of intoxication. These incidents occurred while Mother was caring for the child. 21. Father believes and therefore avers on multiple occasions, the child has been exposed to adults smoking marijuana and that, upon information and belief, Children and Youth Services received a referral from another relative that such activity was occurring in Mother's household. 22. Father believes and therefore avers that Mother's actions have demonstrated a callous disregard for the child's best interests and if not for his economic constraints, he would have pursued this modification months prior to the filing of the instant petition, but was without sufficient resources to do so. 23. Moreover, Father was without demonstrative proof of Mother's neglectful behavior until he was made aware, by the child's school, of the large number of absences which, together with Mother's other behaviors, indicated to Father the seriousness of the situation in Mother's household. 24. Due to Father's work schedule, he will be available to care for the child every morning, and either he or his fiance is available after school if Father is working, and weekends during the hours the child is not in school. 25. The best interest and permanent welfare of the child will be served by granting the relief requested because Father will be able to provide for the child's medical, educational, emotional and physical needs in a stable, safe, and nurturing environment. 26. The best interests and permanent welfare of the child would be served by this Court issuing an Order granting primary physical custody of the child to Father. WHEREFORE, Petitioner, T. Scott Disbrow, prays this Honorable Court enter an Order granting primary physical custody of the child to Petitioner/Father, granting periods of visitation or partial physical custody to Respondent/Mother, and granting shared legal custody of the child to both parties and any additional relief as the Court deems appropriate. Respectfully submitted, WOLF & WOLF, Attorneys at Law Dated: February 02009 Na oli Esquire 10 a igh Street Car sle, PA 17013 Supreme Court I.D. No. 87380 (717) 241-4436 Attorney for Defendant VERIFICATION I, the undersigned, do hereby verify that I am the defendant/petitioner in this action and that the facts set forth in this petition are true and correct to the best of my information knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.GS. Section 4904, relating to unsworn falsification to authorities. fih 2009 t T. Scott Disbrow NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF (now JEHAN SAMIR IBRAHIM) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION - LAW TIMOTHY SCOTT DISBROW, : NO. 2004 - 3818 CIVIL TERM Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Nathan C. Wolf, Esquire, attorney for Defendant, do hereby certify that I have served a copy of the foregoing Petition for Modification of Custody upon the following individual by postage prepaid mail, addressed as follows: Kristin R. Reinhold, Esquire 5922 Linglestown Road Harrisburg, PA 17112 Jehan S. Ibrahim 1404 Bradley Drive Apartment B-112 Carlisle, PA 17013 Date: February _I ,), 2009 wolf, Esquire for Defendant G CIO CJ O NJ ; _. A JEHAN SAMIR DISBROW (NOW JEHAN IN THE COURT OF COMMON PLEAS OF SAMIR IBRAHIM) PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2004-3818 CIVIL ACTION LAW TIMOTHY SCOTT DISBROW IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, February 24, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, March 23, 2009 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entrv of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ac ueline M. Verne Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 1 C._ --s ;-rw ? NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR DEFENDANT JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF (now JEHAN SAMIR IBRAHIM) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION - LAW TIMOTHY SCOTT DISBROW, : NO. 2004 - 3818 CIVIL TERM Defendant : IN CUSTODY ST IFULATIONANDAGREEII E THIS STIPULATION AND AGREEMENT entered into this /I day of u / , 2009, by and between TIMOTHY SCOTT DISBROW (hereinafter referred to as "Father") and JEHAN SAMIR IBRAHIM (hereinafter referred to as "Mother'). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Father and Mother are the parents of one minor child, namely, DAMIAN FREDRICK DISBROW (age 8 years, born January 1, 2001); and, WHEREAS, the parties are subject to a custody order entered at this term and docket on September 30, 2004, by the Honorable Edgar B. Bayley, and now wish to enter into an amended agreement relative to the custody of the parties' child; and, NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. The parties shall have shared legal custody of the child. 2. The parties shall share physical custody of the child in accordance with the following two-week schedule effective, March 17, 2009: a. In the first week of the rotation, Mother shall have custody of the child from after school on Wednesday until Friday morning, unless the child does not have school, in which instance custody shall exchange at 12:00 noon. Father shall then have custody of the child from Friday after school until Monday morning, or if the child does not have school, custody shall exchange at 12:00 noon. b. In the second week of the rotation, Mother shall have custody of the child from after school on Mondays until Wednesday morning, unless the child does not have school, in which instance custody shall exchange at 12:00 noon. Father shall have custody of the child from Wednesday until Friday morning, unless the child does not have school, in which instance custody shall exchange at 12:00 noon. Mother shall also have custody of the child from Friday after school until Monday morning unless the child does not have school, in which instance custody shall exchange at 12:00 noon. 3. The prior order shall remain in full force and effect with regard to the holiday schedule and the holiday schedule shall preempt the schedule set forth above. 4. Each party shall be entitled to a total of two nonconsecutive weeks of uninterrupted vacation with the child during the summer vacation period. The party seeking to exercise said weeks of vacation shall notify the other party in writing no less than thirty (30) days prior to the date the week would commence. 5. Transportation of the child shall be shared such that the parties shall meet to exchange custody at a mutually agreed-upon location. In the absence of an agreed-upon location, the receiving party will pick up the child from the home of the party having custody. 6. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child are protected. 7. The parties shall do nothing that may estrange the child from either party or hinder the natural development of the child's love or affection for the other parry. 8. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing. 9. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 10. In the event of the breach of the agreement of the parties by any party, the nonbreaching party shall have the right to file a petition for contempt of court and to seek specific performance of the terms of the agreement of the parties. t 11. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child. 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. ?.,.- ?e, v -A TIMOTHY COTT DISBROW (SEAL) HAN SAMIR IBRAHIM COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND :SS: On this, the 1 `7 day of 116,ol, , 2009, before, the undersigned officer, appeared TIMOTHY SCOTT DISBROW known to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument, and acknowledged that he executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA Notarial Sari Nathan C. Wolf, Notary Public Carlisle eoro, Cumberland County (SEAL) Commigion Expires April 19, 2012 Member, Pennsylvania Assodatlon of Notaries Not COMMONWEALTH OF PENNSYLVANIA :SS: COUNTY OF CUMBERLAND On this, the __L7_ day of ?, 2009, before, the undersigned officer, appeared JEHAN SAMIR IBRAHK known to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument, and acknowledged that she executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA Notarial Seat Nathan C. Wolf, Notary Public (SEAL) Carlisle Boro, Cumberland County Commisaion rea April 19, 2012 Nota ub mwnbw, Mylventa Aswaladon of Notaries WITNESSETH: i C D . _ _'j r MAR 9 2009 JEHAN SAMIR DISBROW (NOW: IN THE COURT OF COMMON PLEAS OF JEHAN SAMIR IBRAHIM), : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO. 2004-3818 CIVIL ACTION - LAW TIMOTHY SCOTT DISBROW, : Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 17th day of March, 2009, the parties having reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, q._, _ _ __?7 ? Fl q ine M. Verney, Esquire, Cus y Conciliator C? Vi j MAR 18 20094 JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON FLEAS OF (now JEHAN SAMIR IBRAHIM) : CUMBERLAND COUNTY, PENNSYLVANIA Plainti ff v. : CIVIL ACTION - LAW TIMOTHY SCOTT DISBROW, : NO. 2004 - 3818 CIVIL TERM Defendant : IN CUSTODY ORDER OF COURT -Jkk NOW, this day of AL 2009, upon presentation and consideration of the attached Stipulation and Agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. _ '..'