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HomeMy WebLinkAbout04-5028STACI A. STEEVER, Plaintiff V. JON A. STEEVER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. Oq- ?oml? CIVIL TERM IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Staci A. Steever, an adult individual currently residing at 779 Hamilton Court, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Jon A. Steever, an adult individual currently residing at RR 1, Box 1565, Mifflintown, Juniata County, Pennsylvania. 3. The parties are the natural parents of two (2) children, namely, Harrison Drexel Steever, born May 12, 1998, and Chloe Abigail Steever, born July 13, 1995. The children were not born out of wedlock. 4. For the past five (5) years, or since the children's birth, the children have resided with the following persons at the following addresses for the following periods of time: NAME ADDRESS DATES Jon A. Steever RR 1, Box 1565 July 2004 to Karen Steever Mifflintown, PA Present Carter & Emma (Karen's children) Jon A. Steever 243 South Hanover Street January 2001 to Carlisle, PA July 2004 NAME ADDRESS DATES Jon A. Steever 243 South Hanover Street January 1999 to Staci A. Steever Carlisle, PA January 2001 The natural mother of the children is Staci A. Steever who resides as aforesaid. She is divorced. The natural father of the children is Jon A. Steever who resides as aforesaid. He is married. 5. 6. 7 8. 9. The relationship of the Plaintiff to the children is that of natural mother. The Plaintiff currently resides alone. The relationship of the Defendant to the children is that of natural father. Defendant currently resides with Karen Steever, his wife, and her two children, Carter and Emma. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the children. Plaintiff has no information of any custody proceedings concerning the children pending in any Court of this Commonwealth. It is in the best interest and permanent welfare of the children to grant the relief requested because: a) Plaintiff enjoyed regular and frequent contact with the children before they moved from the area in July 2004; b) Plaintiff believes it is in the children's best interest to maintain the relationship she has with them; and c) Plaintiff believes the limited contact she has had with the children since their move is detrimental to them. 10. Plaintiff does not know any person not a party to this proceeding who claims to have custody or visitation rights with respect to the children. WHEREFORE, Plaintiff requests your Honorable Court to schedule a Custody Conciliation Conference followed by a hearing at which time she should be granted partial physical custody of the children. Respectfully submitted, 0az 1\ 01n ?a x.n n jmxk?dln Hannah Herman-Snyder, Es ire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE: O V S I A. STEE , Plaintiff t C n S' N c.? t? O f-J cn -r+ al i f lr ?C7 u STACI A. STEEVER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 04-5028 CIVIL ACTION LAW JON A.STEEVER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday October 14, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, at 4th Floor Cumberland County Courthouse, Carlisle on Friday, November 05, 2004 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/ Hubert X. Gilroy', Esa_mhc Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR 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 'y/ ar o/ STACI A. STEEVER, Plaintiff V. JON A. STEEVER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-5028 CIVIL ACTION - LAW IN CUSTODY ACCEPTANCE OF SERVICE I, Douglas G. Miller, Esquire acknowledge that on the d3r day of 6 w' , 2004, I received a true and attested copy of a Complaint for Custody and resulting Order of Court dated Thursday, October 14, 2004, filed by Plaintiff, Staci A. Steever, in the above captioned action and acknowledge that I am authorized to do so on behalf of the Defendant, Jon A. Steever. Date: /01; &0 Douglas . Miller, Esquire 60 West lomfret Street Carlisle, PA 17013 C"? Aa -e n7 r :. .. i C STACI A. STEEVER, Plaintiff V. JON A. STEEVER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-5028 IN CUSTODY COURT ORDER AND NOW9 this (4- day o9Avaiz?-.9 upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The father, Jon A. Steever, and the mother Staei A. Steever, shall enjoy shared legal custody of Harrison Drexel Steever, born May 12, 1998 and Chole Abigail Steever, born July 13, 1995. 2. Father shall enjoy primary physical custody of the minor children. 