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HomeMy WebLinkAbout05-1675DANIELLE R. NICKLE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. oy- Civil Term JASON Z. NENNINGER, CIVIL ACTION - CUSTODY Defendant PETITION FOR CUSTODY 1. Plaintiff is Danielle R. Nickle, who currently resides at 14 Southside Drive, Newville, Cumberland County, Pennsylvania, 17241. 2. Defendant is Jason Z. Nenninger, who currently lives at 1827 Ritner Highway, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff is the mother of the following child and seeks custody of the following child: NAME DOB ADDRESS Haley Marie Nenninger 7/4/04 14 Southside Drive Newville, Pa. 17241 Mother and Father are not married. Mother currently has primary physical custody of the child. During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESSES DATES Danielle Nickle Jason Z. Nenniger Danielle Nickle Jeff and Tina Nickle (Maternal Grandparents) 13051 Mongul Road 14 Southside Drive Newville, Pa. 17241 Sept. 04 - 3/1/05 3/1/05 - present The mother of the children is: Danielle R. Nickle, and she currently resides at 14 Southside Drive, Newville, Pa. 17241. She is not married. The father the children is: Jason Z. Nenninger, and he currently resides at 1827 Ritner Highway, Carlisle, Pa. 17013. He is not married. 4. The relationship of plaintiff to the child is that of Mother. The persons that the Plaintiff currently resides with are: the child and the child's maternal grandparents, Jeff and Tina Nickle. 5. The relationship of defendant to the children is that of Father. The defendant currently resides with his parents. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the child or anyone who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: Since the parties separated mother has been the primary caretaker for the child. Mother currently lives with her parents and is best suited to continue being the primary caretaker. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant custody of the children. Respectfully submitt _ Zg G Date: 2 duAn-?', Jane Adams, Esquire YD. o.79465 04-gouth Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Date: (I (?? Danielle R. Nickle, Plaintiff Qj 1 i_ 1 C. n? r, cJ ? ?s.a C_7 CS+ C.7 -1i ?i r + DANIELLE R. NICKLE PLAINTIFF V. JASON Z. NENNINGER DEFENDANT IN THE COURT OF COMMON CUMBERLAND COUNTY, 05-1675 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, Apri101, 2005 upon consideration of it is hereby directed that parties and their respective counsel appear before Jacqueline M. at 4th Floor, Cumberland County Courthouse, Carlisle on _ Tuesday, May 03, for a Pre-Hearing Custody Conference. At such conference, an effort will be made to res if this cannot be accomplished, to define and narrow the issues to be heard by the court, a order. All children age five or older may also be present at the conference. Failure to ap provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection Special Relief orders, and Custody orders to the conciliator 48 hours prior to schedu FOR THE COURT. By: Custody Conciliator OF VANIA attached Complaint, rney, Esq. , the conciliator, 15 at 10:30 AM e the issues in dispute; or to enter into a temporary r at the conference may om Abuse orders, I hearing. The Court of Common Pleas of Cumberland County is required by law to co ply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonabl 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 ust attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IIF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE T E 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 ?QN, ?'?? I on? DANIELLE R. NICKLE, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 05 - 1675 Civil Term JASON Z. NENNINGER, CIVIL ACTION -CUSTODY Defendant AFFIDAVIT OF SERVICE AND NOW, this April 19, 2005, I, Jane Adams, Esquire, hereby certify that on April 13, 2005, a certified true copy of the CUSTODY PETITION and ORDER SETTING CUSTODY HEARING was served, via certified mail, restricted delivery, return receipt requested, addressed to. j Jason Nenninger 1827 Rimer Hi hwa ¦ Complete items 1, 2, and 3. Also complete Item 41f Restricted Delivery is desired. d address on the reverse a i A. Signature X ? 8dreaeee g y Shippensburg, Pa. 17257 n ¦ Pr nt your name A that th s can rto the bsc ardf the ou. mallplece, . R?'ved by (Rl ed Name) G: fe of DelNery DEFENDANT or on the front 9 space permits. p le delh*ry address dtft ntfmm ham t4 ? Yes 1. Art cle Addressed to: If YES, enter delivery address below: ? No ` i Pn h to e? /"r ?! ZLS m l 1 ',!1 7 ? L V L( !1 l 1 r `ems W T/rr775,7 3. servlcolype Jid certified mail 13 Bpm MaK PAN" RVOW ter MN&OX11186 O?edMd COA.M 4. RwWv d DAvwyt Oft FW o yes 2. Article Nwnber 7003 3110 004 5775 4504 marwier Ilom s ke label) PS Form 3811, February 2004 Donm* Moan R10*t _„W. w:._ tOW6UaAM610 Respectfully Submitted: J ne ams, Esquire I o. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DANIELLE R. NICKLE, No. 05-1675 Plaintiff KNIGHT & ASSOCIATES, P.C. V. CIVIL ACTION - LAW JASON Z. NENNINGER, IN CUSTODY Defendant PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter my appearance on behalf of the Defendant, Jason Z. Nenninger, in the above- captioned matter. Respectfully submitted, Dated: April ?? 2005 Attorney for Defendant Attorney I.D. No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DANIELLE R. NICKLE, Plaintiff V. JASON Z. NENNINGER, Defendant No. 05-1675 CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I hereby verify that on April , 2005, I served a true and correct copy of the foregoing Answer by United States First Class Mail, postage prepaid, addressed as follows: Jane Adams, Esquire 64 South Pitt Street Carlisle, Pennsylvania 17013 Attorney for Plaintiff KNIGHT & ASSOCIATES, P.C can M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorney for Defendant F Wse?Mde'T m?o¢AGendo¢20DS3?W-lanswecwId T •? T r-- ? ? ? t ?? 1..? ' ?` ? `1 ) f^l • ? ? nl ?.? ?.,? ?4 ?') IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DANIELLE R. NICKLE, No. 05-1675 Plaintiff V. CIVIL ACTION - LAW JASON Z. NENNINGER, IN CUSTODY Defendant ANSWER TO PETITION FOR CUSTODY AND NOW, this Z36-day of April, 2005, comes the Defendant, Jason Z. Nenninger, by and through his counsel, Knight & Associates, P.C., and files the following Answer to Petition for Custody and in support thereof avers as follows: Admitted. Byway of further answer, since the beginning of April, Plaintiff Danielle R. Nickle ("Mother") has resided with Defendant Jason Z. Nenninger ("Father") and his parents at 1827 Rimer Highway, Shippensburg, Pennsylvania 17257. 2. Admitted. Admitted in part, denied in part. Paragraph 3 of Plaintiffs Petition is denied to the extent that it alleges that Mother has had primary physical custody of the child. Additionally during ]March until March 20, 2005, the child resided with the parties at Father's residence and since the beginning of April 2005 the parties have resided together with the child at Father's residence. Admitted in part, denied in part. Paragraph 4 of Plaintiff s Petition is denied only to the extent that after Plaintiff filed the Petition, the child and the parties resided at Father's residence. 5. Admitted. 6. Admitted. Denied. It is denied that Mother has been the primary caretaker for the child. Father avers that the parties have shared custody of the child, and that he has been an equal caretaker for the child due to Mother's work schedule. Admitted. WHEREFORE, Defendant, Jason Z. Nenninger requests that the Court grant shared legal and physical custody of the children to the parties. Respectfully Submitted, KNIGHT & ASSOCIATES, P.C. SAM. