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HomeMy WebLinkAbout02-2313 NM • ERIN L. CORNMAN, : IN THE COURT OF COMMON PLEAS PLAINTIFF : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs. : NO. 02-2313 CIVIL TERM BRENT S. CORNMAN, : CIVIL ACTION -LAW DEFENDANT : IN CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty(20) days after this Petition and Notice are served,by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Petition or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor Cumberland County Courthouse l Courthouse Square Carlisle PA 17013 ((717)240-6200 c) rasa) F 'z { r�-,� c W 3>c) :w ZC7 ,cra �z 0 Pkt ttg3,°° l all a0-Din ERIN L. CORNMAN, : IN THE COURT OF COMMON PLEAS PLAINTIFF : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs. : NO. 02-2313 CIVIL TERM BRENT S. CORNMAN, : CIVIL ACTION - LAW DEFENDANT : IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY ORDER AND NOW,comes the Plaintiff, ERIN L. CORNMAN, by and through her counsel, Susan Kay Candiello, Esquire, and files this Petition for Modification of Custody Order upon a cause of action of which the following is a statement: 1. The Plaintiff is ERIN L. CORNMAN who currently resides at 415 Geary Avenue, New Cumberland, Pennsylvania, 17070. 2. The Defendant is BRENT S. CORNMAN, who currently resides at 760 Kise Mill Road, York Haven, York County, Pennsylvania, 17370. 3. Plaintiff seeks Shared Legal Custody and Shared Physical Custody of the following child: Name Present Residence Date of Birth JENNA M. CORNMAN 760 Kise Mill Road October 6, 2000 York Haven, PA 4. The child was born in wedlock. 5. The child is presently in the Primary Physical custody of Defendant who resides at 760 Kise Mill Road, York Haven, PA, 17370. • 6. During the past five (5) years, the child has resided with the following persons at the following addresses: Name(s) Address Dates Defendant 760 Kise Mill Road 2006 to Present Wife, Christina, York Haven, PA Step-Daughter, Kendra 7. The mother of the child is Plaintiff whose current address is 415 Geary Avenue, New Cumberland, Cumberland County, PA 17070. ' 8. Plaintiff and Defendant have been married, but are currently divorced. 9. The father of the child is Defendant, who currently resides at 760 Kise Mill Road, York Haven, PA, 17370. 10. Defendant is married. Defendant currently resides with his wife, Christina, and his step-daughter, Kendra. 11. Plaintiff is single. Plaintiff resides"alone. 12. Plaintiff has participated as a party in a prior custody agreement concerning the custody of the child in this court. The court, term and number, and its relationship to this action are as follows: the court was Cumberland County, the docket number is 2002-2313, the result was a custody order which is attached hereto and made a part hereof as Exhibit"A". 14. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth,at this time. 15. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. Al F. Father will simply not agree with anything Mother suggests or requests, often not even giving Mother the courtesy of speaking with her; G. Father's Wife states "she does not have to follow the current custody order,because she is not a party and she can do whatever she wants"; H. Although the Mother is not in the child's same school district, Mother would be able to transport the child to and from school and the child would be able to sleep longer in the morning when with Mother, due to the differences between Mother's schedule and Father and his Wife's schedules; I. Mother has great love and concern for her child and does not believe it is in her child's best interest to be raised only by her Father. 17. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff, ERIN L. CORNMAN, requests this Honorable Court continue Shared Legal Custody between the parties, and grant Plaintiff, ERIN L. CORNMAN and Defendant, BRENT S. CORNMAN, SHARED PHYSICAL CUSTODY, of the minor child,JENNA M. CORNMAN. Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO • Dated: October , 2013 �Ck4v■. • - Susan Kay Candi: ls, squire Counsel for Plaintiff PA I.D. # 64998 710 Gladstone Court Mechanicsburg PA 17055 (717) 724-2278 VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are true . and correct to the best of her knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. DATED: /0, .Gt ce A A ERIN L ORNMAN eiwGr '�t Vali-131N 44 8" • SEP 2 1 2006 ERIN L. CORNMAN, : IN THE COURT OF COMNiDNVEEAt OF— CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 02-2313 CIVIL TERM v. CIVIL ACTION — LAW BRENT S. CORNMAN, IN CUSTODY Defendant Guido, J. - ORDER OF COURT AND NOW, this ' day of September, 