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Home My WebLink About05-4935 15450608122005 PYS835 in County Pennsylvania Pqqe 1 Docket Entries 8/12/2005 Cover Sheet Case No 2004-01037 PlaIntIff: PENNINGTON DEBBIE L ** (VS) ** Defendant: KNEPP THERESA A DECKER ERIC JR COVER CLAIR JR I I I I I I I I t.,.;eruri€,w , .,,- i....;.;.ViU w:::' LJht:red ana filed in Ihis office. IN TESrlMONY WHEREOF, f hereunto set my hand and ClIUIe the Seal of the Court to Afflvp-i this /;<,pl , A. 2001~ ()S' -).n),~ (!.""LL, <-y~ 15450608122005 PYS835 in County Pennsylvania Docket Entries Pqge 2 8/12/2005 Case No 2004-01037 PENNINGTON DEBBIE L (VS) KNEPP THERESA A Date Filed FIRST ENTRY - - - - - - - - - - - - - - 1 S/04/04 COMPLAINT FOR CUSTODY FILED - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 2 S/17/04 CUSTODY MEDIATION ORDER OF COURT FILED A CONCILIATION OR MEDIATION CONFERENCE SCHEDULED FOR 9 AM SEPTEMBER 22 2004 COPIES DISTRIBUTED TO ALL APPROPRIATE PARTIES - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 3 S/19/04 CORRESPONDENCE FILED COPIES DISTRIBUTED TO PLAINTIFF AND M ROSELLE ESQUIRE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 4 S/19/04 NOTE TO FILE FILED COPIES DISTRIBUTED TO ALL APPROPRIATE PARTIES - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 5 8/24/04 RETURN OF SERVICE FILED - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 6 S/26/04 RETURN OF SERVICE FILED - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 7 8/26/04 RETURN OF SERVICE FILED - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 8 10/01/04 STIPULATION TO ENTRY OF ORDER FOR CUSTODY FILED - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 9 10/06/04 PRO SE PLEADING FILED - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 10 10/06/04 CUSTODY AGREEMENT/STIPULATION FILED COPIES DISTRIBUTEb TO M ROSELLE ESQUIRE AND DEFENDANTS - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 11 11/19/04 NOTE TO FILE : CHRIS WOLFKEIL HAS FILED - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 12 11/24/04 CORRESPONDENCE FILED -MS PENNINGTON - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 13 12/14/04 CORRESPONDENCE FILED - - - - - - - - - - - - - - - - - - - - - - - - - - - - 14 1/14/05 CORRESPONDENCE FILED COPY MAILED TO PLAINTIFF - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 15 2/14/05 ORDER FOR CONTEMPT PROCEEDING FILED SCHEDULED FOR 11:30 AM APRIL IS 2005 MAIN COURTROOM IF PLAINTIFF ATTENDS AND COMPLETES EDUCATION PROGRAM FOR SEPARATED PARENTS OR COMPARABLE PROGRAM PRIOR TO APRIL lS 2005 SHE NEED NOT REPORT FOR CONTEMPT PROCEEDING PLAINTIFFS FAILURE TO COMPLY WITH ORDER MAY RESULT IN ISSUANCE OF BENCH WARRANT COPIES DISTRIBUTED TO PLAINTIFF AND M ROSELLE ESQUIRE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 16 3/0S/05 SHERIFFS RETURN FILED DEFENDANT MOVED NO FORWARDING ADDRESS - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 17 4/18/05 ORDER FOR CONTEMPT PROCEEDING FILED RE-SCHEDULED TO MAY 17 2005 1:30 PM MAIN COURTROOM PLAINTIFF'S FAILURE TO COMPLY WITH ORDER MAY RESULT IN WARRANT COPIES DISTRIBUTED TO PLAINTIFF AND M ROSELLE ESQUIRE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - lS 5/17/05 SHERIFFS RETURN FILED SERVED DEBBIE L PENNINGTON - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 19 5/26/05 CUSTODY ORDER BY THE COURT FILED CONFERENCE SCHEDULED FOR 11 AM JULY 20 2005 COURTROOM 2 COPIES DISTRIBUTED TO APPROPRIATE PARTIES - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 20 6/10/05 CERTIFICATE OF SERVICE OF PETITION OF MODIFICATION OF CUSTODY FILED - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 21 6/17/05 PENN STATE EDUCATION PROGRAM FOR PLNT FILED - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 22 8/12/05 CUSTODY TRANSFERRED FILED ACTION TRANSFERRED TO CUMBERLAND COUNTY S/12/2005 COPIES TO M ROSELLE ESQ D PENNINGTON T KNEPP E DECKER & C COVER - - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - - - IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY. PENNSYLVANIA DEBBIE PENNINGTON, Plaintiff VS. CP-44..CV-I037-2004 THERESA A. KNEPP, ERIC DECKER, JR., Putative Father 1 CLAIR COVER, JR., Putative Father 2, Defendants ORDER AND NOW, this 11 th day of August, 2005, after review of the file and a custody conference on July 20, 2005, this court hereby GRANTS primary custody to the paternal grandparents with whom the child now resides. This court hereby relinquishes jurisdiction of this case and transfers jurisdiction to Cumberland County where the child and grandparents currently reside. NOTICE OF ENTRY OF ORDER OR DECREE PURSUANT TO PA. R.C.P. NO. 236 NOTIFiCATION - THIS DOCUMENT HAS BEEN FILED IN THIS CASE. PROTHONOTARY, MIFfLIN COUNTY, PA DATE: ~/1'".l./()!; dfliE CO TIMOTHY PRESIDEN CC: (Michael A. Roselle, Esq. / Debbie Pennington, 104 North G~and Street, Lewistown, P A 17044 {Theresa A. Knepp, 152 W. Fourth Street, Lewistown, P A 17044 and .821 West Fourth Street, Lewistown, PA 17044 (Eric Decker, 119 South Chestnut St., Mechanicsburg, P A 17055 "Clair Cover, 128 Valley St., Apt. 5, Lewistown, PA 17044 File Certified from !he I'8COI'd 81 entered and filed In this offICe. IN TESTIMONY WHEREOF, thereunto set my hand and cauae the Selll of tb" Court be Affi ed this /;f./-A dll ( A.D., 2 r- S ~ ~ c (') ~ - o % -0 ~ ~ 0 ~ G') = ~ ~l"l ~ .., ~ =- ~\!i. -n ~ g.o a Q. (JQ .... ~Q"N~ a. .... (J) ;- r:.n ~ m Q. ~ -0 ~. ". ~ ~ ~ ~ -0 ~ m ~ (/) o vo -:::J o s- .... '" ~ .... ';:l\ 11 s- ~ ~ l"l ~ ~ '*" t~' ~\~ ~ ? $ ~ '"'I 1"""\ r:, \ J. e' 0 ~a~ ... "1 ~ ~ e~s ~ ~ ~ r:.n ~. {"'i....; ~ Q So.... l"""~ t:: ~ ~ ,.,~ ~;l"t:: ~. ~ ~ p {"'i""'.... Q 'Q' ~ ~a~(JCl ~ % i. ~ ~ ~ r/ l.1.J ;; ~ ;' p.. ? ~ ~ ,.... a ~,.... ~ ~ Q a (j ~ ~ ~ ~t ~ ~ ... ~ ~;- ~. "'~~ 0 ~ ~ i;j ~ .... ~ ,." ,.,-' IN THE COURT OF CO .' PLEAS OF MIFFLIN COUNT \'NSYL VANIA j!('ic nJ DM*e~ Tr ;f; ic..-ke"1 1? Dee kl? r Civil Action No. 1031 of J O()4 "I Plaintiff "q -'il '-' ',~":, Pi (::~:,o \--~ vs. ('::.",\ ,.,. 'j "D ''"'J ~::u ophbiP j... Pt7nnir!5 ton Defendant .......- -, -< l.-J MODIFICATION OF CUSTODY CERTIFICATE OF SERVICE FOR PETITION F'OR MODIFICATION OF CUSTODY, PARTIAL CUSTODY OR VISITATION ORDERS AND FOR CONTEMPT PETITIONS I, };'r/c_,ir <4- ~lrJ.e1{ Ii !kin- O J day of Y \) n G , hereby certify that on , 20 .6...J~, I served the Defendant with a the true and correct copy of a Petition for Modification or Contempt of an Order for Custody, Partial Custody or Visitation by one ofthe following methods: (CHECK ONE) ( ~ Service was made by United States Postal Service, first class, postage prepaid, certified, restricted delivery, return-receipt requested to the Defendant, on the r.. \:">\ day of ~\,j'\\e.. ,20 QiL. The return receipt signed by the Defendant is attached hereto. ( ) The Defendant was personally served with a true and eorrect copy of the above pleading by hand-delivering the same to the Defendant or by handing a copy at the residence or place of business of the Defendant as set forth in Pa.R.C.P. 9402. Personal service was made at the following location and time: at on the day of ,20_,at _.m. If service was made on an adult, other than the Defendant, at the n~sidence or place of business, the name ofthis adult is I verify that the statements made in this certificate of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. ~ ~dOiJ6 te 1~ {; .. hi'C} Signatur fPerson 0 Made Service .