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorney for Defendant VERIFICATION I verify that the statements made in the foregoing Answer to Petition for Custody are true and correct to the best of my knowledge, information and belief. This Verification is made by Defendant's counsel based upon information provided by Defendant to Defendant's counsel regarding the factual averments contained herein. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904, relating to unworn falsification to authorities. FAUsa FolderTin pca PoemsVLitigoGOnAvuification-pltfmh IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DANIELLE R. NICKLE, No. 05-1675 Plaintiff V. CIVIL ACTION - LAW JASON Z. NENNINGER, IN CUSTODY Defendant CERTIFICATE OF SERVICE I hereby verify that on April Z??2005, I served a true and correct copy of the foregoing by United States First Class Mail, postage prepaid, addressed as follows: Jane Adams, Esquire 64 South Pitt Street Carlisle, Pennsylvania 17013 Attorney for Defendant KNIGHT & ASSOCIATES, P.C. can M. Shultz, Esquire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorney for Defendant PrAUla I?olderAFirtn Da ,s Genducs20U179i-I answer wyd T-> ?'? i? `? ? ?? ?1 _ t is [.:. N ? ?! ? ?G' _ Lp ?r? ?l _ 'fl - x.. . 4 ? ?l RECEIVED JUN 0 8 2005 DANIELLE R. NICKLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-1675 CIVIL TERM : CIVIL ACTION - LAW JASON Z. NENNINGER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this _ (A day of T4J) c_ , 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Danielle R. Nickle, and the Father, Jason Z. Nenninger, shall have shared legal custody of Haley Marie Nenninger, born July 4, 2004. 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 her health, education and religion. 2. Mother shall have physical custody of the child at all times other than as set forth in Paragraph 3. Father shall have the following periods of physical custody A. Beginning June 17, 2005 alternating weekends from Friday at 7:30 p.m. to Sunday at 7:00 p.m. B. Two overnights per week which may be consecutive, to coincide with Father's days off from work, at times as agreed by the parties. C. Such other times as the parties agree. 4. Thanksgiving shall be shared from 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. and alternated from year to year. Mother shall have the earlier time in odd numbered years and the later time in even numbered years. Father shall have the later time in odd numbered years and the earlier time in even numbered years. 5. Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from 12:00 noon Christmas Day to 12:00 noon on December 26. Father shall have Block A in odd numbered years and Block B in even numbered years. Mother shall have Block A in even numbered years and Block B in odd numbered years. 6. Father shall have physical custody of the child on New Year's Eve at times agreed by the parties and Mother shall have physical custody of the child on New to u_...- .41rv .1 rol l - 2r- =17? y :._ Year's Day at times agreed by the parties. Each parent shall have the same amount of time unless otherwise agreed. 7. Easter shall be shared from 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. Mother shall have the earlier time in even numbered years and the later time in odd numbered years. Father shall have the earlier time in odd numbered years and the later time in even numbered years. 8. Mother shall have physical custody of the child on Mother's Day from 9:00 a.m. to 7:00 p.m. Father shall have physical custody of the child on Father's Day from 9:00 a.m. to 7:00 p.m. 9. Father shall be entitled to two hours of physical custody of the child on the child's birthday 10. In the event that either party is in need of a babysitter for more than three hours, they shall contact the non-custodial parent in sufficient time so that the non- custodial parent can take advantage of the time, and offer said time to the non-custodial parent. 11. Transportation shall be shared such that the receiving party shall transport the child. 12. Neither party shall do or permit a third party to do or say anything that 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. 13. 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: Jane Adams, Esquire, Counsel for Mother f Y -U 5 Sean M. Shultz, Esquire, Counsel for Father DANIELLE R. NICKLE, Plaintiff V. JASON Z. NENNINGER, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :2005-1675 CIVIL TERM : CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Haley Marie Nenninger July 4, 2004 Mother 2. A Conciliation Conference was held in this matter on June 7, 2005. Mother, Danielle R. Nickle, was present with her counsel, Jane Adams, Esquire, and Father, Jason Z. Nenninger, was present with his counsel, Sean M. Shultz, Esquire. The parties agreed to the entry of an Order in the form as attached. 6 7 Date gacqu ine M. Verney, Esquire - Custody Conciliator DANIELLE R. NICKLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 2005-1675 CIVIL TERM JASON Z. NENNINGER, Defendant IN CUSTODY PETITION TO MODIFY CUSTODY AND NOW, comes Jason Z. Nenninger, by and through his counsel, Michael J. Whare, Esquire and in support of his Petition to Modify Custody avers as follows: 1. Petitioner is Jason Z. Nenninger, hereinafter referred to as "Father". 2. Respondent is Danielle R. Nickle, hereinafter referred to as "Mother". 3. The parties are the parents of Haley Marie Nenninger, born July 4, 2004 and Alexis Lynn Nenninger, born October 26, 2006, hereinafter referred to as "Children". 4. The Honorable J. Wesley Oler entered a Custody Order in regards to the above captioned case on June 11, 2005. (Attached as Exhibit A) 5. Since the entry of said Order, there has been a significant change in circumstances in that: a) Mother and Father reconciled shortly after the Order of June 11, 2005 and married on December 15, 2006. b) Mother left the marital residence on or about April 13, 2009. c) Mother and Father had another child together, Alexis Lynn Nenninger. d) Father would like to modify the current custody order to include Alexis. e) Father is best able to provide a safe and stable environment for the Children. f) Father has undertaken and performed the primary parental responsibilities for the Children since Mother left the marital home. 6. The best interest of the Children will be served by the Court modifying said Order and granting Father primary physical custody. WHEREFORE, Petitioner respectfully requests this Honorable Court grant his Petition to Modem Custody. Respectfully submitted, _'m ? Date: ?! Michael I Whar , Esquire 37 East Pomfret Street Carlisle, PA 17013 Supreme Ct. Id No. 89028 Attorney for Plaintiff DANIELLE R. NICKLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 2005-1675 CIVIL TERM JASON Z. NENNINGER, Defendant IN CUSTODY VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: ason enninger, Petitioner DANIELLE R. NICKLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : Civil Action- Law No. 2005-1675 CIVIL TERM JASON Z. NENNINGER, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, Michael J. Whare, Esquire, attorney for Petitioner, do hereby certify that I this day mailed a copy of the within Petition to Modify Custody upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Danielle R. Nenninger 525 Third Street College Park Apts., Apt. 515 Carlisle, PA 17013 °fi lR,o Dated: 4' Michael J. Whare, squire Attorney for Petitioner RECEIVED JUN 0 8 2005' DANIELLE R. NICKLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-1675 CIVIL TERM : CIVIL ACTION - LAW JASON Z. NENNINGER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of , 2005, upon consideration of the attached Custody Concil ation Report, it is ordered and directed as follows: 1. The Mother, Danielle R. Nickle, and the Father, Jason Z. Nenninger, shalfl have shared legal custody of Haley Marie Nenninger, born July 4, 2004. 