2006, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Legal Custody. The parties, Erin L Cornman and Brent S. Cornman, shall have shared legal custody of the minor child, Jenne M. Cornman born October 6, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms a 23 Pa. C. S. §5309, each parent shall be entitled to all records and information pertaining to the child including, but not limited to, medical, dental, religious or school records, the residence address of the child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. All decisions affecting the child's growth and development including, but not limited to, choice of camp, if any; choice of child care provider; medical and dental treatment; psychotherapy, or like treatment; decisions relating to actual or potential litigation involving the children directly or as a beneficiary, other than custody litigation; education, both secular and religious; scholastic athletic pursuits and other extracurricular activities; shall be considered major decisions and shall be made with the parents jointly, after discussion and consultation with each other and with a view toward obtaining and following a harmonious policy in the child's best interest. The parties shall endeavor to coordinate the child's medical appointments in such a fashion that when it is reasonably possible to do so, both parties are available to attend. . Should one parent take the child to the doctor, the other parent shall be notified before hand, if reasonably possible. Otherwise, the other parent is to be notified within twelve hours, either by phone or e-mail. i ' 'NO. 02-2313 CIVIL TERM The child shall continue to attend school in the school district in which Father resides. Both parents names shall be listed in the school record as primary persons of contact in the event of an emergency. In the event the school is unwilling to send notices, announcements and report cards to each parent, Father shall make copes and send them to Mother within forty-eight hours of the receipt of such documents. 2. Physical Custody— School Year. A. During the school year, Father will have custody Sunday evening through Thursday night. B. Mother will have custody two of every three weekends, commencing with . September 15, 2006 and September 22, 2006. Father's next custodial weekend shall begin September 29, 2006. C. For purposes of this Order, a custodial weekend begins Friday after the parent is off work and continues until Sunday evening at 7:00 p.m. . D. Mother shall have custody from after work until 7:00 p.m. on Tuesdays and Thursdays preceding her custodial weekends. Mother shall also have custody on Wednesdays and Fridays from after work until 7:00 p.m. preceding Father's custodial weekend. E. The school year schedule shall begin the Sunday before school begins. The summer schedule shall begin the first Monday that school is out for summer school recess. 3. On days when school is not in session, and Father is not available, then Mother shall have the first option to take care of Jenne that day. if Mother is also not available, Father will then make arrangements for alternate care. 4. Summer Schedule. During the summer, Mother will have custody on Mondays and Tuesdays and alternating weekends. Father will have custody on Wednesdays and Thursdays and alternating weekends. The alternating weekend schedule during the summer shall begin with Mother having the first custodial weekend of summer. 5. Vacation. Each parent shall be entitled to three weeks of custody each summer for purposes of summer vacation. The parties shall provide each other with notice of their selective weeks no later than May 30'". In the event that the parties have scheduled conflicting vacation arrangements, the parent first providing written notice shall have choice of the vacation week. The weeks for vacation shall be scheduled during the time when the vacationing parent has five consecutive days of custody under the summer schedule. s , NO. 02-2313 CIVIL TERM 6, During any period of custody or visitation the parties to this Order shall not possess or use non-prescribed controlled substances, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise ensure, to the extent possible, that the other household members and/or house guests comply with this prohibition. 7. Neither party shall do or say anything which may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the child's love and respect for the other parent. Each parent shall ensure that third parties also comply with this provision during his or her periods of custody. The parties' custody litigation and child support are adult matters, which neither party shall discuss with the minor child. 