? BY THE Distribution: than C. Wolf, Esquire For the Defendant Jehan Samir Ibrahim Pm Se Plaintiff 47-0 co?. Di 1 N LU c z) C11 r1C- CD r N 0 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 T FI.L.ED f, - FIC: a ' 6t.t -7 Pl [: ATTORNEY FOR DEFENDANT P1: t Y JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF (now JEHAN SAMIR IBRAHIM) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant : CIVIL ACTION - LAW : NO. 2004 - 3818 CIVIL TERM : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW comes the Petitioner, Timothy Scott Disbrow, by and through his attorney, Nathan C. Wolf, Esquire, and files this petition for modification of custody, respectfully representing as follows: 1. The plaintiff/respondent is Jehan Samir Ibrahim, formerly Jehan Samir Disbrow, an adult individual residing at 1404 Bradley Drive, Apartment B-112, Carlisle (North Middleton Township, Cumberland County), Pennsylvania 17013. 2. The defendant/petitioner is Timothy Scott Disbrow, an adult individual who resides at 461 Petersburg Road, Carlisle (South Middleton Township, Cumberland County) Pennsylvania 17015. 3. The plaintiff and defendant are the natural parents of one minor child, namely: Name Present Residence Age Damian Fredrick Disbrow 461 Petersburg Road 10 years Carlisle, PA 17015 D.O.B. 1/1/2001 4. The child is presently the subject of an Order for Custody issued March 19, 2009 by the Honorable Edgar B. Bayley, incorporating the terms of a stipulated agreement between the parties for shared legal custody and physical custody of the child. A true and correct copy of the order of which modification is sought is attached hereto as Exhibit "A." lU. 001°f" ? t f- t' 2a 5 /79 5. Father seeks a modification of custody based upon developments that have occurred since the issuance of said custody order. 6. On or about March 3, 2011, North Middleton Township Police were dispatched to Mother's residence to respond to a domestic disturbance, namely an argument between Mother and maternal grandmother. 7. Ultimately, the North Middleton Township Police Department discovered evidence of illegal drug use in the residence by Mother and others whom Mother was allowing to stay in the bedroom which was to be occupied by the child and his half-sister (who is not subject to this action). 8. North Middleton Township Police Officers discovered deplorable living conditions, and evidence of drug use and paraphernalia in plain view within the apartment. 9. The child and his half-sister, age 3 years, were present when the police arrived at the residence and had apparently been living in these conditions for some time. 10. To her credit, after initially denying any drug use, Mother ultimately admitted to the officers that she was still using heroin and turned over her paraphernalia to the Officers. 11. The North Middleton Police determined that it was necessary, because of the living conditions and the presence of controlled substances, to contact Children and Youth Services, who directed that custody of the child should be immediately turned over to Father and the child's half- sister was placed in the care and custody of the maternal grandmother for the evening. 12. Children and Youth Services has implemented a safety plan providing that Mother have no unsupervised contact with her children until further notice, to which Mother has agreed. (A true and correct copy of the safety plan is attached hereto as Exhibit "B") 13. The safety plan also provides that Father shall have custody of the child until further notice. 14. On more than one occasion, Father has had concerns about Mother's condition and the condition her apartment. These observations occurred while Mother was caring for the child. 15. Mother's continued drug use and her history of exposing the child to poor living conditions and to dangerous prescription medication used to treat drug dependency which was found in the open in Mother's apartment as well as dangerous drug paraphernalia, including used heroin needles, justifies limiting her contact with the child to supervised visits until she is no longer abusing drugs or associating with known drug users and dealers. 16. Father is gainfully employed as an emergency services dispatcher and has a stable household where he is completely capable of caring for the child's needs. 17. The best interest and permanent welfare of the child will be served by granting the relief requested because Father will be able to provide for the child's medical, educational, emotional and physical needs on a primary basis in a stable, safe, and nurturing environment. 18. The best interests and permanent welfare of the child would be served by this Court issuing an Order granting primary physical custody of the child to Father and limiting Mother to periods of supervised visitation pending further Order of Court WHEREFORE, Petitioner, T. Scott Disbrow, prays this Honorable Court enter an Order granting primary physical custody of the child to Petitioner/ Father, granting periods of visitation to Respondent/Mother, and granting shared legal custody of the child to both parties and any additional relief as the Court deems appropriate. Respectfully submitted, WOLF & WOLF, Attorneys at Law Dated: March 77, 2011 Supreme Court I.D. No. 87380 (717) 241-4436 Attorney for Defendant MAR 1, 8 20086 JEHAN SAMIR DISBROW, (now JEHAN SAMIR IBRAHIM) Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004 - 3818 CIVIL TERM IN CUSTODY ORDER OF COURT NOW, this R day'of JkAUtL 2009, upon presentation and consideration of the attached Stipulation and Agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made a Ord Distribution: Nathan C. Wolf, Esquire For the Defendant Jehan Samir Ibrahim Pro Se Plaintiff LX?4 l8(TA f- NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF (now JEHAN SAMIR IBRAHIM) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. TIMOTHY SCOTT DISBROW, Defendant : CIVIL ACTION - LAW NO. 2004 - 3818 CIVIL TERM IN CUSTODY STIPULATIONAND AGREEMENT THIS STIPULATION AND AGREEMENT entered into this /? day of Kz/? , 2009, by, and between TIMOTHY SCOTT DISBROW (hereinafter referred to as "Father") and JEIIAN SAMIR IBRAHIM (hereinafter referred to as "Mother"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Father and Mother are the parents of one minor child, namely, DAMIAN FREDRICK DISBROW (age 8 years, born January 1, 2001); and, WHEREAS, the parties are subject to a custody order entered at this term and docket on September 30, 2004, by the Honorable Edgar B. Bayley, and now wish to enter into an amended agreement relative to the custody of the parties' child; and, NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. The parties shall have shared legal custody of the child. 2. The parties shall share physical custody of the child in accordance with the following two-week schedule effective, March 17, 2009: a. In the first week of the rotation, Mother shall have custody of the child from after school on Wednesday until Friday morning, unless the child does not have school, in which instance custody shall exchange at 12:00 noon. Father shall then have custody of the child from Friday after school until Monday morning, or if the child does not have school, custody shall exchange at 12:00 noon. b. In the second week of the rotation, Mother shall have custody of the child from after school on Mondays until Wednesday morning, unless the child does not have school, in which instance custody shall exchange at 12:00 noon. Father shall have custody of the child from Wednesday until Friday morning, unless the child does not have school, in which instance custody shall exchange at 12:00 noon. Mother shall also have custody of the child from Friday after school until Monday morning unless the child does not have school, in which instance custody shall exchange at 12:00 noon. 3. The prior order shall remain in full force and effect with regard to the holiday schedule and the holiday schedule shall preempt the schedule set forth above. 