3. Mother shall enjoy periods of temporary physical custody of the minor children as follows: a. On alternating weekends from 5:00p.m. on Friday until 5:00p.m. on Sunday. The parties shall share transportation equally on exchange of custody pursuant to a schedule agreed upon by the parties whereby the parties shall either meet halfway or one parent will pick up and one parent will deliver. b. On the Monday evening following father's weekend, mother shall also have custody at a restaurant at a halfway point between the parties. Mother's custody shall be for a period of two hours, with the parties meeting at the halfway point. C. At such other times as agreed upon by the parties. 4. The parties shall alternate custody of the minor children on major holidays pursuant to a schedule agreed upon by the parties. V 5. Mother shall also have a period of one week of vacation in the summer with the mother to give father at least 30 days notice as to when she intends to exercise vacation. 6. The parties may modify this schedule as they agree. Absent an agreement between the parties, the schedule set forth above shall control. 7. In the event the parties experience any problems with the custody schedule set forth above, legal counsel for the parties may contact the custody Conciliator to schedule a telephone conference call with the Conciliator to address those issues. 8. Both parties shall have reasonable telephone contact with the minor children when they are in the custody of the other parent. BY " Judge Cc: , fouglas G. Miller, Esquire ,yannph Herman-Snyder, Esquire J ;mil 0?'pa -P f-I'l 60 :8 N'Y Z- 030 UOI JONATHAN A. STEEVER, Plaintiff r v. STACI A. STEEVER, Defendant Prior Judge. Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-5028 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children/child who are the subject of this litigation is as follows: Harrison Drexel Steever, born May 12, 1998 and Chloe Abigail Steever, born July 13, 1995. 2. A Conciliation Conference was held on November 5, 2004, with the following individuals in attendance: The mother Staci A. Steever, with her attorney Honnith Herman-Snyder, and the father, Jon A. Steever, with his attorney Douglas G. Miller. 3. The parties agree to the entry of an order in the form as attached. DATE a/ Hubert ) Custody STACI A. STEEVER (SUMMERS), : IN THE COURT OF COMMON PLEAS RespondentlPlaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. 15"O?? No. 2004 - SM JONATHAN A. STEEVER, Petitioner/Defendant CIVIL ACTION - IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW, this 10 day of December, 2007, comes the Defendant, JONATHAN A. STEEVER, by and through his attorneys, Irwin & McKnight, and presents the following Petition for Modification of Custody Order, averring as follows: 1. The Petitioner is Jonathan A. Steever, an adult individual currently residing at RR 3, Box 1565, Mifflintown, Juniata County, Pennsylvania 17059. 2. The Respondent is Staci A. Steever, now known as Staci A. Summers, an adult individual residing at 250 West Ridge Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. On December 1, 2004, an Order of Court was entered in this matter establishing primary physical custody of the children with the Petitioner and partial physical custody of the children for the Respondent. A true and correct copy of said Order signed by the Honorable Edgar B. Bayley, which Order was entered by consent following a Conciliation Conference before Hubert X. Gilroy, Esquire, is attached hereto and incorporated herein by reference as Exhibit "A." 4. The Order of Court essentially established periods of partial physical custody with Respondent on alternating weekends and alternating Monday evenings, although the parties subsequently abandoned the evening exchanges. 5. At the time of the 2004 Order of Court, and for the majority of the lives of the parties' children, Petitioner has been employed as a publishing company editor. 6. In March 2006, Petitioner was laid off from his existing job as a publishing company editor. 7. After a lengthy job search for new employment in his given field, Petitioner obtained a job as a project manager for an educational publisher in Baltimore, Maryland. 8. The Petitioner then began commuting from Mifflintown, Juniata County, Pennsylvania to Baltimore, Maryland. 9. Prior to obtaining the employment position in Maryland, Petitioner and his wife did not have health insurance coverage, were forced to obtain food stamps and other public assistance, and relied upon monies withdrawn from Petitioner's 401(k) retirement plan and credit card debt. 2 10. While Petitioner's new employment in Maryland did not immediately provide him with health insurance benefits and forced him to commute a long distance, Petitioner accepted the position because he had limited job opportunities in the publishing field. it. Furthermore, even after accepting the new job in Maryland, Petitioner continued to be qualified for and receive public assistance benefits. 