8. Transportation. Transportation is to be shared by the parties by their mutual agreement. 9. Holidays. The parties will alternate the following holidays: New Year's Day, Memorial Day, Independence Day, Labor Day and Thanksgiving. 10. Easter. The parties will alternate custody of the child for Easter each year to commence with Father having custody for Easter, 2007, and subsequent odd-numbered years. Mother will have custody for Easter, 2008, and subsequent even-numbered years. However, Mother shall be permitted to have custody on Easter Morning during Father's Easter holiday time in order to take the child to church services, after which Mother will return the child to Father for the remainder of Easter. 11. Christmas. The Christmas holiday will be divided into two segments, Segment A and Segment B. Segment A shall be from December 24th at noon until December 25th at noon. Segment B shall be from December 25th at noon until December 26th at 7:00 p.m. In Oven-numbered years, Mother shall have Segment A and Father shall have Segment B. in Odd-numbered years, Father shall have Segment A and Mother shall have Segment B. However, when Father has Segment A Mother shall be permitted to take the child to Christmas Eve church service, after which she will return the child to Father. 12. The parties shall alternate having custody of the child on the child's birthday with Father having custody in even-numbered years and Mother having custody in odd- numbered years. 13. Mother's Day and Father's Day. Jenna will be with Mother on Mother's Day and with Father on Father's Day. The custodial period for these holidays shall be from Saturday at 6:00 p.m. until Sunday at 7:00 p.m. • NO. 02-2313 CIVIL TERM 14. Reasonable Telephone Access. Both parties shall have the right to reasonable ;telephone contact with the child during the other party's period of custody. The child may ;initiate a telephone call to the non-custodial parent upon their request. Neither party shall ;interfere with the other party's telephone contacts with the child. Each party shall make all ;reasonable efforts to promptly return calls or messages left by the other party regarding the child. 15. Neither party shall relocate in a way that will require a change in the custodial !schedule in the absence of 60 days written notice to the other parent. This 60-day notice provision is required in order to provide the parties with an opportunity to work out an alternative schedule, or, if necessary, to provide adequate time for bringing the matter back • before the Court for the scheduling of a Plowman hearing. • 16. This Order VACATES and replaces all prior Orders of custody in this matter. It shall be permissible for the parents to vary from this custodial schedule by their mutual agreement, with an eye toward a harmonious policy, focusing and placing child's interest ahead of their own. , BY TH: COURT: • Edward E. Guido, J. Dist: Gerald S.Robinson, Esquire,P.O.Box 5320, Harrisburg,PA 17110-1709 Erin L. Cornman, 12 Hazel Circle,Mechanicsburg, PA 17050 • TRUE (.OP"V FROM RECORD ' igesimpirrOgroot, 1 here*nb>trtlw WS . f the essi of said Co at CEO, A. ? h I • ,') • .. ,2 . � L J v ,I • • • • EXHIBIT "B" QM 2016 s� ERIN L. CORNMAN : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : 02-2313 CIVIL ACTION LAW BRENT S. CORNMAN Defendant : IN CUSTODY ORDER OF COURT • AND NOW, this day of , 2010, upon • consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Orders of this Court shall continue in effect as modified by this Order. 2. The parties shall engage in a course of therapeutic family counseling with a professional to be selected by agreement between the parties. The purpose of the counseling shall be to assist the parties in addressing concerns which have arisen in the family in such a manner as to promote the Child's emotional well-being. 3. In addition to the counseling required in the preceding paragraph, the parties shall make arrangements for the Child to participate in family counseling with a professional to be selected by agreement. 4. In the event either party feels it is necessary to return to conciliation after having completed four joint family therapy sessions, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference. BY THE COURT., • • Edward E. Guido J. • cc: Susan Kay Candiello, Esquire—Counsel for Mother Jaime D. Black, Esquire —Counsel for Father • • TRUF_ O M D R In Testimony whereof, !here unto set riy hand and the seaj of said Curt at Car;:; Pa This '" J`ay of 44.