4. Each party shall be entitled to a total of two nonconsecutive weeks of uninterrupted vacation with the child during the summer vacation period. The party seeking to exercise said weeks of vacation shall notify the other party in writing no less than thirty (30) days prior to the date the week would commence. Transportation of the child shall be shared such that the parties shall meet to exchange custody at a mutually agreed-upon location. In the absence of an agreed-upon location, the receiving party will pick up the child from the home of the party having custody. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child are protected. 7. The parties shall do nothing that may estrange the child from either parry or hinder the natural development of the child's love or affection for the other party. 8. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing. 9. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 10. In the event of the breach of the agreement of the parties by any party, the nonbreaching party shall have the right to file a petition for contempt of court and to seek specific performance of the terms of the agreement of the parties. 11. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child. 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. WITNESSETH: EAL) TI OTHY S OTT DISB OW ? ZA -(SEAL)JEHAN SAMIR IBRAHIM COMMONWEALTH OF PENNSYLVANIA : :SS: COUNTY OF CUMBERLAND On this, the / I day of , 2009, before, the undersigned officer, appeared TIMOTHY SCOTT DISBROW known to me ( or satisfactorily proven) to be the same person whose name is subscribed to the within instrument, and acknowledged that he executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Nathan C. Wolf, Notary Public Carlisle Boro, Cumberland County (SEAL) My Commission Expires April 19, 201;; Member, Pennsylvania Association of "inu-nc;: Notat??c COMMONWEALTH OF PENNSYLVANIA : :SS: COUNTY OF CUMBERLAND On this, the , day of 2009, before, the undersigned officer, appeared JEHAN SANER IBRAHIM, known to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument, and acknowledged that she executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set myl and and official seal. COMMONWEALTH OF PENNSYLVANIA ? (SEAL) Notarial Seal Nathan C. Wolf, Notary Public Not blic Carlisle Boro, Cumberland County My Commission Expires April 19, 2012 Member, Pennsylvania Association of Notaries U TN V 1 15 b U U W V?1 U 0.4 4- O a? Q 9 P-0 NI Q z? 9- Cd U CCdd z CV C/1 U a 1 o 7IN b ? 0 0 3 U CIO Cd t b ?U zH ?T - bcl ? U w ?U a w 0 0 ?a a? d O O Ca ? O O p p VD ` u u N O U ? Q O N H •3 5 .? a? a ? ? o U y ? y Q cd 0 0 •~ o? w°a r4l? .w C's w ? o ? w 0 a? CIS U ? o, o ? N O O 0 w 0 a? N N w ?pA C7 6~1 ? N iyC p W pr ? ?00 ?00 a ?? w? O U W O > b ° .? O O? U ? O C ?b w? G •Y o ?U w? ?U 3 ? as ? •p T y ?Y ? O ?za VERIFICATION I, the undersigned, do hereby verify that I am the defendant/petitioner in this action and that the facts set forth in this petition are true and correct to the best of my information knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. r 2011 -777 =>C - T. Scott Disbrow NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF (now JEHAN SAMIR IBRAHIM) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION - LAW TIMOTHY SCOTT DISBROW, : NO. 2004 - 3818 CIVIL TERM Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Nathan C. Wolf, Esquire, attorney for Defendant, do hereby certify that I have served a copy of the foregoing Petition for Modification of Custody upon the following individual by postage prepaid mail, addressed as follows: Jehan S. Ibrahim 1404 Bradley Drive Apartment B-112 Carlisle, PA 17013 Date: March -Z, 2011 f JEHAN SAMIR DISBROW IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA 2004-3818 CIVIL ACTION LAW TIMOTHY SCOTT DISBROW ° IN CUSTODY ° DEFENDANT ORDER OF COURT AND NOW, Wednesday, M?rch 09, 2011 upon consideration of the attached Complaint, it is hereby directed that parties and their rebpective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, April 13, 2011 ___ at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference ml ay provide grounds for entry of a temporary or permanent order. The court hereby directs the parti s to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody order to the conciliator 48 hours prior to scheduled hearing. F6R THE COURT. By: ls/ ac ueline M. Verne Es _ Custody Conciliator The Court of Common Pleas lof Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infor$nation about accessible facilities and reasonable accommodations available to disabled individuals Navin business before the court, please contact our office. All arrangements must be made at least 72 hours prior to?ny hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THI.1 HAVE AN ATTORNEY OR CANNON FORTH BELOW TO FIND OUT WHI ela PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET RE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 ,Telephone (717) 249-3166 3 JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2004-3818 CIVIL ACTION - L?W TIMOTHY SCOTT DISBROW Defendant : IN CUSTODY 331- ORDER OF COURT ? n = 0 AND NOW this q day of ` 42,- , 2011, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated March 19, 2009 shall remain in full force and effect with the following modifications. 2. Father shall have primary physical custody of the child. 3. Mother shall have the following periods of partial physical custody: A. During the school year: 1. Alternating Mondays and Thursdays from 5:00 p.m. to 8:00 p.m. 2. Alternating Saturdays and Sundays from 12:00 noon to 7:00 p.m. 3. Such other times as the parties agree. B. During the summer or school breaks: 1. Alternating Mondays and Thursdays from 10:00 a.m. to 5:00 p.m. 2. Alternating Saturdays and Sundays from 12:00 noon to 7:00 p.m. 3. Such other times as the parties agree. 4. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for June 14, 2011 at 8:30 a.m. BY E COURT, J. cc: Nathan C. Wolf, Esquire, Counsel for Father 11*?Jehan Samir Disbrow, pro se 1404 Bradley Dr. B-112 Carlisle, PA 17013 ODpivs j) K-6 JEHAN SAMIR DISBROW, Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2004-3818 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edgar B. Bayley, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Damian Frederick Disbrow January 1, 2001 Father 2. A Conciliation Conference was held in this matter on April 15, 2011, with the following in attendance: The Father, Timothy Scott Disbrow, with his counsel, Nathan C. Wolf, Esquire, and the Mother, Jehan Samir Disbrow, pro se. 3. A prior Order of Court were entered by the Honorable Edgar B. Bayley dated March 19, 2009 providing for shared legal custody and shared physical custody on a 2/3/2 schedule. 4. The parties agreed to an Order in the form as attached. 5 3-!I /K. x Date ac eline M. Verney, Esquire Custody Conciliator JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2004-3818 CIVIL ACTION - LAW TIMOTHY SCOTT DISBROW, : Defendant : IN CUSTODY ? ORDER OF COURT C-n AND NOW hi /5 d 'r7" , t s ay k- , 2011, upon consideration of the attached Custody Report nciliation , it is ordered and direct ed as follows l . The prior Orders of Court dated May 4, 2011 and May 11, 2011 shall remain in full force and effect with the following modification. 2. Once the Safety Plan is lifted by Cumberland County Children & Youth Services, the parties shall revert to the physical custody schedule for Mother as listed in the Order of Court dated May 4, 2011. 3. This Order is entered pursuant to 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. c? Nathan C. Wolf, Esquire, Counsel for Father 0a,(ed Jehan Samir Disbrow, pro se ,es M 1404 Bradley Dr. ? 