--- -. . Co\npIete 1ItIIIe1. t; . .' Item 4 W ne..b Iulo.d DIlMIr _...... . .l>rItrtyow_end......___ 80 that _ '*' rwlum !heCIM/ II> lJ'IU. . AllIIch IhI8 ~ to !he bilk".. ft\IIIpIece. or en IIle frorIl W lIpIC8 ......... 1. ___10: ~bi e-.- f etlf\~~ IO'f{\J.~. .(o.u) b~ ~ noVy Cl AQonl CAclJ. I C.DoIe"'~ L-'. 05 D. 1I~__<llllent_1lIm 11 Cl Yell 1I\'IiI$,_~__ ClNo :e..~ MIIII [J E>cpou_ . P II"] od [J ReIllnlReoolptlor"""__ cl_ Moll Cl C.O.D. 4. _t.AI.d DoIivory'I /&lIa Fee) [J Yell 2. Article Number m-mw 7004 2510 0001 6417 0473 PS Form-Jb I I. I __Y ....... DomrIIIIc......., fIlIoIIpt 11 OU'f6lfO IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY, PENNSYLVANIA Debbie Pennington, Plaintiff vs. CP-44-CV -1037-2004 Theresa A. Knepp, Eric Decker, Jr., Putative Father 1 Clair Cover, Jr., Putative Father 2 Defendants ORDER AND NOW, this 25th day of May, 2005, per Petition for Modification of a Partial Custody or Visitation Order filed May 24, 2005, by Defendant Decker, custody ,:onference in the above matter is scheduled for 11 :00 aJl)., Wednesday, July 20, 2005, in Courtroom Two of the Mifflin County Courthouse, 20 North Wayne Street 3FL, Lewistown, P A. NOTICE OF ENTRY OF ORDER OR DECREE PURSUANT TO PA. R.C.P. NO. 236 NOTIFICATION - THIS DOCUMENT HAS BEEN FILED IN THIS CASE. PROTHONOTARY, MIFFLIN COUNlY, PA DATE: 5"/~j,/15 BY THE COURT: ~ PRESIDENT JUDGE c: ~ichael A. Roselle, Esq. I'o\~\o~ /Theresa A. Knepp \~d. \,)). \-()\>S~ '3\. \...L\>.),~~I' ,\\ \\\J\'\ 22 W",l Fuurth SI., Lewislowll, fA 17g~4 10 \~ -I\I,L~(\\ \0 r, /Eric Decker 10.\ \0. ",,,,,,, ~" 119 South Chestnut St., Mechanicsburg, P A 17055 \ n , . ,,""'" .,t"\ .' ../ Clair Cover -'-"'" "\"'" ;:..':" CJ .. 128 Valley St., Apt. 5, Lewistown, PA 17044 '''1,:: nc) File C) c :~~ (f; ~ <..:.,':~ ::r C:,:,:l '..-'" -,,- -" ~I~'" .." -< r.." r..,) z- o- r "n'l J> C)C) c: z - -1 .. --< '" IN THE COURT C -:OMMON PLEAS OF MIFFLIN C~ . fNTY, PENNSYL VANIA L::'I) J ~ Dec.-kef'; Jf -f .111 /cAel( .f{cfvtf7f1e OedCf Civil Action No. \ [):')1 of 9.M , Plaintiff ....r 'I "t'; ... r''''.- ~- ..,., vs. hJ ..c" (" C)(iy (, ).""i U _ CJ 11bb, e: J Pet7l:/ir13 ;"'0 efendant - - " --1 W -< _D MODIFICATION OF CUSTODY n C'"" PETITION FOR MODIFICATION OF A PARTIAL CUSTODY OR VISITATION ORDER TO THE HONORABLE JUDGE OF SAID COURT: The Petition of ):- r / G ,t-r o\.-ti 1(' kp'1 ~ .0<<, k E' e. respectfully represents as follows: 1. ThePlaintiffis Fo'c.- j)akt'rYrl.4iil'kR'f ,r;' Ikrtn 2. The above case was brought on ~I'j \.','" I t4 , (year)J,(1JI.-L, and this Court entered a custody order on (jetn be (" 6 , (year) ,;)!~ L{: A copy of that Order is attached to this Petition. 3. The Plaintiff believes the Court's Order should be changed for the following reasons: frllSiified Je:y~1 CA)'5roOIj pitrers filed crJ,9 /l');:J/(y, ~-63otf fkll1c- Ilf Dpfe,1denT' (il!€N'r?>wdd c{., sh... ~I'ts beF'l\ t"'iJi'I':T<"'d ~ OJ Iyr<."hl 1,.,.5l)eS w;+I1 o'l-he. m, I\u (!~, Jrpn c{.- fh'/dren 4- Jic' cAll ~.~, I ~ y f'ls:seJ -1-r::>+P"-I') J~4- r"'~A"t;',)pS 1'1MY1e-$'(\, +,me.5 (Jhoere.. ('.1=\,.-: 1.\1"'<: nll<P5T;"/1PbJ"". <- rIAl/C,," (?h<YRf7()P r!4rr7€. bA-C' k. /-.,.) 1', <::;,''- I( /'r()fY', /7('1" ~/11 ,J}4end"f'J'5 (' ~re- URD;:>qclE"'" IS ,1<;\nS (' l'l~l p;s~I}iJ(,\,/'5r-9in1 do fAr::; Or i)no (0, 1\ nf'T ,\'p~ her f; () . (Attach extra pages ifneeded) Sh('~ rz, 4. The Plaint' 'equests the court's order be changed: 1110WS: M (I iJ <:, Tn nil \r:> 'De '(\.\.\ArAe~ ~ L~p<\ r'A-~.h~() ~"b \Y~t<'rJ:~r l.ll--W, ,y,,\C- ~e'9 ~. ~ ~ef^ A-S e -0 - /lXb'h\ OIl>,. \ V A r<<nT . "'~\-eS~ l^-e~~ I \ oJ '\ \\.. (I 1'\,)(", 0'rfl"l \,<;<;:,.. ") N\~(j 04-"'" \:f\.1\n'l-b I~ $",\-e~""oe.b 'S~)\"pA $;..,\1""'> A-, ~,\:\c\\,.q-s ('eSid...Q\\<'~ \l~\\PI~ 9p(\\,,\\ "y"'Tl1"\ ~ ''nA-Oe< "0 -r~\"-tc ~. (\ ,"" \.L r:\-T t9 II 'Pt-"S S\' e '"S \j>" \) \~(\ ('e\~'t-\d~ ~ ~~,\<i <;,j.. hilS ("';o'th;r~ " f', c...\" 1.1\ .\' d L>({' . WHEREFORE, Plaintiff requests your Honorable Court to grant a Rule upon the Defendant to show cause why the modification requested should not be granted. Respectfully submitted, \f\Ci.:J Ci4; ,:;1M';) Date [AN-_ Yl-D O{V/YI \)La" I S ~ PI 'ntif ~I;:bf J)iJ/fl'/)i~ ~dm:) VERIFICATION I verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. 1llit ~ 9. Lj I :J if! 5 Date f'~11.J,~ '\)<< ):;tf ~:%}'1 A~tX7lP !Ja PLAINTIFF'S ADDRESS Name: f:rJ't/ Jr oJ.; Ihlf' 1<1'1 [JJ'f' ka Street N ame/PO Box /I q .5 () UH, (I hI!' It' f) t! f ,5 rIa t City (J/rc-h't /llt.C, bory State P /I Zip Code tltH;,7 DEFENDANT'S ADDRESS Name: Debbie. L {J!(J())t19 b(} Street Name/PO Box J 0 4 mom City J(.J is ro(Jn t-ntnrl 5rrerT State P rr Zip Code J 7v l/4 FALSAFIED LEGAL CUSTODY PAPERS FILED ORIGINALLY ON AUGUST 03, 2004: Debbie swore on court documents that her residence was in Delaware while she actually resided at 17 West Fourth Street, along with Theresa Knepp and baby, Cheyanne, who never resided in Delaware, as stated on same papers. In January she moved into a one-bedroom apartment at 104 North Grand Street. HOME OF DEFENDANT OVERCROWDED AND PER LANDLORD SHE HAS BEEN EVICTED: When we went to pick up Cheyanne for visits, there was always Debbie and her boyfriend, a nephew, and either one or two of her sons residing in this one bedroom apartment along with Cheyanne. Plus a small dog, which was not housetrained at first. Per her landlord, Bill Stidfole, he told us that she was evicted for non- payment of rent and overcrowded conditions. If she can't pay rent how can she take care of Cheyanne? All Cheyanne's clothes were only to 6 months old and to small for her, we had to go out and buy her clothes so she had something decent to wear. CURRENT ISSUES WITH OTHER MINOR CHILDREN AND CHILDREN & YOUTH SERVICES: Children and Youth were working with Debbie to get custody of one of her sons. Debbie told me that they recommended she give custody of Cheyanne to us if she wanted to get custody of her own child. CHILD PASSED TO FRIENDS AND RELATIVES NUMEROUS'I'IM&<<; WHERE CARE WAS QUESTIONABLE: We got a phone call at one in the moming from Debbie to go pick Cheyanne up on Fourth Street at a friend's house, Connie Knepp. When we got there to pick her up, she was napping. Connie woke her and when she went to diaper her, Cheyanne had dirtied. and it was dried on her to the point Connie had to use pressure to clean it off. She was also filthy, clothes and face and hands. The last time we picked her up at the apartment, Debbie had left the child with an older woman, whom we did not know. We were also told by this woman that Cheyanne was staying at her house at night and sleeping on a couch with her, not in her own bed. From what we have seen her friends and relatives have the child more than she does, which is not a stable home life. She was also so hungry that day she ate two and a half jars of baby food before she was satisfied. I don't believe she is being fed properly, every time we get her she's got a bottle of milk carrying it around. TWICE CHEYANNE CAME BACK TO US SICK FROM BEING IN DEBBIE'S CARE: Cheyanne came back to us this last time so sick with a cold, that it took us over a week to get her over it. On the phone, Debbie told me that she had allergies and her doctor said she would be fine. It may have started that way but her symptoms were more on the line of a cold. If she were being cared for properly, she would not have these colds when she visits there. DEFENDANT IS USING CHILD AS A PAWN; SAYING DO THIS OR YOU WILL NOT SEE HER TILL SHE'S 18: Debbie is constantly saying she is going to make sure we don't get custody of Cheyanne if we don't do as she says. She wanted us to use her lawyer to do a change to custody so she could still control us. She wanted to be able to just call up anytime she wanted and have us take Cheyanne to her. Every time she wanted Cheyanne back, she would call us on the phone, using the F word constantly, demanding we drop what we were doing and take her to her. She refused to come here and pick her up. 