12. Petitioner therefore continued his search for alternate employment while working in Maryland, and subsequently received a more substantial job offer from a publishing company in Vermont. 13. On or about November 9, 2007, Petitioner accepted the job opportunity with Tuttle Publishing in Vermont due to the increase in salary and employment benefits, particularly health insurance coverage for himself, his wife, and the parties' minor children. 14. Petitioner now seeks the consent of Respondent and/or approval to relocate the parties' minor children to Vermont. 15. Petitioner has offered Respondent the opportunity to substantially increased time during summer and holiday vacations in order to make up for the alternating weekend time she would lose throughout the school year if Petitioner and the children relocate to Vermont. 3 16. Respondent has indicated to Petitioner that she may also be relocating out of Pennsylvania in the near future, presumably to Indiana where the majority of her immediate family is located. 17. Petitioner accordingly requests that this Court modify the current custody schedule granting him primary physical custody during the school year and granting Respondent substitute partial custody during summer and holiday vacations. 18. Petitioner further requests that this Court grant his request to relocate the minor children to Vermont. 19. The best interests and permanent welfare of the child require that the Court modify the current custody schedule as requested in this Petition. 20. Petitioner has previously sought the consent of Respondent in this matter prior to the filing of this Petition, and Respondent has indicated her desire to have a Conciliation Conference scheduled to decide this matter. 4 WHEREFORE, Defendant respectfully seeks the entry of an Order of Court granting Defendant's Petition for Modification of Custody Order. Respectfully submitted, IRWIN & McKNIGHT Dated: December 14, 2007 By: fA &-., d- A* -TA0]r-r1Aw- A ff - OL. Douglas Miller, squire Supreme Court I.D. No. 83776 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Attorney for Defendant VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. a ' JONATHAN A. STEEVER Date: 12/14/07 EXHIBIT "A" STACI A. STEEVER, Plaintiff V. JON A. STEEVER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-5028 IN CUSTODY COURT ORDER 10ece m?e AND NOW, this day ofere?nber, 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The father, Jon A. Steever, and the mother Staci A. Steever, shall enjoy shared legal custody of Harrison Drexel Steever, born May 12, 1998 and Chole Abigail Steever, born July 13, 1995. 2. Father shall enjoy primary physical custody of the minor children. 3. Mother shall enjoy periods of temporary physical custody of the minor children as follows: a. On alternating weekends from 5:00p.m. on Friday until 5:00p.m. on Sunday. The parties shall share transportation equally on exchange of custody pursuant to a schedule agreed upon by the parties whereby the parties shall either meet halfway or one parent will pick up and one parent will deliver. b. On the Monday evening following father's weekend, mother shall also have custody at a restaurant at a halfway point between the parties. Mother's custody shall be for a period of two hours, with the parties meeting at the halfway point. C. At such other times as agreed upon by the parties. 4. The parties shall alternate custody of the minor children on major holidays pursuant to a schedule agreed upon by the parties. 5. 6. 7. 8. Mother shall also have a period of one week of vacation in the summer with the mother to give father at least 30 days notice as to when she intends to exercise vacation. The parties may modify this schedule as they agree. Absent an agreement between the parties, the schedule set forth above shall control. In the event the parties experience any problems with the custody schedule set forth above, legal counsel for the parties may contact the custody Conciliator to schedule a telephone conference call with the Conciliator to address those issues. Both parties shall have reasonable telephone contact with the minor children when they are in the custody of the other parent. BY THE COURT, Cc: Judge Douglas G. Miller, Esquire Hannah Herman-Snyder, Esquire aU=? the sr'- r r 1 ? ..? { 1 ?. fin.. _ ... JONATHAN A. STEEVER, Plaintiff . V. STACI A. STEEVER, . Defendant . Prior Judge. Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-5028 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children/child who are the subject of this litigation is as follows: Harrison Drexel Steever, born May 12, 1998 and Chloe Abigail Steever, born July 13, 1995. 2. A Conciliation Conference was held on November 5, 2004, with the following individuals in attendance: The mother Staci A. Steever, with her attorney Hannah Herman-Snyder, and the father, Jon A. Steever, with his attorney Douglas G. Miller. 