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 her health, education and religion. 2. Mother shall have physical custody of the child at all times other than as set forth in Paragraph 3. 3. Father shall have the following periods of physical custody: A. Beginning June 17, 2005 alternating weekends from Friday at 7:30 p.m. to Sunday at 7:00 p.m. B. Two overnights per week which may be consecutive, to coincide with Father's days off from work, at times as agreed by the parties. C. Such other times as the parties agree. 4. Thanksgiving shall be shared from 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. and alternated from year to year. Mother shall have the earlier time in odd numbered years and the later time in even numbered years. Father shall have the later time in odd numbered years and the earlier time in even numbered years. 5. Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from 12:00 noon Christmas Day to 12:00 noon on December 26. Father shall have Block A in odd numbered years and Block B in even numbered years. Mother shall have Block A in even numbered years and Block B in odd numbered years. 6. Father shall have physical custody of the child on New Year's Eve at times agreed by the parties and Mother shall have physical custody of the child on New E?_ h i L I ?- t-14 1( Year's Day at times agreed by the parties. Each parent shall have the same amount of time unless otherwise agreed. 7. Easter shall be shared from 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. Mother shall have the earlier time in even numbered years and the later time in odd numbered years. Father shall have the earlier time in odd numbered years and the later time in even numbered years. 8. Mother shall have physical custody of the child on Mother's Day from 9:00 a.m. to 7:00 p.m. Father shall have physical custody of the child on Father's Day from 9:00 a.m. to 7:00 p.m. 9. Father shall be entitled to two hours of physical custody of the child on the child's birthday. 10. In the event that either party is in need of a babysitter for more than three hours, they shall contact the non-custodial parent in sufficient time so that-the non- custodial parent can take advantage of the time, and offer said time to the non-custodial parent. 11.. Transportation shall be shared such that the receiving party shall transport the child. 12. Neither party shall do or permit a third party to do or say anything that 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. 13. 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, 0(,,, d J. cc: Jane Adams, Esquire, Counsel for Mother Sean M. Shultz, Esquire, Counsel for Father TRUE COPY FROM Rr COPPI) to Taatlinony whereof, l here ur„a set my hanc and ttte mW of saW at "Isle, Pa. this iay , V_ Pratt nourv fi HE H009, JJ1, 19 ki 4-0. 00 PQ An-I GG* 1050 0* aaco 4a DANEILLE R. NICKEL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JASON Z. NENNINGER DEFENDANT 2005-1675 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Friday, June 26, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at__ 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, July 21, 2009 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for 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/ ac ueline M. Verne Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact Our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 FILED-Of FU CF THE PROTH 'rA tY 2899 JUN 26 PM 3: 41 PENNSYLVA',\M I0 DANIELLE R. NICKLE, Plaintiff VS. JASON Z. NENNINGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-1675 CIVIL TERM IN CUSTODY PRAECIPE FOR ENTRY OF APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the Plaintiff, Danielle Nickle, in the above captioned case. Respectfully submitted, 400) J ssica Holst, Esquire MidPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 Date: a?'?`'0f DANIELLE R. NICKLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 05-1675 CIVIL TERM JASON Z. NENNINGER, IN CUSTODY Defendant CERTIFICATE OF SERVICE I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for the Plaintiff, Danielle Nickle, hereby certify that I have served a copy of the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following date and in the manner indicated below: U.S. First Class Mail, Postage Pre-Paid Michael J. Whare, Esquire 37 East Pomfret Street Carlisle, PA 17013 Date: Jessica Holst, Esquire MidPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 r j '' 2059 S JUL 2 3 2009 &7 DANIELLE R. NICKLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2005-1675 CIVIL TERM : CIVIL ACTION - LAW JASON Z. NENNINGER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of ?v , 2009, upon consideration of the attached Custody Conciliation Repot it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. , of the Cumberland County Court House, on the,P3,Jd day of 2009, at g,_3,0_ o'clock, -A. M., at which time testimony will be taken. 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 five days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Order of Court dated June 11, 2005 shall remain in full force and effect with the following modifications and additions. 3. The prior Order of Court shall also apply to Alexis Lynn Nenninger, born October 26, 2006. 4. Physical custody of the children shall be shared on the schedule as set forth in the prior Court Order. In the event that a hearing is not scheduled and an Order of Court is not entered prior to the start of school for the 09/10 school year, Haley Marie Nenninger shall attend kindergarten in the Carlisle School District. 5. 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, esley Oler, cc ichael J. Whare, Esquire, counsel for Father ,eessica Holst, Esquire, MidPenn Legal Services, counsel for Mother v DANIELLE R. NICKLE, Plaintiff V. JASON Z. NENNINGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :2005-1675 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., 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 Haley Marie Nenninger July 4, 2004 shared Alexis Lynn Nenninger October 26, 2006 shared 2. A Conciliation Conference was held in this matter on July 21, 2009. Father, Jason Z. Nenninger, was present with his counsel, Michael J. Whare, Esquire, and Mother, Danielle R. Nickle, was present with her counsel, Jessica Holst, Esquire, MidPenn Legal Services. 3. The Honorable J. Wesley, Oler, Jr. previously entered an Order of Court dated June 11, 2005 providing for shared legal custody, and Mother having 8 overnights in a 14 day period and Father having the remaining overnights during the same period. Following that Order of Court, the parties reconciled and a second child was born to the parties. The parties recently separated again and are seeking a court order concerning both children, the oldest of whom will be attending kindergarten this fall. The parties previously registered the older child in Carlisle School District. Mother has relocated to Dillsburg in the Northern York School District. 4. Father's position on custody is as follows: Father seeks shared legal custody and primary physical custody, with mother having alternating weekends during the school year. During the summer, Father is satisfied with shared physical custody. Father asserts that he was the primary caregiver of the children when the parties were together as Mother worked the 3-11 shift and slept until noon most days. Father receives disability and is available at all times to care for the children. He denies Mother's allegation that he misuses pain medication. 