'This last time she called at Cheyanne's bath time, which is at 7 pm, and was F'ing Eric, Jr to bring her up immediately. Pap Decker was talking to her, till she started using the foul talk and then he hung up on her. We don't talk lilce that, and we don't appreciate this child being around it. We did finally take her up that night, she was sink bathed and clean clothes put on her. This was 8:30 at night, which was past Cheyanne's bedtime. At that time we thought she was going to keep her from us as she threatened constantly. We don't feel Debbie is fit to raise this child or any child, with conditions that we have seen and the lifestyle she lives. We were up in July of 2004, per phone calls with Theresa, to pick Cheyanne up to take care of her. Debbie and others at that house refused. to allow us to take her, saying she was being taken care of properly and the living conditions were in good standing. I don't know how that same day after we left that Debbie was able to convince Theresa to give her custody, when things had been good for us. She railroaded Theresa, and has been since. Theresa is mentally slow but if she had had a little help she could have been a better mom. As long as I was there, taking care of the baby, it was good. When I was picked up and taken to jail, everyone started railroading Theresa. I am willing to take the care of Cheyanne for the next 18 years, without a DNA test, I am listed as legal father and I would like the courts to appoint me as such, with my mother as backup custodial parent in case anything happens to me. We would like Clair Cover, Sr. removed from any custody paperwork, as he has child molestation charges against him and he is not fit to raise her. The courts have read the reasons that Debbie Pennington and Clair Cover should not have custody of this child. I offer a full time job, a home that my parents have never been evicted from, and complete care of this child till she is of age or out of school. I believe this is what the courts are looking for. We love this little girl and can provide a better home life than the other people involved in this case. Thank you, Eric, Jr./Rickey Roxanne Decker - IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY, PENNSYL VANIA CIVIL DIVISION DEBBIE L. PENNINGTON, Plaintiff CIVIL ACTION NO. iDYl OF 2004 vs. IN CUSTODY -,- ---, THERESA A. KNEPP, ERIC DECKER, JR., Putative Father 1, CLAIR COVER, JR., Putative Father 2, Defendants -,.., ""'1 I ',.' ~ - ("")('1 t::J .1> ..p --'1 en -< ORDER L .-tL-- AND NOW, this .2 dayof OC.'0~~ , 2004, the within Stipulation having been presented, read and considered, it is ORDERED AND DECREED that the provisions set forth in said Stipulation regarding custody ofCHEYNNE M. DECKER, are hereby adopted as the Order of this Court and the parties are directed to abide thereby. BY THE COURT: Date:~ .-- (~ . PJ. The Original of this Document has been filed in the Office of the Prothonotary/Clerk of Court on /6) L/I '-I I I J i IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY,i PENNSYL VANIA CIVIL DIVISION I CIVIL ACTION fo.1637 OF 2004 DEBBIE L. PENNINGTON, Plaintiff vs. IN CUSTODY ~ = = -= o , rrl. ::.-.... ::Uc..""J Pi ::;:u:---.! ---4 -~ DC; "T"J ;.1: (")0 0--1 c:> ;:o::xJ ----1-< STIPULATION TO ENTRY OF ORDER FOR cus~ill!Y'" DEBBIE L. PENNINGTON and THERESA A. KNEPP and ERIC pECKER, JR. and CLAIR COVER, JR. , parties named above, hereby consent and stipulate tf the entry of an Order of Custody in the above captioned matter: I THERESA A. KNEPP, ERIC DECKER, JR., Putative Father 1, CLAIR COVER, JR., Putative Father 2, Defendants 1) :J: "T"J "T"J '"T"J z- , om 00 c: z -i -< ry Ul I. The legal right to make major decisions affecting the best interests of the Defendants' daughter, Cheynne M. Decker (D.O.B. 06-15-04), including, but ndt limited to, medical, religious and educational decisions, shall be shared by the parties. For the purpose of medical and educational decisions, each party shall be considered tr be custodial parent and shall have his or her right to access all information concerning hese matters, including all hospital, doctor and school records. , 2. DEBBIE L. PENNINGTON, in Loco Parentis of the child, shall hate primary physical custody of the minor child. I , 3. Defendant/Mother, THERESA A. KNEPP, shall have partial custody rights as agreed by the Plaintiff and DefendantlMother. 4. Defendant/Putative Father 1, ERIC DECKER, JR.., shall have partikl custody rights as agreed by the Plaintiff and Defendant/Putative Father 1. ! ! I 5. Defendant/Putative Father 2, CLAIR COVER, JR., shall have parti*l custody rights as agreed by the Plaintiff and DefendantlPutative Father 2. , 6. Ifit is determined at any time who the natural father of the minor dhild is, the other named Putative Father shall no longer have any legal custody or pl)ysical custody rights to the minor child which have been granted under this Order. i Nothing in this Stipulation shall preclude one or all parties from pdtitioning the Court for , a modification of this Order or Agreement. Date? /r2j/ Oij I J~ Debbie 1. Pennington, Plaintiff Date: Y/d <YO'! J, I fAtJ/lO"" ,/- '-I~~~ Theresa a. Knepp, Defen antiMother I Date 'f ;30 -0 ''/ 'I, r!:'-r~ ?1 Eric Decker, Jr., Defendant/P Date (; / ,;;; ~~V C/ fA if LO ~/~( Clair Cover, Jr., Defendant/Putative Father 2 MEDICAL CONSENT AUTHORiZATION - .. ~).o. ~ ~ CHECK ONE: (.J) !, ~eAP_'\ ('A. ~~r\f' f'P , naw residing at ~ ')- I....) L.) t::b S~ L"h)\'" \-n (,0v\ ,PA 1't-611 l} , am the parent af the child(ren) listed be law and there are no. Caurt Orders naw in effect that wauld prohibit me from canferring the pawer to. cansent upan anather persan. OR ( I, , naw residing at , P A , am the legal guardian ar legal custadian af the child(ren) by Caurt Order (capy attached, if available) and there are no. ather Caurt Orders in effect that wauld prohibit me from conferring the pawer to. cansent upan anather persan. I, --(hpx~~A. Y-..nep? ,daherebycanferupan %bie. fer')(\i^~-kJf). ,naw residing at D.J:b, e. f1 VI (\ Il'\CJ1on ~Lrd?~~cJ}<: (2 C\ Sek~rd ,~/'1'17..3 , the pawer to. cansent to. necessary medical ar mental health treatment far the fallawing child(ren): ~~~~r~Yl Q <<\~~~~r ,li@"; residing a~Q~-;)?~ 5eQ ~D<d ~. , l'f<:f?3 who. was barn anJ\.I.i'\€ IIS'"J :J.CO'l ; . naw residing at , PA , who. was barn an , naw residing at , P A , '\vha was born on and an the child(ren)'s behalf do. hereby state that the pawer to. cansent, which 1 canfer, shallnat be affected by my subsequent disability ar incapacity. The power which I confer is specifically limitedta ItrealfhC:0~.