-1--CE , t : IN THE COURT OF COMMON PLEAS ERIN I. EDWARDS (formerly known as : DAUPHIN COUNTY, PENNSYLVANIA Cornman) Plaintiff • vs. : NO. 2002 - 2313 �. BRENT S. CORNMAN • Defendant : CIVIL ACTION - CUSTODY 'ff I • 1 CRIMINAL RECORD/ABUSE HISTORY AFFIDAVIT 1:i I I r:r■ al�c,r�S , hereby swear or affirm, subject to penalties of . 1 law including 18 Pa. C.S. §4904 relating to unsworn falsification to authorities that: I, - 1. Unless indicated by my checking the box next to a crime below, neither I nor any member of my household have been convicted, pled guilty or pled no 1. 1: . contest to any of the following crimes in Pennsylvania or in any other jurisdiction: , r. NO EXCEPTIONS r s r�dh '.�.t>r�" 'N �i'xagF "`1 T^ .2sR '+'"^vq.-�,ni•'.s;;ixr roa - 7.. 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Unless indicated by my checking the box next to a crime below, neither I nor any member of my household have a present and/or past history of violent or abusive conduct, except as listed below: c Check � a� � I:ter ,���.. y� ;. � �� 1 ?i al 5 a x ���4414r k. 5 .c' t t' �t 1.71 t 3 S i ',' Crime * �„ i Self ouseholld 0i Date heat . 1 ii# ; I r ` Member �, ; J a A finding of abuse by a o Children &Youth Agency or 0 0 similar agency in Pennsylvania or similar statute in another jurisdiction i ;busive`conduct a defin , � � k 4 s ' ® _V, under the Protection fro � O h ``j woR F ; buu e Actin Pen sylvaria_or h ° mow 1 0��� ! 7.a ft� t- 4 r *�T 4 �" ',fir. �Y s� � �r =� 41 - ��simil`arstatutelinnanother y;, t- Wr ❑ Other: 0 ❑ Please list any evaluations, counseling or other treatment received following conviction: If any conviction above applies to a household member, not a party, state that person's relationship to the child(ren). OCTOBER , 2013 L2/rte ll Signature E6(1 1.. a„-Ards- Printed Name • 3 ERIN L. CORNMAN, : IN THE COURT OF COMMON PLEAS PLAINTIFF : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs. : NO. 02-2313 CIVIL TERM i °C r s BRENT S. CORNMAN, : CIVIL ACTION -LAW d © , DEFENDANT : IN CUSTODY vo -. fi\ a PLAINTIFF MOTHER'S PETITION FOR CONTEMPT -4 AND NOW, comes the Plaintiff, ERIN L. CORNMAN, (now known as Edwards), and respectfully avers the following in support of this Petition for Contempt: 1. The Plaintiff is ERIN L. EDWARDS, (hereinafter referred to as "Mother"), who currently resides at 415 Geary Avenue, New Cumberland, Pennsylvania, 17070. 2. The Defendant is BRENT S. CORNMAN, (hereinafter referred to as "Father"), who currently resides at 760 Kise Mill Road, York Haven, York County, Pennsylvania, 17370. 3. Jenna M. Cornman, sometimes known as "Jenna", born on October 6, 2000, is the subject matter of this action. 4. The parties are subject to the Order of Court dated September 25, 2008, as amended by an agreed upon Order dated June 15th , 2010. (Said Orders are attached as Exhibits A and B respectively.) 5. Father has intentionally and wilfully violated paragraph 3. Of the Amended Order, which state "the parties shall make arrangements for the child to participate in family counselling". Father has not shown up at the last two appointments and there is no evidence he or the daughter will show up at any more. Jenna has had less than six appointments since May, 2013. 6. Father has intentionally and wilfully not notified Mother of dental appointments. The daughter has needed dental interventions for some time now, but Father refuses to let Mother put daughter on her Dental Insurance and have her expenses covered 75%. 7. Father has intentionally and wilfully not notified Mother of the child's soccer schedule, coach, team, or any even asked Mother if she would like her to play or not. 8. Father did arrange for Mother to have her own password to learn of her daughter's grades, but Mother knows little if anything about what her daughter does in school. 9. Mother was awarded Shared Legal Custody of her daughter in the present custody order, but Father does not share information, does not share information in a timely manner or simply makes a unilateral decision without even considering Mother's input, thoughts and concerns, resulting in Mother being totally left out of any decisions in the child's life. A. 11. Father's wife, Christina, makes all decisions and plans for the child's extra-curricular activities and after it is done, notifies Mother of what will occur, frequently Mother is not notified at all or not in a timely manner. Father's Wife states "she does not have to follow the current custody order, because she is not a party and she can do whatever she wants". 12. Mother has not seen her daughter, overnight, since March 17th, 2013, and Father is therefore in violation of the entire custody schedule. 