3. The parties agree to the entry of an order in the form as attached. DATE Hubert X. Gilroy Esquire Custody Conc' ' for CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: Karl E. Rominger, Esquire Rominger & Associates 155 South Hanover Street Carlisle, PA 17013 Date: December 14, 2007 IRWIN & McKNIGHT Douglas G. JAMer, Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Attorney for Defendant m 4 p q?„ N p n t STACI A. STEEVER (SUMMERS) IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JONATHAN A. STEEVER DEFENDANT 2004-5028 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, December 20, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, January. 11, 2008 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. 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/ Hubert X. Gilroy, Esq. 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 C?-an c/ ` tNi VAWNN2:l,j ZZ :Z Wd OZ 030 LODZ hiViQ G -l('-)'6d 3Hi. ?Q 30U 4-0911) DEC 171007a+? r v STACI A. STEEVER (SUMMERS), : IN THE COURT OF COMMON PLEAS Respondent/Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. raxi" No. 2004 ---5982 JONATHAN A. STEEVER, Petitioner/Defendant CIVIL ACTION - IN CUSTODY ORDER OF COURT AND NOW, this day of , upon consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before the conciliator, at , on the day of at . M. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at this conference may provide grounds for entry of a temporary or permanent order. BY THE COURT, By: J. 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 800-990-9108 717-249-3166 STACI A. STEEVER (SUMMERS), Respondent/Plaintiff V. JONATHAN A. STEEVER, Petitioner/Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 2004 - -SM : CIVIL ACTION - IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW, this 14`h day of December, 2007, comes the Defendant, JONATHAN A. STEEVER, by and through his attorneys, Irwin & McKnight, and presents the following Petition for Modification of Custody Order, averring as follows: 1. The Petitioner is Jonathan A. Steever, an adult individual currently residing at RR 3, Box 1565, Mifflintown, Juniata County, Pennsylvania 17059. 2. The Respondent is Staci A. Steever, now known as Staci A. Summers, an adult individual residing at 250 West Ridge Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. On December 1, 2004, an Order of Court was entered in this matter establishing primary physical custody of the children with the Petitioner and partial physical custody of the children for the Respondent. A true and correct copy of said Order signed by the Honorable Edgar B. Bayley, which Order was entered by consent following a Conciliation Conference before Hubert X. Gilroy, Esquire, is attached hereto and incorporated herein by reference as Exhibit "A." 4. The Order of Court essentially established periods of partial physical custody with Respondent on alternating weekends and alternating Monday evenings, although the parties subsequently abandoned the evening exchanges. 5. At the time of the 2004 Order of Court, and for the majority of the lives of the parties' children, Petitioner has been employed as a publishing company editor. 6. In March 2006, Petitioner was laid off from his existing job as a publishing company editor. 7. After a lengthy job search for new employment in his given field, Petitioner obtained a job as a project manager for an educational publisher in Baltimore, Maryland. 8. The Petitioner then began commuting from Mifflintown, Juniata County, Pennsylvania to Baltimore, Maryland. 9. Prior to obtaining the employment position in Maryland, Petitioner and his wife did not have health insurance coverage, were forced to obtain food stamps and other public assistance, and relied upon monies withdrawn from Petitioner's 401(k) retirement plan and credit card debt. 2 10. While Petitioner's new employment in Maryland did not immediately provide him with health insurance benefits and forced him to commute a long distance, Petitioner accepted the position because he had limited job opportunities in the publishing field. it. Furthermore, even after accepting the new job in Maryland, Petitioner continued to be qualified for and receive public assistance benefits. 12. Petitioner therefore continued his search for alternate employment while working in Maryland, and subsequently received a more substantial job offer from a publishing company in Vermont. 13. On or about November 9, 2007, Petitioner accepted the job opportunity with Tuttle Publishing in Vermont due to the increase in salary and employment benefits, particularly health insurance coverage for himself, his wife, and the parties' minor children. 