HomeMy WebLinkAbout01-3299LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 01 - 3..x.99 CIVIL TERM
: CIVIL ACTION -LAW
GERALD W. JONES,
Defendants : IN CUSTODY
PETITION FOR CUSTODY
COMES NOW, Plaintiff, Lorrie Ann Jones, by and through her attorney, James J. Kayer, Esquire
and avers as follows:
1. Plaintiff is Lome A. Jones, adult individual, residing at, 408 Walnut Street Unit B, Boiling
Springs, Cumberland County, Pennsylvania 17007.
2. Defendant Gerald W. Jones, an adult individual whose current address is 38 Carlton Avenue,
Carlisle, Cumberland County, PA, 17013.
3. Plaintiff seeks custody of the following children:
Name
Present Residence
Age
Tiffany Nicole Jones, 408 Walnut Street Unit B, Boiling Springs, PA, born June 18, 1988, 12 years old.
Megan Rebecca Jones, 408 Walnut Street Unit B, Boiling Springs, PA, born June 14, 1992, 8 years old.
The children were born in wedlock.
The children are presently in the custody of the Plaintiff.
During the past five years, the children have resided with the following person(s) at the below
address(es):
Birth until April, 2001; With mother, Lorrie Ann Jones and father, Gerald W. Jones at 38 Carlton Avenue,
Carlisle, Cumberland County, PA.
April 2001 until present; With mother Lorrie Ann Jones at 408 Walnut Street Unit B, Boiling Springs,
Cumberland County, PA.
4. The mother of the children is Lorrie Ann Jones, an adult individual whose current address is
408 Walnut Street Unit B, Boiling Springs, PA
5. The father of the children is Gerald W. Jones, an adult individual, whose current address is
38 Carlton Avenue, Carlisle, PA.
6. The relationship of Plaintiff to the children is that of the mother. The Plaintiff currently
resides with the children and the following person(s):
Name
No one.
Relationship
The relationship of the defendant to the children is that of father.
7. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation
concerning the custody of the children in this or another court. Plaintiff has no information of a custody
proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of
a person not a party to the proceedings who has physical custody of the children or claims to have custody
or visitation rights with respect to the children.
8. The best interest and permanent welfare of the children will be served by granting primary
physical custody of the children to the Plaintiff. Prior to the parties' separation, the Plaintiff served as the
children's' primary care giver. Since the separation the children have resided with the Plaintiff and this
pattern has continued.
9. Each parent whose parental rights to the children has not been terminated and the person who
has physical custody of the children have been named as parties to this action. All other persons, names
below, who are known to have or claim a right to custody or visitation of the children will be given notice
of the pendency of this action and the right to intervene:
Name Address Basis of Claim
None
WHEREFORE, Plaintiff requests the court to grant custody of the children to Plaintiff.
Respectfully submitted,
Date: -3V ?&4( el
Superior Ct. I.D. 50838
VERIFICATION
I, James J. Kayer, Esq., am the attorney for Lorrie Ann Jones, and being duly affirmed according to
law, depose and say that the facts set for the in the foregoing Custody Petition are true and correct to the best
of my knowledge, information, and belief.
This verification is made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unworn
falsification to authorities.
Date: 5? Z 3G/0 /
James
for
4 East Liberty Avenue
Carlisle PA 17013
(717) 243-7922
Court I.D. # 50838
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LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2001-3299 CIVIL TERM
GERALD W. JONES, : CIVIL ACTION - LAW
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 74-0 day of V%% . 2002, upon
consideration of the attached Custody Conciliation eport. it is ordered and directed as
follows:
The prior Order of Court dated August 17, 2001 shall remain in full force
and effect, except as amended as follows:
2. Father shall have three nonconsecutive weeks of partial physical custody
of the children, one week in June, July and August, provided he give notice to Mother by
May 31, 2002 and said weeks do not conflict with Mother's scheduled vacation or the
Children's scheduled activities.
3. Mother shall have physical custody of the Children on Mother's Day from
9:00 a.m. to 9:00 p.m. Father shall have physical custody of the Children on Father's
Day from 9:00 a.m. to 9:00 p.m.
4. The parties shall submit to a custody evaluation with Dr. Stanley
Schneider and share equally the expenses for said evaluation. In the event that either
party disagrees with the custody evaluation recommendation, they may contact the
Conciliator to schedule another Conciliation Conference.
5. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY THE
J.
cc: Johnna J. Kopecky, Esquire, Counsel for Wr g/3/o ? .
Karl E. Rominger, Esquire, Counsel for -S .F
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. 2001-3299 CIVIL TERM
GERALD W. JONES, CIVIL ACTION -LAW
Defendant
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 Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Tiffany Nicole Jones June 18, 1988 Mother
Megan Rebecca Jones June 14, 1992 Mother
2. A Conciliation Conference was held in this matter on May 1 ,2002, with
the following individuals in attendance: Mother, Lorrie A. Jones, was present with her
counsel, Johnna J. Kopecky, Esquire. Father, Gerald W. Jones was present with his
counsel. Karl E. Rominger, Esquire.
3. Prior Orders of Court, dated July 2, 2001 and August 17, 2001 were
previously entered by the Honorable Edgar B. Bayley.
4. The parties agreed to an Order in the form as attached.
Date • _acq line M. Verney. Esquire
Custody Conciliator
GERALD JONES IN THE COURT OF COMMON PLEAS OF
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V.
01-3299 CIVIL ACTION LAW
LORRIE]ONES
DEFENDANT IN CUSTODY
AND NOW, Tuesday, April 02, 2002 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, May 01, 2002 at 2:30 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: /s/ Jacqueline M. Verney. Esqv
o
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 heating.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
C62 P??
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CO. e-.11
GERALD JONES, :IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v :NO. O (- X1M
LORRIE JONES :CIVIL ACTION
Defendant :CUSTODY
PETITION TO MODIFY
Petitioner is Gerald Jones, who resides at 38 Carlton Avenue, Carlisle, Cumberland
County, Pennsylvania 17013.
2. Respondent is Lorrie Jones, who resides at 408 Walnut Street Unit B, Boiling Springs,
Cumberland County, Pennsylvania 17007.
On July 2, 2001 the Honorable Bayley entered the following custody Order. (Attached as
Exhibit "A')
4. Since the entry of said Order, there has been a significant change in circumstances in that
the Mother is being investigated for abuse
5. The best interest of the children will be served by the Court in modifying said Order.
WHEREFORE, Petitioner prays this Court to grant the modification of the custody Order
as follows: Primary Physical Custody for Father, with visitation for Mother.
Respectfully Submitted,
Karl E. Rominger, Esquire
Rominger & Bayley
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff
Date:, r, ZL - ° 2
I verify that the statements made in this petition are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. cons. Stat. § 4904 relating to
unworn falsification to authorities.
Date: .3 2 G C
Gerald Jones,
CERTIFICATE OF SERVICE
I, Karl E. Rominger, Esquire, attorney for Gerald Jones, do hereby certify that I this day
served a copy of the Petition to Modify Custody upon the following by depositing same in the
United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows:
Johanna Kopecky, Esquire
26 West High Street
Carlisle, PA 17013
ZZ - C'
Karl E. Rominger, Esquire
Attorney for Plaintiff
coPV 8 200e
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. NO. 2001-3299 CIVIL TERM
GERALD W. JONES, : CIVIL ACTION -LAW
Defendant .
IN CUSTODY
ORDER OF COURT
91
AND NOW, this
day of I 2001 upon
consideration of the attached Custody Con ' ation eport, it is ordered and directed as
follows:
1. The Mother, Lome A. Jones, and the Father, Gerald W. Jones, shall have
shared legal custody of Tiffany Nicole Jones, born June 18, 1988 and Megan Rebecca
Jones, born June 14, 1992. Each parent shall have an equal right, to be exercised jointly
with the other parent, to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion.
2. Beginning Monday July 2, 2001 and continuing throughout the summer
until the entry of another Order of Court, the parties shall share physical custody of the
children on a week on/week off basis, with the time of transfer being Mondays at 6:00
p.m. Father shall begin his week on July 2, 2001 at -6:00 p.m. Mother's week shall begin
July 9, 2001 at 6:00 p.m. The parties shall alternate weeks thereafter.
3. The receiving party shall be responsible for the transportation of the
children unless otherwise agreed by the parties.
4. Father shall administer or guarantee that Megan's caregiver will
administer Megan's prescribed medication, although it is noted that Father objects to the
child taking the medication.
5. Each party shall be responsible for transporting the children to their
doctor, dentist or orthodontist appointments while the children are in their custody.
6. Neither party shall do or say or permit others to do or say anything which
may estrange the children from the other parent, injure the opinion of the children as to
the other parent, or hamper the free and natural development of the children's love and
respect for the other parent.
Exhibit "A"
7. Both parties shall have liberal telephone contact with the children while
the children are in the custody of the other parent.
8. Mother shall have custody of the children the weekend of September 28
through September 30, 2001 to take the children to a wedding. Mother shall provide
snake-up time for Father.
9. This Order shall not act to prejudice either party regarding their respective
positions concerning custody.
10. 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.
11. Another Conciliation Conference is scheduled for August 15, 2001 at 8:30
a.m., provided new Counsel for Mother is available.
BY THE COURT,
cc: Lorrie A. Jones, pro se
408 Walnut Street
Unit.B
Boiling Springs, PA 17007
Philip Spare, Esquire, Counsel for Father
TRUE COPY FROM RECORD
In Testimony whereof,)) here unto set my hand
and tt}gml of said 91urt at Carlisle, Pa.
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. : 2001-3299 CIVIL TERM
GERALD W. JONES, CIVIL ACTION -LAW
Defendant
IN CUSTODY
PRIOR JUDGE: None
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Tiffany Nicole Jones June 18, 1988 Mother
Megan Rebecca Jones June 14, 1992 Mother
2. A Conciliation Conference was held in this matter on June 27, 2001, with
the following individuals in attendance: Mother, Lorrie A. Jones, was present by
telephone. Her counsel, James J. Kayer, Esquire was present. (Mr. Kayer is withdrawing
his appearance from the matter at the conclusion of the Conciliation Conference with the
consent of Mother.) Father, Gerald W. Jones was present with his counsel, Philip Spare,
Esquire.
3. The parties agreed to an Order in the form as attached.
Date UJac eline hemey, Esquire
Custody Conciliator
JUN 2 $ 2001,,,1 /\
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AUG 15 2001 t
LORRIE A. JONES,
Plaintiff
V.
GERALD W. JONES,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
NO. 2001-3299 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this I /I day of A414 2001, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Order of Court dated July 2. 2001 shall remain in full force and
effect until August 26, 2001, at which time the prior Order of Court is hereby vacated and
this Order shall take effect.
2. The Mother, Lorrie A. Jones, and the Father, Gerald W. Jones, shall have
shared legal custody of Tiffany Nicole Jones, born June 18, 1988 and Megan Rebecca
Jones, born June 14. 1992. Each parent shall have an equal right, to be exercised jointly
with the other parent, to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion.
3. Beginning Sunday, August 26, 2001, Mother shall have primary physical
custody of the children.
4. Father shall have periods of partial physical custody of the children as
follows:
a. Every Tuesday and Thursday from 4:00 p.m. to 8:00 p.m.
b. Alternating weekends from Friday at 4:00 p.m. to Sunday at 6:00 p.m.
Father's alternating weekends shall begin September 7, 2001.
5. The receiving party shall be responsible for the transportation of the
children unless otherwise agreed by the parties.
6. Neither party shall do or say or permit others to do or say anything which
may estrange the children from the other parent, injure the opinion of the children as to
the other parent, or hamper the free and natural development of the children's love and
respect for the other parent.
7. Both parties shall have liberal telephone contact with the children while
the children are in the custody of the other parent.
8. This Order shall not act to prejudice either party regarding their respective
positions concerning custody.
9. This Order is considered a Temporary Order 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. In the event that Father's work schedule changes,
Father may immediately request another conciliation Conference.
cc: Johnna J. Kopecky. Esquire, Counsel for Mother J-11-01
Philip H. Spare, Esquire, Counsel for Father "°a
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AUG 1 5 2001V
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. : 2001-3299 CIVIL TERM
GERALD W. JONES, CIVIL ACTION -LAW
Defendant
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 Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Tiffany Nicole Jones June 18. 1988 Mother
Megan Rebecca Jones June 14, 1992 Mother
2. A Conciliation Conference was held in this matter on August 15, 2001.
with the following individuals in attendance: Mother, Lorrie A. Jones, was present with
her counsel, Johnna J. Kopecky. Esquire. Father, Gerald W. Jones was present with his
counsel, Philip H. Spare, Esquire.