13. Recently, Father promised Mother that she would have some time with her daughter for her daughter's birthday. Father then, unbeknownst to Mother took daughter on a camping trip,the daughter's telephone was broken, Father's cell phone was turned off and Mother did not get to see or even talk to her daughter for her birthday. 14. Mother has incurred attorney's fees in the amount of approximately $1,000.00 in discussing and preparing these documents and filing fees. Mother will incur additional fees in attending the hearing and conciliation to be held as a result of Father's actions. Mother seeks reimbursement of these fees from Father. 15. As a direct result of Father's actions or failure to act, Mother is being denied the ability to be a mother to her daughter. Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO Dated: October t o t , 2013 c S Susan Kay Can 'el o, Esquire Counsel for Plai ,ff PA I.D. # 64998 710 Gladstone Court Mechanicsburg PA 17055 (717) 724-2278 VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are true and correct to the best of her knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. DATED: 1 v .l� . 3 CtElr,t12AW ERIN LYNN CORNMAN- Ggc4636,43 , . I ,„- . a, [ i . . 1 . , .. • -.. : IN THE COURT OF COMMON PLEAS : ERIN I. EDWARDS (formerly known as :- DAUPHIN COUNTY, PENNSYLVANIA 1 , I Cornman) . i • . , , Plaintiff . . . vs. : NO. '2002 - 2313 BRENT S. CORNMAN : , ._ Defendant • : CIVIL ACTION - CUSTODY l• , . . . . . • . . CRIMINAL RECORD/ABUSE HISTORY AFFIDAVIT /-, I Lr;A Qu9arzi3 , hereby swear or affirm, subject to penalties of I 1 I law including 18 Pa. C.S. §4904 relating to unsworn falsification to authorities that: i , 1. Unless indicated by my checking the box next to a crime below, neither I 11 ' nor any member of my household have been convicted, pled guilty or pled no I, contest to any of the following crimes in Pennsylvania or in any other jurisdiction: • NO EXCEPTIONS , ; . , .„--7-...-„....Tri,-..c.zi...:„...„%fg.,,,,,,,,,“,,,,,,,,Z.7,41b1, ...r4r*.7M. ..,....'Fi7,7,ul,■3..1,4 LI ...,,,,,I.1 •!imTITT...11... airr;r4t1g..14.1....,41: •,,' , i WedINT:fil%0,:t2Z.?1,44",,p;ig iViet$1,V8MT,Vs444,tek:;;,% -r4A.,,,,,..4g.:i. V.,:e.weilzi,i4,..„4 , ,.: 2,174.;;;,; [1 /01;s7W-..-SAr, 4:!,ngn4:!„,:t a0air-41,04-,1,,,,," 1,W;1.;*!ttfAVathgr":"*.iIt: "*.40'7'';,,,:.:;W...1)iDate--.1off..?-g•-,:t-;....-,:..pcwil-? a oft_S,.ift4, -:%;'!'A't' e ,,,s„_v:,,,?,,,,:tri:-vlolmFifk.gilimw, '8 •.: '1474kt',',,Ag.dialixi;,.z,,ve.,,- ,-.1111311e,-,t:;:tr,,A-,i..•, -4 '0,,.;,,i,,fifi ..e .1-:,,,,. ,,ptie t o. a e::4. vle.,..,,,.is,.: t-in 4 iitipp, iIll'os-VO' :-.=-Atar AA17-,i ,,,r...-s.v-i ..,.T.,.4p-: lc ..y..., e,rveme. •.,."'. .14-;rfax'':$,..:..'!-,,',-Ai,--,',..V-2-1 ,,C- -:.44.ft%- : -E-'10:-.f% Member- ..4.4.,-,. .-T.::'olea...:,,,s.;A ,.-4, . ,q.1.?,12Y. 4tFaiga,-z1- ?.„,,...-.,,,,,a,_..is-A_3:..4., *: .1`. t.i.,;:r4 ,4,-.r.Z.a: II r-,Ale431: :',,:..', ,,%41,•-8, Contempt for violation of a . 17] Protection from Abuse order 1 . 1 or agreement; „ ,T..-.'...i.,3 ,./ ',/..,:tt?,2•. ,c i144,10,1AiieYRY:1149,4494agrAVISe4,,cc1;75,.•','itAKI: :::l 0,.CRA,.:41,„i;1 i*:?i.'.?'.' 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[ El Stalking; 1 ■ ' 0 .. , klaw5,,,,,,,--1w.:-.71.5,,,,,pii-414.7);gagpwr, 7,40,4001.-inilp7-174,m- viA.,,,,,Aiwo-a.kg„.7..ffiopicrT:,m-fwgi; 1 tnsnv,,t,t:edar,,,a,64,msfmr,to:Axv4zz,,:*-5:v,gr;=,ggig-fk-IArg:aisfvisttAw,;'1,::;,4sJem:zfx::=4.givtz-! 1 ',--•,:,:::k.'.,:7,-.t.,-2::rt-te4-'.A.....4 'P'-',4--=',IN---.LAN.:,'5...-o.-,—.: ,--2?.ard'eq.,14;:-,', Orkiik.:.--.N.•,V..iil-i,-4,4At.*- ,,..-vti4i4„.6.,-V,:-.:?‘irc,i0P4 tz;r4.2-V.g"gti.V.V SIONZW-,-. iv 1 - • i 1 • 1 i . 1 i - ! • .... .. . . —• • - - -- - - - - - - • I, . . : . I ❑ Unlawful restraint; ❑ . !r •�jv,,7,,i -, ra •�"`37 yr` "rFa.f :42,,-)1:',4,4 f."',s s c rn. •i-: Gheckc� sF�1. "3�4+"�" .�'���` v - � tit >+f�i � �' ,�� ' $ k��� Y � � r s 3 , k Y .. 11.:, a}c .r.+! st , -� 1' x 9aa", j eP -, ,, , es qty 1. y y R �- >7 Other r ft Date of r4 {,..x�all� �� ?s� _ ; •'* � �,:� � ud�!'yi n� � �3'. "�y.,��.y .� � �. a -stn �+"� � �,��y Ike ;;Grime . r Self y ;Household 5>z-Name eonv{ct{orn, 1�4k*r • �fhat - h t,f,� _ r . : 41;101(-74:: r s 4;• Sri_ i� m 3 ad'.sib: -,r r 5 r1r v SenttemC. -AA �,�-,,44 �� Member ',.-..1:,..7,,,,, 1,:or Plead • Ippjy1 fL..it.11_3'a�.? 1P.6•rxt't,Y 1 fl'.-1.- ..'t.-.'.'b %x.�, i i.,.`�r '"., -' f1 s9+,it� '` 7,. g,A b: my < :.. ❑ False imprisonment; y t ; ,'3.e ' y r',: �-�i � K .e.r h3ray -4.�r a '+r `'fi a;t•`"� r r Lunn{gaychild tl o afmotorL* - • , ,E--. iii- . �: k4'M"� `�`• y H r,,vsi it ' E`r ", `4,,,, c'"i. ` 3 .ty`3,. i w q" let 7ti i,ov.