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HomeMy WebLinkAbout05-2984 SAMANTHA M. ROHRER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. OS" - ~9Pj C!r(jl~~ JASON E. ROHRER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER AND NOW, this day of , 20 , upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the Conciliator, at on the day of 20_, at o'clock _.m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary Order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent Order. FOR THE COURT, By Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, P A 17013 (717) 240-6200 - SAMANTHA M. ROHRER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. C>S'-~9PJ G'u~L'--r-~ : CIVIL ACTION - LAW JASON E. ROHRER, Defendant : IN CUSTODY COMPLAINT FOR CONFIRMA nON OF PRIMARY PHYSICAL CUSTODY AND NOW, comes the Plaintiff, by and through her attorneys, Mancke, Wagner & Spreha, and files the following Complaint for Confirmation of Prim my Physical Custody as follows: 1. Your Plaintiff is Samantha M. Rohrer, who is an adult individual residing at 22 Trine Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania. 2. Defendant, Jason E. Rohrer, is an adult individual residing at 478 N. Mountain Road, Newville, Pennsylvania. 3. The parties are the natural parents of Randy Eugene Rohrer, II, born May 24, 1999. 4. The child was born during wedlock. 5. Plaintiff is the natural mother of the child having an address as contained in Paragraph I; Defendant is the natural father having an address as contained in Paragraph 2. -.. 6. For the past five years, the child has resided as follows: a. for the last three years with the Plaintiff at 22 Trine Avenue, Mt. Holly Springs, Pennsylvania; b. for the two years previous to that at 34 South Middlesex Road, Carlisle, Cumberland County, Pennsylvania with the Plaintiff and Defendant. 7. Plaintiff is not aware of any other person who is exercising a right to custody or partial custody of the child. 8. The child has resided with the Plaintiff subject to periods of visitation in Defendant. 9. The Plaintiff desires to confirm custody of the child for the following reasons: a. Plaintiff has been and will continue to provide the day to day care which is in the best interest of the child; b. Defendant has suggested that Defendant is going to take the child and leave the state of Pennsylvania which would be contrary to the best interests ofthe child. WHEREFORE, Plaintiff prays the Court to grant relief in the fonn of continning primary physical custody in the Plaintiff subject to periods of partial custody in the Defendant. Respectfully submitted: ER & SPREHA By /' . ard Wagner, Esquire ID #23103 2233 North Front Street Harrisburg, P A 17 I 10 (717) 234-7051 -.. - VERIFICATION document are true and correct. I understand that false I Verify that the statements made in the foregoing statements herein are made subject to the penalties of 18 Pa.c.s. Section 4904, relating to unsworn falsification to authorities. DATE: -... >]Ul fU:A if / . \...-: (o,l(-O :) - -,:) (:) 1Q \ ........ \t- ........ ........ - ~ lI) r-- L.v C> ~ ~ -0 "l ~ .....() P-- ~ Q ...., ~ = C- eo" -or?, of' <- ~:D ri";' c: z~:;: :;.z:: plr:. :/ '. I -Of'" (J) :00 -< ...0 Q\(~.:) ii~ -0 ~5:\~ -;:0::' :,.(-., <:"? ('sf'" :;:.:: -.-.\ :;l <.11 ?u ("ri .< SAMANTHA M. ROHRER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 05-2984 CIVIL ACTION LA W JASON E. ROHRER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Monday, June 20, 2005 , upon consideration ofthe attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Suuday, Esq. at 39 West Main Street, Mechanicsburl:, fA 17055 on Wednesday, July 13,2005 , the conciliator, at 9:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Isl Da.wn S. Sunda.v. Esq. Custody Conciliator y The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation 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 HA VE 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 -- ~ b ~ ~ ~ Jb-(7C? '~Z~ ~ _>27.QC".tp ~~~~~-~ Yf?OZO-~ ','.','IJI",.\,"..I /\.~;, ' I . i~";:i::'JnJ S'1 :8 kid 02: Hrir SDUl itJVIO"JOiilCi::id 3Hl :10 \ - :bd~O-(]311:l ~ECEIVED JUL 182005(;\ SAMANTHA M. ROHRER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA vs. 05-2984 CIVIL ACTION LAW JASON E. ROHRER Defendant IN CUSTODY ORDER OF COURT . ~D NOW, this 18'" d~y ~f <l~ . ' 2005, upon consideration of the attached Custody ConCIlIatIOn Report, It IS ordered and directed as follows: I. The Mother, Samantha M. Rohrer, shall have primary physical custody of Randy Eugene Rohrer, II, born May 24, 1999. 2. The Father, Jason E. Rohrer, shall have partial physical custody of the Child every Saturday, beginning July 16, 2005 from 10:00 a.m. until 6:00 p.m. through the additional custody conciliation conference scheduled in this Order. In order to compensate for the times when the Father will not be able to exercise his Saturday periods of custody when the Mother is on vacation from August 19 through 28, 2005, the Father shall have custody ofthe Child on August 18 and on August 29 from 5:00 p.m. until 8:00 p.m. 3. The Father shall contact the Child by telephone every Wednesday evening at 8:00 p.m. While the Child is on vacation with the Mother from August 19 through 28, 2005, the Mother shall ensure that the Child contacts the Father at least two times by telephone. 4. Unless otherwise agreed between the parties, the parent receiving custody of the Child shall be responsible to provide transportation for the exchange of custody at the other party's residence. 