1511 B-112 K,8 Carlisle, PA 17013 JEHAN SAMIR DISBROW, Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2004-3818 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: Edward E. Guido, J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Damian Frederick Disbrow January 1, 2001 Father 2. A Conciliation Conference was held in this matter on June 14, 2011, with the following in attendance: The Father, Timothy Scott Disbrow, with his counsel, Nathan C. Wolf, Esquire, and the Mother, Jehan Samir Disbrow, pro se. 3. The Honorable Edward E. Guido entered Orders of Court dated May 4, 2011 and May 11, 2011 providing for shared legal custody, Father having primary physical custody with Mother having periods of supervised visitation consistent with a Children & Youth Safety Plan. 4. The parties agreed to an Order in the form as attached. ? -t LI i! Date Jacq ine M. Verney, Esquire Custody Conciliator JEHAN SAMIR DISBROW, (now Jehan Samir Ibrahim) Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2004-3819 CIVIL ACTION-LAW : IN CUSTODY C-) C7.1 rn rn ^ N 2 ' CD v ? cY? -tea r? -T PETITION TO MODIFY CUSTODY The Petitioner, Plaintiff Jehan Ibrahim, by and through her counsel, MidPenn Legal Services, respectfully represents the following in support of her petition for modification: Plaintiff/Petitioner is Jehan Ibrahim, hereinafter referred to as Mother, who resides at 1404 Bradley Drive, Apt. B-112, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant/Respondent is Timothy Disbrow, hereinafter referred to as Father, ',who resides at 461 Petersburg Road, Carlisle, Cumberland County, Pennsylvania 17015. 3. On May 1/ 2011, and June 15, 2011, the Honorable Judge Edward E. Guido entered a custody order for the parties' minor child, Damian Fredrick Disbrow, born January 1, 2001. A copy of those Orders are attached as Exhibit A & B. The orders, in pertinent part, grants the parties shared legal custody, Father primary custody, and Mother partial physical custody. 4. Prior to March of 2011, Mother and Father shared physical custody of their minor child on a week-on, week-off schedule. 5. On March 7, 2011, Father petitioned this Court for primary custody after criminal charges were filed against Mother. Ultimately, Mother pled nolo contendere to endangering the welfare of children on November 14, 2011, for which she was sentenced on January 31, 2012, to three (3) years i ofprobation. On January 11, 2012, Mother pled guilty to a related charge at a separate dojcket for use and/or possession of drug paraphernalia. Mother was sentenced on March 20, 2012, to additional Y probation. 6. At the April 2011 custody conciliation, Mother agreed to Father having primary physical custody, with Mother having supervised physical custody. 7. On June 15, 2011, this Court lifted the supervision requirement. 8. From March of 2011 until January of 2012, Mother cooperated with Cumberland County Children and Youth Services, completing the agencies Service Plan. On January 31, 2012, CYS completed its final evaluation on Mother and assessed that Mother was a low safety risk to her children. A copy of this final service plan is attached as Exhibit C. 9. Mother has also been in drug treatment since March of 2011 and has been substance free for approximately one (1) year. See Discovery House letter attached as Exhibit D. 10. Mother is a part-time student in the Dental Assistant program at HACC, and works part- time as a retail associate at the House of Cards located in the Carlisle Plaza Mall. 11. Mother has primary custody of a four (4) year-old daughter, Jayden Leach, Who is minor child's half-sister. Under the current custody order, this sibling group does not have substantial contact. 12. The best interests and welfare of the minor child would be best served by this Court granting Mother additional periods of partial physical custody, as she wishes to' have more substantial contact with the minor child so as to maintain and further develop the mother-son relationship that has been established. WHEREFORE, Mother respectfully requests this Court to modify the existing Order for Custody and grant Mother additional periods of partial physical custody. Date: O- l0? Respectfully submitted, MIDPENN LEGAL SERVICES r. leis, Esquire for Plaintiff Attorfey ID No. 310094 401 E. Louther Street, Suite 103 Carlisle, PA 17013 (717) 243-9400 A .,- VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the attached Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. JL -IdaLn- /J c"A°? G a J I an Ibrahim JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2004-3818 CIVIL ACTION - LAW TIMOTHY SCOTT DISBROW, : Defendant : IN CUSTODY r -r x r cnr ?rti; -C tn ORDER OF COURT <cc AND NOW, this day fWnciliation 2011, uon ':O consideration of the attached Custody Report, it is ordered and directed as follows: 1. The prior Orders of Court dated May 4, 2011 and May 11, 2011 shall remain in full force and effect with the following modification. 2. Once the Safety Plan is lifted by Cumberland County Children & Yquth Services, the parties shall revert to the physical custody schedule for Mother as listed in the Order of Court dated May 4, 2011. 3. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence bf mutual consent, the terms of this Order shall control. BY TH T, J. dNathan C. Wolf, Esquire, Counsel for Father 7Jehan Samir Disbrow, pro se 1404 Bradley Dr. B-112 Carlisle, PA 17013 CppiP.s ?i?a C?-51kbd 14 3 ARAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2004-3818 CIVIL ACTION - L c, n "h TIMOTHY SCOTT DISBROW, rn -n Defendant : IN CUSTODY z -.c M -or,; <a a -Co ORDER OF COURT N AND NOW, this CeA day of #142- , 2011, upon ', consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated March 19, 2009 shall remain in full force and effect with the following modifications. 2. Father shall have primary physical custody of the child. 3. Mother shall have the following periods of partial physical custody:' A. During the school year: 1. Alternating Mondays and Thursdays from 5:00 p.m. to 8:QQ p.m. 2. Alternating Saturdays and Sundays from 12:00 noon to 7:,00 p.m. 3. Such other times as the parties agree. B. During the summer or school breaks: 1. Alternating Mondays and Thursdays from 10:00 a.m. to :00 P.M. 2. Alternating Saturdays and Sundays from 12:00 noon to 700 p.m. 3. Such other times as the parties agree. 4. 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. ?mother Conciliation Conference is scheduled for June 14, 2011 at 8:30 a.m. BY COURT, J. 4 11 SERVICE PLAN Parents, guardians, custodians and children have the right to participate in the development of this plan; however, if you disagree with this plan you are not required to sign and have the right to appeal. ! Parents, guardians and custodians must notify the county agency within 24 hours when the child or family moves from one residence to another. Please notify the agency if you require accommodations to participate in the development of the plan as required I by the Americans with Disabilities Act. This plan will be provided in alternate format upon request. i r-- Case Name: Ibrahim County: Cumberland Case Number: 1735 Date of Initial/Revised Plan: 01/11/2012 Date Accepted for Service: 03/31/0011 FV7 Revised Plan ? Initial Service Plan Date of Next Plan Review: 06!30/2012 INITIAL ST_RENGTHS:_ -The family is utilizing community resources -There are family supports available for the family -The family is cooperative -Mother is in Drug/Alcoholtreatment - Discovery House -The children's needs are being met STRENGTHS IDENTIFIED DURING REVIEW: - The family is cooperative and willing to work on their issues - The family utilizes community resources _ There continues to be family supports available for the children _ The children's needs are being met Mother continues to work on her D&A treatment at Discovery House and is progressing - Mother attends HACC for Dental Assistant Mother is currently working part-time at the House of Cards - Damian was closed out on 8/17/11 and living with his biological father - Jayden was enrolled in Headstart Services 7/22/11 - Jayden has been back in her mother's home unsupervised since the beginning of October, 2011 "' Etib;?c Date of Initial/Revised Plan: Case Number: Family Name: 01/11/2012 1735 Ibrahim INITIAL REASON ACCEPTED FOR SERVICE: - Describe the initial situation(s) and the causes of the situation(s): On 3/3/11 the RS was called to the home by the MGM, Josetta Ibrahim, at which time there were reports and evidence of herion use in the home, multiple people in the home, and the home was very dirty. RS made arrangements for MGM to take the children for tonight. The current situation is that Damian was closed out on 8/17/11 and continues to live with his biological father. Jayden was returned to her mother without supervision 10/1111 - Effects on identified individual (s): In recent home