`. 0 t ` 2 y?'� c-./ hl -1 yor 5 f scY S' _.�..." T.f, ___•'-'.0,1-4,•'.1.r h4 �i`'Y.. X'# {-:.ni—.-?- - -..�;= 4 -`s°R s-�tiwc. T.. t` °^'f,..4,:�,: ,. Rape, statutory sexual E1 assault, involuntary,deviate • • sexual intercourse, sexual ' • . - assault, aggravated indecent • assault, indecent assault, 0 . , • ' indecent exposure, sexual _ .; abuse of children, "sexual • exploitation of children, , . . • , sexual intercourse with an animal or incest; ' , • - _;C{ 2� `F�`•sc?fir :w �. � �� .+. W i'C+s•�• r'� t•: Sexkoffen der non co, pl tang e;x r Y , b 't x }�. � <c r "'x40 } .r+.,m Y x.31 1 f,t:4.4 ,. 3.aye ,- ! Y i w .5„.„.._, with,reglation5X ;zy � ;"� ,*, � '�A `; T ,'-',,t1-'4,'''.r , �; - r.'requirements statute courttfr. x � .:. w1�r {� ;'s�� ';f, ,,• . o der p obat nnor parole or ^ ' s' :, ' . '' X 1' { `'' '"` , { I .' .. ' other>requirements under;18 `O �ti; : ,� 1 t � ti • T� c r -'r x e y.r r74'• 9` { ' ,r }a Ir fix ` 'Pa C S �8 30L nd 42�Pa� r }....6„.;,.'41,-,,..* '� '�' ,i z �g.,1"Sii -, . G fFrk s.r �.i'h r, ;1s,� FC SG'��s� fr�, r eiF Vt-4 ]eY 1 3vr Yr .tiu . ,.-'.,;.Z. ;r, �. + .rise.°�1 :../LA-w'-d...2h. .�.I3W _:S :a`� .r.A '`1 :-:}.0 ti ,...�''., ' "` .s,' _•e-.:A:a°'3�.` °. f`Prfs.>-4,,.,,,a » � ...W......'1...3"..:.,i X,Wr s 1. ..;5. r. 0 Arson and related offenses; ❑ • 0 , ,•L , .-„„••,...,,,„,..,,,,,- ,,„....,,,,,,w..•'WO.''' p, .."•',11.•..:,,i`71",:'. .,•$`417M4:7.;.A•rW-{ ;4"...;!•'ii.,3-, ,7,,t';''...q40'c;173 2",%ye..i.W.,;•,-;:g..:44,,,,11.,d p' ; a , }•,§ 4 1,Conealing, eath o ae ch{Id . r F ® '„ 4 N `i kl* ` f,g . ai � a xc ry fi htf , ,'...40A E 'i S ( Y s Endangering the welfare of. .•. ❑ children; . ❑'' ❑ . . Y r radii ,barterin bu in v � 41 .,`' ? V. ,, .. N�S4Y .:*1-P; 3. gi Pr gi , Y „gn xr + ® ,,,u ksell{n ,1'ot dealin In Infant a �'� ,„4,-,-� . 3�- ��-«,�Y�y ��..�.g � ,t:�s 9'� rs e n� }S:-®, , �+ '�stP+i�dy, iX�Y.td ri ,�” ' �N���4 2 ,. ` Chlitdr211_t *fl;:-s,Fi4'; :r' _ .'„` : 4�� ='Ykk � .. vi:... s �? . Prostitution and related 0 • offenses; ❑ ❑ r� } F ziRy arN' 'x ^? R c ;24' C •„ a 4 F 1 s M,1-. i ,0 v k,,t•A `' .7 Obscene and othersexual�� ", ' � �,1 �� .•1 „-s.,- i,. !if'4-s.;04PA,*`3.K ref•Gv '#- ,, 3..,,t - k 4 k.. tr 1' #Aw ,:,,f.+.,- '�' S i �, , � materials and,, erformances, ® � rrg, , Y� .,. ,� t,_ fo , �: �' Corruption of minors or - ❑ unlawful contact with a ❑ , ❑ • minor; ` ' • i ? 2 • L Y 4 2. Unless indicated by my checking the box next to a crime below, neither I nor any member of my household have a present and/or past history of violent or abusive conduct, except as listed below: hk 6 " n :' A" ,: " ° iitA M 1 . ^{Cec ::. y1 T J i_.) C) ' tie j ^ z•1 E i { y 7 40 4 `- tr ? `- ' ;` `, r Nuey r y Grime`i � y ,Y Self ohold at; A finding of abuse by a fl Children &Youth Agency or ❑ ❑ similar agency in Pennsylvania or similar statute in another jurisdiction ti -bu ueco uct m de'f ned . �' Y ', 'f ` i� t S WY-WY AtC•6 d { f � r iV' rt a"cif?, `'z ''at '� 4,-underthe0Prote;tionfrom 7 V ill r rx ' -` • ,- AbusekActlin Perim§, I`va is er .aq $ te,- ''s a ` '' C" �1Q. "�:^.Y• NIIE.a4 f47- i`J+y4, f4. �" K '4f • v rte '? i similar statute it notheer --'.,t--, ,,: t t • Other: ❑ ❑ ❑ Please list any evaluations, counseling or other treatment received following conviction: If any conviction above applies to a household member, not a party, state that person's relationship to the child(ren). OCTOBER dif, 2013 At:,cyae_Api , Signature t`;(1 /- a.„,,,d, Printed Name 3 ERIN L. CORNMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. r -, 2002-2313 CIVIL ACTION LAW = ``" BRENT S. CORNMAN = � r`)� IN CUSTODY 70, — DEFENDANT � `==: ORDER OF COURT tsj AND NOW, Wednesday,October 30,2013 , upon consideration of the attached Complaibf; it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday,Esq. ,the conciliator, at 39 West Main Street,Mechanicsburg,PA 17055 on Tuesday,November 26,2013 2:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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. You must file with the Court a verification regarding any criminal record or abuse history regarding you and anyone living in your household on or before the initial in-person contact with the court (including, but not limited to, a conference with a Judge or custody conciliator) but not later than 30 days after service of the complaint or petition. No party may make a change in the residence of any child which significantly impairs the ability of the other party to exercise custodial rights without first complying with all of the applicable provisions of 23 Pa.C.S. §5337 and Pa.R.C.P.No. 1915.17 regarding relocation. FOR THE COURT, By: /s/ Dawn S. Sunday, 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. I.F 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. J Cumberland County Bar Association ESl 32 South Bedford Street �. Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 4713 NOV 13 Abi cik AND KOPE & ASSOCIATES, LLC EN NS)1VAN M NT x. HILARY VESELL, ESQ. ATTORNEY I.D. 308358 395 St. Johns Church Road, Suite 101 Camp Hill, PA 17011 (717) 761-7573 hvesell @kopelaw.com Attorney for Defendant ERIN L. CORNMAN, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs. : No. 02-2313 CIVIL TERM • BRENT S. CORNMAN, • Defendant : CIVIL ACTION - LAW : IN CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of Brent S. Cornman, the Defendant in the above-captioned case. 1110 J LuLCLl1L' .�� DATE HILARY VESL, ESQUIRE 395 St. John hurch Road Camp Hill, PA 17011 Supreme Court ID# 308358 CERTIFICATE OF SERVICE I, Hilary Vesell, do hereby certify that on this 12th day of November 2013, I served a true and correct copy of the foregoing Praecipe for Entry of Appearance via first class mail, postage prepaid, addressed as follows: Susan Kay Candiello, Esq. 710 Gladstone Court Mechanicsburg, PA 17055 HILARY VESELL, ESQUIRE 395 St. Johns hurch Road Camp Hill, PA 17011 Supreme Court ID# 308358 (717) 761-7573 Attorney for Defendant ' t� THE PF,OiH01O u r n ni3 @iOV 20 A.1110: 52 CUMBERLAND COUNP( PENNSWANIA KOPE &ASSOCIATES, LLC HILARY VESELL, ESQ. ATTORNEY I.D. 308358 395 St. Johns Church Road, Suite 101 Camp Hill, PA 17011 (717) 761-7573 hvesell @kopelaw.com Attorney for Defendant ERIN L. CORNMAN, : IN THE COURT OF COMMON PLEAS, Plaintiff : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs. : No. 02-2313 CIVIL TERM • BRENT S. CORNMAN, • Defendant : CIVIL ACTION - LAW : IN CUSTODY ANSWER TO MOTHER'S PETITION FOR CONTEMPT AND NOW comes the Defendant, Brent S. Cornman, by and through his attorney, Hilary Vesell, Esq. and Kope and Associates, LLC, and files this Answer to the Plaintiffs Petition for Contempt and in support thereof, avers the following: 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied in part, admitted in part. While it is admitted that the agreement was amended upon Order dated, June 15, 2010, it is specifically denied that the date of the original Order was September 25, 2008. To the contrary, the date of the original Order was September 25, 2006. By way of further answer, Plaintiffs Exhibit "B" appears to be the recent Petition for Modification and not the 2010 Court Order, as referenced. Furthermore, it is believed and, therefore, averred that the parties have further modified the Court Order by agreement of the parties to accommodate the Mother's work schedule so that the Mother could spend more time with the child. 5. Denied. To the contrary, the parties have participated in six (6) counseling sessions together. Furthermore, neither party made arrangements for the child to attend family counseling sessions. 6. Denied. To the contrary, the Father has made the Mother aware through email of all dental appointments for the child. Furthermore, if the child switches health insurances, the child will be forced to go to a different dentist. 7. Denied. To the contrary, the child plays softball and not "soccer. Furthermore, the Father has made the Mother aware of the child's softball schedule also through email. 8. Denied. To the contrary, Father has made Mother aware of all school information through email as well, including report cards and PSSA scores. Furthermore, all other information regarding the child's school is available on the school's website. 9. Denied. Father has provided and included Mother in all decision making regarding the child especially through email communication. 10. No response required as Paragraph (10) was skipped in Plaintiff's Petition. 11. Denied. To the contrary, all decisions relating to the daughter have been made by both Father and Mother. Furthermore, Father's current wife has only attempted to help the parties and the child, where appropriate. 12. Denied. To the contrary, the Mother has not attempted to exercise her custody schedule with the child. Furthermore, the child has told the Mother that she does not wish to see her to which the Mother consents by not picking up the child for her custody periods. By way of further answer, the Father has attempted to mend the relationship between the Mother and child. 13. Denied. To the contrary, Father, his wife, and the child had returned from a preplanned camping trip on the afternoon of child's birthday. Furthermore, while the child's cellular phone was not working, the Mother did not attempt to call the Father or his wife's cellular phone to reach the child on her birthday. 