5. Mother's position on custody is as follows: Mother seeks shared legal custody and primary physical custody, with father having alternating weekends during the school year. During the summer, Mother is satisfied with shared physical custody. Mother is currently unemployed and is able to care for the children. She asserts that father misuses pain medication. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the prior Order with modifications. It is expected that the Hearing will require one day. Date /tt cq ne M. Verney, Esquire Custody Conciliator OF THE 2009 J UL 24 PM 1: 47 DANIELLE R. NICKLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JASON Z. NENNINGER, Defendant NO. 05-1675 CIVIL TERM IN RE: PETITION TO MODIFY CUSTODY BEFORE OLER, J. ORDER OF COURT AND NOW, this 240' day of November, 2009, upon consideration of Defendant's Petition To Modify Custody with respect to the parties' children, Haley Marie Nenninger (d.o.b. July 4, 2004) and Alexis Lynn Nenninger (d.o.b. October 26, 2006), and following a hearing held on November 23, 2009, the petition is denied, and (a) the custodial terms of the order of court dated July 23, 2009, shall remain in full force and effect as to both children, (b) the older child shall remain in the Carlisle Area School District System, and (c) the parties may deviate from the custodial terms of the order by mutual consent. BY THE COURT, Wesley O r Jr., J. ?1. Shana M. Walter, Esq. MidPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 Attorney for Plaintiff Michael J. Whare, Esq. 37 E. Pomfret Street Carlisle, PA 17013 Attorney for Defendant :rc ''(^ iui.. 2009 NOV 24 PI 2: 2 9 DANIELLE R. NICKEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW JASON Z. NENNINGER, Defendant 2005-1675 CIVIL TERM IN RE: PETITION TO MODIFY CUSTODY ORDER OF COURT AND NOW, this 23rd day of November, 2009, upon consideration of Defendant's Petition To Modify Custody with respect to the parties' children, Hayley Marie Nenninger (date of birth, July 4, 2004) and Alexis Lynn Nenninger (date of birth, October 26, 2006), and following a hearing held on this date, the record is declared closed, and the matter is taken under advisement. v Shana M. Walther, Esquire 213-A North Front Street Harrisburg, PA 17101 For Plaintiff ./ Michael J. Whare, Esquire 37 East Pomfret Street Carlisle, PA 17013 For Defendant :mae nn l?p"J [ ES rYl?..t-? 1 By the Court, 2003 DI;C - ! PCl 2: 3 8 T t r'! y ~ i { ~ 6 .t '..! 1 3 1 ~ . i C::I.iJ 1 ~..~11~.Yv~f°~ DANIELLE R. NICKLE :IN THE COURT OF COMMON PLEAS OF (n.k.a. DANIELLE R. NENNINGER):CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Petitioner v. :CIVIL ACTION - LAW JASON Z. NENNINGER . Defendant/Respondant :No. 05-1675 CIVIL TERM EMERGENCY PETITION FOR SPECIAL RELIEF IN CU TODY And now comes Danielle Nenninger by and through her attorney, Mary A. Etter Dissinger, Esq., and respectfully prays this Court grant her Emergency Petition for Special Relief in Custody, and in support of her request further avers: 1. Petitioner is Danielle Nenninger, natural mother of the children in the above captioned matter. 2. Respondent is Jason Nenninger, natural father of the children in the above captioned matter. 3. The children of the parties are: Haley M. Nenninger - DOB - 7/4/04 Alexis L. Nenninger - DOB - 10/26/06 4. This matter has historically been presented to and presided over by the Honorable J. Wesley Oler, Jr. 5. n A Order of Court dated November 24, 2009, (See copy attached as Exhibit "A") the most recent Order in this matter, upholds the Custody Order of July 23, 2009, (See copy attached as Exhibit "B") which supports the terms of s~~~ ov Pd ~y ~~ a-sb3~N the Custody Order of June 11, 2005, (See copy attached as Exhibit "C") and incorporates the terms to the younger child of the parties, Alexis L. Nenninger. 6. Plaintiff/Petitioner has been contacted by a Cumberland County Police Unit's (North Middleton Township) detectives, informing her they raided Father's home. 7. Mother was informed that drugs, hypodermic needles, and other drug paraphernalia were found in Father's residence, where he lives with the children when they are in his custody. 8. The Police have indicated they will be charging Defendant/Respondent with Endangering the Welfare of the Children and Possession of Drug Paraphernalia, and possibly other charges as well. 9. Plaintiff/Petitioner has been notified that there has been communications between the Cumberland County Police Unit and the Cumberland County Children and Youth Agency, although she is not certain which entity contacted the other initially. 14. Cumberland County Children and Youth Agency has instructed Plaintiff/Petitioner not to let Defendant/Respondent have custody of the children. 11. Plaintiff/Petitioner strongly believes it is in the children's best emotional and physical interest to be removed from Father's partial physical and shared legal custody. 12. Plaintiff/Petitioner strongly believes it is in the children's best emotional and physical interest to have all contact between Father and the children terminated until such time as the investigation and charges against Defendant/Respondent are either dropped or deemed by authorities to not be of negative effect or danger to the children. 13. This Petition to Modify Custody is being submitted in conjunction with Plaintiff/Petitioner's Emergency Petition for Special Relief in Custody. 14. Counsel for Defendant/Respondent has been notified of Plaintiff/Petitioner's intentions to file this Petition to Modify Custody, via US MAIL DELIVERY. 15. Plaintiff/Petitioner, requests this Court to remove the children from Defendant/Respondent's partial physical and shared legal custody and to grant her sole physical and sole legal custody. WHEREFORE, Plaintiff/Petitioner, prayerfully requests this Honorable Court grant her Petition to Modify Custody, and her request for sole physical and sole legal custody and barring all contact between Father and the children of the parties RESPECTFULLY SUBMITTED: M Mary A Etter Dissinger Esq. Attorney for Plaintiff/Petitioner 400 S. State Road Marysville, PA 17053 (717)957-3474 (717)957-2316 - fax VERIFICATION I, Danielle R. Nenninger, (f.k.a. Danielle R. Nickle), verify that the statements made in the above captioned document are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification. Danielle R. Nenninger, aintiff ,a DANIELLE R. NICIZLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW JASON Z. NENNINGER, pefendant N0.05-1675 CIVIL TERM 1N RE: PETITION TO MODIFY CUSTODY BEFORE OLER, J. ORDER OF COURT AND NOW, this 24`~ day of November, 2009, upon consideration of Defendant's Petition To Modify Custody with respect to the parties' children, Haley Marie Nenninger (d.o.b. July 4, 2004) and Alexis Lynn Nenninger (d.o.b. October 26, 2006), and following a hearing held on November 23, 2009, the petition is denied, and (a) the custodial terms of the order of court dated July 23, 2009, shall remain in full force and effect as to both children, (b) the older child shall remain in the Carlisle Area School District System, and (c) the parties may deviate from the custodial terms of the order by mutual consent. BY THE COURT, Sham M. Walter, Esq. MidPenn Legal Services 401 E. Loather Street Carlisle, PA 17013 Attorney for Plaintiff Michael J. Whare, Esq. 37 E. Pomfret Street Carlisle, PA 17013 Attorney for Defendant :rc + ~ ~,. ~~ ~ .. Wesley O Jr., J. m,~a,,,fto~. ~~-,~,~~07 (''°~~.. EXHIBIT ~ A ~. 