14. Petitioner now seeks the consent of Respondent and/or approval to relocate the parties' minor children to Vermont. 15. Petitioner has offered Respondent the opportunity to substantially increased time during summer and holiday vacations in order to make up for the alternating weekend time she would lose throughout the school year if Petitioner and the children relocate to Vermont. 3 16. Respondent has indicated to Petitioner that she may also be relocating out of Pennsylvania in the near future, presumably to Indiana where the majority of her immediate family is located. 17. Petitioner accordingly requests that this Court modify the current custody schedule granting him primary physical custody during the school year and granting Respondent substitute partial custody during summer and holiday vacations. 18. Petitioner further requests that this Court grant his request to relocate the minor children to Vermont. 19. The best interests and permanent welfare of the child require that the Court modify the current custody schedule as requested in this Petition. 20. Petitioner has previously sought the consent of Respondent in this matter prior to the filing of this Petition, and Respondent has indicated her desire to have a Conciliation Conference scheduled to decide this matter. 4 WHEREFORE, Defendant respectfully seeks the entry of an Order of Court granting Defendant's Petition for Modification of Custody Order. Respectfully submitted, IRWIN & McKNIGHT -34? - Dated: December 14, 2007 By: Douglas . Miller, squire Supreme Court I.D. No. 83776 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Attorney for Defendant VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. .<'-L Z-?? - JONATHAN A. STEEVER Date: 12/14/07 EXHIBIT "A" STACI A. STEEVER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW JON A. STEEVER, NO. 04-5028 Defendant IN CUSTODY COURT ORDER be-r-C M, e b AND NOW, this day of ?Feren?er, 2004, upon consideration of the attached Custody Conciliation report, it is ordered and directed as follows: 1. The father, Jon A. Steever, and the mother Staci A. Steever, shall enjoy shared legal custody of Harrison Drexel Steever, born May 12, 1998 and Chole Abigail Steever, born July 13, 1995. 2. Father shall enjoy primary physical custody of the minor children. 3. Mother shall enjoy periods of temporary physical custody of the minor children as follows: a. On alternating weekends from 5:00p.m. on Friday until 5:00p.m. on Sunday. The parties shall share transportation equally on exchange of custody pursuant to a schedule agreed upon by the parties whereby the parties shall either meet halfway or one parent will pick up and one parent will deliver. b. On the Monday evening following father's weekend, mother shall also have custody at a restaurant at a halfway point between the parties. Mother's custody shall be for a period of two hours, with the parties meeting at the halfway point. C. At such other times as agreed upon by the parties. 4. The parties shall alternate custody of the minor children on major holidays pursuant to a schedule agreed upon by the parties. 5. Mother shall also have a period of one week of vacation in the summer with the mother to give father at least 30 days notice as to when she intends to exercise vacation. 6. The parties may modify this schedule as they agree. Absent an agreement between the parties, the schedule set forth above shall control. 7. In the event the parties experience any problems with the custody schedule set forth above, legal counsel for the parties may contact the custody Conciliator to schedule a telephone conference call with the Conciliator to address those issues. 8. Both parties shall have reasonable telephone contact with the minor children when they are in the custody of the other parent. BY THE COURT, Cc: R Judge Douglas G. Miller, Esquire Hannah Herman-Snyder, Esquire 67 SUE O /1n .. f VI 0:01"c; JONATHAN A. STEEVER, Plaintiff V. STACI A. STEEVER, Defendant Prior Judge. Kevin A. Hess IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-5028 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children/child who are the subject of this litigation is as follows: Harrison Drexel Steever, born May 12, 1998 and Chloe Abigail Steever, born July 13, 1995. 2. A Conciliation Conference was held on November 5, 2004, with the following individuals in attendance: The mother Staci A. Steever, with her attorney Hannah Herman-Snyder, and the father, Jon A. Steever, with his attorney Douglas G. Miller. 3. The parties agree to the entry of an order in the form as attached. 