3. A prior Order of Court dated July 2, 2001 was previously entered by the
Honorable Edgar B. Bayley.
4. The parties agreed to an Order in the form as attached.
k -Is--(j I ,,?y /H L,?Date (d'acq line M. Verney, Esquire
Custody Conciliator
JUN E 8 2001
LORRIE A. JONES,
IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. NO. 2001-3299 CIVIL TERM
GERALD W. JONES, CIVIL ACTION -LAW
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this ?a/L-day of , 2001, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The Mother, Lorrie A. Jones, and the Father, Gerald W. Jones, shall have
shared legal custody of Tiffany Nicole Jones, born June 18, 1988 and Megan Rebecca
Jones, born June 14. 1992. Each parent shall have an equal right, to be exercised jointly
with the other parent, to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion.
2. Beginning Monday July 2. 2001 and continuing throughout the summer
until the entry of another Order of Court, the parties shall share physical custody of the
children on a week on/week off basis, with the time of transfer being Mondays at 6:00
p.m. Father shall begin his week on July 2, 2001 at 6:00 p.m. Mother's week shall begin
July 9, 2001 at 6:00 p.m. The parties shall alternate weeks thereafter.
3. The receiving party shall be responsible for the transportation of the
children unless otherwise agreed by the parties.
4. Father shall administer or guarantee that Megan's caregiver will
administer Megan's prescribed medication, although it is noted that Father objects to the
child taking the medication.
5. Each party shall be responsible for transporting the children to their
doctor, dentist or orthodontist appointments while the children are in their custody.
6. Neither party shall do or say or permit others to do or say anything which
may estrange the children from the other parent, injure the opinion of the children as to
the other parent, or hamper the free and natural development of the children's love and
respect for the other parent.
7. Both parties shall have liberal telephone contact with the children while
the children are in the custody of the other parent.
8. Mother shall have custody of the children the weekend of September 28
through September 30, 2001 to take the children to a wedding. Mother shall provide
make-up time for Father.
9. This Order shall not act to prejudice either party regarding their respective
positions concerning custody.
10. 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.
11. Another Conciliation Conference is scheduled for August 15, 2001 at 8:30
a.m., provided new Counsel for Mother is available.
BY THE COURT
cc: Lorrie A. Jones, pro se
408 Walnut Street
Unit B
Boiling Springs, PA 17007
Philip Spare. Esquire, Counsel for Father
C J.
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JUN 2 8 2001
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF 91
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V.
GERALD W. JONES,
Defendant
PRIOR JUDGE: None
: 2001-3299 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 Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Tiffany Nicole Jones June 18. 1988 Mother
Megan Rebecca Jones June 14, 1992 Mother
2. A Conciliation Conference was held in this matter on June 27, 2001, with
the following individuals in attendance: Mother. Lorrie A. Jones, was present by
telephone. Her counsel. James J. Kayer, Esquire was present. (Mr. Kayer is withdrawing
his appearance from the matter at the conclusion of the Conciliation Conference with the
consent of Mother.) Father, Gerald W. Jones was present with his counsel, Philip Spare,
Esquire.
3. The parties agreed to an Order in the form as attached.
Date
Oaccrueline M. Verney, Esquire Custody Conciliator
LORRIE A. JONES IN THE COURT OF COMMON PLEAS OF
PLAINTIFF : CUMBERLAND COUNTY. PENNSYLVANIA
V.
GERALD W. JONES 01-3299 CIVIL ACTION LAW
DEFENDANT
. IN CUSTODY
AND NOW, Friday June 01, 2001 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor Cumberland County Courthouse, Carlisle on Wednesday June 27, 2001 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. 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: /s/ facqueline
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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.01 - 3 297 CIVIL TERM
GERALD W. JONES, CIVIL ACTION -LAW
Defendants : IN CUSTODY
ORDER OF COURT
hereby directed that the parties and their respective counsel appear before
custody Conciliator, at
Esquire,
, 2001, at _ o'clock _.M., for a Pre-Hearing Custody Conference. At such
conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to
define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age
five or older may also be present at the conference.
for entry of a temporary or permanent order.
Failure to appear at the conference may provide grounds
FOR THE COURT,
By:
AND NOW, this day of June 2001, upon consideration of the attached Petition, it is
Esquire
Custody Conciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact 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.
cc: James J. Kayer, Esquire
Attorney for Plaintiff
James J. Kayer, Esquire
Attorney for Plaintiff
4 East Liberty Avenue
Liberty Loft
Carlisle, PA 17013
(717) 243-7922
Philip H. Spare, Esquire
Attorney for Defendant
2 O LUU4
MAY
LORRIE JONES. : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY. PENNSYLVANIA
NO. 2001-3299
GERALD JONES : CIVIL ACTION
Defendant : IN CUSTODY
CUSTODY MEMORANDUM
AND NOW, comes Gerald Jones, Defendant by and through his counsel. Karl E.
Rominger. Esquire and submits his Custody Memorandum pursuant to the Order of Court dated
March 5. 2004.
I. FACTUAL BACKGROUND:
Gerald Jones is the biological father of the minor children, Tiffany Nicole Jones, date of
birth. June 18. 1988 and Megan Rebecca Jones, date of birth. June 14. 1992. Father and
Mother are still married but have been separated for approximately two years.
During that time Mother has had primary physical custody of the children with
shared legal custody between the parties with Father having alternating weekend
visitation. There was an Order of Court dated November 8, 2002, granting primary
physical custody to Mother with shared legal custody between the parties. Father
contends that Mother is in contempt of the November 8. 2002, Order of Court because
she has not sent the children for the alternating weekend visitation.
There was a custody evaluation completed by Dr. Stanley Schneider and Father
does not agree with the findings of Dr. Schneider as he believes and therefore avers that
Dr. Schneider did not take all of the information into consideration such as, telephone
calls which Mother has made to Father. Mother also threatened to take away all
communication with the children until Father signs the divorce papers.
II. NAMES AND AGES OF THE CHILDREN:
Tiffany N. Jones - Age 15 Megan R. Jones - Age 11
III. PROPOSED ORDER FOR RESOLUTION:
Primary physical custody with father with shared legal custody.
NAMES OF FACTUAL WITNESSES:
Donald and Kay Jones - Paternal grandparents will testify to the relationship between
Father and children.
Melissa Nailor - Friend of Father will testify to the interactions between Father and
children.
Debra Ocher - Friend of Father will testify to her observations of the relationship of
Father and children.
Tiffany and Megan Jones -Minor children of Father and Mother.
IV. NAMES AND ADDRESSES OF EXPERT WITNESSES:
At this time. Father does not propose to call any expert witnesses. He does reserve the
right to supplement this list of witnesses as necessary.
VI. LEGAL AND FACTUAL ISSUES FOR RESOLUTION:
There are no unique legal issues. and the Court will be called upon to determine which
parent would be best suited to provide the primary physical care for the child.
VII. ESTIMATED LENGTH OF TRIAL:
One day.
VIII. NEED FOR A HOME STUDY:
Father does not request a home study at this time but does reserve the right to request one
if the need for one becomes apparent.
IX. NEED FOR A PSYCHOLOGICAL EVALUATION:
There has already been a psychological evaluation performed by Dr. Stanley Schneider.
Dr. Schneider recommended joint counseling with Franko Associates and Mother stopped taking
the children.
Date: /?#Ya.a; 3OVY Respectfully submitted.
ROMINGER & BAYLEY
Karl E. Rominger. Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Defendant
RICK SCOTT,
Plaintiff
V.
TRACY (SCOTT) FAILOR,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:NO: 2003-4811 CIVIL ACTION - LAW
IN CUSTODY
1. Karl E. Rominger, Esquire. attorney for Defendant. do hereby certify that I this day
served a copy of the Custody Memorandum upon the following by depositing same in the
United States Mail, first class postage prepaid, at Carlisle. Pennsylvania, addressed as follows:
Carol J. Lindsay, Esquire
Saidis, Shutf: Flower & Lindsay
26 West High Street
Carlisle, PA
Dated: May 20.2004
Respectfully submitted.
ROMINGER, BAYLEY & WHARE
Karl E. Rominger. Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Defendant
Lorrie A. Jones, In the Court of Common Pleas of
Petitioner Cumberland County, Pennsylvania
V. No. 2001-1579 Civil Term
Gerald W. Jones, Civil Action - Law
Respondent In Divorce
PI AINTIFF'S PRE-TRIAI STATFMFNT PER Pa-RC-P_ 1920-31(h)
AND NOW, comes Plaintiff, by and through her counsel, SAIDIS, SHUFF,
FLOWER & LINDSAY, and respectfully submits her Pre-Trial Statement as follows:
1. BACKGROUND: The parties hereto are husband and wife having
been joined in marriage on July 5, 1982 and having separated on or about March15,
2001. There were two children born of the marriage, Tiffany Nicole Jones, born
June 18, 1988 and Megan Rebecca Jones, born June 14, 1992. Since separation,
the children have lived with their mother and visited with their father.
This is the first hearing before this court on the issue of custody. On
July 2, 2001 a court order issued pursuant to the parties agreement. A copy of the
Custody Order is attached hereto as Exhibit "A". By it's terms primary physical
custody remained with Plaintiff, hereinafter Mother.
The second conciliation conference was held on August 15th, 2001.
Once again Mother retained primary physical custody of the children subject to
periods of partial custody to Father. A copy of the August 171h, 2001 Court Order
is attached hereto as Exhibit "B"
On March 22, 2002, the Defendant, hereinafter Father, filed a
Petition to Modify the custody order. Another conciliation conference was held on
May 3`°, 2002. The order from that conference called for a custody evaluation with
Dr. Stanley Schneider, the cost to be equally shared between the parties. Mother
filed a Petition for Contempt, because, among other things, Father refused to
make or keep appointments with Dr. Schneider for the custody evaluation. A copy
of the order of May 3`d, 2002 is attached hereto as Exhibit "C.
On November 8'h, 2002, after conciliation, an order was entered
determining that Father was in Contempt of the May 3, 2002 order and permitting
to purge his contempt by following through with the custody evaluation. The prior
custody orders were vacated and a new custody put in its place according to the
terms of which primary physical custody remained with Mother. The November
eh, 2002 order required, furthermore, that Father give Megan the medication
required for multiple mental health issues and that the parties maintain civility. A
copy of the order of November 8,n, 2002 is attached hereto as Exhibit "D"
On July 28th, 2003 Dr. Schneider completed his evaluation. A copy
of his evaluation is attached hereto as Exhibit "E".
Subsequent to the evaluation neither party sought modification of
the order providing primary physical custody to Mother.
On February 4th, 2004, however, Father filed a Petition to Modify
Custody for Contempt. A conciliation conference was held on March 2nd, 2004
from which the present order, that of March 5th, 2004 issued. A copy of that order
is attached hereto as Exhibit "F".
it. WITNESSES: Witnesses for Mother shall include:
A. Lorrie Jones, Mother who will testify regarding her care for the
children.
B. Dr. Stanely Schneider. Dr. Schneider will testify with regard to his
recommendations after extensive contact with the family.
C. Audrey Aarhus. Ms. Aarhus has been Tiffany's therapist for years and will testify
regarding Tiffany and her relationship with her Father.
D. Linda Stamy, maternal grandmother, will testify regarding her ongoing contacts
with her grandchildren and daughter.
E. Clay Stamy, maternal grandfather, will testify with regard to his relationship with
his grandchildren and that of their mother.
II. MOTHERS POSITION ON CUSTODY.
Primary physical custody should remain with mother subject to periods of partial
custody on alternating weekends with father.
Respectfully submitted,
Saidis, Shuff, Flower & Lindsay,
J
AI4 ,(? a , 'i
Date: By:
CAROL J. DSAY, Esquire
ID# 44693
26 West High Street
Carlisle, Pennsylvania 17013
(717) 243-6222
Attorney for Defendant
pl I rl?
Lorne A. Jones,
Gerald W. Jones,
Petitioner
V.
Respondent :
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 2001-1579 Civil Term
Civil Action - Law
In Divorce
rFRTIFI .ATE nF SERVE
AND NOW, THIS -12 DAY OF 0 200y, I,
CAROL J. LINDSAY, ESQUIRE, OF THE LAW FIRM OF SAIDIS, SI F, FLOWER & LINDSAY,
ATTORNEYS, HEREBY CERTIFY THAT I SERVED THE WITHIN DEFENDANT'S PRETRIAL STATEMENT
THIS DAY BY DEPOSITING SAME IN THE UNITED STATES MAIL, FIRST CLASS, POSTAGE PREPAID,
IN CARLISLE, PENNSYLVANIA, ADDRESSED TO:
Karl E. Rominger, Esquire
ROMINGER & BAYLEY
155 S. Hanover Street
Carlisle PA 17013
SAIDIS, SHUFF, FLOWER & LINDSAY
Attorneys for Defendant
9 n
By: Carol J. Li ay, Esquire
ID# 44693 '
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Exhibit A
JUN 2 8 2001 ,,
LORRIE A. JONES,
Plaintiff
V.