visits it appears that Jayden continues to be the happy-go-lucky little girl when first met. She is enrolled in Headstart. The house is clean, mother is working part-time ano going to ritAi u Tor a aegree Ir1 UVIR41 r+ssaaa+u. 011a 4VIS.IVIUV. tv - ' v-- ,,, her treatment at the Discovery House for Methodone. Mother continues to have scheduled visitation with her son Damien; and only wishes to have him back with her. Concerns: Currently the only concern is if Jehan would relapse; however, presently she is always available for random drag testing and is very consistent with her treatment. Initial level of risk on: 03/31/2011 was: ? High ?X Moderate ? Low ? No REASON FOR REVISION: Describe the current situation(s) and the causes of the situation: There is a FSPR scheduled for 1/18/12 and Caseworker Seely will be advocating for case closure. Initially the case was open due to evidence of heroin use in the mother's home and the children were removed. Jayden went with the MGM, Josetta Ibrahim and the biological father, Scott Disbrow took his song Damien'. Currently Damien is closed out and continues to live with the father and Jayden is now back with the mother since 10/1/11. Effects on identified individual (s): Mother continues to comply with services. Mother is thrilled that she now has her daughter back in her home and only wishes she had her son back; however, he continues to reside with his biological father. Jehan does not think she has enough time with her son and misses him very much. Concerns: The only concern is if Jehan would relapse. Current level of risk on: 01/11/2012 was: - ------------------------------------- ? High ?? 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N y co O O A m 3 n Ws ?_amr H W = N < N m a? m v m 3 ? 'Z M X °a3 O S ? `o CD S mNw Fro 0 f 0 0 o O y ?v CD 3 m L :3 y ? O ? N 3 N 3 M' r a 0y? ?M? 1 m o L W N m x s m m 0) M < W d d n rn r c s n m p3j C S D1 r y 3 D Z Z `? N 3 D (D Z 0 C T Ul '? fo Z w 0) t o 7 O C D1 0 y o co ° ?' s M C ? 3 o Z M . 01. vc D m c CL ;o o C o m w = H n to Z O f0 T ''. S M C (D @ . v ,. m fn cn O W ID n C +n fD N [ tt T C o of m N K w o Z V 7 C --1 to rn p 0 m o 4 Op °' _ -i m W CL y ? V 3 a 3 ?t N < ? I? m a 0 v CD ? v Cr C O m a S m o Q D ? ? N N d 3 ? O t0 O r•? < 01 co CD N O/ a a ,. m 33 d IO O o p = Z a a co CD ?. 3 C M m 0 (?D O O ? O O C ? ma S = V S 0 Z •°' Oa CD o 0 o? m N m a d 7 O N O N n 0 tl1 m z C O J W U1 T 3 Z m c s I n 0 -= A"riff THE CENTER FOR RECOVERY 6 HOPE 3/19/12 To whom this may concern, This is to inform you that Jehan Ibrahim is a patient at Discovery House in Harrisburg, PA which is a methadone clinic. Jehan has been in treatment here since Marh 11 th, 2011. Throughout the course of one month, Jehan is responsible for attending two and a half hours of counseling and/or group sessions, to which she spends most of her time attending individual counseling with her primary counselor. She has made progress in her treatment, and has been given privileges of having more freedom which allows her to also take care of and focus her time on other responsibilities in her life. She is',only required to come to the clinic several days per week instead of everyday. Jehan is continuing to;work with the treatment team at Discovery House toward her goals, and has shown great improvement both within her treatment as well as within herself over the past year that!I have been working with her. Jehan poses no risk to her children and provides a safe and stable environment for the both of them. She is capable of caring for her children and is not a danger to them in any way. Sin erely, Danielle Schultz, BA Counselor Discovery House 99 South Cameron Street Harrisburg, PA 17101 (717) 233-7290x802116 Our Mission To provide comprehensive 5ervica5 for persons affected by addiction through community awareness, duality and holistic Clinical 5ervicc5 Commission on Accreditation of Rehabilitation Facilities in an efficient, Safe, and fiocally'sound environment. /41.4 -b ,99 South Cameron 5treet Harrisburg, PA 17101 717-233-72P0 • Fax: 717-233-5334 1-abb-POORWAY 0 www.discoveryhouce.com w? U'l`'i JCS (T TILL' FROT(fjNur %; `r JEHAN SAMIR DISBROW,2 # 2 I??:?R2 1 PM : IE COURT OF COMMON PLEAS OF (now Jehan Samir Ibrahim) : CUMBERLAND COUNTY PENNSYLVANIA Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. : NO. 2004-3818 CIVIL ACTION-LAW TIMOTHY SCOTT DISBROW, Defendant : IN CUSTODY PETITION FOR SPECIAL RELIEF Petitioner, Jehan Ibrahim, by and through her counsel, MidPenn Legal Services, files this Petition for Special Relief seeking this Honorable Court's permission to take her minor child Damio Disbrow on vacation to Disney World from April 6, 2012, until April 15, 2012, and states the following: 1. Petitioner is the above-named Plaintiff, hereinafter referred to as Mother, who resides at 1404 Bradley Drive, Apt. B-112, Carlisle, Cumberland County, Pennsylvania 17013. 2. Respondent is the above-named Defendant, hereinafter referred to as Father, who resides at 461 Petersburg Road, Carlisle, Cumberland County, Pennsylvania 17015. 3. On May 11, 2011, and June 15, 2011, the Honorable Edward E. Guido entered custody orders for the parties' minor child, Damian Fredrick Disbrow, born January 1, 2001. A correct copy of those orders are attached as Exhibit A & B. The orders in pertinent part grant the parties shared legal custody, Father primary custody, and Mother partial physical custody. 4. Mother and her immediate and extended family have scheduled a vacation to Kissimmee, Florida, from April 6, 2012, through April 15, 2012. Mother has sought permission from Father to take minor child on this vacation and Father has denied permission. 5. Mother believes that it is in Damian's best interest to participate in this family vacation because Damian deserves to share this once in a lifetime family vacation with his four year old sister Jayden, and Damian will be able to meet his extended overseas family (aunts, uncles, and cousins from Egypt). 6. Damian maternal grandparents, Samir and Josetta Ibrahim, have rented a five bedroom, 4 %2 bath house in the gated community of Windsor Hills. This home includes a game room and privatepool. The address for this home is 2698 Manesty Lane, Kissimmee, Florida, 34747. A copy of the rental agreement and pictures of the home are attached as Exhibits C-J. 7. The extended family has rented two additional homes in this gated community, where they will stay during this vacation. 8. During this vacation, family will visit multiple amusement parks, including Disney World, Epcot Center, Island of Adventure, and The Wild Kingdom. Mother believes that Damian will enjoy visiting these parks. 9. Mother has two recent criminal convictions. Mother pled nolo contendere to endangering the welfare of children on November 14, 2011, for which she was sentenced on January 31, 2012, to three (3) years of probation. On January 11, 2012, Mother pled guilty to a related charge at a separate docket for use and/or possession of drug paraphernalia. Mother was sentenced on March 20, 2012, to additional probation. The Honorable Edward E. Guido presided over Mother's criminal cases. 10. Cumberland County Children and Youth closed its case with Mother in January 2012, after working with Mother for eleven months and Mother completing the requirements of the CYS Service plan. On January 31, 2012, CYS completed its final evaluation on Mother and assessed that Mother was a low safety risk to her children. A copy of this final service plan is attached as Exhibit K. A copy of CYS closing letter is attached as Exhibit L. 11. Mother has been in drug rehabilitation counseling for one year at Discovery House. Mother's counselor Danielle Schultz has assessed that Mother does not pose a risk to her children. A copy of the counselor's evaluation is attached as Exhibit M. 12. This vacation would result in Damian missing four days of school. Damian's school policy allows children to miss up to five days for vacations. A copy of the South Middleton School District's Parent Request Form is attached as Exhibit N. WHEREFORE, Mother respectfully requests this Court to hold a hearing to determine whether Mother may take minor child Damian Disbrow to Florida, from April 6, 2012 until April 15, 2012. Date: Respectfully Submitted, MIDP LEGAL ERVICES By: Amy H' s, Esquire Attorn or Defendant Supreme Ct. ID No. 310094 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the attached Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: ,3/o?O?o2D< a J a Ibrahim 3 JEHAN SAMIIR DISBROW, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2004-3818 CIVIL ACTION - LAW TIMOTHY SCOTT DISBROW, _, Defendant : IN CUSTODY r n CD fi ?x 2 r= ? ROF COURT OR RDDE < c , r c-; z ?c. =, thi da o AND NOW 2011 6n'? ? .x ? y , s , u ? , . consideration of the attached Custody nciliation Report, it is ordered and directed as", follows: 1. The prior Orders of Court dated May 4, 2011 and May 11, 2011 shall remain in full force and effect with the following modification. 