~}~~;t~il health care decisian making, and it may be.exerciseda..rlly...b..o?f.....I.....h..'e...\P...\iWiWlil'1il.;~llJiI!\~flit~j>jJ.,~....".'.'. '.!c.,.... . .' .... . .... . ," .... .......... .",,';;',~.': ">,:'>,,:',',:;;:".>';',-, 'do', "_,,.,;', The persan named abave may cQllsel'lUb tl"rejC'!i~ll!!l~~ ~\lI~!lt.;~ i;\:":'.--, :>JV::.f, ;'<:ij',i., ,', not apply): medical, dental, surgical, deveI0'p:$l;.~f'lI~K;;' . . '" ~, IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY, PENNSYLVANIA CIVIL DIVISION DEBBIE L. PENNINGTON, Plaintiff CIVIL ACTION NO. OF 2004 vs. IN CUSTODY THERESA A. KNEPP, ERIC DECKER, JR., Putative Father 1, CLAIR COVER, JR., Putative Father 2, Defendants COMPLAINT FOR CUSTODY 1. The Piaintiffis Debbie L. Pennington, residing at 26272 Seaford Road, Seaford, Sussexx County, Delaware, 19973 since June 2003. - 2. The Defendant is Theresa A. Knepp, residing at 22 West Fourth Street, Lewistown, Mifflin County, Pennsylvania since April 2004. 3. The Defendant, Putative Father 1, is Eric Decker, Jr., currently incarcerated in Lebanon County Prison, 730 East Walnut Street, Lebanon, P A 17042. He is not scheduled to be released until January 2005. 4, The Defendant, Putative Father 2, is Clair Cover, Jr., residing at 128 Valley Street, Apt 5, Lewistown, Pennsylvania. 5, Plaintiff seeks custody of the following child: Name Cheynne M. Decker Present Residence 22 West Fourth Street, Lewistown, PA ~ 1 month (DOB 06/15/04) The child was born out of wedlock. The child is presently in the custody of the Plantifj~ Debbie L. Pennington, who resides at the address specified in Paragraph One (1). During the past one (1) month the child has resided with the following persons and at the following addresses: From Birth until the filing ofthis petition the child has resided at 22 West Fourth Street, Lewistown, P A 17044 with Defendant/Theresa A. Knepp, Dawn Michael, Barb Cruse, Rodney Cruse, Harry Michael, Kevin Haines, Chasity 1. Wiebner, Garrett W. Wibner, Clair Cover, III, and Eric Decker and other persons. The Defendant/Mother signed Temporary Custody over to Plaintiff on July 26, 2004. A copy of the Temporary Custody Agreement is attached and marked as Exhibit "ONE". The mother of the child is Defendant, Theresa A. Knepp, who currently resides at the address specified in Paragraph Two (2). She is single. The Putative Father, No. I is Defendant, Eric Decker, currently residing at the address specified in Paragraph Three (3). He is single. The Putative Father, No.2 is Defendant, Clair Cover, Jr. currently residing at the address specified in Paragraph Four (4). He is single. The in Loco Parentis of the child is Plaintiff, Debbie 1.. Pennington, currently residing at the address specified in Paragraph One (1). 6. The relationship of Plaintiff to the child is that of in Loco Parentis. She currently resides with her sons, Mountain Ritter, age 8 and Justin Hess, age 19, and her paramour Scott Van Hekle. 7. The relationship of Defendant to the child is that of natural mother. She currently resides with Dawn Michael, Barb Cruse, Rodney Cruse, Harry Michael, Kevin Haines, Chasity 1. Wiebner, Garrett W. Wibner, Clair Cover, III and Eric Decker. 8. The relationship of Defendant to the child is that of Putative Father, No. I, Eric Decker who is currently incarcerated in Lebanon County Prison. 9 The relationship of Defendant to the child is that of Putative Father, No.2, Clair Cover, Jr.. It is unknown as to who resides with Mr. Cover, Jr. 10, Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this court 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 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, 11, The best interest and permanent welfare of the child will be served by granting the reliefrequested because Plaintiff is in Loco Parentis of the child, has taken care of the child since birth and she can best provide for the needs of the child. 12, 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, Plaintiffrequests the Court to grant custody of the child. Date: <;?'- L1 ~ 0 ~ c:t;/)/)J /1;1; Michael A. Roselle, Esquire Attorney for Plaintiff VERIFICA TION I verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S S 4904 relating to unsworn falsification to authorities. Date: '6 -O"!;-{)'/ ~~.J-~~~ Plaintiff Joseph A. Bradley. Sheriff Baron K. Lewis, Chief Deputy Laurie J. Kozak, Deputy Christoher S. Shade, Deputy Charles L. Angney, Deputy '::"""" r r'i David W. Molek, Solicitor ~ (717) 248.9656 ,':0;; 3: W"' SHERIFF'S OFFICE MIFFLIN COUNTY 20 North Wayne Street Lewistown, PA 17044 (717) 242-1105 .. (717) 242-1808 Fax: (717) 248-2907 -, -, .-< '1 'TI r~~: ..,., z- r- (')fI1 00 C- :.i' -i ("::::.J ~::J ""~. -q C) 2~~ :::.()....:O -' \J -~.-<," .. Plaintiff: Debbie L Pennington Court NLftftber: 1tJ's'il1J04 County: Mifflin County Defendant: Theresa A Knepp,Eric Decker and Clair Cover Jr Type of Writ or Complaint: IilllWrit Order Iilll Complaint Name: Debbie L Pennington Address: 104 N Grand St Lewistown Pa 17044 Serve At Name: Address: Indicate Unusual Service: D Comm. of Pa. Iilll Deputization [J Other Now 20 , I, SHERIFF OF MIFFLIN COUNTY, PA. do hereby deputize the Sheriff of County to execute this Writ and make retum thereof according to law. This deputization is made at the request and risk of plaintiff. X SherlffofMifflin co. Special Instructions or other information that will assist in expediting service: Attomey or other Organization requesting service: Mifflin Co Court ledge receipt of the Wri 0 omplaint as indicated above: Telephone No: (717) 248-4613 Date Received: 4/1912005 Date Filed: 4/1512005 Exp. Date: 5/1712005 CERTIFY and RET that I l>1I have personally served. Iilll have legal evidence of service as shown in "Remarks", D have executed as shown in "Remarks", the Writ or Complaint described on the individual, company, corporation, etc. at the address shown above or on the individual, company, corporation, etc., at the address inserted below, handing a TRUE and ATTESTED copy thereof. Iilll I hereby certify and retum a NOT FOUND because I am unable to locate the individual, company, corporation, etc., name above. (See Remarks below.) Name and Title of individual served: Iilll A person of suitable age and discretion Served Debbie L Pennington then residing at the defendent's usual place of abode. Address where served (complete only if different than shown above) Date of Service: I Time: Debs Corner Restaurant 5 Main 51 Lewislown Pa17044 5/1212005 2:50 PM Attempts Date Miles Dep.lnt. Date Miles Dep.lnt. Date Miles Dep.lnt. 3 4/1912005 2 BKL 5/512005 2 BKL 5/1212005 2 BKL Advance Costs Service Costs Mileage Postage Surcharge Notary I Total I Refund $0.00 $0.00 $0.00 $0,00 $0,00 $0,00 $0,00 $0,00 Remarks: (See other side) Swom to and subscribed before me this _j, Notarial Seal pret L. Bowersox, Notary Publi'~ , Lewistown Boro. Mifflin Countv , My Commission Expires Feb. 4. if''' ~o~__ 5/1 B12005 5/1612005 Notarial Seal IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY. PENNSYLVANIA Debbie L. Pennington, Plaintiff CP-44-CV-I037-2004 v. ~ = = '-'" 3: .." .." r.." zr= co ,H" -0 go z ~ -t U'I -< ClD Theresa A. Knepp, Eric Decker, Jr., Pntative Father 1, Clair Cover, Jr., Putative Father 2, Defendants In Custody o r~.