GERALD W. JONES,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYLVANIA
NO. 2001-3299 CIVIL TERM
: CIVIL ACTION -LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this day of 2001, upon
consideration of the attached Custody Concilia ' Report, it is ordered and directed as
follows:
1. The Mother, Lome A. Jones, and the Father, Gerald W. Jones, shall have
shared legal custody of Tiffany Nicole Jones, bom June 18, 1988 and Megan Rebecca
Jones, bom June 14, 1992. Each parent shall have an equal right, to be exercised jointly
with the other parent, to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion.
2. Beginning Monday July 2, 2001 and continuing throughout the summer
until the entry of another Order of Court, the parties shall share physical custody of the
children on a week on/week off basis, with the time of transfer being Mondays at 6:00
p.m. Father shall begin his week on July'2, 2001 at -6:00 p.m. Mother's week shall begin
July 9, 2001 at 6:00 p.m. The parties shall alternate weeks thereafter.
3. The receiving party shall be responsible for the transportation of the
children unless otherwise agreed by the parties.
4. Father shall administer or guarantee that Megan's caregiver will
administer Megan's prescribed medication, although it is noted that Father objects to the
child taking the medication.
5. Each party shall be responsible for transporting the children to their
doctor, dentist or orthodontist appointments while the children are in their custody.
6. Neither party shall do or say or permit others to do or say anything which
may estrange the children from the other parent, injure the opinion of the children as to
the other parent, or hamper the free and natural development of the children's love and
respect for the other parent.
7. Both parties shall have liberal telephone contact with the children while
the children are in the custody of the other parent.
8. Mother shall have custody of the children the weekend of September 28
through September 30, 2001 to take the children to a wedding. Mother shall provide
make-up time for Father.
9. This Order shall not act to prejudice either party regarding their respective
positions concerning custody.
10. 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.
11. Another Conciliation Conference is scheduled for August 15, 2001 at 8:30
a.m., provided new Counsel for Mother is available.
BY THE COURT,
cc: Lorrie A. Jones, pro se
408 Walnut Street
Unit.B
Boiling Springs, PA 17007
Philip Spare, Esquire, Counsel for Father
TRUE COPY FROM RECORD
In Testimony whetteegqf, I heFe unto set my hand
and #0 seal of sa!4(Court at Carlisle, Pa.
JUN 2 8 2001
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V.
GERALD W. JONES,
Defendant
PRIOR JUDGE: None
2001-3299 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 Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Tiffany Nicole Jones June 18, 1988 Mother
Megan Rebecca Jones June 14, 1992 Mother
2. A Conciliation Conference was held in this matter on June 27, 2001, with
the following individuals in attendance: Mother, Lon ie A. Jones, was present by
telephone. Her counsel, James J. Kayer, Esquire was present. (Mr. Kayer is withdrawing
his appearance from the matter at the conclusion of the Conciliation Conference with the
consent of Mother.) Father, Gerald W. Jones was present with his counsel, Philip Spare,
Esquire.
3. The parties agreed to an Order in the form as attached.
Date UJac eline M. Verney, Esquire Custody Conciliator
Exhibit B
AM 15 20010
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. NO. 2001-3299 CIVIL TERM
GERALD W. JONES, CIVIL ACTION -LAW
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this /I r= day of &A.& , 2001, upon
consideration of the attached Custody Concilia on Report, it is ordered and directed as
follows:
1. The prior Order of Court dated July 2, 2001 shall remain in full force and
effect until August 26, 2001, at which time the prior Order of Court is hereby vacated and
this Order shall take effect.
2. The Mother, Lorrie A. Jones, and the Father, Gerald W. Jones, shall have
shared legal custody of Tiffany Nicole Jones, born June 18, 1988 and Megan Rebecca
Jones, born June 14, 1992. Each parent shall have an equal right, to be exercised jointly
with the other parent, to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion.
3. Beginning Sunday, August 26, 2001, Mother shall have primary physical
custody of the children.
4. Father shall have periods of partial physical custody of the children as
follows:
a. Every Tuesday and Thursday from 4:00 p.m. to 8:00 p.m'.
b. Alternating weekends from Friday at 4:00 p.m. to Sunday at 6:00 p.m.
Father's alternating weekends shall begin September 7, 2001.
5. The receiving party shall be responsible for the transportation of the
children unless otherwise agreed by the parties.
6. Neither party shall do or say or permit others to do or say anything which
may estrange the children from the other parent, injure the opinion of the children as to
the other parent, or hamper the free and natural development of the children's love and
respect for the other parent.
7. Both parties shall have liberal telephone contact with the children while
the children are in the custody of the other parent.
8. This Order shall not act to prejudice either party regarding their respective
positions concerning custody.
9. This Order is considered a Temporary Order 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. In the event that Father's work schedule changes,
Father may immediately request another conciliation Conference.
BY THE COURT,
/S4 R_ /&,e,;
J.
cc: Johnna J. Kopecky, Esquire, Counsel for Mother
Philip H. Spare, Esquire, Counsel for Father
TRUE COPY FROM RECORD
in Testimony whereof, I here unto set my hand
and the seal of said Court at Carlisle, Pa.
This /7 f day ofd,,,, - -2v& ,
Prothonotary
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. : 2001-3299 CIVIL TERM
GERALD W. JONES, CIVIL ACTION -LAW
Defendant
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 Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Tiffany Nicole Jones June 18, 1988 Mother
Megan Rebecca Jones June 14, 1992 Mother
2. A Conciliation Conference was held in this matter on August 15, 2001,
with the following individuals in attendance: Mother, Lome A. Jones, was present with
her counsel, Johnna J. Kopecky, Esquire. Father, Gerald W. Jones was present with his
counsel, Philip H. Spare, Esquire.
3. A prior Order of Court dated July 2, 2001 was previously entered by the
Honorable Edgar B. Bayley.
4. The parties agreed to an Order in the form as attached.
9_/S--d/ " /h. Kn??
Date acq line M. Verney, Esquire
Custody Conciliator
Exhibit C
MAY 0 2 2002
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2001-3299 CIVIL TERM
GERALD W. JONES, : CIVIL ACTION - LAW
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 3A-d day of A , 2002, upon
consideration of the attached Custody Conciliation R port, it is ordered and directed as
follows:
1. The prior Order of Court dated August 17, 2001 shall remain in full force
and effect, except as amended as follows:
2. Father shall have three nonconsecutive weeks of partial physical custody
of the children, one week in June, July and August, provided he give notice to Mother by
May 31, 2002 and said weeks do not conflict with Mother's scheduled vacation or the
Children's scheduled activities.
3. Mother shall have physical custody of the Children on Mother's Day from
9:00 a.m. to 9:00 pm. Father shall have physical custody of the Children on Father's
Day from 9:00 a.m. to 9:00 p.m.
4. The parties shall submit to a custody evaluation with Dr. Stanley
Schneider and share equally the expenses for said evaluation. In the event that either
party disagrees with the custody evaluation recommendation, they may contact the
Conciliator to schedule another Conciliation Conference.
5. 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, t
cc: Johnna J. Kopecky, Esquire, Counsel for Mother
Karl E. Rominger, Esquire, Counsel for Father
T" W" FR(MA REQOW
flr T#Kftw *% ad. I hers seb set WN MME
iW AN no of "M coral at a"*, ft,
r++?y7,°,
p?.
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. : 2001-3299 CIVIL TERM
GERALD W. JONES, CIVIL ACTION -LAW
Defendant
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 Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Tiffany Nicole Jones June 18, 1988 Mother
Megan Rebecca Jones June 14, 1992 Mother
2. A Conciliation Conference was held in this matter on May 1,2002, with
the following individuals in attendance: Mother, Lorrie A. Jones, was present with her
counsel, Johnna J. Kopecky, Esquire. Father, Gerald W. Jones was present with his
counsel, Karl E. Rominger, Esquire.
3. Prior Orders of Court, dated July 2, 2001 and August 17, 2001 were
previously entered by the Honorable Edgar B. Bayley.
4. The parties agreed to an Order in the form as attached.
S a -oa
CA -
Date acq line M. Verney, Esquire
Custody Conciliator
Exhibit 0
NOV 1 2 N2 2002 q
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.2001-3299 CIVIL TERM
GERALD W. JONES, : CIVIL ACTION - LAW
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 9+?_ day of 2002, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. Father is in contempt of the Order of Court dated May 2, 2002. Father
may purge the contempt by scheduling and following through with the custody evaluation
with Dr. Schneider.
2. The prior Orders of Court, dated July 2, 2001, August 17, 2001 and May
3. 21002, are hereby vacated in their entirety and replaced with the following:
3. The Mother, Lorrie A. Jones. and the Father, Gerald W. Jones, shall have
shared legal custody of Tiffany Nicole Jones, born June 18, 1988 and Megan Rebecca
Jones, born June 14, 1992. Each parent shall have an equal right, to be exercised jointly
with the other parent, to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion.
4. Mother shall have primary physical custody of the children.
5. Father shall have periods of partial physical custody of the children as
follows:
a. Every Tuesday and Thursday from 4:30 p.m. to 8:00 p.m.
b. Alternating weekends from Friday at 4:30 p.m. to Sunday at 6:00 p.m.
c. Father shall have three nonconsecutive weeks of partial physical custody of
the children, one week in June, July and August, provided he give notice to
Mother by May 31, 2002 and said weeks do not conflict with Mother's
scheduled vacation or the children's scheduled activities.
6.
Mother shall have physical custody of the children on Mother's Day from 9:00 a.m. to
9:00 p.m. Father shall have physical custody of the children on Father's Day from 9:00
a.m. to 9:00 p.m. lwnww?
7. In the event that either party is in need of babysitting services for more
than two hours during their period of custody, they shall contact the non-custodial parent
and offer the opportunity to care for the children.
8. The parties shall submit to a custody evaluation with Dr. Stanley
Schneider and share equally the expenses for said evaluation. In the event that either
party disagrees with the custody evaluation recommendation, they may contact the
Conciliator to schedule another Conciliation Conference.
9. The receiving party shall be responsible for the transportation of the
children unless otherwise agreed by the parties.
10. Father shall administer or guarantee that Megan's caregiver will
administer Megan's prescribed medication, although it is noted that Father objects to the
child taking the medication.
11. Each party shall be responsible for transporting the children to their
doctor, dentist, orthodontist or other medical appointments.
12. Each party is responsible for transporting the children to their regularly
scheduled extracurricular activities.
13. Neither party shall do or say or permit others to do or say anything which
may estrange the children from the other parent, injure the opinion of the children as to
the other parent, or hamper the free and natural development of the children's love and
respect for the other parent.
14. Both parties shall have liberal telephone contact with the children while
the children are in the custody of the other parent. The parties will only utilize the home
telephone number for emergency health care contact. Otherwise cell phone calls will be
utilized or e-mail. Custody matters/requests/information shall not be relayed through the
children.
15. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY ]H OURT,
/S '
T
J.
TRUE COY O
Lindsay, q In Testims, y whe o, ? ra.:.re REs RJ set cc: Karl o E. J. n aer, EEsquire, CtCounsel for Father he sea) Ofs F i j=re unto a Pa
my g
hat
B WIN / C0 rt at Carlisle, Pat
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :2001-3299 CIVIL TERM
GERALD W. JONES, : CIVIL ACTION - LAW
Defendant
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:
I. The pertinent information concerning the Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Tiffany Nicole Jones June 18, 1988 Mother
Megan Rebecca Jones June 14. 1992 Mother
2. A Conciliation Conference was held in this matter on November 6, 2002,
with the following individuals in attendance: Mother, Lorrie A. Jones, was present with
her counsel, Carol J. Lindsay, Esquire. Father, Gerald W. Jones was present with his
counsel, Karl E. Rominger, Esquire.
3. Prior Orders of Court dated July 2. 2001, August 17, 2001 and May 3,
2002 were previously entered by the Honorable Edgar B. Bayley.
4. Presently before the court is Mother's Petition for Contempt. The Order
of Court dated May 2, 2002 ordered the parties to undergo a custody evaluation with Dr.