1111&dd DATE Hubert X. Gilroy Esquire Custody Conc' ' for CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: Karl E. Rominger, Esquire Rominger & Associates 155 South Hanover Street Carlisle, PA 17013 Date: December 14, 2007 IRWIN & McKNIGHT a6'zWff-Ax Doug) as G. filler, Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Attorney for Defendant c ? R r c,? FEB 14 2008,rY ;,? STACI A. STEEVER (SUMMERS), IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW JONATHAN A. STEEVER, NO. 2004-5028 Defendant IN CUSTODY COURT ORDER AND NOW, this /Oday of February, 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No. 2 of the Cumberland County Courthouse on the '17 -a day of*44, k- 2008 at q: .m. At this hearing, the father shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, this Court's prior Order of December 1, 2004 shall remain in place. cc: 'Karl E. Rominger, Esquire ?bouglas G. Miller, Esquire Ma 1 Lik ??al?og - IT LLJ ? r STACI A. STEEVER (SUMMERS), Plaintiff v JONATHAN A. STEEVER, Defendant Prior Judge: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004-5028 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Harrison Drexel Steever, born May 12, 1998, and Chloe Abigail Steever, born July 13, 1995. 2. A Conciliation Conference was held on February 8, 2008, with the following individuals in attendance: The mother, Staci A. Steever (Summers), with her counsel, Karl E. Rominger, Esquire, and the father, Jonathan A. Steever, with his counsel, Douglas G. Miller, Esquire. 3. Father has primary physical custody of the minor children pursuant to a December 1, 2004 Order of Court. Father lost his job in Juniata County, got a temporary lower paying job in Maryland and now has acquired a better paying job with benefits in Vermont. Father wants to relocate to Vermont with his current wife and the two minor children. 4. Mother is unwilling to agree to father relocating to Vermont with the two minor children. She suggests that there should be other options available for father from an employment perspective that would accommodate mother continuing to enjoy alternating weekends with the children and other periods of custody. 5. This is a relocation case and the parties are unable to agree. The Conciliator recommends an Order in the form as attached. Date: ; - - A a(W- 'V 'es' Hubert X. Gilroy, Esquire Custody Conciliator / STACI A. STEEVER (SUMMERS), Respondent/Plaintiff V. JONATHAN A. STEEVER, Petitioner/Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ?Zg No. 2004 -#082- CIVIL ACTION - IN CUSTODY ORDER OF COURT AND NOW, this ay of 2008, upon presentation and %7:-z consideration of the attached stipulation and agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. ?.1 C -? co -` -' 41 STACI A. STEEVER (SUMMERS), Respondent/Plaintiff V. JONATHAN A. STEEVER, Petitioner/Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 2004 -SW CIVIL ACTION - IN CUSTODY STIPULATION AND AGREEMENT THIS STIPULATION AND AGREEMENT entered into this I T ~ day of March, 2008, by and between STACI A. SUMMERS (hereinafter referred to as "Mother"), and JONATHAN A. STEEVER (hereinafter referred to as "Father"). WHEREAS, Father and Mother are the natural parents of two (2) minor children, Harrison Drexel Steever, bom May 12, 1998, currently age 9, and Chloe Abigail Steever, born July 13, 1995, currently age 12; and WHEREAS, the custody of the minor children is currently set forth in an Order of Court dated December 1, 2004; and WHEREAS, Father and Mother desire to enter into a comprehensive custody stipulation and agreement setting forth the physical and legal custody arrangements for their minor children, to be in effect hereafter and until altered by subsequent Order of Court or agreement of the parties; and WHEREAS, Father and Mother desire to confirm their agreement relative to custody of the minor child and execute a Stipulation and Agreement to effect the same. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. The parties shall have shared legal custody of Harrison Drexel Steever and Chloe Abigail Steever. All decisions affecting the children's growth and development shall be considered major decisions and shall be made by the parents jointly, after discussion and consultation with each other, and with a view towards obtaining and following the children's best interests which decisions shall include, but not limited to: choice of camp, if any; medical and dental treatment; education; scholastic or athletic pursuits and other extracurricular activities. 2. Father shall have primary physical custody of Harrison Drexel Steever and Chloe Abigail Steever. Following the completion of the 2007-08 school year, Father shall also be permitted to relocate with the minor children to Vermont and enroll them in school there. 