5. The parties and counsel shall attend an additional custody conciliation conference in the office ofthe conciliator, Dawn Sunday, on September 8,2005 at 8:30 a.m. to review the custody arrangements and discuss expansion of the partial custody schedule. 6. This Order is entered pursuant to an agreement of the parti,es 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, cc:A. Richard Wagner, Esquire - Counsel for Mothe fison E. Rohrer, Father -/ 4,1 ~~~ J. j Wf'~.o'> <y\ o ViN7/'(""' I '~lrV-'" ,"', i\..d < i\..~-' ":,,'"::;,,?:,t'\)nJ I 2 : 11 Hd 9 I lnr SOOl AW.LONOi-lJOSd 3Hl .:10 38l:UO-<J3ll::l SAMANTHA M. ROHRER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 05- 2984 CIVIL ACTION LAW JASON E. ROHRER Defendant 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 Randy Eugene Rohrer, II May 24, 1999 Mother 2. A conciliation conference was held on July 13, 2005, with the following individuals in attendance: The Mother, Samantha M. Rohrer, with her counsel, P. Richard Wagner, Esquire, and the Father, Jason E. Rohrer, who is not represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. JA'1 / Yr ")-bb5 Date Daw~~ Custody Conciliator )'RECEIVED ~~p 09 21l1lS>\ SAMANTHA M. ROHRER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 05-2984 CNIL ACTION LAW JASON E. ROHRER Defendant IN CUSTODY ORDER OF COURT AND NOW, this ,:J.' day of ?rre..hv- , 2005, upon consideration of the attached Custody Conciliation Report, it IS ordered and directed as follows: I. The prior Order of this Court dated July 18, 2005 is vacated and replaced with this Order. 2. The Mother, Samantha M. Rohrer, and the Father, Jason E. Rohrer, shall have shared legal custody of Randy Eugene Rohrer, II, born May 24,1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. 3. The Mother shall have primary physical custody ofthe Child. 4. The Father shall have partial physical custody ofthe Child in accordance with the following schedule: A. The Father shall have custody of the Child on alternating weekends, beginning Saturday, September 10, 2005 on Saturday and Sunday from 8:00 a.m. until 10:00 p.m. for two weekend periods of custody. B. Beginning Saturday, October 8, 2005, the Father shall have custody of the Child on alternating weekends from Saturday at 10:00 a.m. through Sunday at 6:00 p.m. C. Begiuning Friday, November 4,2005, the Father's alternating weekend periods of custody shall be expanded to run from Friday at 4:30 p.m. through Sunday at 6:00 p.m. D. The Father may have additional periods of custody with the Child as arranged by agreement between the parties. 5. The Father shall contact the Child by telephone every Wednesday evening at 8:00 p.m. '-. -':;".:r'\J S \ :8 \..rs ':-i \ ()~:~lS SUDl 6. The parties shall share having custody of the Child on holidays as arranged by agreement. 7. Each party shall be entitled to have custody of the Child for two uninterrupted weeks during the sununer school break each year upon providing notice to the other party by April 1. In the event notice is provided after the April 1 deadline, the requesting party shall no longer be absolutely entitled to the selected period of custody although the party receiving the request shall not unreasonably withhold consent. The party providing notice first shall be entitled to preference on his or her selection of vacation dates. Unless otherwise agreed, each party shall schedule periods of custody under this provision to include his or her regular alternating weekend. Vacation weeks shall be scheduled non-consecutively unless otherwise agreed. 8. Unless otherwise agreed between the parties, the parent receiving custody of the Child shall be responsible to provide transportation for the exchange of custody at the other party's residence. 9. The parties and counsel shall attend a custody conciliation conference in the office of the conciliator, Dawn S. Sunday, on October 25, 2005 at 8:30 a.m. The purpose of the conference shall be to address any concerns of either party prior to instituting the full weekend periods of custody under this Order. 10. This Order is entered pursuant to an agreement ofthe 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, cc: P. Richard Wagner, Esquire - Counsel for Mo~er ~ _ Jason E. Rohrer, Father j ~ tf - It/-aS' All J. SAMANTHA M. ROHRER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 05-2984 CNIL ACTION LAW JASON E. ROHRER Defendant IN CUSTODY Prior Judge: Kevin A. Hess 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: CURRENTLY IN CUSTODY OF NAME DATE OF BIRTH Randy ("Rand") Eugene Rohrer, II May 24,1999 Mother 2. A conciliation conference was held on September 8, 2005, with the following individuals in attendance: The Mother, Samantha M. Rohrer, with her counsel, P. Richard Wagner, Esquire, and the Father, Jason E. Rohrer, who is not represented by counsel in this matter. 3. The parties agreed to entry of an Order in the form as attached. ~ Date g-,dex>> . il~ Custody Conciliator . RECI:;':IVED OCT 2 6 2005 BY: rv\~ SAMANTHA M. ROHRER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 05-2984 CIVIL ACTION LAW JASON E. ROHRER Defendant IN CUSTODY ORDER AND NOW, this 25th day of October, 2005 , the conciliator, being advised by plaintiffs counsel at the time of the conciliation conference scheduled for today that the outstanding issues have been resolved by agreement between the parties, hereby relinquishes jurisdiction. FOR THE COURT, . (l- Dawn S. Sunday, Esquire Custody Conciliator c>{ c ,\i. :1'! '" , ., i ~ , , :1 ~.) r~ ~ ,~ . . (