Schneider. Father has failed to schedule any appointment with Dr. Schneider. I
recommend that Father be found in contempt of the May 3, 2002 Order of Court, but he
may purge the contempt by scheduling an appointment and following through with the
custody evaluation.
5. The parties agreed to an Order in the form as attached. ' /
Date Oficq ine M. Verney, Esquire
Custody Conciliator
Exhibit E
FEB 0 8 2004
412 Frhrd Read
came ®I, PA IWI
PAeme: 70.782.299
FIEUMB2_111516
July 28, 2003
GUIDANCE
ASSOCIATES
PENNSYLVANIA
Carol J. Lindsay, Esquire
Saidis, Shuff, Flower & Lindsay
26 West High Street
Carlisle, PA 17013
Karl E. Rominger, Esquire
Rominger & Bayley
155 South Hanover Street
Carlisle, PA 17013
Re: Jones v. Jones
Stanlen E Eehnelder, M.S.
mmcnr
I mu.SuldencePA.eem
Cumberland County Court of Common Pleas
No. 2001-3299
Civil Action - Law
In Custody
Dear Attorneys:
I am sending my findings and recommendations regarding custody of Tiffany, age fifteen,
and Megan, age eleven.
I met with each parent, interviewed them and each completed custody-related instruments
including: Life History Questionnaires, Parent Self-Report Data forms and a personality
inventory, the Minnesota Multiphasic Inventory - 2 (MMPI-2).
The girls were seen when brought in by family members on different occasions.
Additionally, I met with the maternal grandparents, Linda and Clay Stamy.
A considerable amount of additional data review included:
Court Data
11/08/02 Court Order-established shared legal custody, primary physical
custody with mother; partial custody with father every Tuesday
and Thursday from 4:30pm to 8:00pm, every other weekend, Friday
4:30pm until Sunday at 6:00pm and three (3) non-consecutive weeks in the
summer, (June, July & August). Further, the court found the father in
Jones v Jones
2
contempt of the prior Order of May 3, 2002 because he did not undergo a
Court order custody evaluation. The Order noted that he may purge the
contempt by scheduling an appointment and following through with custody
evaluation. The Order also noted that "father will administer or guarantee
that Megan's caregiver(s) will administer Megan's prescribed medication,
although it is noted that father objects to the child
taking the medication."
05/03/02 Court Order - entered pursuant to an agreement of the parents at a
Custody Conciliation Conference.
05/02/02 Custody Conciliation Summary Report
03/22102 Fathers petition to modify custody
08/17/01 Court Order (Temporary) - Beginning August 26th 2001 mother
shall have primary physical custody.
08/15/01 Custody Conciliation Summary Report
07/02101 Court Order- Beginning July 2, 2001, continuing throughout the
summer. The Court established what the parents agreed to, namely
alternating weeks.
06/28/01 Custody Conciliation Report
05/30/01 Mother's original petition for custody
Attomey Data
04/0502 Attorney Kopecky to Attorney Rominger with attached letter from
Children and Youth Services
03/26/02 Copy of Cumberland County Children and Youth letter to Lorrie
noting that the suspected abuse was determined to be "unfounded."
12102/02 Copy of Cumberland County Children and Youth to Lorrie
recommending continued family counseling.
(no date) Custody Stipulation and Agreement form (unsigned)
(no date) Correspondence from Attorney Kopecky to Dr. Schneider
01/29/03 Attorney Lindsey, letter to Attorney Rominger
School/Mental Health Data
05/07/03 Tiffany's nomination to Who's Who Among American High School
students. It was noted that Tiffany is an Honor Roll student, involved in
church youth group, cheerleading and swimming
04/25/03 South Middletown School District, Special Education Evaluation report
regarding Megan. Megan was found to have average intelligence, non-
eligible for Special Education Services but needing remedial work for Math.
04/04103 Megan's Psychiatric Records from Holy Spirit Hospital 5/00-4/03
04/01/03 Telephone contact with Audrey Aarhus, ACSW
03/10/03 Treatment summary from Mary Jo Hardick, LCSW, regarding
Tiffany.
03/07/03 Letter to Lorrie from South Middletown School District by
Heather Groff, School Counselor
Telephone contacts with Dr. Mary Bartus-White, Psychiatrist
March 3, March 14 & July 2, 2003
01/20/03 Treatment summary regarding Megan from Kay Balcziunas, MSN,
RN, CS.
Jones v Jones 3
12/20/02 Letter from Lorrie from South Middleton School District by
Heather Groff, School Counselor
12/99 Lorrie's psychiatric evaluation and treatment plan with medication
supervision reports from January 2000 to January 2003.
Megan's report cards - Kindergarten through fifth grade
Tiffany's report cards - Kindergarten through ninth grade
(seventh grade report card missing)
Additional Data
07/02/03 Telephone call from Tiffany
06/09/03 Telephone Contact from Linda Stamy. Maternal grandmother
(undated) Note from Lorrie
Megan's notes May 2003 regarding relay of life walk
03/31/03 Three page letter from Tiffany to Dr. Schneider
(no date) Lorries notes (29 pages) 2000-2003
03/07/00 Medical Report regarding Lorrie's injury to left hand
Gerald (Gent') (Issues and Findings):
Gerry presents as a concerned, over-the-road truck driver, who is currently not working
related to injuries sustained from an automobile accident. Typically his work hours were
9:00pm to 6:00am. He would sleep during the day. He has traditionally been an over-the-
road truck driver.
Gerry was apologetic regarding his perceived difficulty expressing himself
Gerry indicates that he has the support of his parents, as well as a niece, Melissa to
provide backup or supervision for the girls in the event that he is unavailable or sleeping.
Gerry indicates that he did not like what was happening in the children's lives and wanted
to change custody. When seen in November 2002, he was very concerned about Lorrie's
relationship with her boyfriend at the time and Gerry's understanding that there was
conflict between this man and Lorrie, and the girls.
Because of an incident resulting in black and blue marks on Tiffany, Children and Youth
Services investigated the incident. Lorrie was the suspected perpetrator of abuse on
Tiffany. This resulted in Gerry filing for modification of custody.
The parents separated with Lorrie moving out with the girls in the Spring of 2001. There
were a number of Court-related custody conferences, all of which resulted in the girls
remaining in the mother's physical custody with the exception of a summer alternating
weekly schedule. The schedule seemed to be meeting the needs of everyone including
Gerry, whose work schedule precluded him from being involved on a more sustained
basis. However, the most recent Court Order established contact between Gerry and the
girls every Tuesday and Thursday from about 4:00pm to 8:30pm. Additionally, he had
Jones v Jones 4
partial custody every other weekend. Because of his work schedule and his attitude, Gerry
did not exercise his Tuesday's and Thursday's on a regular basis.
Gerry wants to "give the girls the opportunity to express their opinions and preferences and
is okay doing what is fair"when asked about custody. He acknowledges that there is a
continuing power struggle between himself and Lorrie. He believes that Lorrie
"badmouths" him and felt that she would not say anything good about his parenting and/or
supervision of the girls. He also acknowledges that he does not believe that Megan needs
her medication describing her as an active child who essentially becomes "spacey" when
on her medication. He notes more positive behavior when Megan is not on her
medication. He notes that she is able to sit still, that she talks a lot less, is more focused
and with the medication generally making her "jumpy."
His description is different from others who see Megan including mental health
professionals, school personnel, Lorrie and the maternal grandparents.
As noted, Gerry wants whatever is in the girls' best interest. He believes that at points in
time, Tiffany wanted to live with him primarily. He is realistic enough to acknowledge that
his former work schedule precluded his being there as a primary physical custodian.
However, he feels that his parents and/or niece would suffice as backup for him. At our
last contact, Gerry admitted that he was stubborn and would like not to have to deal with
Lorrie who apparently wants Gerry to call her when he wants the children. This resulted in
his missing an appointment between the custody evaluator and the girls. By February
2003, Gerry acknowledged that an ideal time for him to be with the girls would be every
afternoon from about 4:00pm to 8:00pm with his indicating that he can modify his work
schedule to be available. He was somewhat at a loss to explain why he did not see the
girls given the November 2002 Court Order which allowed him to be with the girls currently
every Tuesday and Thursday. He retracted his saying that he sleeps a lot in the
afternoons blaming Lorrie who would not let him have the girls, indicating that she is in
violation of the Court Order. He admits that he does not like the idea of asking Lorrie or
even communicating with her. This has resulted with his basically seeing the girls every
other weekend. If awarded primary custody, he said he would, "never keep the kids from
Lorrie." Gerry indicated that if he could not get primary custody that he would be "okay
with alternating weeks." There was reference made to child support payments.
There is nothing noteworthy in Gerry's family of origin experiences, which would influence
and/or shape his current parenting practices and child management techniques. There is
no evidence of any abuse, neglect or substance abuse in his family of origin. His father is
reportedly a Pentecostal Minister. Gerry's parents have remained married, celebrating
forty-eight years.
Gerry would change nothing in how he was raised. He presents his parents as available,
gentle. He describes himself as a conflict avoider, meaning, he would, "back away" in a
disagreement. He admits to being stubborn which contributes to the current conflict with
Lorrie.
Gerry has not received any manner of mental health treatment, has had no contact with
the criminal justice system and has never abused any alcohol or drugs. A recent issue
Jones v Jones 5
reported by both girls is their concern about Gerry's reported behavior of his using alcohol
and possibly drinking and driving and also his beginning to smoke cigarettes. As noted
below, both girls are upset and distressed with their fathers reportedly current behaviors.
Gerry's child management techniques are generally appropriate. However, there was a
major confrontation between himself and Tiffany in March, 2003, which was upsetting to
both of them in addition to Megan. Overall, the girls report that their father does not
engage in any unacceptable child management techniques. Gerry has a good value
system, appears ethical, rational and realistic.
Gerry's personality inventory validity scales reflect his denying minor faults and weakness
to which most people are willing to admit. This may be a reflection of his religious
orientation. In addition to suggesting a defensive (protective) test-taking attitude, persons
with his scores tend to be conventional, conforming, moralistic and rigid and to over-value
their own self-worth. They also generally have little awareness of the consequences to
other people of their behavior. There are no elevations on content scales reflecting his
having any fears, obsessions, depression or anxieties, which would impact his parenting.
His clinical scales are consistent with individuals who tend to rationalize their behavior and
transfer blame to others accepting little or no responsibility for their own behaviors. They
present themselves as trusting with high moral standards, while denying hostility and
negativity.
Lome (Issues and Findings):
Throughout my contacts with Lorrie she was anxious, nervous and flighty as reflected by
her speech, which most often was pressured and tangential. Lorrie has enough insight to
recognize her behavior and describes herself as "emotional and nervous." She has been
and continues to be under psychiatric care.
Lorrie works full time at a regional medical center cafeteria and reports no difficulty with
work, and in fact, reports recently receiving a raise.
Lords seems very focused on, and perhaps obsessed with, Gerry's behavior and her
inability to effectively establish a positive communication with him regarding the girls.
However, she is not and has never ignored the girl's well being. She questions Gerry's
motivation in his filing for primary custody and indicated that, historically, he apparently
had no major concerns with her parenting of the girls - which is reflected in the various
custody conciliation summaries and Court Orders, both temporary and permanent, placing
the girls with Lorrie.
Lorrie believes that Megan benefits from her medication and is distraught over the notion
that Gerry does not give Megan her prescribed meds. When Gerry was seen on February
25, 2003, he did indicate he does give Megan her medications. However, Megan has
returned from weekend visits with her behavior suggesting that perhaps she did not get her
medications.
Throughout contacts with Lorrie, she described her frustrations with Megan, coupled with
her concerns about Megan's behavior and her general well-being. Of late, she is also
Jones v Jones 6
concerned about Tiffany's relationship with Gerry as related to an incident between the two
of them in March, 2003. Both Gerry and Tiffany (as well as Lorrie) appear to be fairly "stiff-
necked" and are stubborn. Megan appears to fulfill the role of family mediator and wants
to insure that all is well between and among family members.
Another issue of Lorrie's relates to her questioning Gerry's supervision of the girls. She
described Tiffany and a girlfriend being with boyfriends with Gerry apparently not providing
supervision. She wants Gerry to be actively involved in the girls' lives, wants him to
exercise his current partial visitation in addition to his summer vacation with the girls and
generally comply with the Court Order.
Lorrie is aware that Megan wants to see her father and is also aware of the recently
emerging ambivalence of both girls in spending time with their father because of his
reported behavior.
Lorrie believes that the current schedule is in the girls' best interest. She believes that she
is addressing the girls' needs, even though she admits to feeling overwhelmed at times,
wants to work with Gerry, wishes he would adhere to his behavioral patterns consistent
with his family's religious orientation, and does not wish to continue to use the girls as a
means of communication with Gerry.