2. Once the Safety Plan is lifted by Cumberland County Children & Youth Services, the parties shall revert to the physical custody schedule for Mother as listed in the Order of Court dated May 4, 2011. 3. This Order is entered pursuant to 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 TH T, J. d- Nathan C. Wolf, Esquire, Counsel for Father t&ikd Jehan Samir Disbrow, pro se ?N'iCs 1404 Bradley Dr. B-112 Carlisle, PA 17013 3 JEE AN SAIVIIR DISBROW, : IN THE COURT OF COMMON PLEAS OF Pidatiff : CUMBERLAND COUNTY, PENNSYLVANIA s V. : NO. 2004-3818 CIVIL ACTION - - =rn TIMOTHY SCOTT DISBROW, : ,r- > _ Defendant : IN CUSTODY r- N ORDER OF COURT AND NOW, this E day of 2011, upon consideration of the attached Custody Conciliatio eport, it is ordered and directed as follows: 1. The prior Order of Court dated May 4, 2011 shall remain in full force and effect with the following modifications. 2. Mother shall have supervised visitation consistent with the safety plan of Cumberland County Children & Youth at the times designated in the Order of Court dated May, 2011. The supervisor shall be maternal grandmother, Josetta Ibrahim. 3. This Order is entered pursuant to a Custody Conciliation Conference. The parties mar modify the provisions of this Order by mutual consent. In the absence of mutual eongent, the terms of this Order shall control. Another Conciliation Conference is scheduled for June 14, 2011 at 8:30 a.m. B E COURT, J. N ,./cc: Nathan C. Wolf, Esquire, Counsel for Father Jehan Samir Disbrow, pro se 1404 Bradley Dr. B-112 S?j?l! Carlisle, PA 17013 p C:) n -+ x rn? ?m C 3 c-) `:1 rri :n villa Thank you for booking a VillaDirect vacation property. Please complete this form and read the berms and conditions as provided on the websitee at http://www.Yilladirect.com/terms.oho. once complete, please sign and send this form to the address shown below. This form comprises both your rental agreement, and acceptance of the terms and conditions. Party Leader details M. Jsetta Ibrahim 1888 Douglas Drive Carlisle PA 17013 Reservation details Check-in date: 04/07/12 Check-out daft: 04/14/12 Nights: 7 At or after 4:00pm At or before 10:00am Booking date: 03/01/12 717-226-1073 House booked: Villa del Sol Guest ID.4MNlM Bedrooms: 5 Badwooms: 3.5 Max occupancy: 10 Guests Guest occupation (please confirm the number of adults and children in your party) Property maximum occupancy # of adults in party # of children in party Total # in party 10 9 I understand that the property has a maximum capacity and the above accurately reflects the number of adults and children that will be occupying the property. I acknowledge that all VibDkect properties are NON SMOKING alt NO PEErSS and any costs for damages or extra cleaning due to smoke or pets will be charged to the credit card on file for the reservation. Damages or cleaning from smoking or pets are specifically not covered by the accidental damage waiver and I authorize any damages tD be charged to the credit card on file. Please check to confirm that the figures in the table alorgNdis match the rental costs that were agreed. If there is any discrepancy, please contact our office on: Phone: 1(407) 397-9818 Email: auestserviees®villadirect.com Fax: 1(407) 397-2823 Address: VillaD ect Management LLC 8132 West Irlo Bronson Hwy Kissimmee, Fl- 34747 Reservation number: 112550 In US Dollars ($) Rental-Villa del Sol $2,500.40 Guest Departure Clean $133.00 Processing Fee $45.00 Electric Pool Heat $245.00 Accidental Damage Waiver $75.00 Sales and resort tax $389.79 Amount PAID $3,388.19 balance due $0.00 I the undersigned, agree that I have read and accept the terms and conditions of rental displayed on the website at htti2://www,villadir=.com/terms.php, and will abide by the terms therein. By signing I also authorize VdlaDirect to charge the credit card on file automatically when final payment is due. I agree that any costs arising from non-accidental loss or damage to the property or ice' inventory wilt be my responsibility. I father agree that, where the damage caused exceeds the waiver coverage paid, the Company will be entitled to receive recompense for loss or damages to the value of said loss or damage and I authorize VdiaDirect to charge the credit card on file for those casts. PLEASE RETURN THI5 RENTAL AGREEMENT WITHIN 3 DAYS BY EMAIL, MAIL OR FAX TO VtlaDirect Management LLC. villa Guest details: M. Josetta Ibrahim 1888 Douglas Drive Carlisle, 17013 PA, USA Property Name: Villa del Sol Reservation charges: Reservation details: (IBRA003) Reservation numMrqo Arrival date: 04/07/12 Departure date: 04/14112 Nights: 7 Adults: 7 Statement of Account Date: Thursday, March 01, 2012 so Check in after 4:00pm Check out before 10:00 am Booking Date: 03101/12 Children: 2 Property Code: MNL2700A Charged Paid Balance Base rental $2,500.40 Accidental damage waiver (ADW) $75.00 Guest Departure Clean $133.00 Processing Fee $45.00 Electric Pool Heat $245.00 Tax $389.79 Tonal: $3,388.19 Payments: 03/01/12 Visa VSYE8CD45F46 $3,388.19 Thal: ;3,388.19 Balance outE landi Credit : 0.00 A'_ ??.. °?=?. s i +? }; ?, ?. I' r t 't 4 »uF. x i ?l ?f ?t f A f "Now ? t ,... is ? .. IMM -y s i ?1? qq ?r OL C,1 V !1 NOW j ¢ 447 r y r`. .:r 4?Y t 11 'tea iar, - .. y, j. . Isl. ? ., C`54Y.•. Via _t w a. _ x -..-. - V `, 1 s " -rte rte. w.. t k - ' J4MSr - t *A% 044 l _ Yx 'b!sif, k SERVICE PLAN Parents, guardians, custodians and children have the right to participate in the development of this plan; however, if you disagree with this plan you are not required to sign and have the right to appeal. Parents, guardians and custodians must notify the county agency within 24 hours when the child or family moves from one residence to another. Please notify the agency if you require accommodations to participate in the development of the plan as required by the Americans with Disabilities Act. This plan will be provided in alternate format upon request. Case Name: Ibrahim County: Cumberland Case Number: 1735 Date of Initial/Revised Plan: 01/11/2012 Date Accepted for Service: 03/31/0011 Initial Service Plan Revised Plan Date of Next Plan Review: 06/30/2012 INITIAL STRENGTHS:-- -The family is utilizing community resources -There are family supports available for the family -The family is cooperative -Mother is in Drug/Alcoholtreatment - Discovery House -The children's needs are being met STRENGTHS IDENTIFIED DURING REVIEW: - The family is cooperative and willing to work on their issues - The family utilizes community resources _ There continues to be family supports available for the children _ The children's needs are being met Mother continues to work on her D&A treatment at Discovery House and is progressing - Mother attends HACC for Dental Assistant - Mother is currently working part-time at the House of Cards - Damian was closed out on 8/17/11 and living with his biological father Jayden was enrolled in Headstart Services 7/22/11 - Ja den has been back in her mother's home unsupervised since the beginning of October, 2011 A-1 K_ Date of Initial/Revised Plan: Case Number: 01/11/2012 1735 i Family Name: Ibrahim INITIAL REASON ACCEPTED FOR SERVICE: Describe the initial situation(s) and the causes of the situation(s): On 3/3/11 the RS was called to the home by the MGM, Josetta Ibrahim, at which time there were reports and evidence of herion use in the home, multiple people in the home, and the home was very dirty. RS made arrangements for MGM to take the children for tonight. The current situation is that Damian was closed out on 8117/11 and continues to live with his biological father. Jayden was returned to Effects on identified individual (s): In recent home visits it appears that Jayden continues to be the happy-go-lucky little girl when first met. She is enrolled in Headstart. I mother is working part-time and going to HACC for a degree in Dental Assistant. She