\') rn:::J ;DC) ::x;-< 0:C ..,,~ 00 0-< c:J> ::0::0 -<-< (f) ".. "'0 ::0 ORDER NOW, this 15th day of April, 2005, upon request of Plaintiff, the Contempt Proceeding for failure to complete the Education Program for Separated Parents or a comparable program in the above matter, which was scheduled for Monday, April 18, 2005, at 11 :30 a.m., is rescheduled to Tuesday, May 17, 2005, at 1:30 p.m., in the Main Courtroom of the Mifflin County Courthouse, 20 North Wayne Street, Third Floor, Lewistown, Pennsylvania. Plaintiff's failure to comply with this Order may result in the immediate issuance of a Bench Warrant. NOTICE OF ENTRY OF ORDER OR DECREE PURSUANT TO PA. R.C.P. NO. 236 NOTIFICATION - THIS DOCUMENT HAS BEEN FILED IN THIS CASE. PROTHONOTARY, MIFFLIN COUNTY. PA DATE: if / 1 $J I t..s BY THE COURT: ~ c: --Debbie 1. Pennington (Service by Sheriff and US Mail) 104 North Grand Street, Lewistown, P A 17044 /Michael A. Roselle, Esq. Sheriff (2) File Joseph A. Bradley, Sheriff Baron K. Lewis, Chief Deputy Laurie J. Kozak, Deputy Christoher S. Shade, Deputy Charles L. Angney, Deputy David W. Molek, Solicitor (717) 248.9656 SHERIFF'S OFFICE MIFFLIN COUNTY 20 North Wayne Street Lewistown, PA 17044 (717)242-1105" (717)242-1808 Fax: (717) 248-2907 Plaintiff: Debbie L Pennington Court Number: CP-44-CV-1037-04 County: Defendant: Theresa A Knepp,Eric Decker Jr Type of Writ or Complaint: Ifill Writ Order Ifill Complaint Name: Debbie L Pennington Address: 30 stanley Lane McVeytown Pa 17051 Serve At Name: Address: c,) '-'.' ", Indicate Unusual Service: Ifill Comm. of Pa. Ifill Deputlzatlon [J Other PI, Now 20 , I, SHERIFF OF MIFFLIN COUNTY, PA. dB:~rebygeputize the Sheriff of County to execute this Writ and make retum th~iJf according to law. This deputization is made at the request and risk of plaintiff. X ;~ c, ,Sheriff of Mifflin Co. Special Instructions or other information that will assist in expediting service: c, :., ,I ~~':; ,~,~-' \ ' , --, I ackn~ledge receipt of the WritJr mplaint as indicated above: X / " ~ ~/',(, . I ereby ERTIFY and RETURN at I Ifill have personally served. Ifill have legal evidence of service as shown in "Remarks". Ifill have executed as shown in "Remarks", the Writ or Complaint described on the individual, company, corporation, etc. at the address shown above or on the individual, company, corporation, etc., at the address inserted below, handing a TRUE and ATTESTED copy thereof. ~I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., name above. (See Remarks below.) TelephonecbliJ: ' (717) 248-4813 Date Received: 2/1512005 L",! en Date Filed: 2/1112005 Exp. Date: 4/1812005 Attorney or other Organization requesting service: Court Name and Title of individual served: Ifill A person of suitable age and discretion Delendant moved,left no forewarding address with McVeytown and Lewistown post offices,(Not then residing at the defendent's usual Found) place of abode. Address where served (complete only if different than shown above) Date of Service: I Time: Attempts Date Miles Dep. In!. Date Miles Dep.ln!. Date Miles Dep. In!. 3 2/1512005 16 BKL 2/2412005 10 BKL 3/412005 10 BKL Advance Costs Service Costs Mileage Postage I Surcharge I Notary I Total I Refund $0,00 $0.00 $0.00 $0,00 $0,00 $0.00 $0,00 $0,00 Remarks: (See other side) Sworn to and subscribed before me this X Notary Public f14>..ri1y1 /I;}, h, /, &ClJ~' Notarial Seal NOTARIAL SEAL PATRICIA A. WILSON. No1llry Pub1ill LewistoWn BolO, Milftin CounlY My Commission Expires March 31, ZJ:Jf1 Baron K Lewis 3/812005 :7 3/8/2005 x Joseph A Sra ~,;f'/i:, IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY. PENNSYLVANIA Debbie L. Pennington, Plaintiff vs. CP-44-CV-1037-04 Theresa A. Knepp, Eric Decker, Jr., and Eric Decker, Jr., Defendants ORDER NOW. this II th day of February, 2005, Debbie L. Pennington is hereby ORDERED to appear before the Court at 11 :30 a.m., Monday, April 18, 2005, in the Main Courtroom, Mifflin County Courthouse, 20 North Wayne Street 3FL, Lewistown, P A, for a contempt proceeding for failure to complete the Education Program for Separated Parents or a comparable program. FURTHER, if Debbie L. Pennington attends and completes the Education Program for Separated Parents or a comparable program prior to Monday, April 18, 2005, she need not report for the contempt proceeding scheduled herein. Plaintifrs failure to comply with this Order may result in the immediate issuance of a Bench Warrant. NOTICE OF ENTRY OF ORDER OR DECREE PURSUANT TO PA. R.C.P. NO. 236 NOTIFICATION - THIS DOCUMENT HAS BEEN FILED IN THIS CASE. PROTHONOTARY, MIFFLIN COUNTY, PA DATE: ;;Lf ( '1/ t S BY THE COURT: ~ ........ TIMOTHY S. SEARER PRESIDENT JUDGE c: ;;;ebbie 1. Pennington (Service by Sheriff and US Mail) ./ 30 Stanley Lane, McVeytown, PA 17051 Michael A. Roselle, Esq. Sheriff (2) File . COURT OF COMMON PLEAS OF MIFFLIN COUNTY 58-JUDICIAL DISTRICT OF PENNSYlVANIA PHONE 17171 248-4613 FAX (717)248-8337 M~min County Courthouse 2Q" North Wayne Street Lewistown, Pennsylvania .17044 TIMOTHY S. SEARER PRESIDENT JUDGE January 14, 200~ Ms. Debbie L. Pennington 30 Stanley Lane McVey1own, PA 17051 RE: Civil Action No. 1037 of 2004 Dear Ms. Pennington: As follow up to phone conversation December30, 2004, qualification for financial hardship for the Education Program for Separated Parents Classes is at the discretion of the PehnState andJustice Safety Institute. You may qualify for waiver of the $45.00 fee or you maybe required to pay the full amount or a portion thereof. First, please call the toll free number 888-737-2299 listed within the brochure to determine if you aTe eligible for finandal hardship. .-\Ctel\ you have done so! please contacHhe Court office t()advi~e the dateyou have selected tp attend. If you Mnot qualify for financial hardship we can discuss extending your deadline tQ-register. Failure to do ,so will result in a hearing scheduled before, the . , '\ . /' . - " . " . Court to consider whe~heror not YQU are in contempHor_ failure ~o attend this mandated program. Sincerely, Christine L. Woltkiel Deputy Court AdIhinistrator c: ."~h:el A: R~~elle,Esq. h;;~ - -I" CD '2), -1'lJ :1:. c;C) 0-< --"',;:'':" '-'-" ?J'" ....~ -"{-'(" <..f) r:: .0 v..J.. ~,'~'i ......<. co . COURT OF COMMON PLEAS OF MIFFLIN COUNTY 58' JUDICIAL DISTRICT OF PENNSYLVANIA PHONE (717) 248-4613 FAX (717) 248.8337 Mimin County Courthouse 20 North Wayne Street lewistown, Pennsylvania 1 7044 TIMOTHY S. SEARER PRESIDENT JUDGE December 13, 2004 Ms.. Debbie L. Penningtfln 30 Stanley Lane McVeytown,PA 17051 RE: Civil Action No. 1037 of 2004 Dear Ms. Pennington: According to our records, you have not completed the Education Program for Separated Parents as directed by the Court. Attendance at this program is mandated for anyone involved in a divorce action or custody/visitation action who has children under the age of 18. ,A copy of the Court Order establishing this program and a brochure explaining the process were sent to you on August 11,2004. Failure to register for this program within ten (10) days for attendance, within thirty (30) days from this date will result in a hearing being scheduled before the Court to consider whether or not you are in contempt for failure tpattend this mandated program. Class size is limited. Please use the registration form from the enclosed brochure or call 1-888-737-2299 (toll free within PA) 6i . 