There is no evidence of any abuse or neglect in Lorrie's family of origin. Interestingly, she
recalls her mother either, "screaming or crying" when she (mother) was upset as Lorrie
was growing. She wanted both parents to stop saying, "we understand what your going
through" - suggesting that Lorrie did not accept her parent's efforts of trying to empathize
with her. As Lorrie matured, she experienced a more open line of communication with
both parents.
Lorrie continues to receive psychiatric treatment for her depression, tension and general
stress. Her emotional status does not appear to be a major impediment to her parenting of
the girls over the years.
Lorrie is proud of her ability to grow to the point where she left Gerry whom she described
as "extremely controlling... when I got tired of being a wallflower and decided he was not
going to dominate the girls and I any more, his revenge was mental and physical abuse."
Lorrie's responses to custody-related instruments continued to reflect her focus on Gerry's
previous behaviors toward her and the girls and his lack of responsibilities regarding
parenting. She continues to see him as uncooperative, obstinate and difficult to work with.
Lorrie has intimate working knowledge of both girls and was able to describe with
extensive detail their activities, interests, behaviors, personality traits, and general style.
Lorrie's personality inventory reflected some naivete and a sense of self-constraint in her
presentation, which is seen as an attempt to forestall negative judgments. Persons with
her validity scale profile are generally unsophisticated and often unaware of how others
see them. Her clinical profile is consistent with persons who punish themselves for
situations, are viewed as immature, and frustrated with situations they typically see as
implacable, and more influential and powerful than she is. She scored somewhat low in
Jones v Jones 7
areas reflecting self-confidence, self-assurance, efficiency and resourcefulness. She
tends to be somewhat dependent and maybe more prone to external controls by others.
This would be consistent with her upbringing and in her previous relationship with Gerry.
Lorrie is dealing with a number of major stressors. She is a working single parent of two
girls each with their own age-related challenges and needs, has been involved in
protracted custody litigation, has emotional states reflecting a need for support, direction,
reinforcement, assurance and validation. She does continue to receive support and
assistance from her parents. She is aware that she can become overwhelmed and
emotionally distraught. However, she has evidenced a capacity to continue to parent
without major deficits evident.
The maternal grandparents, Linda and Harry "Clay" Stamy, acknowledge being a
stabilizing influence in Lorrie and the children's lives. Dr. Mary Bartus-White, in one of my
contacts with her, also noted the stability that Linda Stamy, in particular, brings to the
family. They are aware of their daughter's emotional status and behavioral repertoire and
are accepting the notion that they need to continue to be there to help Lorrie in the event
she maintains primary physical custody. Mrs. Stamy describes a very open relationship
with Megan with whom she has contact with on numerous days of each week. She also
talked about a positive relationship with Tiffany, who she is concerned may have self-
concept issues related to body image. They note both girls want their father's attention
and affection and will do what they can to promote the girls' relationship with their father.
Megan (Issues and Findings):
Megan is an eleven-year-old youngster who will be entering the sixth grade. She is a good
student but struggles with mathematics.
Megan continues to receive counseling from mental health professionals and appears to
be benefiting from her current medication regimen, which addresses her moods as well as
ADHD. She presents as a bright, well-spoken, sensitive, alert, courteous youngster who is
too aware of the dynamics and relationship between and among herself and her family
members.
Megan, as noted above, appears to be the family mediator. She wants a relationship with
both parents, wants everyone to be happy, for the divorce to be over, and for the conflict to
go away. When seen early on during the data collection, (March 2003) she talked about
alternating weeks. Most recently (July 2003) she expressed concerns about her father's
behaviors noted above. She has a good relationship with her father's relationship, Deb,
but does not want to visit unless and until her father stops what she described as his
smoking and drinking. Apparently, Deb also offered Megan some beer. She said that she
stuck her pinky in the beer and didn't like it saying, "It was nasty." Most recently, Megan is
confused and conflicted and is unsure about the outcome of not only the custody but also
her relationship with her parents. She seemed aware of her father and Deb having
intimate relationships. She is very concerned about her father's physical recovery. She
did state "I miss my dad and wish he would change his act."
Jones v Jones
8
A review of collateral information provided by others familiar with Megan indicates with
consistency that she benefits from her medication regimen and her emotional state and
well-being will improve once the parental conflict subsides or resolves.
Tiffany (Issues and Findings):
Tiffany is an honor roll student who is also on mood-related medication. She does not
think she is depressed but she is struggling with her relationships, especially with her
father because of his recent behaviors noted. She wants a relationship with both parents
but indicates that she is more like her mother but does get along with her father, at least
historically. Her former therapist noted that Tiffany's solution to her difficulties was to live
primarily with her father. She indicated to me that, "he takes care of me but he lets me
have my independence." Lorrie seems to provide more supervision and monitoring in that
regard.
Overall, Tiffany sees both parents as supportive, loving and offering assistance to her
when needed. However, given her age, she identifies her mother as being more sensitive
and aware of what she is going through in her adolescence. She described her dad as, "a
guy... he just doesn't understand... personal problems with me and my boyfriend."
However, she misses her father but in a telephone conversation (7/2/03) made it clear that
she will not visit with her father until the drinking issue is resolved.
RECOMMENDATIONS:
I am recommending that primary physical custody of both girls remain with Lorrie. Lorrie is
available on a regular basis for the girls. She has been the primary physical custodian
historically and addresses the girl's emotional, academic, personal,
psychiatric/psychological and medical needs. She is aware of, involved with, and
responsive to the girls and their relationship with their father, is aware of what is happening
with Megan, in particular, academically and has taken steps to address Megan's difficulties
(math) in school. Lorrie continues to have support from her parents. She wants to be
flexible regarding the girls being with Gerry and would promote times other than what the
current Court Order proves - given that he is more responsible and responsive to the girls.
She wants the girls to have positive experiences with their father. Similarly, Gerry
verbalizes his intent to never limit or restrict the girls time with Lorrie should he become
primary custodian. At this time, he primarily is recuperating and recovering from a serious
vehicular accident. However, it is our understanding he intends to return to work. His
work schedule, should it be similar to his work schedule historically, would preclude his
being readily available and an active presence in the girl's lives. During his recuperating
and rehabilitation period, if he is around and the girls visit, there is nothing to preclude his
having partial custody on a regular basis especially during the summer. To assist in that
regard, I am strongly recommending that he and the girls have two or three counseling
sessions together in a neutral, supportive and safe environment to address the girls
concerns regarding his recent reported behaviors.
Lorrie has an intimate knowledge of the girls, she knows their friends, she is in contact with
school personnel and her involvement in that regard, exceeds Gerry's. Developmentally,
the girls are in a psychosexual developmental stage where their needs would better be
Jones v Jones
9
met with Lorrie as the primary physical custodian. Lorrie also apparently monitors and
supervises the girls, especially Tiffany in her current relationship with boys. Lorrie has a
continuing working relationship with health professionals involved in the girls' lives. She
continues to receive the support of her parents and in combination assured that the girls'
needs are addressed.
I am recommending some short-term counseling (five to six sessions) between the parents
to help them address more effective co-parenting and gain insights regarding how their
behaviors toward one another impact the girls. At a minimum, both parents need to stop
sharing their opinions regarding the other - basically not talk about the other parent in
earshot of the girls whether they are awake or asleep.
Respectfully,
v
Stanley E. Schneider, Ed.D.
Diplomate
Professional Academy of Custody Evaluation
SES/aw
Exhibit F
MAR 0 3 2004
LORRIE JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
GERALD JONES, :NO. 2001-3299 CIVIL TERM
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW9 this S? w day of J/U zzl1 , 2004, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. A Hearing is scheduled in Court Room No. Y_, of the Cumberland
County Court House, on the d 7 ¢ day of 7h 2004, at 9:36
o'clock, A.. M., at which time testimony will be t cen. For purposes of this Hearing,
the Father shall be deemed to be the moving party and shall proceed initially with
testimony. Counsel for each party shall file with the Court and opposing counsel a
Memorandum setting forth each party's position on custody, a list of witnesses who will
be expected to testify at the Hearing and a summary of the anticipated testimony of each
witness. These Memoranda shall be filed at least ten days prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties, the following
shall remain in effect:
The prior Order of Court dated November 8, 2002 is hereby vacated.
4. The Father, Gerald Jones, and the Mother, Lorrie Jones shall have shared
legal custody of Tiffany Nicole Jones, born June 18, 1988 and Megan Rebecca Jones,
born. June 14, 1992. Each parent shall have an equal right, to be exercised jointly with
the other parent, to make all major non-emergency decisions affecting the children's
general well-being including, but not limited to, all decisions regarding their health,
education and religion.
5. Mother shall have primary physical custody of the children.
6. Father shall have the following periods of partial physical custody of the
children beginning March 12, 2004:
A. Alternating weekends, Friday at 4:30 p.m. to Sunday at 6:00 p.m., except that
for March 12, 2004 weekend, the Friday pickup time shall be 8:00 p.m.
because one of the children has a doctor's appointment in Lancaster.
B. Three nonconsecutive weeks, one in June, July and August, provided he give
notice to Mother by May 31 and said weeks do not conflict with Mother's
scheduled vacation or the children's scheduled activities.
7. Father's alternating weekend schedule is expressly contingent upon Father
attending at least one counseling session with the children and Audrey Aarhus. The first
counseling session is scheduled for March 4, 2004. This condition precedent to the start
of weekend periods, applies only if Father cancels the counseling session, not if the
counselor or the children cancel the session. Both parents shall sign releases so that the
counselor may discuss the counseling with both parties. Father is also expected to attend
a second counseling session on the following Thursday if the counselor is available.
8. Easter shall be shared such that the children will be returned to Mother at
2:00 p.m.
9. Mother shall have physical custody of the children on Mother's Day from
9:00 a.m. to 9:00 p.m. Father shall have physical custody of the children on Father's Day
from 9:00 am. to 9:00 p.m.
10. In the event that either party is in need of babysitting services for more
than two hours during their period of custody, they shall contact the non-custodial parent
and offer the opportunity to care for the children.
11. Transportation shall be shared such that the parties shall meet at K-Mart in
Carlisle to exchange custody.
12. Father shall administer or guarantee that Megan's caregiver will
administer Megan's prescription medication, although it is noted that Father objects to
the child taking the medication.
13. Each party shall be responsible for transporting the children to their
doctor, dentist, orthodontist or other medical appointments.
14. Each party is responsible for transporting the children to their regularly
scheduled extracurricular activities and jobs.
15. Neither party shall do or say or permit others to do or say anything which
may estrange the children from the other parent, injure the opinion of the children as to
the other parent, or hamper the free and natural development of the children's love and
respect for the other parent.
16. Both parties shall have liberal telephone contact with the children while
the children are in the custody of the other parent. Father shall at the conclusion of the
conciliation conference supply a land line telephone number to Mother. Mother may
only use this number for emergency purposes and to contact the children while they are
in Father's custody. Custody matters/requests/information shall not be relayed through
the children.
17. The parents shall, as soon as practicable, begin co-parenting counseling
through Franco Associates.
18. Neither party may consume alcohol immediately before or during their
periods of physical custody.
19. Neither party may smoke in the children's presence.
20. Neither party may view pornographic or sexually explicit movies while
the children are in their physical custody.
21. The parties may modify this Order by mutual agreement. In the absence
of mutual consent, the terms of this Order shall control.
BY THE COURT,
iSi n #t-m
fivin A. Hess, J.
cc: Karl E. Rominger, Esquire, counsel for Father
Carol Lindsay, Esquire, counsel for Mother
rPUE COPY FROM RECORl3
Lt- • ;:yiimotnt Whooof, I here unto set nqr hand
Q seal of said Court at Carlisle, Pa.
Ana
' hdthondouv
LORRIE JONES,
Plaintiff
V.
GERALD JONES,
Defendant
PRIOR JUDGE: Kevin A. Hess, J.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2001-3299 CIVIL TERM
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 Children who are the subjects of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Tiffany Nicole Jones June 18, 1988 Mother
Megan Rebecca Jones June 14, 1992 Mother
2. A Conciliation Conference was held March 2, 2004 with the following
individuals in attendance: The Father, Gerald Jones, with his counsel, Karl E. Rominger,
Esquire, and the Mother, Lorrie Jones, with her counsel, Carol Lindsay, Esquire.