continues to be involved in l i ean, s c The house her treatment at the Discovery House for Methodone. Mother continues to he" scheduled visitation with her son Damien; and only wishes to have him back with her. Concerns: Currently the only concern is if Jehan would relapse; however, presently she is always available for random drug testing and is very consistent with her treatment. Initial level of risk on: 03/31/2011 was: -I High XD Moderate F-] Low ? No REASON FOR REVISION: Describe the current situation(s) and the causes of the situation: There is a FSPR scheduled for 1/18/12 and Caseworker Seely will be advocating for case closure. Initially the case was open due to evidence of heroin use in the mother's home and the children were removed. Jayden went with the MGM, Josetta Ibrahim and the biological father, Scott Disbrow took his son, Damien. Currently Damien is closed out and continues to live with the father and Jayden is now back with the mother since 10/1/11. Effects on identified individual (s): Mother continues to comply with services. Mother is thrilled that she now has her daughter back in her home and only wishes she had her son back; however, he continues to reside with his biological father. Jehan does not think she has enough time with her son and misses him very much. Concerns: The only concern is if Jehan would relapse. 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CD CA m 0 C sn N O G m s CL C C i 3 O f H C Co y • C 7 ? ? A CD 7 CD H c 2 m C-- C m a d 01 t O y i ac fD a cD CL0 CA m y a ' • I a . I Cv CQ CD C11 CL 2. CD 3 C Q CD Co CD 7 S CD m ? C 0 CO m o n M r CD 0) A Q M 3 m Z w ;o CO) Z C m A 5 CA CL X CO) D Z N o o _ N T O CD CD 1 m O 3 S 0 m CA CD Z C 3 J C try -4 1 co m J ? C W cn co .9 O f:J S 0 M m A J N m T 3 N cim N -U7 O O N O j m < - a O. m 0 ? = A d (p A 00 Q m O -? \ ? A Q O O C CP ? J m m m c m z c °a °, CUMBERLAND COUNTY CHILDREN AND YOUTH SERVICES _ Protecting Children - Preserving Families - Promoting Well-being Human Services Building, 16 West High Street, Suite 200, Carlisle, PA 17013-2961 Telephone: 1-888-697-0371, Extension 6120 Fax: (717) 240-6433 Email: CCCY@ccpa.net January 26, 2012 Jehan Ibrahim 1404 Bradley Dr. Apt.B 112 Carlisle, PA 17013 RE: Jayden Leach Dear Ms. Ibrahim, The purpose of this letter is to inform you that effective this date Cumberland County Children and Youth Services has closed your case. The decision was made to close your case due to your compliance with the FSP (Family Service Plan) and recommendations of this Agency as well as the Discovery House. As you are aware, your case was opened in March, 2011, due to your substance abuse and your conduct that placed your children at risk. I am pleased that you, with the support of your family, got the help you needed. You have shown so much improvement by consistently testing negative for any substance abuse and getting your life back together. I believe you really wanted to change, and you proved that by diligently working to get your daughter back in your home, enrolling at HACC for classes to become a Dental Hygienist and finding a part-time job. You also followed through with services for your daughter who now attends Headstart. Keep up the good work Jehan and never lose the faith that has brought you this far. Call me with any questions, and I wish you all the luck in your future. It was a pleasure working with you and your family. Sincerely, X- ?0- B onnie Seely Cumberland County Children and Youth Services Caseworker cc: File Li , ( I " Ki -9 -=.. A" riff THE CENTER FOR RECOVERY 6 HOPE 3/19/12 To whom this may concern, This is to inform you that Jehan Ibrahim is a patient at Discovery House in Harrisburg, PA which is a methadone clinic. Jehan has been in treatment here since Marh 11 th, 2011. Throughout the course of one month, Jehan is responsible for attending two and a half hours of counseling and/or group sessions, to which she spends most of her time attending individual counseling with her primary counselor. She has made progress in her treatment, and has been given privileges of having more freedom which allows her to also take care of and focus her time on other responsibilities in her life. She is only required to come to the clinic several days per week instead of everyday. Jehan is continuing to work with the treatment team at Discovery House toward her goals, and has shown great improvement both within her treatment as well as within herself over the past year that !I have been working with her. Jehan poses no risk to her children and provides a safe and stable environment for the both of them. She is capable of caring for her children and is not a danger to them in any way. Sin?erely, sue,-?C??'L?? ? (%'""` ?^I ??,>• Danielle Schultz, BA Counselor Discovery House 99 South Cameron Street Harrisburg, PA 17101 (717) 233-7290x802116 Our Mission To provide comprehensive services for persons affected by addiction through community awareness, duality and holistic clinical services in an efficient, safe, and fiscally Sound environment. r Commission on Accreditation of Rehabilitation Facilities m 99 5outh Cameron Street Harrisburg, PA 17101 717-233-7290 • Fax: 717-233-5334 1-888-00ORWAY • www.ii5roveryhouse.com y l $ b 4 Forge Road Boiling Springs, PA 17007 PARENT REQUEST FORM - EDUCATIONAL TRIP Permission is requested for the pupil(s) listed below to be granted excused absence from school to participate in an educational trip. All pupils and all schools, if several are involved, must be listed The following information related to the planned trip. 1. Pupil(s) Name Grade H.R. # 1 3. Ii. Dates of Absence from School: III. Trip Itinerary: W. What is the nature of the educational experience provided by this trip? V. Who willi be accompanying the pupil(s)? VI. Is this a trip new to the student(s) or will it be a repeat of a previous trip? *************************************OFFICE USE ONLY****************************** Total Educational Days taken before this request: Approved: Yes No # Days Excused # Days Unexcused Administrator's Signature REASON: NOTE: A student will be permitted to take up to five (5) school days per school year (maximum of two (2) trips) per school year. All days beyond five will be recorded as unexcused. Iron Forge Educational Center 717-258-6484 4 Forge Road Boiling Springs, PA 17007 JEHAN SAMIR ]BRAHIM, : IN THE COURT OF COMMON PLEAS OF (formerly Jehan Samir Disbrow) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. :NO. 2004-381$ CIVIL ACTION-LAW TIMOTHY SCOTT DISBROW _QZ , a Defendant rr? CO : IN CUSTODY a . ° ? r ..? 1> N rr C, zi? PRAECIPE TO PROCEED IN FORMA PAUPERIS -=' 'N' To the Prothonotary: Kindly allow Jehan Ibrahim, Petitioner, to proceed in forma au eris. I, Amy Hirakis, Esquire, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Respectfully submitted, MIDPENN LEGAL SERVICES Date: 3 - ?? Amy Hs, Esquire Attorn y or Plaintiff Attorney ID No. 310094 401 E. Louther Street, Suite 103 Carlisle, PA 17013 (717) 243-9400 JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF (now Jehan Samir Ibrahim) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO. 2004-3819 CIVIL ACTION-LAW TIMOTHY SCOTT DISBROW, F Defendant : IN CUSTODY -oz ;z Z -1D cn t" zo NJ 'X7 r* :71 ? PRAECIPE FOR ENTRY OF APPEARANCE ?- . ? a C'") jr _ TO THE PROTHONOTARY: Please enter my appearance on behalf of the Plaintiff Jehan Ibrahim in the above matter. DATE: March 21, 2012 Ztt y Hir , Esquire orn Or Plaintiff Supre Ct. ID # 310094 401 E. Louther Street, Ste 103 Carlisle, PA 17013 (717)243-9400 JEHAN SAMIR DISBROW, (now Jehan Samir Ibrahim) Plaintiff V. TIMOTHY SCOTT DISBROW, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. 2004-381$ CIVIL ACTION-LAW IN CUSTODY -C' :7-T ) °. CERTIFICATE OF SERVICE` = oaf ,. I, Amy Hirakis, Esquire, of MidPenn Legal Services, attorney for the Plaintiff Jehan Ibrahim, hereby certify that I have served a copy of the Praecipe for Entry of Appearance, Petition for Modification, and Petition for Special Relief on the following date and in the manner indicated below: U.S. First Class Mail, Postage Pre-Paid Nathan Wolf, Esquire 10 West High Street Carlisle, PA 17013 MIDPENN LEGAL SERVICES Date: ?3-a1-?? 