1Q~9 NOV 24 ~H 2= 2 9 PE;~~\~:Yl.VA~IA JUL 2 319 ~ DANIELLE R. NICKLE, : IIN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :2005-1675 CIVIL TERM CIVIL ACTION -LAW JASON Z. NENNINGER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this ~~ day of ~ v , 2009, upon consideration of the attached Custody Conciliation Repo , it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. ~,_, of the Cumberland County Court House, on then?3~l day of _7~~(ie~_, 2009, at 9'%3D o'clock, ~. M.. at which time testimony will be taken. 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 parry'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 five days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Order of Court dated June 11, 2005 shall remain in full force and effect with the following modifications and additions. 3. The prior Order of Court shall also apply to Alexis Lynn Nenninger, bom October 26, 2006. 4. Physical custody of the children shall be shared on the schedule as set forth in the prior Court Order. In the event that a hearing is not scheduled and an Order of Court is not entered prior to the start of school for the 09/10 school year, Haley Marie Nenninger shall attend kindergarten in the Carlisle School District. 5. 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 esley Oler, Jai' , ~ c • ichael J. Whare. Esquire, counsel for F er ,d'~ssica Holst, Esquire, MidPenn Legal Services, counsel for Mother ~ ~x-~iwr ~_ DANIELLE R NICKLE, pt~tintitf v. JASON Z. NENNINGER, Defendant :1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ZOOS-1673 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. CUSTODY CONCIiLIATi N SUMMARY REPORT lIN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CItVIL 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 Haley Marie Nenninger July 4, 2004 shared Alexis Lynn Nenninger October 26, 2006 shared 2. A Conciliation Conference was held in this matter on July 21, 2009. Father, Jason Z. Nenninger, was present with his counsel, Michael J. Whare, Esquire, and Mother, Danielle R. Nickle, was present with her counsel, Jessica Hoest, Esquire, MidPenn Legal Services. 3. The Honorable J. Wesley, Oler, Jr. previously entered an Order of Court dated June 11, 2005 providing for shared legal custody, and Mother having S overnights in a 14 day period and Father having the remaining overnights during the same period. Following that Order of Court, the parties reconciled and a second child was born to the parties. The parties recently separated again and are seeking a court order concerning both children, the oldest of whom wilt be attending kindergarten this fall. The parties previously registered the older child in Carlisle School District. Mother has relocated to Dillsburg in the Northern York Schoo! District. 4. Father's position on custody is as follows: Father seeks shared legal custody and primary physical custody, with mother having alternating weekends during the school year. During the summer, Father is satisfied with shared physical custody. Father asserts that he was the primary caregiver of the children when the parties wcre together as Mother worked the 3-11 shift and slept until noon most days. Father receives disability and is available at all times to care for the children. He denies Mother's allegation that he misuses pain medication. 5. Mother's position on custody is as follows: Mother seeks shared legal custody and primary Physical custody, with father having alternating weeketuis during the school year. During the summer, Mother is satisfied with shared physical custody. Mother is currently unemployed and is able to care for the children. She asserts that father misuses pain medication. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the prior Order with modifications. It is expected that the Hearing will require one day. Date ? - ~ ~ ~ 0 9 Y M. Verney, Esq~ Custody Conciliator OF THE F~1~r" ~~~'TARY 1009 JUI.24 PM I ~ 4'1 CUM---- , ;_, ~_u~v'?Y ~tiPdS''LVANiA RECEIVED JUN 0 8 20Q5~'' DANIELLE R. NICKLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : NO.2005-1675 CIVIL TERM CIVIL ACTION -LAW JASON Z. NENNINGER, Defendant : IN CUSTODY QRDER OF COURT AND NOW, this t I ~~ day of ~~ e.- , 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Danielle R. Nickle, and the Father, Jason Z. Nenninger, shall have shared legal custody of Haley Marie Nenninger, bom July 4, 2004. Each paretrt shall have an equal right, to be exercised jointly with the other parent, to make all major non~mergcncy dccisions affecting the child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. Mother shall have physical custody of the child at all times other than as set forth in Paragraph 3. 3. Fathcr shall have the following periods of physical custody: A. Beginning June 17, 2005 alternating weekends from Friday at 7:30 p.m. to Sunday at 7:00 p.m. B. Two overnights per week which may be consecutive, to coincide with Father's days off from work, at times as agreed by the parties. C. Such other times as the parties agree. 4. Thanksgiving shall be shared from 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. and alternated from year to year. Mother shall have the earlier time in odd numbered years and the later time in even numbered years. Father shall have the later time in odd numbered years and the earlier time in even numbered years. 5. Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from 12:00 noon Christmas Day to 12:00 noon on December 26. Father shall have Block A in odd numbered years and Block B in even numbered years. Mother shall have Block A in even numbered years and Block B in odd numbered years. 6. Father shall have physical custody of the child on New Year's Eve at times agreed by the parties and Mother shall have physical custody of the child on New EXHIBIT ~1 0 r 3 `~~ .~ ~ `t? .G 3 NS ~p .r ~ '~,~~ Year's Day at times agreed by the parties. Each parent shall have the same amount of time unless otherwise agreed. ?. Easter shall be shared from 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. Mother shall have the earlier time in even numbered years and the later time in odd numbered years. Father shall have the earlier time in odd numbered years and the later time in even numbered years. 8. Mother shall have physical custody of the child on Mother's Day fmm 9:00 a.m. to 7:00 p.m. Father shall have physical custody of the child on Father's Day from 9:00 a.m. to 7:00 p.m. 9. Father shall be entitled to two hours of physical custody of the child on the quid's birthday. 10. In the event that either party is in need of a babysitter for more than three hours, they shall contact the non-custodial parent in sufficient time so thatthe non- custodial parent can take advantage of the time, and offer said time to the non-custodial parent. 1 l . Transportation shall be shared such that the receiving party shall transport the child. 12. Neither party shall do or permit a third party to do or say anything that may estrange the child from the other parent, injure the opinion of the child as to the other parent, or hamper the &ee and natural development of the child's love and respect for the other parent. 13. 