3. The Honorable Kevin A. Hess previously entered an Order on November
8, 2002 providing for shared legal custody, with Mother having primary physical custody
and Father having periods of partial physical custody on alternating weekends, Tuesday
and Thursday after school and three weeks in the summer. The Order also provided for a
custody evaluation to be performed by Dr. Stanley Schneider. Dr. Schneider
recommended Mother continue to have primary physical custody. Father filed a Petition
to Modify and Contempt alleging that he has not had contact with the children since July,
2003, except for limited telephone contact.
4. Father's position on custody is as follows: Father seeks shared legal and
primary physical custody of the children. Father disagrees with Dr. Schneider's
evaluation claiming that there is additional information that Dr. Schneider did not
consider. He alleges Mother has alienated the children against him. He denies drinking
in the car with the children. Father maintains that Mother is in contempt of the
November 8, 2002 Order of Court because she has not sent the children for the
alternating weekends.
5. Mother's position on custody is as follows: Mother seeks shared legal
custody and primary physical custody with Father having an alternating weekend
schedule. Mother believes that Dr. Schneider's recommendations should be implemented
including the counseling. She maintains that the children do not want to visit Father
because of his reprehensible behaviors of drinking while driving, smoking and viewing
pornographic movies. Mother asserts she is not in contempt of the prior Order of Court
because the children would not be safe with Father due to his drinking.
6. The Conciliator recommends an Order in the form as attached scheduling
a Hearing and entering an order providing for shared legal custody, Mother having
primary physical custody, and Father having alternating weekends. It is expected that the
Hearing will require one day.
Date Acq eline M. Verney, Esquire
Custody Conciliator
NOV072002
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.2001-3299 CIVIL TERM
GERALD W. JONES, : CIVIL ACTION - LAW
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this f ` day of ,1/.....-r.? . 2002, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. Father is in contempt of the Order of Court dated May 2, 2002. Father
may purge the contempt by scheduling and following through with the custody evaluation
with Dr. Schneider.
2. The prior Orders of Court, dated July 2, 2001, August 17, 2001 and May
3. 2002. are hereby vacated in their entirety and replaced with the following:
3. The Mother, Lorrie A. Jones, and the Father, Gerald W. Jones, shall have
shared legal custody of Tiffany Nicole Jones, born June 18. 1988 and Megan Rebecca
Jones, born June 14, 1992. Each parent shall have an equal right, to be exercised jointly
with the other parent, to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion.
4. Mother shall have primary physical custody of the children.
5. Father shall have periods of partial physical custody of the children as
follows:
a. Every Tuesday and Thursday from 4:30 p.m. to 8:00 p.m.
b. Alternating weekends from Friday at 4:30 p.m. to Sunday at 6:00 p.m.
c. Father shall have three nonconsecutive weeks of partial physical custody of
the children, one week in June. July and August, provided he give notice to
Mother by May 31.2002 and said weeks do not conflict with Mother's
scheduled vacation or the children's scheduled activities.
6.
Mother shall have physical custody of the children on Mother's Day from 9:00 a.m. to
9:00 p.m. Father shall have physical custody of the children on Father's Day from 9:00
a.m. to 9:00 p.m.
(ZP
7. In the event that either party is in need of babysitting services for more
than two hours during their period of custody, they shall contact the non-custodial parent
and offer the opportunity to care for the children.
8. The parties shall submit to a custody evaluation with Dr. Stanley
Schneider and share equally the expenses for said evaluation. In the event that either
party disagrees with the custody evaluation recommendation, they may contact the
Conciliator to schedule another Conciliation Conference.
9. The receiving party shall be responsible for the transportation of the
children unless otherwise agreed by the parties.
10. Father shall administer or guarantee that Megan's caregiver will
administer Megan's prescribed medication, although it is noted that Father objects to the
child taking the medication.
11. Each party shall be responsible for transporting the children to their
doctor, dentist, orthodontist or other medical appointments.
12. Each party is responsible for transporting the children to their regularly
scheduled extracurricular activities.
13. Neither party shall do or say or permit others to do or say anything which
may estrange the children from the other parent, injure the opinion of the children as to
the other parent, or hamper the free and natural development of the children's love and
respect for the other parent.
14. Both parties shall have liberal telephone contact with the children while
the children are in the custody of the other parent. The parties will only utilize the home
telephone number for emergency health care contact. Otherwise cell phone calls will be
utilized or e-mail. Custody matters/requests/information shall not be relayed through the
children.
15. 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.
11_g_o? R?s
BY THE COURT.
J.
cc. arol J. Lindsay, Esquire. Counsel for Mother
,,, arl E. Rominger. Esquire, Counsel for Father
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : 2001-3299 CIVIL TERM
GERALD W. JONES, : CIVIL ACTION - LAW
Defendant
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:
I. The pertinent information concerning the Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Tiffany Nicole Jones June 18, 1988 Mother
Megan Rebecca Jones June 14. 1993 Mother
2. A Conciliation Conference was held in this matter on November 6, 2002,
with the following individuals in attendance: Mother, Lorrie A. Jones, was present with
her counsel, Carol J. Lindsay. Esquire. Father, Gerald W. Jones was present with his
counsel, Karl E. Romingen Esquire.
3. Prior Orders of Court dated July 2.2001. August 17, 2001 and May 3.
2002 were previously entered by the Honorable Edgar B. Bayley.
4. Presently before the court is Mother's Petition for Contempt. The Order
of Court dated May 2, 2002 ordered the parties to undergo a custody evaluation with Dr.
Schneider. Father has failed to schedule any appointment with Dr. Schneider. I
recommend that Father be found in contempt of the May 3, 2002 Order of Court, but he
may purge the contempt by scheduling an appointment and following through with the
custody evaluation.
5. The parties agreed to an Order in the form as attached.
uz
Date cq line M. Verney, Esquire
Custody Conciliator
MAR? Z004
LORRIE JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
GERALD JONES, : NO. 2001-3299 CIVIL TERM
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 6-1'4 day of . 2004, upon
consideration of the attached Custody Conciliation R port, it is ordered and directed as
follows:
1. A Hearing is schedujed in Court Room No. , of the Cumberland
County Court House, on the .27! day of 2004, at
o'clock, J. M., at which time testimony will be tal n. For purposes of this Hearing,
the Father shall be deemed to be the moving party and shall proceed initially with
testimony. Counsel for each party shall file with the Court and opposing counsel a
Memorandum setting forth each party's position on custody, a list of witnesses who will
be expected to testify at the Hearing and a summary of the anticipated testimony of each
witness. These Memoranda shall be filed at least ten days prior to the Hearing date.
2. Pending further Order of Court or agreement of the parties, the following
shall remain in effect:
The prior Order of Court dated November 8, 2002 is hereby vacated.
4. The Father, Gerald Jones, and the Mother, Lome Jones shall have shared
legal custody of Tiffany Nicole Jones, born June 18, 1988 and Megan Rebecca Jones,
bom June 14, 1992. Each parent shall have an equal right, to be exercised jointly with
the other parent, to make all major non-emergency decisions affecting the children's
general well-being including, but not limited to, all decisions regarding their health,
education and religion.
5. Mother shall have primary physical custody of the children.
6. Father shall have the following periods of partial physical custody of the
children beginning March 12, 2004:
lya'UNCHiUM :111 j0
3?iia0-43'!Ij
A. Alternating weekends, Friday at 4:30 p.m. to Sunday at 6:00 p.m., except that
for March 12, 2004 weekend, the Friday pickup time shall be 8:00 p.m.
because one of the children has a doctor's appointment in Lancaster.
B. Three nonconsecutive weeks, one in June, July and August, provided he give
notice to Mother by May 31 and said weeks do not conflict with Mother's
scheduled vacation or the children's scheduled activities.
7. Father's alternating weekend schedule is expressly contingent upon Father
attending at least one counseling session with the children and Audrey Aarhus. The first
counseling session is scheduled for March 4, 2004. This condition precedent to the start
of weekend periods, applies only if Father cancels the counseling session, not if the
counselor or the children cancel the session. Both parents shall sign releases so that the
counselor may discuss the counseling with both parties. Father is also expected to attend
a second counseling session on the following Thursday if the counselor is available.
8. Easter shall be shared such that the children will be returned to Mother at
2:00 p.m.
9. Mother shall have physical custody of the children on Mother's Day from
9:00 a.m. to 9:00 p.m. Father shall have physical custody of the children on Father's Day
from 9:00 a.m. to 9:00 p.m.
10. In the event that either party is in need of babysitting services for more
than two hours during their period of custody, they shall contact the non-custodial parent
and offer the opportunity to care for the children.
11. Transportation shall be shared such that the parties shall meet at K-Mart in
Carlisle to exchange custody.
12. Father shall administer or guarantee that Megan's caregiver will
administer Megan's prescription medication, although it is noted that Father objects to
the child taking the medication.
13. Each party shall be responsible for transporting the children to their
doctor, dentist, orthodontist or other medical appointments.
14. Each party is responsible for transporting the children to their regularly
scheduled extracurricular activities and jobs.
15. Neither party shall do or say or permit others to do or say anything which
may estrange the children from the other parent, injure the opinion of the children as to
the other parent, or hamper the free and natural development of the children's love and
respect for the other parent.
16. Both parties shall have liberal telephone contact with the children while
the children are in the custody of the other parent. Father shall at the conclusion of the
conciliation conference supply a land line telephone number to Mother. Mother may
only use this number for emergency purposes and to contact the children while they are
in Father's custody. Custody matters/requests/information shall not be relayed through
the children.
17. The parents shall, as soon as practicable, begin co-parenting counseling
through Franco Associates.
18. Neither party may consume alcohol immediately before or during their
periods of physical custody.
19. Neither party may smoke in the children's presence.
20. Neither party may view pornographic or sexually explicit movies while
the children are in their physical custody.
21. The parties may modify this Order by mutual agreement. In the absence
of mutual consent, the terms of this Order shall control.
BY THE COURT,
J.
cc: Karl E. Rominger, Esquire, counsel for Fat}:
Carol Lindsay. Esquire, counsel for Mother
0V
:
MAR 0 3 7f1114
LORRIE JONES,
Plaintiff
V.
GERALD JONES,
Defendant
PRIOR JUDGE: Kevin A. Hess, J.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2001-3299 CIVIL TERM
: 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 Children who are the subjects of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Tiffany Nicole Jones June 18, 1988 Mother
Megan Rebecca Jones June 14. 1992 Mother
2. A Conciliation Conference was held March 2, 2004 with the following
individuals in attendance: The Father, Gerald Jones, with his counsel, Karl E. Rominger,
Esquire, and the Mother, Lome Jones, with her counsel, Carol Lindsay, Esquire.
3. The Honorable Kevin A. Hess previously entered an Order on November
8, 2002 providing for shared legal custody, with Mother having primary physical custody
and Father having periods of partial physical custody on alternating weekends, Tuesday
and Thursday after school and three weeks in the summer. The Order also provided for a
custody evaluation to be performed by Dr. Stanley Schneider. Dr. Schneider
recommended Mother continue to have primary physical custody. Father Fled a Petition
to Modify and Contempt alleging that he has not had contact with the children since July,
2003, except for limited telephone contact.
4. Father's position on custody is as follows: Father seeks shared legal and
primary physical custody of the children. Father disagrees with Dr. Schneider's
evaluation claiming that there is additional information that Dr. Schneider did not
consider. He alleges Mother has alienated the children against him. He denies drinking
in the car with the children. Father maintains that Mother is in contempt of the
November S, 2002 Order of Court because she has not sent the children for the
alternating weekends.
5. Mother's position on custody is as follows: Mother seeks shared legal
custody and primary physical custody with Father having an alternating weekend
schedule. Mother believes that Dr. Schneider's recommendations should be implemented
including the counseling. She maintains that the children do not want to visit Father
because of his reprehensible behaviors of drinking while driving, smoking and viewing
pornographic movies. Mother asserts she is not in contempt of the prior Order of Court
because the children would not be safe with Father due to his drinking.
6. The Conciliator recommends an Order in the form as attached scheduling
a Hearing and entering an Order providing for shared legal custody, Mother having
primary physical custody, and Father having alternating weekends. It is expected that the
Hearing will require one day.
-1
3 . ,? -off/ i ...?..... ?t V?-•_-.?.?
Date ificqtkine M. Verney, Esquire
Custody Conciliator
LORRIE JONES IN THE COURT OF COMMON PLEAS OF
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V.
GERALDJONES
DEFENDANT
• 01-3299 CIVIL ACTION LAW
. IN CUSTODY
ORDER OF COURT
AND NOW, Friday, February 13, 2004 , 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 Tuesday, March 02, 2004 at 9:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court herebv 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: /a/ jacqueZne M. Vema En. C
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
- /7"-/ A4? ha U.