7Cmy rq?or s, Esquire Atto Plaintiff Atto ey ID No. 310094 401 E. Louther Street, Suite 103 Carlisle, PA 17013 (717) 243-9400 JEHAN SAMIR DISBROW, : IN THE COURT OF COMMON PLEAS OF (now Jehan Samir Ibrahim) : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2004-3818 CIVIL ACTION-LAW V. TIMOTHY SCOTT DISBROW, CUSTODY Defendant ORDER OF COURT NOW, this A r day of March 2012, upon consideration of the Petition For Special AND Relief, a hearing is scheduled for , 2012, at l/• Od/o determine ? whether Plaintiff"Jehan Ibrahim shou be grante rmission to take minor child Damion Disbrow on vacation to Florida from April 7, 2012 until April 15, 2012. e Court, Judge Distribution: = -- - + Amy Hirakis, Esquire ; ? MidPenn Legal Services a 401 E. Louther Street, Ste 103 Carlisle, PA 17013 , N '? r-i =a ? V Nathan Wolf, Esquire 10 West High Street Carlisle, PA 17013 (o f , eS t na d ed ?L JEHAN SAMIR DISBROW r ) IN THE COURT OF COMMON PLEAS C? rv r:> y' _, PLAINTIFF r"Cu 14P CUMBERLAND COUNTY, PENNSYLV 3'. XX- ;;a -0 rT, V. 2004-3818 CIVIL ACTION LAW} } TIMOTHY SCOTT DISBROW ca IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, _ Monday, March 26, 2012 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator, at _ MDJ_ Office, 1901 State St., Camp Hill, PA 17011 on Friday, May 04, 2012 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Melissa P. Greets Esq. t y? Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites "Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. copy V,?, Pew? 6V y dsr?pw wo r? ?v Cir°E vy- col' fr (91 /7r/ i Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 (phcr 1?c?7D-f JEHAN SAMIR DISBROW, IN THE COURT OF COMMON PLEAS OF (Now Jahan Samir Ibrahim): CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Petitioner V. TIMOTHY SCOTT DISBROW, Defendant/Respondent NO. 2004-3818 CIVIL TERM IN CUSTODY IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 2nd day of April, 2012, after hearing, the Petition For Special Relief is granted. Mother is granted temporary custody of the child, Damion Disbrow, from 5:00 p.m. on Thursday, April 5, 2012, until 5:00 p.m. on Sunday, April 15, 2012, so that the child may accompany her on a family vacation to Florida. By the Court, Edward E. Guido, J. ? Amy Hirakis, Esquire MidPenn Legal Services For the Petitioner Nathan C. Wolf, Esquire Wolf & Wof For the Respondent Sheriff t - -?? ...b. Z . _., ,F srs ell C 3 JEHAN SAMIR DISBROW, IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 04-3818 CIVIL TERM V. CIVIL ACTION - LAW TIMOTHY SCOTT DISBROW, IN CUSTODY Defendant ORDER OF COURT AND NOW, this P3 day of May, 2012, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. This Order vacates and replaces all prior Orders entered in this matter. 2. LEI Custody. The parties, Jehan Samir Disbrow and Timothy Scott Disbrow, shall have shared legal custody of the minor child, Damian Frederick Disbrow, born January 1, 2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa. C. S. §5336, each parent shall be entitled' to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. School Year Physical Custody. Father shall have primary physical custody subject to Mother's rights of partial custody, which shall be arranged as follows: A. Commencing May 10, 2012, on alternating Thursdays from 4:30 p.m. until 8:30 p.m. B. Commencing May 14, 2012, on alternating Mondays from 4:30 p.m. until 8:30 p.m. C. Commencing on May 19, 2012, on alternating weekends from Saturday at 9:00 a.m. until Sunday at 7:00 p.m. and on June 2, 2012 through June 3, 2012 from Saturday at 9:00 a.m. until Sunday at 7:00 p.m. D. Commencing with Mother's first weekend period of custody following the commencement of the 2012/2013 school year, Mother's weekend custodial time shall begin at 4:30 p.m. on Friday and end at 7:00 p.m. on Sunday. NO. 04-3818 CIVIL TERM 4. Summer Physical Custody. Father shall have primary physical custody in the summer, subject to Mother's rights of partial custody, which shall be arranged as follows: A. Commencing June 6, 2012, on alternating weeks from Wednesday at 8:30 a.m. until Thursday at 7:00 p.m. B. Commencing June 25, 2012, on alternating Mondays from 8:30 a.m. until Tuesday at 7:00 p.m. C. On alternating weekends, commencing June 29, 2012 from Friday at noon until Sunday at 7:00 p.m. 5. Fathers' Day and Mother's Day 2012. Mother will have custody for Mother's Day from 9:00 a.m. to 7:00 p.m. Father will have custody for Father's Day from 9:00 a.m. to 7:00 p.m. 6. VAcation. Each parent will be entitled to up to two nonconsecutive weeks of custodial time for purposes of summer vacation. The parties will provide each other with 30 days written notice of their intended vacation plans for the purpose of avoiding any scheduling conflicts. In the event that a scheduling conflict arises, the parent first providing written notice to the other shall have choice of vacation time. A. Father shall have custody for purposes of vacation from June 9, 2012 through June 16, 2012. 7. Within five (5) business of the entry of this Order, Mother shall sign authorizations for the release of random drug testing reports performed' by any treatment facility where she is in care, including but not limited to, Discovery House, providing that the report be released to her probation officer, Nicole Gutshall. Upon random drug testing, any negative reports shall be reported to Attorney Nathan Wolf, counsel for Father. Any positive reports of random drug testing shall first be reported to the Custody Court Judge in this matter prior to release to counsel for Father. Mother shall also sign an authorization allowing for the release of any random drug testing reports be released to counsel for Father. 8. The parent receiving custody shall provide transportation incident to the custodial exchange. 9. The holiday schedule attached as Exhibit "A" shall supercede the regular schedule and the vacation schedule. NO. 04-3818 CIVIL TERM 10. Neither party shall have the child miss more than two and a half days of schools for purposes of educational leave time per academic year. BY 2;;W1 Edward E. Guido, J. Dist: Amy Hirakis, Esquire, MidPenn Legal Services 401 E. Louther Street Suite 103, Carlisle, PA 1 ?813 t/ Nathan C. Wolf, Esquire, 10 west High Street, Carlisle, PA 17013 -0 C /Nicole Gutshall, Cumberland County Probation, 4 East Liberty Avenue, Carlisle, PA 17013 r;iw =c Z M 3W es ,fed 0, L --c rill- Pp w x 0 3 ?C-- G7 JEHAN SAMIR DISBROW, Plaintiff v. TIMOTHY SCOTT DISBROW, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3818 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the child who is the subject of this litigation is as follows: MAKE DATE OF BIRTH Damian Frederick Disbrow January 1, 2001 CURRENTLY IN THE CUSMDY OF Father 2. Mother filed a Petition to Modify Custody on March 21, 2012. A Custody Conciliation Conference was held on May 4, 2012. Present for the conference were: the Mother, Jehan Samir Disbrow, and her counsel, Amy Hirakis, Esquire; the Father, Timothy Scott Disbrow, and his counsel, Nathan C. Wolf, Esquire. 3. The parties reached an agreement in the ?- L te an Order as attached. elissa Peel Greevy, Custody Conciliator :496078 EXHIBIT "A" The following holiday schedule shall supersede the regular schedule: A. Child' Birthday. The parties will share time with the child on his birthday (January 18) each year. B. h ' tmas. Christmas shall be divided into two segments, Segment A and Segment B. Segment A shall be from December 24th at Noon until December 25 at 3:00 p.m. Segment B shall be from December 25th at 3:00 p.m. until December 26th at 3:00 p.m. In even-numbered years, Father shall have Segment A and Mother shall have Segment B. In odd-numbered years, Mother shall have Segment A and Father shall have Segment B. C. Alternating Holidays. The parties will alternate the following holidays: Easter, Memorial Day, Labor Day and Thanksgiving. The custodial period for these holidays shall be from 6:00 p.m. the day before the holiday until 6:00 p.m. the day of the holiday. D. Mother's Day / Father's Day. Mother will have custody for Mother's Day and Father will have custody for Father's Day. The custodial period for these holidays shall be from 6:00 p.m. the day before the holiday until 7:00 p.m. the day of the holiday. E. Ramadan. Mother shall be entitled to have custodial periods on the first and last days of Ramadan. The first day of fasting for Ramadan 2012 is expected to be July 21, 2012. Therefore, Mother will have custody of the child for the first day of Ramadan 4:00 p.m. to 8:00 p.m. On the last day of Ramadan when the ending of fasting is celebrated by feast, Mother shall have custody for this holiday from 4:00 p.m. to 8:00 p.m.