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: Jane Adams, Esquire, Counsel for Mother ~~~~ G , ~ y .v ~ Sean M. Shultz, Esquire, Counsel for Father '~~°~'d ~i DANIELLE R. NICKLE :IN THE COURT OF COMMON PLEAS OF (n.k.a. DANIELLE R. NENNINGER):CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Petitioner v. :CIVIL ACTION - LAW JASON Z. NENNINGER Defendant/Respondent :No. 05-1675 CIVIL TERM CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, Esquire do hereby certify that a copy of the foregoing document has been duly served upon Michael J. Whore, Esq., attorney of record for Defendant/Respondent, Jason Z. Nenninger, by depositing same in the United States Mail, postage prepaid, addressed as follows: Michael J. Whore, Esq. 37 E. Pomfret Street Carlisle, PA 17013 (717)243-3561 Date : lY / G ~_~01~.,.. ~ --~ Mary. Etter Dissinger, `Esq. Attorney for the PlaintifflPetitioner ~'~~,..~r~l-u~F1C~ flF T~'' ~ ~..;t (.~~a~0 i~~~~~ . ~ ~ n ~. I','" ~. DANIELLE R. NICKLE :IN THE COURT OF COMMON PLEAS OF (n.k.a. DANIELLE R. NENNINGER):CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Petitioner v. :CIVIL ACTION - LAW JASON Z. NENNINGER . Defendant/Respondant :No. 05-1675 CIVIL TERM PETITION TO MODIFY CUSTODY And now comes Danielle Nenninger by and through her attorney, Mary A. Etter Dissinger, Esq., and respectfully prays this Court grant her Petition to Modify Custody, and in support of her request further avers: 1. Petitioner is Danielle Nenninger, natural mother of the children in the above captioned matter. 2. Respondent is Jason Nenninger, natural father of the children in the above captioned matter. 3. The children of the parties are: Haley M. Nenninger - DOB - 7/4/04 Alexis L. Nenninger - DOB - 10/26/06 4. This matter has historically been presented to and presided over by the Honorable J. Wesley Oler, Jr. 5. An Order of Court dated November 24, 2009, (See copy attached as Exhibit "A") the most recent Order in this matter, upholds the Custody Order of July 23, 2009, {See copy attached as Exhibit "B") which supports the terms of sxo,ae ~- ~.~y ~~~~a~ /Z,~~d 303 the Custody Order of June 11, 2005, (See copy attached as Exhibit ~~C") and incorporates the terms to the younger child of the parties, Alexis L. Nenninger. 6. Plaintiff/Petitioner has been contacted by a Cumberland County Police Unit's (North Middleton Township) detectives, informing her they raided Father's home. 7. Mother was informed that drugs, hypodermic needles, and other drug paraphernalia were found in Father's residence, where he lives with the children when they are in his custody. 8. The Police have indicated they will be charging Defendant/Respondent with Endangering the Welfare of the Children and Possession of Drug Paraphernalia, and possibly other charges as well. 9. Plaintiff/Petitioner has been notified that there has been communications between the Cumberland County Police Unit and the Cumberland County Children and Youth Agency, although she is not certain which entity contacted the other initially. 10. Cumberland County Children and Youth Agency has instructed Plaintiff/Petitioner not to let Defendant/Respondent have custody of the children. 11. Plaintiff/Petitioner strongly believes it is in the children's best emotional and physical interest to be removed from Father's partial physical and shared legal custody. 12. Plaintiff/Petitioner strongly believes it is in the I children's best emotional and physical interest to have all contact between Father and the children terminated until such time as the investigation and charges against '~ Defendant/Respondent are either dropped or deemed by authorities to not be of negative effect or danger to the 'i !! children. I'' "; 13. This Petition to Modify Custody is being submitted in '~ i conjunction with Plaintiff/Petitioner's Emergency Petition j for Special Relief in Custody. 14. Counsel for Defendant/Respondent has been notified of Plaintiff/Petitioner's intentions to file this Petition to Modify Custody, via US MAIL DELIVERY. 15. PlaintifflPetitioner, requests this Court to remove the children from Defendant/Respondent's partial physical and shared legal custody and to grant her sole physical and sole legal custody. WHEREFORE, Plaintiff/Petitioner, prayerfully requests this Honorable Court grant her Petition to Modify Custody, and her request for sole physical and sole legal custody and barring all contact between Father and the children of the parties RESPECTFULLY SUBMITTF~p: ., >1 C Mary ~. Etter Dissinger,"Esq. Attorney for Plaintiff/Petitioner 400 S. State Road Marysville, PA 17053 (717)957-3474 (717)957-2316 - fax VERIFICATION I, Danielle R. Henninger, (f.k.a. Danielle R. Nickle), verify that the statements made in the above captioned document are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification. Danielle R. Henninger, plaintiff DANIELLE R. NICKLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION -LAW JASON Z. NENNINGER, . Defendant NO.OS-1b75 CIVIL TERM IN RE: PETITION TO MODIFY CUSTODY BEFORE OLER J. ORDER OF COURT AND NOW, this 24a' day of November, 2009, upon consideration of Defendant's Petition To Modify Custody with respect to the parties' children, Haley Marie Nenninger (d.o.b. July 4, 2004) and Alexis Lynn Nenninger (d.o.b. October 26, 2006), and following a hearing held on November 23, 2009, the petition is denied, and (a) the custodial terms of the order of court dated July 23, 2009, shall remain in full force and effect as to both children, (b) the older child shall remain in the Carlisle Area School District System, and (c) the parties may deviate from the custodial terms of the order by mutual consent. BY THE COURT, Shama M. Walter, Esq. MidPenn Legal Services 40I E. Loather Street Carlisle, PA 17013 Attorney for Plaintiff Michael J. Where, Esq. 37 E. Pomfret Street Carlisle, PA 17013 Attorney for Defendant :rc ,! ,:. CC ~ Wesley O Jr., J. ~~ n~-a`~C' ~I-1~.a7 l~'bA~`r I EXHIBIT ~ A .._ FILEu-C~~~ ,;;t 1609 NOY 24 PM 2~ 29 CUMo~ - '~:i.: '~UiJTY F'Ez~~~:SY~VAhfIA JUL 2 32009 ~ DANIELLE R. NICKLE, Plaintiff V. JASON Z. NENNINGER, Defendant : IN TAE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2005-1675 CIVIL TERM CIVIL ACTION -LAW IN CUSTODY ORDER OF COURT AND NOW, this ~~ day of 3 v , 2009, upon consideration of the attached Custody Conciliation Repo , it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. _L_, of the Cumberland County Court House, on the,~~ day of _~~el~,, 2009, at 4%~p o'clock, ~. M.. at which time testimony will be taken. 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 five days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Order of Court dated June 11, 2005 shall remain in full force and effect with the following modifications and additions. 3. The prior Order of Court shall also apply to Alexis Lynn Henninger, born October 26, 200b. 4. Physical custody of the children shall be shared on the schedule as set forth in the prior Court Order. In the event that a hearing is not scheduled and an Order of Court is not entered prior to the start of school for the 09!10 school year, Haley Marie Henninger shall attend kindergarten in the Carlisle School District. 5. 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, Oler, c~hael J. Where, Esquire, counsel for Fat~er ,3~ssica Hoist, Esquire, MidPenn Legal Services, counsel for Mother ~ ~ierr ~ ~-_ DANIELLE R. NICKLE, Pls~intiff V. JASON Z. NENNINGER, Defendant IN TAE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ZOOS-1675 CIVIL TERM CML ACTION -LAW IlY CUSTODY PRIOR JUDGE: J. Wealey Oler, Jr., 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 Haley Marie Nenninger July 4, 2004 shared Alexis Lynn Nenninger October 26, 2006 shared 2. A Conciliation Conference was held in this matter on July 21, 2009. Father, Jason Z. Nenninger, was present with his counsel, Michael J. Where, Esquire, and Mother, Danielle R. Nickle, was present with her counsel, Jessica Holst, Esquire, MidPenn Legal Services. 