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8Z :£ 1'. L 1833 WZ
?lUv1.':<'?rwGad Ni 90
LORRIE JONES :IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent :CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO: 2001-3299
GERALDJONES
:CIVIL ACTION
Defendant/Petitioner :CUSTODY
ORDER OF COURT
AND NOW, . 2004, upon consideration of the attached Complaint, it is
hereby directed that the parties and their respective counsel appear before
the conciliator, at
on the day of
2004, at
FEB O 5 TOOT
o'clock. _.nn.. for a Pre-Hearing Custody Conference. At such conference, an effort will be
made to resolve the issues in dispute. or if this cannot be accomplished. to define and narrow the
issues to be heard by the Court, and to enter into a temporary order. All children age five or
older may also be present at the conference. Failure to appear at the conference may provide
grounds for entry of a temporary or permanent order.
FOR THE COURT:
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court.
please contact 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 LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
V
LORRIE JONES, :IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent :CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 2001-3299
GERALD JONES :CIVIL ACTION
Defendant/Petitioner :CUSTODY
PETITION TO MODIFY CUSTODY/CONTEMPT
Petitioner is Gerald Jones, who resides at 38 Carlton Avenue, Carlisle, Cumberland
County, Pennsylvania 17013.
2. Respondent is Lorrie Jones. who resides at 408 Walnut Street Unit B, Boiling Springs.
Cumberland County, Pennsylvania 17007.
3. On November 8, 2002, the Honorable Kevin E. Hess entered the following custody
Order. (Attached as Exhibit "A")
4. Since the entry of said Order, there has been a significant change in circumstances in that:
(a) Mother is disobeying the Court Order by not allowing visitation with the Father.
(b) Mother is alienating the children from the Father.
(c) Mother has not paid for the psychological evaluation performed by Dr. Stanley
Schneider as ordered by the Court. Father has paid for the aforementioned evaluation.
(Attached as Exhibit "B")
The best interest of the children will be served by the Court in modifying said Order.
WHEREFORE. Petitioner prays this Court to grant the modification of the custody Order
as follows: Primary Physical Custody for Father, with visitation in Mother and find Mother in
contempt of the Order of Court dated November 8, 2002.
Respectfully Submitted,
Karl E. Rominger. Esquire
Rominger, Bayley & Whare
155 South Hanover Street
Carlisle. PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Defendant/Petitioner
Date: February 4. 2004
LORRIE JONES, :IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 2001-3299
GERALD JONES :CIVIL ACTION
Defendant :CUSTODY
CERTIFICATE OF SERVICE
1. Karl E. Rominger. Esquire. attorney for Gerald Jones, do hereby certify that I this day
served a copy of the Petition to Modify Custody/Contempt upon the following by depositing
same in the United States mail, postage prepaid, at Carlisle. Pennsylvania, addressed as follows:
Carol J. Lindsay. Esquire
26 West High Street
Carlisle. PA 17013
Karl E. Rominger. Esquire
Attorney for Defendant/Petitioner
Date: Februarv 4. 2004
I verify that the statements made in this petition are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. cons. Stat. § 4904 relating to
unswom falsification to authorities.
3- 7f
Date:
Gerald Jones, Defendant/ titioner
Nov 11 7 2Ulk
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.2001-3299 CIVIL TERM
GERALD W. JONES, : CIVIL ACTION - LAW
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, the +11 day of f 0\/t°mDP_iR , 2002, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. Father is in contempt of the Order of Court dated May 2, 2002. Father
may purge the contempt by scheduling and following through with the custody evaluation
with Dr. Schneider.
2. The prior Orders of Court, dated July 2, 2001, August 17, 2001 and May
3, 2002, are hereby vacated in their entirety and replaced with the following:
3. The Mother, Lorrie A. Jones, and the Father, Gerald W. Jones, shall have
shared legal custody of Tiffany Nicole Jones, bom June 18, 1988 and Megan Rebecca
Jones, born June 14, 1992. Each parent shall have an equal right, to be exercised jointly
with the other parent, to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion.
4. Mother shall have primary physical custody of the children.
5. Father shall have periods of partial physical custody of the children as
follows:
a. Eery Tuesday and Thursday from 4:30 p.;n. to 8:00 p.m.
b. Alternating weekends from Friday at 4:30 p.m. to Sunday at 6:00 p.m.
c. Father shall have three nonconsecutive weeks of partial physical custody of
the children, one week in June, July and August, provided he give notice to
Mother by May 31, 2002 and said weeks do not conflict with Mother's
scheduled vacation or the children's scheduled activities.
6.
Mother shall have physical custody of the children on Mother's Day from 9:00 a.m. to
9:00 p.m. Father shall have physical custody of the children on Father's Day from 9:00
a.m. to 9:00 p.m.
??c?{idvf "A"
7. In the event that either party is in need of babysitting services for more
than two hours during their period of custody, they shall contact the non-custodial parent
and offer the opportunity to care for the children.
8. The parties shall submit to a custody evaluation with Dr. Stanley
Schneider and share equally the expenses for said evaluation. In the event that either
party disagrees with the custody evaluation recommendation, they may contact the
Conciliator to schedule another Conciliation Conference.
9. The receiving party shall be responsible for the transportation of the
children unless otherwise agreed by the parties.
10. Father shall administer or guarantee that Megan's caregiver will
administer Megan's prescribed medication, although it is noted that Father objects to the
child taking the medication.
11. Each party shall be responsible for transporting the children to their
doctor, dentist, orthodontist or other medical appointments.
12. Each party is responsible for transporting the children to their regularly
scheduled extracurricular activities.
13. Neither party shall do or say or permit others to do or say anything which
may estrange the children from the other parent, injure the opinion of the children as to
the other parent, or hamper the free and natural development of the children's love and
respect for the other parent.
14. Both parties shall have liberal telephone contact with the children while
the children are in the custody of the other parent. The parties will only utilize the home
telephone number for emergency health care contact. Otherwise cell phone calls will be
utilized or e-mail. Custody matters/requests/information shall not be relayed through the
children.
15. 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.
cc: Carol J. Lindsay, Esquire, Counsel for Mother I'• t ""`y "'?=' ' ?''`'' L;`.;.; :t my hand
Karl E. Rominger, Esquire, Counsel for Father :.,;I °( a 'a,
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LORRM A. JONES
IN THE COURT OF COMMON PLEAS OF
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V.
• 01-3299 CIVIL ACTION LAW
GERALD W. JONES
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Wednesday, August 28, 2002 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse Carlisle on Wednesday, September 18, 2002 at 3:30 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: ls/ JUQudneM. Verney, o
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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
.kv foie 8
zo
L?gz9i?n
Lome A. Jones,
Petitioner
V.
Gerald W. Jones,
Respondent
ORDER OF COURT
AND NOW, this day of
In the Court of Common Pleas
Cumberland County, Pennsylvania
No. 2001-3299 Civil Term
Civil Action - Law
In Custody
2002, upon consideration of the
attached Petition for Contempt, it is hereby directed that the parties and their respective
counsel appear before the
the conciliator, at
on the day of , 2002, at
o'clock, _.m., for a Hearing on the Contempt. At such Hearing, 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 five or older
may be present at the Hearing. Failure to appear at the Hearing may provide grounds for
entry of a temporary or permanent order.
BY THE COURT:
By:
Custody Conciliator
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTOIU6TS•ATtlAW
26 W. High Street
Carlisle. PA
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the
court, please contact 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 PAPERTO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle PA 17013
Phone: (717) 249-3166 or 800-990-9108
Lome A. Jones, In the Court of Common Pleas
Petitioner Cumberland County, Pennsylvania
V. No. 2001-3299 Civil Teri
Gerald W. Jones, Civil Action - Law
Respondent In Custody
PETITION FOR CONTEMPT
AND NOW, comes the Petitioner, Lome A. Jones, by and through her attorney,
Saidis, Shuff, Flower & Lindsay and respectfully avers the following:
1. The Petitioner is Lome Jones an adult individual residing at 408 Walnut Street,
Unit B, Boiling Springs, Cumberland County, Pennsylvania 17007.
2. Your Respondent is Gerald W. Jones an adult individual residing at 38 Carlton
Avenue, Carlisle, Cumberland County, Pennsylvania 17013.
3. On or about May 3, 2002, a Court Order was entered providing that the parties
shall submit to a custody evaluation with Dr. Stanley Schneider; a copy of said
Order is attached hereto and made a part hereof marked as "Exhibit A".
4. Since the Order was in place, the Respondent has refused to contact Dr. Schneider
and make an appointment to move the custody evaluation along.
5. The Petitioner has her first appointment with Dr. Schneider on October 8, 2002,
SAIDIS
SHUFF, FLOWER
& LINDSAY
ArIUMMI-AT-JAW
26 W. High Street
Carlisle, PA
and has been trying to get in before that time but was given information that the
Respondent has refused to contact them at this time.
6. In addition, the Respondent has advised that he will refuse to take the children to
their regularly scheduled activities during his periods of custody, including but not
limited to the cheerleading practices and football games for Megan.
7. Further, it has come the attention of the Petitioner that the Respondent refuses to
give the child, Megan, her medication, and throws it away during his periods of
partial physical custody.
WHEREFORE, the Petitioner respectfully requests your Honorable Court to find the
Respondent, Gerald W. Jones, in contempt as follows:
1. To order him to immediately contact Dr. Stanley Schneider and begin his course of
evaluation for the custody proceedings;
2. Order the said Gerald W. Jones to take the children to their regularly scheduled
activities during his periods of partial physical custody; and
3. Give the children any medication that they are directed by a physician to consume.
Respectfully submitted,
SAIDIS, SHLIFF, FLOWER & LINDSAY
Date: $ - 15 - 02 By:
Johnna opec ,Esq re
Supreme Court ID #53147
26 W. High Street
Carlisle PA 17013
(717) 243-6222
Attorney for the Petitioner
SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle. PA
VERIFICATION
I verify that the statements made in this Petition for Contempt 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 unswom falsification to authorities.
Dated: Q. (YGYUOO
Lorrie A. Jones, Petitio er
SAIDIS
SNUFF, FLOWER
& LINDSAY
26 W. High Slreel
Carlisle, PA
I 6 MAY 0 2 2002 'D4
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2001-3299 CIVIL TERM
GERALD W. JONES, : CIVIL ACTION - LAW
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this _3 AA day of , 2002, upon
consideration of the attached Custody Conciliation R port, it is ordered and directed as
follows:
1. The prior Order of Court dated August 17, 2001 shall remain in full force
and effect, except as amended as follows:
2. Father shall have three nonconsecutive weeks of partial physical custody
of the children, one week in June, July and August, provided he give notice to Mother by
May 31, 2002 and said weeks do not conflict with Mother's scheduled vacation or the
Children's scheduled activities.
3. Mother shall have physical custody of the Children on Mother's Day from
9:00 a.m. to 9:00 pm. Father shall have physical custody of the Children on Father's
Day from 9:00 a.m. to 9:00 p.m.
4. The parties shall submit to a custody evaluation with Dr. Stanley
Schneider and share equally the expenses for said evaluation. In the event that either
party disagrees with the custody evaluation recommendation, they may contact the
Conciliator to schedule another Conciliation Conference.
5. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY THE COURT,
J.
cc: Johns J. Kopecky, Esquire, Counsel for Mother
Karl E. Rominger, Esquire, Counsel for Father
TRUE COPY FRou REcoft
W. whet d. I hats uldp art ffq bw
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II
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. : 2001-3299 CIVIL TERM
GERALD W. JONES, CIVIL ACTION -LAW
Defendant
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 Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Tiffany Nicole Jones June 18, 1988 Mother
Megan Rebecca Jones June 14, 1992 Mother
2. A Conciliation Conference was held in this matter on May 1,2002, with
the following individuals in attendance: Mother, Lorrie A. Jones, was present with her
counsel, Johnna J. Kopecky, Esquire. Father, Gerald W. Jones was present with his
counsel, Karl E. Rominger, Esquire.
3. Prior Orders of Court, dated July 2, 2001 and August 17, 2001 were
previously entered by the Honorable Edgar B. Bayley.
4. The parties agreed to an Order in the form as attached.
S a -OA
Date
acq line M. Verney, Esquire
Custody Conciliator
AUG 15 2001
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. NO. 2001-3299 CIVIL TERM
GERALD W. JONES, CIVIL ACTION -LAW
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 17` day of (X.au+.& , 2001, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. The prior Order of Court dated July 2, 2001 shall remain in full force and
effect until August 26, 2001, at which time the prior Order of Court is hereby vacated and
this Order shall take effect.