1-814-863-0079 (outside PA) to make the necessary arrangements to promptly attend the program. As explained within the enclosed brochure, registration is required at least one week prior to the selected program date; unregistered participants will not be permitted to attend class. Children may not attend the program. Once registered, please telephone the conrt office and advise the date you selected to attend. If you have any questions at all with respect to this matter, please advise. .Sincerely, Christine L. Wolfkiel Deputy Court Administrator C') ~ 3:: c:::;) ro- c;::) "t;;..- ..,., C:::} ''''1'1 rr, .- n r- .-"Tl ~;,i~~ z- .c r- 01'"'1 r)C> 1) 00 (::)i~ c: z ;0 ~ -j .,-,.".( -< U) U1 en EncloMur c: ichael A. Roselle, Esq. File . COURT OF COMMON PLEAS OF MIFFLIN COUNTY 58" JUDICIAL DISTRlcloF PENNSYlVANIA PHONE (717) 248-4613 FAX (717) 248-8337 Mimin County Courthouse 20 North Wayne St,.eet Lewistown, Pennsylvania 17044 TIMOTHY S. SEARER PRESIDENr JUDGE November 23, 2004 Ms. Debbie L. Pennington 26272 Seaford Road Seaford, DE 19973 RE: Civil Action No. 1037 of 2004 f'k, ,PtM::;ron Dear Mr. eel" . According to our records, you have not completed the Education Program for Separated Parents as directed by the Court. Attendance at this program is mandated for anyone involved in a divorce action or custody/visitation action who has children under theage of 18. A copy of the Court Order establishing this program and a brochure explaining the process were sent to you on August 11, 2004. Failure to register [or this program within ten (10) days for attendance within thirty (30) days from this date will result in a hearing being scheduled before the Court to consider whether or not you are in contempt for failure to attend this mandated program. Class size is limited. Please use the registration form from the enClosed brochure or call 1-888-737-2299 (toll free within P A) or 1-814-863-0079 (outside PA) to make the necessary arrangements to promptly attend the program. As explained within the enclosed brochure, registration is required at least one week prior to the selected pro~ram date; ul/registered participants ~i11 not be permitted to attend class. . Children may notattend'the program. ' ' Once registered, please telephone the court office and advise the date you selected to attend. . If you have any questions at all with respect to this matter, please advise. Sincerely, ""'-1 Christine L. W olfkiel Deputy Court Administrator .-\ :.:-J Enclosure c: fIichael A. Roselle, Esq. IFile ' IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY, PENNSYL VANIA CIVIL DIVISION DEBBIE L. PENNINGTON, Plaintiff CIVIL ACTION No.lojf) OF 2004 vs. IN CUSTODY 3: '"'1'''1 THERESA A. KNEPP, ERIC DECKER, JR., Putative Father 1, CLAIR COVER, JR., Putative Father 2, Defendants , ---.j --- ..., :;.~: r= C-)("r] CJ ',j .1> ....9 -j en ~,.< ORDER (1"1- AND NOW, this .2 day of Dc.. ~~ R.... ,2004, the within Stipulation having been presented, read and considered, it is ORDERED AND DECREED that the provisions set fOlth in said Stipulation regarding custody of CHEYNNE M. DECKER, are hereby adopted as lihe Order of this Court and the parties are directed to abide thereby. BY THE COURT: Date:~ <- {~~ ' PJ. e : rf\ f-vllili, \\M, / NOTICE OF ENTRY OF ORDER OR DECREE PURSUANT TO PA. R.C.P. NO. 236 NOTIFICATION - THIS DOCUMENT HAS BEEN FILED IN THIS CASE. PROTHONOTARY, MIFfliN COUNTY, PA DAJE: (4/ L / tJj IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY, PENNSYL VANIA CIVIL DIVISION CIVIL ACTION NO. 1037 OF 2004 DEBBIE L. PENNINGTON, Plaintiff vs. IN CUSTODY C") r--""I": P":,:t", :::0 C) ;::>:;-1 o::r: o "'rJz no g~ ::0 ;:0 -1-< (J) ..... = C;:::':3 -= C;) n -< 3: "'rJ "'rJ r --., ::z- r or" 00 c:: ::z -i -< THERESA A. KNEPP, ERIC DECKER, JR., Putative Father 1, CLAIR COVER, JR., Putative Father 2, Defendants "D r:,> U1 STIPULATION TO ENTRY OF ORDER FOR CUSTODY DEBBIE L. PENNINGTON and THERESA A. KNEPP and ERIC DECKER, JR. and CLAIR COVER, JR. , parties named above, hereby consent and stipulate to the entry of an Order of Custody in the above captioned matter: 1. The legal right to make major decisions affecting the best interests ofthe Defendants' daughter, Cheynne M. Decker (D.O.B. 06-15-04), including, but not limited to, medical, religious and educational decisions, shall be shared by the parties. For the purpose of medical and educational decisions, each party shall be considered to be custodial parent and shall have his or her right to access all information concerning these matters, including all hospital, doctor and school records. 2. DEBBIE L. PENNINGTON, in Loco Parentis ofthe child, shall have primary physical custody ofthe minor child. 3. DefendantlMother, THERESA A. KNEPP, shall have partial custody rights as agreed by the Plaintiff and Defendant/Mother. 4. DefendantlPutative Father 1, ERIC DECKER, JR.., shaU have partial custody rights as agreed by the Plaintiff and DefendantlPutative Father I, 5. DefendantlPutative Father 2, CLAIR COVER, JR., shall have partial custody rights as agreed by the Plaintiff and DefendantlPutative Father 2. 6. If it is determined at any time who the natural father of the minor child is, the other named Putative Father shall no longer have any legal custody or physical custody rights to the minor child which have been granted under this Order. Nothing in this Stipulation shall preclude one or all parties from petitioning the Court for a modification of this Order or Agreement. Date:'ljcr! 00/ ~Nl;Q-J L Debbie L. Pennington, Plaintiff Date: Y/d':VOCf -1AtJ/iOL, fJ- '1~~ Theresa a. Knepp, Defen t/Mother Date: '/. 7-30 -(j 1 y, c:~ ?1 Eric Decker, Jr., Defendant/Puta . Date: (; / ,;{~/c;t/ (J ff- if ,~O 'V8( Clair Cover, Jr., DefendantlPutaJ;ive Father 2 :I:i'\ Th-(. Court Of COl",/\'\"I6"\ PI~o.<, o~ r't\;~~h'", Co lJ....t'l I 'Pe-nt'). CII-':CL 1):t:.v'J:.~OV\ , , 'De-bID; 'to L I "Pe",,; ,,~t;Qn. V 10.' (\ \-:~~ vs- Th e,n:.$c;,. A. 1< N'G.?P f"....-'O:.. N. 'Oec..K~R,"'S'R '?...,)ell.f-;ve.. C rVIL. Ac.'h'ot'\ lVe (0"31 ot~D6 T" _.IV :.....pus~~'t:t , ,':'.." ~~ .." 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II'} $. c.~~ sf" v t: St.. h'\Q.vl-o,.""it.s 61,)1"'~ PA. l70S-oS ? o.l'" '\) e.c..K e..R. ;Z 3"1 N. Li f\c..o I" S-t, 1=l-'?-t, A. ?o.\M~""C>- PRo 1707"if "d",,(\<i..+ rn\<:..~ e.oJ ?c.. 'tb<=>>< ~q I Le.w,"stowY'\ flli. 17oLf"'l f'neli5o.. ~\,)rk'e. Da.v~d ~ J(o.1-he.Y" \ f\~ YY\o.....)<<;~'R. '3'"3'1 S. Wo.1h€. St:. L~\N\~towh Pj1, 11D"I"i 'PO\)~ a..~6 I 5~ Wc.si. l.~W\sto.;:.", ~ o..M- 4tl... fl\-, W-el~~ st. 170~4 fr\; \d.r \!..~ f, '" +'Z..\!.. \ 1'6'3 W ~s-t l../l-I-.. S-t . L-te<>.J"St6Wv'\ PI\. Llc4'1 \)~\A'" VV);,:.I~e.o..\ ~~ VJ~si 4+'- st , LoQ.wistown f'1\. l7c4~ 1>1'CAS1:.. o.lo",'lL r<'\'J t~-e. ?t"'i lV'o.,\<- ro ,?-e.<:>p1e prc,SIl,.1)t: to sto.tQ", Yh-e, 1"("\.,.-(;l.... 0.. ,~ ch;ld('C..", 0.,'" b fh.o..-t- :r. 001'\ It Y'Y\" S tr Q,<1\.t Sc.rr-..e" t;Me... Th.a..l'\k '100 E~ 'hD~_,~R h.o.V'~ fI... ~s e.. YY\ 1 love, ti-- ~"" ~t fh.~ IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY. PENNSYL VANIA CIVIL DIVISION CIVIL ACTION NO. fcfYJOF 2004 DEBBIE L. PENNINGTON, Plaintiff vs. IN CUSTODY THERESA A. KNEPP, ERIC DECKER, JR., Putative Father 1, CLAIR COVER, JR., Putative Father 2, Defendants RETURN OF SERVICE I, Michael A. Roselle, Esquire, attorney for Plaintiff, DEBBIE L. PENNINGTON, assert and state the following: That I served Defendant, CLAIR COVER, JR., Putative Father 2, a true and correct copy of Complaint in CUSTODY by mailing same to him at the Lewistown Post Office, Lewistown, Pennsylvania on August 23, 2004, to his address at 128 Valley Street, Apt 5, Lewistown, (Mifflin County) Pennsylvania, and he accepted service on August 24, 2004 as evidenced by his signature on certified mail, restricted delivery, Postal Service 7002 0860 0004 1630 5554. Attached hereto is Defendant's signature. Such items marked Exhibit "1". BY: Mic ael A. Roselle, Es Attorney for Plaintiff Sworn to and Subscribed before JZ~ cJt, -II, Day of 2004. -. U S, Postal ServIce CERTIFIED MAIL RECEIPT L Oomestlc Mdl( Only No fnSl1r,mce Coverage Provldco, ::r Postage $ $.0.2:2: CJ I)l)H CJ L, CJ Certified Fee 04 .!.) Poetmark He.. C Return Reeelpt Fee .JJ {Endorsement Required} cO Restricted DelIvery Fee C (Endorsement Required) OJ Total Pcm.ge & fH8 $ $8. Ju CJ C nt 0 1'- ._._.......--......._.tl~...~Jl>.L"-..._....._..._........__._.._......._..._ ~.A~N~ 4 ~~.~.~...._J Jo....\1c. \ q~.~lt.,A.(21.5._..... """_.ZIP.. . . ~ l\ \ f)../ 6,.). 08/23/2004- ;11 . . Complete ijem$ 1, 2, and 3. Also complete Rem 4 if Restricted Delivery is desired. . Print your name and address on the reverse 80 that we can return the card to you. . Atlech this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to; ~~~ ld.'l; \I~k).-,M3 d?~~~ ~ \}D'-l4 3. Service Type ." ~1.ExpressMaJl -0- Registered 0 Return Receipt for Merchandile o Insured Mati 0 C.O.D. . I ~. ... I~ 'Hiq 7002 0860 OOO~ 1630 5554 2. Article Number (Copy from service label) PS Form 3811, July 1999 Domestic Retum ReoEript Hl2595-00.M-Q952 EXHIBIT "ONE" IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY, PENNSYLVANIA CIVIL DIVISION DEBBIE L. PENNINGTON, PLAINTIFF Civil Action No. 1037 of 2004 vs THERESA A. KNEPP, ERIC DECKER, JR., Putative Father 1 CLAIR COVER, JR., Putative Father 2 DEFENDANTS : IN CUSTODY RETURN OF SERVICE I, Michael A. Roselle, Esquire, attorney for Plaintiff, DEBBIE L. PENNINGTON, assert and state the following: That I served Defendant, ERIC DECKER, JR. Putative Father 1, a true and correct copy of Complaint in CUSTODY by mailing same to him at the Lewistown Post Office, Lewistown, Pennsylvania on August 23, 2004 , to his address at clo Lebanon County Prison, 730 East Walnut Street, Lebanon, Pennsylvania, and Jason Miller, an employee of Lebanon County Prison accepted service as evidenced by his signature on certified mail, restricted delivery, Postal Service 7002 0860 000416305547. Attached hereto is Jason Miller's signature, an employee of Lebanon County Prison. Such items marked Exhibit" 1". BY: &m~ V~ Michael A. Roselle, Esquire Attorney for Plaintiff Sworn to and Subs~bed before 7J;n this cJtiJ Day of 1/1+ 2004. d~ cI~ Notary P~ VlCIlE\' L SODER. NoWy NIle ~ "'........... MIlD! CClurlIy, PA c.......J Ian M..... U S. Postal ServIce CERTIFIED MAIL RECEIPT ')omestlc Mall Only No Insurance Coverage Provided) c m ..D ,..,. :r c c c Postage $ Cettllled fee C Return Receipt Fee ..D__ cO R4astrtcted DeU~ Fee C (Endorsement Required) ru Total Pottage &. Fees I ~.J).8:; .." 0044 O~. ..> .J Postmorl< Heno ~..)I 08/23/2004 $ $t:.Jv c ~ ~.;::::rt~.~J.b--""--'''-'''''''lli:~::-''''''l ._._.__...._...____.._../.l:l__J~bo.nJ:l0.ntcw - . -. I' CIIy, S_. ZJP+ ~ -l ;.. . . Complete ~ems 1, 2, and 3. Also complete ~em 4 if Restricted Delivery Is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Grue lft~ ~b ~~JX\n0" ~v~ ?~\) '730~V)c&~~ ~~~nu"" \'A IID~d.. 2. Article Number {Copy from service labeV D. Is address dlfl'efent from Item 1? If YES, enter delivery address below: o Agent o AcId_ DYes o No 1< e st'-I'd"'.!. iJ<-liV411"'i +0 c... COQ('ec.-~rio,,"c;d FDl.LI (I+-/ '5'ee ()(,(\IY\ Sq \,",-0, , \..D \;jJ"'ice Type ~&gistered o Insured Mail ~ Express Mail Return Receipt tor Merch8ndt8e [J C,O.D. .. PS Form 3811, July 1999 7002 0860 0004 1630 5547 uomestic Return Receipt 102595-oo-M-0952 EXHffiIT "ONE" IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY, PENNSYLVANIA CIVIL DIVISION DEBBIE L. PENNINGTON, Plaintiff CIVIL ACTION NO. 1037 OF 2004 vs. IN CUSTODY THERESA A. KNEPP, ERIC DECKER, JR., Putative Father 1, CLAIR COVER, JR., Putative Father 2, Defendants RETURN OF SERVICE I, Defendant Theresa A. Knepp, assert and state the following: That I was served, a true and correct copy of Complaint in Custody by hand delivery on August 23, 2004 at 3:20 p.m. at Attorney Michael A. Roselle's Office, Mifflin County Courthouse, 20 North Wayne Street, Lewistown, (Mifflin County) Pennsylvania, and she accepted service on August 23, 2004 as evidence by Defendant's signature. BY-7l1MMfA ~'-- Theresa A. Knepp, Defenda t Sworn to and Subscribed before 4;,:+ rJ$1l Day of 2004. ~~~~ ~ary P lic I/lClIEV L SODER. NGI8Iy rutile ~"\.IU._'M\,_Cl<riy.PA Co..III I n M.1,2OClll . COURT OF COMMON PLEAS OF MIFFLIN COUNTY 58" JUDICIAL DISTIUCT OF PENNSYLVANIA " PHONE 17171248-4613 fAX (7171248'8337 Mimin C9unty'~Courth~u~e' 20 North Wayne Street l&wjstown~ Pennsylvania 17044 TIMOTHY S. SEARER' , PRESIDENT JUDGE August 11, 2004 'I'; Ms. Debbie L. Pe1;ll1ington , --. I 26272 Seaford Road Seaford, DE 19973 RE: Civil Action No. 1037 of 2004 Dear M5. :Pennington: EnC16s~d is a copy ofan Order issued by The Honorabl~ Timothy S. Searer, President Judge of the ' Mifflin County Court of Commoll Pleas. Anyone filing a divorce action who is the parent of a child . or children under the age of eighteen (18) years or is a litigant in a custody/visitation action 1S court oi:dered to attend the Education Program' for Separated Parents within sixty (60) days from the date o( fili/!.g. Class size is limited.. If yo~ previously completed this program due to referral ina , - " \ " " . '. ~ " separate civil action, please notify the Court immediately. . III addition, a brochure is enclosed which explains the Program. and the registration process. There are over 500 comparable ,programs throughout the:United States. TO, explore other locations nearest " to .you if you are"not within the Lewistown area, telephone 1-888-737-229.9 (toil free withinPA) or . I ~ . '.. :. _ ..... " _" . . '. "'. _, . 1-.814-863~0079 (outside P A) and spc:ak with a staff assistant at the Penn State Justice and Safety . . Institute., As explained witl;rinthe enclOSed brochure, regi~tratioI). is required at least oIle week prior to theseJected program date a(ld children may not attend the program as child care is not Provided.' . / . ' -'. In order to avoid further sanctions by the Court, it isimperatiye YOuTegister for the Program within the time period specified. If you have any questions at all, please feel free to call. Sincerely, i ChrlstineL. Wolfkiel Deputy Co\irt Administrator , ~..., ) Enclosures c: ~ael A. Roselle, Esq. V;~~~n IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY, PENNSYLVANIA Debbie L. Pennington, Plaintiff vs. Civil Action No. 1037 of 2004 Theresa A. Knepp, Eric Decker, Jr., Putative Father 1, Clair Cover, Jr., Putative Father 2, Defendants Note to File NOW, August 11,2004, referral to the Education Program for Separated Parents is not required herein for Defendants, Theresa A. Knepp and Clair Cover, Jr., in that they have already been referred to said program in Civil Action No. 1036 of2004. And further, referral to the Education Program is temporarily suspended for Defendant, Eric Decker, Jr., in that he is presently incarcerated in Lebanon County Prison, 730 East Walnut Street, Lebanon, P A. The Court reserves referral to the program at a future date if deemed necessary. clw c: 1M. Roselle, Esq. jrheresa A. Knepp 22 West Fourth Street, Lewistown, P A 17044 ..