3. The Honorable J. Wesley, Oler, Jr. previously entered an Order of Court dated June 11, 2005 providing for shared legal custody, and Mother having 8 overnights in a 14 day period and Father having the remaining overnights during the same period. Following that Order of Court, the parties reconciled and a second child was born to the parties. The parties recently separated again and are seeking a cows or~r concerning both children, the oldest of whom wilt be attending kindergarten this fall. The parties previously registered the older child in Carlisle School District. Mother has relocated to Dillsburg in the Northern York School District. 4. Father's position on custody is as follows: Father seeks shared Legal custody and primary physical custody, with mother having alternating weekends during the school year. During the summer, Father is satisfied with shared physical custody. Father asserts that he was the primary caregiver of the children when the parties were together as Mother worked the 3-11 shift and slept until noon most days. Father roceives disability and is available at all times to care for the children. He denies Mother's allegation that he misuses pain medication. 5. Mother's position on custody is as follows: Mother seeks shared legal custody and primary physical custody, with father having alternating weekends during the school year. During the summer, Mother is satisfied with shared physical custody. Mother is currently unemployed and is able to care for the children. She asserts that father misuses pain medication. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the prior Order with modifications. It is expected that the Hearing will require one day. Date ? '~ - -n9 V e M. Verney, Esquire Custody Conciliator FlLE~U, OF THE F~1Y~sn'~'rTARY 1Q09 JUL 24 PM 1 ~ 4 7 CL~M~,::-~ ~ _ ~_ivly? Y ~P1Pdv~'LVr'tI~{A REC~rvEO ~u~ o s 2005 DANIELLE R NICKLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2005-1675 CIVIL TERM CML ACTION -LAW JASON Z. NENNINGER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this _~ day of ~~ er , 2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Danielle R. Nickle, and the Father, Jason Z. Nenninger, shall have shared legal custody of Haley Marie Nenninger, born 3uly 4, 2004. Each parent shat! have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the child's general wel!•being including, but not limited to, all decisions regarding her health, education and religion. 2. Mother shall have physical custody of the child at all times other than as set forth in Paragraph 3. 3. Father shall have the following periods of physical custody: A. Beginning dune 17, 2005 alternating weekends from Friday at 7:30 p.m. to Sunday at 7:04 p.m. B. Two overnights per week which may be consecutive, to coincide with Father's days off from work, at times as agreed by the parties. C. Such other times as the parties agrce. 4. Thanksgiving shall be shared fmm 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. and alternated fmm year to year. Mother shall have the earlier time in odd numbered years and the later time in even numbered years. Father shall have the later time in odd numbered years and the earlier time in even numbered years. 5. Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from 12:00 noon Christmas Day to 12:00 noon on December 26. Father shall have Block A in odd numbered years and Block B in even numbered years. Mother shall have Block A in even numbered years and Block B in odd numbered years. 6. Father shall have physical custody of the child on New Year's Eve at times agreed by the parties and Mother shall have physical custody of the child on New EXI118R o~~. O 7- ~ ~-? -~ Y~ ~ ~~ ~~ ~~ ~ ~ .?,'~y ~ ~i ~~ Year's Day at tames agreed by the parties. Each parent shall have the same amount of time unless otherwise agi'eed. 7. Easter shall be shared from 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. Mother shall have the earlier timc in even numbered years and the later time in odd numbered years. Father shall have the earlier time in odd numbered years and the Later time in even numbered years. 8. Mother shall have physical custody of the child on Mother's Day from 9:00 a.m. to 7:00 p.m. Father shall have physical custody of the child on Father's Day from 9:00 a.m. to 7:00 p.m. 9. Father shall be entitled to two hours of physical custody of the child on the child's birthday. 10. In the event that either patty is in need of a babysitter for more than three hours, they shall contact the non-custodial parent in sufficient time so that the non- custodial parent can take advantage of the time, and offer said time to the non-custodial parent. 11. Transportation shall be shared such that the receiving party shah transport the child. 12. Neither party shall do or permit a third party to do or say anything that 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. 13. 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: Jane Adams, Esquire, Counsel far Mother ~~~ G , ~ y .d ~ Sean 1V1. Shultz, Esquire, Counsel for Father '"7,~'"' DANIELLE R. NICKLE ;IN THE COURT OF COMMON PLEAS OF (n.k.a. DANIELLE R. NENNINGER):CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Petitioner , v. :CIVIL ACTION - LAW JASON Z. NENNINGER , Defendant/Respondant :No. 05-1675 CIVIL TERM CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, Esquire do hereby certify that a copy of the foregoing document has been duly served upon Michael J. Whare, Esq., attorney of record for Defendant/Respondent, Jason Z. Nenninger, by depositing same in the United States Mail, postage prepaid, addressed as follows: Michael J. Whare, Esq. 37 E. Pomfret Street Carlisle, PA 17013 (717) 243-3561 Date: / G Z - ary, Etter Dissing r, Esq. Attorney for the Plaintiff/Petitioner DANIELLE R. NICKLE PLAINTIFF V. JASON Z. NENNINGER DEFF,NDANT AND NOW, Monday, November Ol, 2010 ,upon consideration of the attached Complaint, ORDER OF COURT /~• / /~ /l~l~i© /1~/-~D 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, November 30, 2010 at 9:30 AM for aPre-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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • 2005-1675 CIVIL ACTION LAW IN CUSTODY FOR. THE COURT, By: /s/ ac ueline M. Verne Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ~~~~/~~~ Cumberland County Bar Association ~~ ~~ ~"".'~`~ ~ ~ `~~~~`''~-~i 32 South. Bedford Street `~'~~~ ~ ~ ~ Carlisle, Pennsylvania 17013 w~ ~~_ /~ _ ~ ~,~.,~-~~~ ~ Telephone (717) 249-3166 c ~ -'~ C17 . ~ I ; ~ [VJ ~ _ ~ ~'. ~ ~n =~" ~ ~~ ~~ w ~ _ ~ ~ ~ o ~ ~ -< DANIELLE R. NICKLE, Plaintiff V. JASON Z. NENNINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05-1675 CIVIL TERM IN RE: PLAINTIFF'S EMERGENCY PETITION FOR SPECIAL RELIEF IN CUSTODY ORDER OF COURT AND NOW, this 12`x' day of November, 2009, upon consideration of Plaintiffs Emergency Petition for Special Relief in Custody, and following a telephone conference held on November 9, 2010, in which Plaintiff was represented by Mary A. Etter Dissinger, Esq., and Defendant was represented by Michael J. Whare, Esq., and it being represented to the court by Defendant's counsel that no charges are pending against Defendant at this time as a result of the search of his premises referred to in Plaintiff's petition, this matter is referred to the custody conciliation conference already scheduled for November 30, 2010. acqueline M. Verney, Esq. 44 South Hanover Street Carlisle, PA 17013 Custody Conciliator ,/Mary A. Etter Dissinger, Esq. 400 S. State Road Marysville, PA 17053 Attorney for Plaintiff G -v ? rncu r.g a zo Jcz ac N O ca a 41-1 Ln 0 O rnr -? rn o° --i0 O -'T1 Or a? v BY THE COURT, ichael J. Whare, Esq. 37 E. Pomfret Street Carlisle, PA 17013 Attorney for Defendant :rc I r • NOV 3 0 Zulu NOV 3 0 2010 DANIELLE R. NICKLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :2005-1675 CIVIL TERM : CIVIL ACTION - LAW JASON Z. NENNINGER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of _ kjo y , , 2010, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. of the Cumberland County Court House, on the day of, 2011, at 0 o'clock, /1-. M., at which time testimony will a taken. For purposes of this Hearing, the Mother 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 five days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Order of Court dated July 23, 2009 shall remain in full force and effect. 