14. Denied. To,the contrary, Mother has simply chosen not to exercise her custody schedule due to a tenuous relationship between the Mother and child and, therefore, the Father is not in contempt of the Custody Order. 15. Denied. To the contrary, the crux of the problem is in the broken relationship of the Mother with the child. Furthermore, the Father has attempted and continues to attempt to repair this relationship without success. Respectfully submitted, Kope & Associates 1���Date: /1 /1 t� I � � _ r '- Hilary Vesell, squire Supreme Co ID # 308358 395 St. John hurch Road Camp Hill, PA 17011 (717) 761-7573 Attorney for Defendant 15. Denied. To the contrary, the crux of the problem is in the broken relationship of the Mother with the child. Furthermore, the Father has attempted and continues to attempt to repair this relationship without success. Respectfully submitted, Kope & Associates — Date: 11 JO/LS .'f Hilary Vesell, = quire Supreme C. , ID # 308358 395 St. Johns Church Road • Camp Hill, PA 17011 (717) 761-7573 Attorney for Defendant • VERIFICATION I, Brent S. Cornman, the Petitioner in this matter, have read the foregoing Answer to Plaintiff's Petition for Contempt. I verify that my averments in this Answer to Mother's Petition for Contempt are true and correct and based upon my persona{. knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities. Dated: )1/P1/..01 �1/1/ �Z � —.. B nt S. Corn • • CERTIFICATE OF SERVICE I, Hilary Vesell, do hereby certify that on this 20th day of November 2013, I served a true and correct copy of the foregoing Praecipe for Entry of Appearance via first class mail, postage prepaid, addressed as follows: Susan Kay Candiello, Esq. 710 Gladstone Court Mechanicsburg, PA 17055 � �L I E HILARY VESELL, ESQUIRE 395 St. Johns rch Road Camp Hill, PA 1 I11 Supreme.Court ID# 308358 (717) 761-7573 Attorney for Defendant 3 ERIN L. CORNMAN • IN THE COURT OF COMMON PLEAS OF Plaintiff • CUMBERLAND COUNTY, PENNSYLVANIA vs. • 2002-2313 CIVIL ACTION LAW • BRENT S. CORNMAN • Defendant • IN CUSTODY ORDER OF COURT AND NOW, this 41 day of �* C.Le O Vt.— , 2013, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The parties shall make arrangements for the Mother and the Child to continue in counseling with a new counselor selected by agreement. The purpose of the counseling shall be to address the problems which have arisen in the Mother-Daughter relationship in an effort to rebuild the relationship and resume the partial custody schedule on a regular basis. The parties shall follow the recommendations of the counselor as to the frequency and duration of the counseling and the Father shall ensure that the Child attends all her scheduled appointments. The parties shall share any costs of the counseling which are not covered by insurance. The parties shall make arrangements to initiate the counseling as soon as possible following the custody conciliation conference. 2. The Father shall bring the Child to the Christmas Eve Service at the River of God Church in Enola so that the Mother can also attend the service with the Child. In addition, the Mother shall have contact with the Child at the Father's residence on Christmas Day at 9:00 a.m. so that the Mother can give the Child her presents and spend time with her on Christmas Day. 3. The Father shall ensure that he is sharing all significant information related to the Child with the Mother including any illnesses, absences from school, scheduled activities and other related information. 4. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with this provision. (-1 `..Y.... C) -4 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 COU Edward E. Guido J. cc: :ism K. Candiello Esquire—Counsel for Mother ..'Hilary Vessel Esquire—Counsel for Father CI:a74/13 f 2�.t lc, ERIN L. CORNMAN : IN THE COURT OF COMMON PLEAS OF Plaintiff • CUMBERLAND COUNTY, PENNSYLVANIA • vs. • 2002-2313 CIVIL ACTION LAW • • BRENT S. CORNMAN Defendant • IN CUSTODY Prior Judge: Edward E. Guido CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME BIRTH YEAR CURRENTLY IN CUSTODY OF Jenna Cornman 2000 Father 2. A custody conciliation conference was held on November 26, 2013, with the following individuals in attendance: the Mother, Erin L. Cornman, with her counsel, Susan K. Candiello Esquire, and the Father, Brent S. Cornman, with his counsel, Hilary Vessel Esquire. 3. The parties agreed to entry of an Order in the form as attached resolving the Mother's Petitions for Contempt and Modification.. Date Dawn S. Sunday, Esquire Custody Conciliator