3. Mother shall enjoy periods of partial physical custody of the minor children as follows: a. During the summer, Mother shall have partial physical custody of the minor children commencing on the first weekend following the completion of the school year until two (2) weeks prior to commencement of each new school year; b. Mother shall also have physical custody of the minor children during the Christmas holiday from Christmas Day through New Year's Day, with the transfer times to be mutually agreed upon by the parties; and c. Mother shall also have physical custody of the minor children during one (1) of the three (3) remaining holiday periods when the children do not have school, namely, Thanksgiving, Winter break, and Spring break. The parties shall agree to such additional holiday period on or before the transfer of the children at the conclusion of Mother's period of custody in the summer. 4. Father agrees to make his best efforts to coordinate transportation of the minor children from Vermont to Carlisle, Pennsylvania during times when he is returning to the area to visit relatives and friends. In the event that Father is not returning to Carlisle, Pennsylvania, however, the parties agree to share transportation and meet at a mutually agreed upon -peift?-fur custody exchanges. I't'r 5. During periods of Mothers partial physical custody, Father agrees to provide his parents to assist Mother in caring for the minor children while she is working at no charge or cost to Mother. Father's parents have indicated their prior agreement to assist Mother without charge in caring for the minor children during her periods of partial physical custody. 6. The parties will keep each other advised immediately relative to any emergencies concerning the minor children and shall, further, take any necessary steps to ensure that the health and well being of the children is protected. During such illness or medical emergency, each parry shall have the right to visit the children as often as he/she deems consistent with the proper medical care of the children. 7. The parties agree that there shall be reasonable, frequent telephone contact with the children during the periods when the children are not in the custody of that party. The children are permitted and shall be encouraged by both parties to both receive and initiate telephone conversations with the non-custodial parent on a regular basis. 8. Neither party shall do anything that may estrange the children from the other party, or injure the opinion of the children as to the other party, or may hamper the free and natural development of the children's love or affection for the other party. 9. It shall be the obligation of each parent to make the children available to the other in accordance with the physical custody schedule and to encourage the children to participate in the plan hereby agreed and ordered. 10. Each party shall be entitled to complete and full information from any doctor, dentist, teacher or other similar authority and have copies of any reports given to them as a parent. Such documents include, but are not limited to, medical reports, academic and school report cards, and birth certificates. 11. Each parent agrees to inform the other parent if he or she desires to remove the children either from their future home in Vermont or their home in Pennsylvania to another state by providing notice at least ten (10) calendar days prior to the anticipated date of departure. In such an instance, the party who desires to remove the children, shall provide the other parent with a general schedule of the planned vacation and its location or locations, along with a telephone number or numbers, including area code, where the children may be reached. 12. The parties desire that this Stipulation and Agreement be made an Order of Court by the Court of Common Pleas of Cumberland County. 13. The parties may temporarily alter the schedule of physical custody as is mutually agreeable in order to accommodate special family events or other changes in their schedule. If the parties cannot agree on any such changes, the terms and provisions of this Order shall control. 14. Any permanent modification or waiver of the provisions of this agreement must be in writing and shall be effective only if made in writing and executed with the same formality as this Stipulation and Agreement. 15. The parties acknowledge that entering into this Stipulation and Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of either party. 16. The parties acknowledge that they have read and understand the provisions of this Stipulation and Agreement. Each party acknowledges that the Stipulation and Agreement is fair and equitable and that it is not the result of duress or undue influence. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seals the day and year first above written. WITNESS: - Iv S A. §ffMERS JONATHAN A. STEEVER CW MOW