3. 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, Wesley Oler, , Low J. c A. Etter Dissinger, Esquire, counsel for Mother !: U ic hael J. Whare, Esquire, counsel for Father EC - Lf L m a t C C n l z ;L to rn o - ; m ° rn- N ? ? •t C7 2 C DC C?l ) rn -< cn -C X DANIELLE R. NICKLE, Plaintiff V. JASON Z. NENNINGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :2005-1675 CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., 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 Haley Marie Nenninger July 4, 2004 shared Alexis Lynn Nenninger October 26, 2006 shared 2. A Conciliation Conference was held in this matter on November 30, 2010. Mother, Danielle R. Nickle, was present with her counsel, Mary A. Etter Dissinger, Esquire, and Father, Jason Z. Nenninger, was present with his counsel, Michael J. Whare, Esquire. 3. The Honorable J. Wesley, Oler, Jr. previously entered an Order of Court dated July 23, 2009 providing for shared legal custody, and Mother having 8 overnights in a 14 day period and Father having the remaining overnights during the same period. 4. Mother's position on custody is as follows: Mother seeks shared legal custody and primary physical custody, with Father having supervised visitation. Mother asserts that Father's home has been searched and drug paraphernalia was found. 5. Father's position on custody is as follows: Father seeks to maintain the status quo. Father maintains that no criminal charges have been filed and he denies any criminal activity. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the prior Order. It is expected that the Hearing will require one-half day. Date `I - 36 - % ? A Custody Conciliator acq ine M. Verney, Esquire FILED-OFFICE OF THE PROTHONOTARY 2011 MAR 30 PM 2: 23 CU PENNSYLVAN A TY DANIELLE R. NICKEL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 2005-1675 CIVIL TERM JASON Z. NENNINGER, Defendant IN CUSTODY MOTION FOR CONTINUANCE AND NOW, comes defendant, Jason Z. Nenninger, by and through his counsel, Michael J. Whare, Esquire and avers as follows: 1. A custody hearing is scheduled for April 7, 2011 at 9:30 a.m. before the Honorable J. Wesley Oler, Jr., in regards to the above captioned matter. 2. On December 10, 2010, the Cumberland County Drug Task Force charged the Defendant, Mr. Nenninger, with two counts of Endangering the Welfare of Children and two counts of Recklessly Endangering Another Person. 3. At the Preliminary Hearing on January 11, 2011, the Commonwealth amended the criminal complaint to add two counts of Corruption of Minors. 4. After hearing testimony at the Preliminary Hearing, District Judge Paula Correal dismissed the two counts of Recklessly Endangering Another Person and the two counts of Corruption of Minors. The two counts of Endangering the Welfare of Children were bound over for Court. Mr. Nenninger is currently scheduled for Formal Arraignment on April 7, 2011 at 9:00 a.m. at the Cumberland County Courthouse on the Endangering the Welfare of Children charges. 6. The allegations made against Mr. Nenninger in petitioner's Petition to Modify Custody are similar to the allegations made against him in the criminal complaint. 7. At the custody hearing currently scheduled for April 7, 2011, Mr. Nenninger will be called to testify. Any testimony given by Mr. Nenninger during the custody hearing may tend to be incriminating in the subsequent criminal matter. 9. One of Mr. Nenninger's bail conditions is that he may only have supervised visits with the children involved in this custody matter. 10. Opposing Counsel, Mary A. Etter Dissinger, Esquire, has been contacted and does not oppose continuing the custody hearing until sometime after September 1, 2011. WHEREFORE, Mr. Nenninger respectfully requests this Honorable Court to grant his Motion to Continue to the custody hearing until sometime after September 1, 2011. Respectfully submitted, Date: W-'? '??A Michael J. Whare Esquire 37 East Pomfret Street Carlisle, PA 17013 Supreme Ct. Id No. 89028 Attorney for Defendant DANIELLE R. NICKEL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law JASON Z. NENNINGER, Defendant : No. 2005-1675 CIVIL TERM : IN CUSTODY VERIFICATION I verify that the statements made in this Motion are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Date: n Z. enninger, Defendant DANIELLE R. NICKEL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 2005-1675 CIVIL TERM JASON Z. NENNINGER, Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Michael J. Whare, Esquire, attorney for Petitioner, do hereby certify that I this day mailed a copy of the within Motion to Continue upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Mary A. Etter Dissinger, Esquire 400 S. State Road Marysville, PA 17053 Dated: 3-3 0 -L( z V::: ?: " Michael J. Wh , Esquire Attorney for Defendant L 1 t DANIELLE R. NICKEL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law -? - -"" - -: rncr) rn ? 4,3..? j?d No. 2005-1675 CIVIL TERM cnr" t - JASON Z. NENNINGER, cn 1 -" Defendant 3 = n IN CUSTODY ORDER OF COURT AND NOW, this day of , 2011, upon consideration of the within Motion for Continuance, Petitioner/Defendant's motion is granted and the custody hearing is continued until the 1.2 -&b day of , 2011 at 1: 3d _p_.m. in Courtroom number 1 in the Cumberland County Court of Common Pleas, Carlisle, Pa 17013. By the Court: Distribution: /,Mary A. Etter Dissinger, Esquire /Michael J. Whare, Esquire 00P;C?2, l41610 Mary A. Etter Dissinger, Esq. 400 South State Road Marysville, PA 17053 (717) 957-3474 - Voice (717) 957-2316 - Fax C ? =m •r? rn -am =-n CD-n DANIELLE R. NICKLE Plaintiff v. JASON Z. NENNINGER Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :No. 05-1675 CIVIL TERM ORDER AND NOW, this 11L day of 1? ti IL , 2011 this matter is continued generally. The parties shall submit a Stipulation for entry as a final Order no later than October 12, 2011. (? iP? vw?j l?? q Distribution: ? Mary A. Etter Dissinger, Esq., 400 South State Road, Marysville, PA 17053 ? Michael J. Whare, Esq., 37 E. Pomfret Street, Carlisle, PA 17013 E•d 91E2-GS6'GiG ua2utssla 92x ja9utssla Li'=01 1102 so des BY THE COURT: 41 Mary A. Etter Dissinger, Esq. 400 South State Road Marysville, PA 17053 (717) 957-3474 - Voice (717) 957-2316 - Fax DANIELLE R. NICKLE Plaintiff V. JASON Z. NENNINGER Defendant C-) r.... r , CY c _. r frl I .i) G7 ' U - r o ? i :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :No. 05-1675 CIVIL TERM ORDER AND NOW, this day of p 2011 upon IJ agreement of the parties, it is hereby Ordered and Decreed that the Stipulation and Agreement is the Order of this Court. BY THE COURT: J. Distribution: 0oPi 4 Oil 1( ? Mary A. Etter Dissinger, Esq., 400 South State Road, Marysville, PA 17053 r/ Michael J. Whare, Esq., 37 E. Pomfret Street, Carlisle, PA 17013 Court Administration -in bile