2. The Mother, Lome A. Jones, and the Father, Gerald W. Jones, shall have
shared legal custody of Tiffany Nicole Jones, born June 18, 1988 and Megan Rebecca
Jones, born June 14, 1992. Each parent shall have an equal right, to be exercised jointly
with the other parent, to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion.
3. Beginning Sunday, August 26, 2001, Mother shall have primary physical
custody of the children.
4. Father shall have periods of partial physical custody of the children as
follows:
a. Every Tuesday and Thursday from 4:00 p.m. to 8:00 p.m.
b. Alternating weekends from Friday at 4:00 p.m. to Sunday at 6:00 p.m.
Father's alternating weekends shall begin September 7, 2001.
5. The receiving party shall be responsible for the transportation of the
children unless otherwise agreed by the parties.
6. Neither party shall do or say or permit others to do or say anything which
may estrange the children from the other parent, injure the opinion of the children as to
the other parent, or hamper the free and natural development of the children's love and
respect for the other parent.
7. Both parties shall have liberal telephone contact with the children while
the children are in the custody of the other parent.
8. This Order shall not act to prejudice either party regarding their respective
positions concerning custody.
9. This Order is considered a Temporary Order 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. In the event that Father's work schedule changes,
Father may immediately request another conciliation Conference.
BY THE COURT,
?s i &.004 !2. /14*
J.
cc: Johnna J. Kopecky, Esquire, Counsel for Mother
Philip H. Spare, Esquire, Counsel for Father
TRUE COPY FROM RECORD
In Testimony whereof, I here unto set my hand
and the seal of said Court at Carlisle, Pa.
This 12 -'?' day -2L-? ,
Prothonofary
:A.
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. : 2001-3299 CIVIL TERM
GERALD W. JONES, CIVIL ACTION -LAW
Defendant
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 Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Tiffany Nicole Jones June 18, 1988 Mother
Megan Rebecca Jones June 14, 1992 Mother
2. A Conciliation Conference was held in this matter on August 15, 2001,
with the following individuals in attendance: Mother, Lome A. Jones, was present with
her counsel, Johnna J. Kopecky, Esquire. Father, Gerald W. Jones was present with his
counsel, Philip H. Spare, Esquire.
3. A prior Order of Court dated July 2, 2001 was previously entered by the
Honorable Edgar B. Bayley.
4. The parties agreed to an Order in the form as attached.
S'-IS'0
Date
d.
acq line M. Vemey, Esquire
Custody Conciliator
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Student Information
L NAME: Jones GRADE: S/»/ey
F NAME Megan HOMEROOM
Middle I: ® ID NUMBER:
Parent/Guardian Secondary Parent/Guardian
Primary Par
Relationship to Student Parent/Guardian
Mrs. Louie Jones
Address
1408 BI I Walnut Street I
PA
Home Phone:
Work Phone:
Primary EMail:
Secondary EMail:
Emergency Contact/Medical
Emergency Contact 1:
Emergency Contact 2:
DOCTOR:
YELLOW BREECHES MIDDLE SCHOOL /
STUDENT DEMOGRAPHIC FORM V
06 ? 113
100600
Dr.
0 Gerald Jones
Address
Home Phone:
Work Phone:
Would you like a mailing sent to this address?
DENTIST: Dr. Burkett
INSURANCE: Health Assurance PPO
Permission to Transport to Hospital 0
Preferred Hospital: Carlisle
.E v-e..1y YN R.p?,Q 11 Sk5 $-(a6 b (-
Allergies: Allergies, ADHD
Permission to give the following medications
Tylenol: DY
Ibuprofen: DY
Antacid: 0
Midol:: YO
PARENT SIGNATURE/
ywsam DENT SIGNATURE
PLEASE REVIEW THE DEMOGRAPHIC AND HEALTH INFORMATION LISTED ABOVE. IF? E ANY
CHANGES MAKE THEM ON THIS FORM. STUDENTS MUST RETURN THIS FORM TO THEIR HOMEROOM
TEACHER BY Thursday, August 28, 2008
BOILING SPRINGS HIGH SCHOOL
STUDENT DEMOGRAPHIC FORM
Student Information
Last Name: _ Jones
First Name: Tiffany
Middle I: N
Primary Parent/Guardian
Relationship to Student
Parent/Guardian
Ms. Lorrie Jones
Address
408B ?- Walnut Street
Boiling Springs I PA _ 17007
Home Phone: 960-9509
Work Phone: 243-1212
EMail:
Grade: 10 (' S1) 7fiv
Homeroom: z13
ID Number: osOS1°I
Secondary Parent/Guardian
Relationship to Student Parent/Guardian
Mr. Gerald Jones
Address
Would you like a mailing sent to this address?
Emergency Contact/Medical Information:
Emergency Contact 1:
Emergency Contact 2:
DOCTOR:
DENTIST: Dr. Burkett-, Allergies: Dust/Pollen/Perfume
INSURANCE: Health Assurance'pp Permission to give the following medications
Permission to Transport to Hospital I Y Antacid: DY Tylenol: FYj
Preferred Hospital: Carlisle Midol: DY Ibuprofen rl
Other Information: If there are any additional health or family concerns (unique heath issues,
custody arrangments, student restrictions, etc...) which you would like to inform the school,
please provide that Information on the back of this form or schedule a meeting with your child's
principal, guidance counselor, or school nurse.
IQ.=
Parent/Guardian Student Signature
Signature '-
PLEASE REVIEW THE DEMOGRAPHIC AND HEALTH INFORMATION LISTED ABOVE. IF THERE ARE ANY
CHANGES, MAKE THEM ON THIS FORM. STUDENTS MUST RETURN THIS FORM TO THEIR HOMEROOM
TEACHER BY Thursday, August 28, 2003
Work Phone: 245-0384
Lorrie A. Jones, In the Court of Common Pleas
Petitioner Cumberland County, Pennsylvania
V. No. 2001-3299 Civil Term
Gerald W. Jones, Civil Action - Law
Respondent In Custody
ORDER OF COURT
AND NOW, this 3i'day of A,.v , 2004, upon the agreement of
the parties, it is hereby ordered and directed that Plaintiff, Lorrie A. Jones, shall have
full legal custody of the parties children Tiffany Nicole Jones born June 18, 1988 and
Megan Rebecca Jones born June 14, 1992. The Plaintiff shall have primary physical
custody of the children and Defendant shall have partial custody at times the parties
can agree.
BY THE COURT:
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATMRNEYS•AT•LAW
26 W. High Street
Carlisle, PA
By:
I
I
LORRIE JONES,
Plaintiff/Respondent
v
GERALD JONES
Defendant/Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 2001-3299
: CIVIL ACTION
:CUSTODY
: JUDGE KEVIN A. HESS
PETITION TO MODIFY CUSTODY
1. Petitioner is Gerald Jones, who resides at 38 Carlton Avenue, Carlisle, Cumberland
County, Pennsylvania 17013.
2. Respondent is Lorrie Jones, who resides at 234 Meals Drive, Carlisle,
Cumberland County, Pennsylvania 17015.
3. On November 8, 2002, the Honorable Kevin A. Hess entered the following custody
Order. (Attached as Exhibit "A")
4. Since the entry of said Order, there has been a significant change in circumstances in that:
(a) The minor child, Megan Jones who is now sixteen (16) years of age has moved in
with Petitioner and desires to continue living with him even after the school year begins.
(b) Petitioner believes and therefore avers that the child is old enough to know who she
wishes to live with.
5. The best interest of the child will be served by the Court in modifying said Order.
LORRIE JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v : NO. 2001-3299
GERALD JONES : CIVIL ACTION
Defendant :CUSTODY
: JUDGE KEVIN A. HESS
CERTIFICATE OF SERVICE
I, Vincent M. Monfredo, Esquire, attorney for Gerald Jones, do hereby certify that I this
day served a copy of the Petition to Modify Custody upon the following by depositing same in
the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows:
Carol J. Lindsay, Esquire
26 West High Street
Carlisle, PA 17013
Date: /-2 /y vy
Respectfully Submitted,
ROMINGER & ASSOCIATES
Vincent M. Monfredo, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 206671
Attorney for Defendant/Petitioner
NOV 12 2M2
NOV 0 72001
LORRIE A. JONES,
Plaintiff
V.
GERALD W. JONES,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.2001-3299 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this _7 day of dnym'baa , 2002, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
1. Father is in contempt of the Order of Court dated May 2, 2002. Father
may purge the contempt by scheduling and following through with the custody evaluation
with Dr. Schneider.
2. The prior Orders of Court, dated July 2, 2001, August 17, 2001 and May
3, 2002, are hereby vacated in their entirety and replaced with the following:
3. The Mother, Lome A. Jones, and the Father, Gerald W. Jones, shall have
shared legal custody of Tiffany Nicole Jones, born June 18, 1988 and Megan Rebecca
Jones, born June 14, 1992. Each parent shall have an equal right, to be exercised jointly
with the other parent, to-make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their
health, education and religion.
4. Mother shall have primary physical custody of the children.
5. Father shall have periods of partial physical custody of the children as
follows:
a. Every Tuesday and Thursday from 4:30 p.m. to 8:00 p.m.
b. Alternating weekends from Friday at 4:30 p.m. to Sunday at 6:00 p.m.
c. Father shall have three nonconsecutive weeks of partial physical custody of
the children, one week in June, July and August, provided he give notice to
Mother by May 31, 2002 and said weeks do not conflict with Mother's
scheduled vacation or the children's scheduled activities.
6.
Mother shall have physical custody of the children on Mother's Day from 9:00 a.m. to
9:00 p.m. Father shall have physical custody of the children on Father's Day from 9:00
a.m. to 9:00 p.m. Aww?
7. In the event that either party is in need of babysitting services for more
than two hours during their period of custody, they shall contact the non-custodial parent
and offer the opportunity to care for the children.
8. The parties shall submit to a custody evaluation with Dr. Stanley
Schneider and share equally the expenses for said evaluation. In the event that either
party disagrees with the custody evaluation recommendation, they may contact the
Conciliator to schedule another Conciliation Conference.
9. The receiving party shall be responsible for the transportation of the
children unless otherwise agreed by the parties.
10. Father shall administer or guarantee that Megan's caregiver will
administer Megan's prescribed medication, although it is noted that Father objects to the
child taking the medication.
11. Each party shall be responsible for transporting the children to their
doctor, dentist, orthodontist or other medical appointments.
12. Each party is responsible for transporting the children to their regularly
scheduled extracurricular activities.
13. Neither party shall do or say or permit others to do or say anything which
may estrange the children from the other parent, injure the opinion of the children as to
the other parent, or hamper the free and natural development of the children's love and
respect for the other parent.
14. Both parties shall have liberal telephone contact with the children while
the children arc in the custody of the other parent. The parties will only utilize the home
telephone number for emergency health care contact. Otherwise cell phone calls will be
utilized or e-mail. Custody matters/requests/information shall not be relayed through the
children.
15. This Order is entered pursuant to an agreement of the parties at a Custody
Conciliation Conference. The parties may modify the provisions of this Order by mutual
consent. In the absence of mutual consent, the terms of this Order shall control.
BY OURT,
,:,I,
S
J.
BUR COPY TOM RE
cc: Carol J. Lindsay, Esquire, Counsel for Mother Tey 1 hare ??
Of If C 9LIk fu d rt at unto try
Karl E. Rominger, Esquire, Counsel for Father
LORRIE A. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :2001-3299 CIVIL TERM
GERALD W. JONES, : CIVIL ACTION - LAW
Defendant
IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley, J.
CUSTODY CONM IATION SIMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Children who are the subject of
this litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Tiffany Nicole Jones June 18,1988 Mother
Megan Rebecca Jones June 14, 1992 Mother
2. A Conciliation Conference was held in this matter on November 6, 2002,
with the following individuals in attendance: Mother, Lorrie A. Jones, was present with
her counsel, Carol J. Lindsay, Esquire. Father, Gerald W. Jones was present with his
counsel, Karl E. Rominger, Esquire.
3. Prior Orders of Court dated July 2, 2001, August 17, 2001 and May 3,
2002 were previously entered by the Honorable Edgar B. Bayley.
4. Presently before the court is Mother's Petition for Contempt. The Order
of Court dated May 2, 2002 ordered the parties to undergo a custody evaluation with Dr.
Schneider. Father has failed to schedule any appointment with Dr. Schneider. I
recommend that Father be found in contempt of the May 3, 2002 Order of Court, but he
may purge the contempt by scheduling an appointment and following through with the
custody evaluation.
5. The pasties agreed to an Order in the form as attached.
1!- 7 oz ?Date Ywq4fine M. Verney, Esquire
Custody Conciliator
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