-Eric Decker, Jr. clo Lebanon County Prison, 703 E. Walnut Street, Lebanon, P A 17042 I Clair Cover, Jr. 128 Valley Street, Apt. 5, Lewistown, PA 17044. File IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY. PENNSYLVANIA CIVIL DIVISION CIVIL ACTION NO. /d370F 2004 ' DEBBIE L. PENNINGTON, Plaintiff vs. IN CUSTODY THERESA A. KNEPP, ERIC DECKER, JR., Putative Father I, CLAIR COVER, JR., Putative Father 2, Defendants ORDER OF THE COURT You, Theresa A. Knepp, Eric Decker, Jr., Clair Cover, Jr., Defendants have been sued in court to obtain Custody of the child Cheynne M. Decker, you are ordered to appear in person at the Main courtr~ifflin County Courthouse, 20 Nifrth Wayne Street, Lewistown, Pennsylvania on ~;;J- ,2004, at ;()O O'clockL.M. for: L a conciliation or mediation conference. a pretrial conference. a hearing before the court. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. 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. NOTICE OF ENTRY OF ORDER OR DECREE PURSUANT TO PA. R.G.P. NO. 236 NOTIFICATION - THIS DOCUMENT HAS BEEN FILED IN THIS CASE. PROTHONOTARY, MIFFLIN COUNlY, PA DATE: '//1/''} Date: ~ I I~ rOY ~~. eu0h\(~;p / ~'~ ,/ ~ Judge's Secretary Judge's Chamber Mifflin County Courthouse 20 North Wayne Street Lewistown, P A 17044 717/248-4613 ~~ ~J. K IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY, PENNSYLVANIA CIVIL DIVISION CIVIL ACTION NO./O> l'J OF 2004 DEBBIE L. PENNINGTON, Plaintiff vs. IN CUSTODY THERESA A. KNEPP, ERIC DECKER, JR., Putative Father I, CLAIR COVER, JR., Putative Father 2, Defendants COMPLAINT FOR CUSTODY I. The Plaintiff is Debbie L. Pennington, residing at 26272 Seaford Road, Seaford, Sussexx County, Delaware, 19973 since June 2003. 2. The Defendant is Theresa A. Knepp, residing at 22 West Fourth Street, Lewistown, Mifflin County, Pennsylvania since April 2004. 3. The Defendant, Putative Father 1, is Eric Decker, Jr., currently incarcerated in Lebanon County Prison, 730 East Walnut Street, Lebanon, P A 17042. He is not scheduled to be released until January 2005. 4. The Defendant, Putative Father 2, is Clair Cover, Jr., residing at 128 Valley Street, Apt 5, Lewistown, Pennsylvania. 5. Plaintiff seeks custody of the following child: Name Cheynne M. Decker Present Residence 22 West Fourth Street, Lewistown, PA ~ I month (DOB 06/15/04) The child was born out of wedlock. The child is presently in the custody of the P1antiff, Debbie L. Pennington, who resides at the address specified in Paragraph One (I). During the past one (I) month the child has resided with the following persons and at the following addresses: From Birth until the filing of this petition the child has resided at 22 West Fourth Street, Lewistown, I' A 17044 with DefendantlTherr~sa A. Knepp, Dawn Michael, Barb Cruse, Rodney Cruse, Hany Michael, Kevin Haines, Chasity L. Wiebner, Garrett W. Wibner, Clair Cover, III, and Eric Decker and other persons. The DefendanUMother signed Temporary Custody over to Plaintiff on July 26, 2004. A copy of the Temporary Custody Agreement is attached and marked as Exhibit "ONE". The mother of the child is Defendant, Theresa A. Knepp, who currently resides at the address specified in Paragraph Two (2). She is single. The Putative Father, No. I is Defendant, Eric Decker, currently residing at the address specified in Paragraph Three (3). He is single. The Putative Father, No.2 is Defendant, Clair Cover, Jr. currently residing at the address specified in Paragraph Four (4). He is single. The in Loco Parentis of the child is Plaintiff, Debbie L. Pennington, currently residing at the address specified in Paragraph One (1). 6. The relationship of Plaintiff to the child is that of in Loco Parentis. She currently resides with her sons, Mountain Ritter, age 8 and Justin Hess, age 19, and her paramour Scott Van Hekle. 7. The relationship of Defendant to the child is that of natural mother. She currently resides with Dawn Michael, Barb Cruse, Rodney Cruse, Hany Michael, Kevin Haines, Chasity L. Wiebner, Garrett W. Wibner, Clair Cover, III and Eric Decker. 8. The relationship of Defendant to the child is that of Putative Father, No. I, Eric Decker who is currently incarcerated in Lebanon County Prison. 9. The relationship of Defendant to the child is that of Putative Father, No.2, Clair Cover, Jr.. It is unknown as to who resides with Mr. Cover, Jr. 10. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this court 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 person not a party to the proceedings who has physical custody ofthe child or claims to have custody or visitation rights with respect to the child. II. The best interest and permanent welfare of the child will be served by granting the reliefrequested because Plaintiff is in Loco Parentis ofthe child, has taken care ofthe child since birth and she can best provide for the needs of the child. 12. 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 child. q--Ll---01 Cfy}/};/ 11J1/ Michael A. Roselle, Esquire Attorney for Plaintiff Date: VERIFICATION I verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S S 4904 relating to unsworn falsification to authorities. ~~.J-~~~ Plaintiff Date: ~ -03-()7' l , TEMPORARY CUSTODY AGREEl\'n~ .' INIe, ~PJff'll('A ~e ~fl ' the natural parentis or gtiardian/s of ~~~ipVl{\e vv\ )),o(\cer,bom --Su,nP is'Oel voluntarily place the above named child in the physical custody of Yf' ~\-,', f' 'V,o V'>v'"\ ;VV'~ t,..,n who resides at dCQrl-t~ 'SFrA<;;"''-c\ "Rt'/"c\ ,SPn\;:',..,rcl }Je. lQQ'1? . 1 am signing this agreement of my own free will and have / Signed t1-wAP A fA '-1A-nf( If Date '1-1(p -tX-\ Sworn before me this ~ {; 71-1 day of .;;:J;jL~ , 4~0r1 HONE" - Commonwealth of Pennsylvania County of tnIFFL/4 On this, the ,g 4 -r 1-1 day of :So L -5 ' 20 ~, before me Sn-IJ/Jill K A!fJ;(E!I()t1!1 , he undersigned officer, personally appeared -r1lF.f{E~.4 It K/.../e;l;J Known to me (or satisfactorily proven) to be the person _ whose name /s subscribed to the within instrument, and acknowledged that~he_ executed the same for the purposes therein contained. f, lJwrl;:unto set my hand ".. -'.,. ;:i:-:'..,..:":,:,:.:,:",:,," ~~J~~ , Notary P blic Notarial Seal Sandra K. Narehood, Notary Public Lewistown Bora, MiffHn County My CommIssion Expires May 7, 2005 Member, pennsylvaniaAssOCietlon at NOllories II ONEil - . I..,......:-y-: r'o MEDICAL CONSENT AUTHORIZATION CHECK ONE: ( .JJ I, ~~ AP}" fA ~,'\I"\.f' f''P ' now residing at ~;I- I/o) /..1 t:b s~ L ~\. ~<<.. \~ , ^ ,V\ ' P A \ '~6q lj , am the parent of the child(ren) listed below and there are no Court Orders now in effect that would prohibit me from conferring the power to consent upon another person. OR ( ) , P A , am the legal guardian or legal custodian of the child(ren) by Court Order (copy attached, if available) and there are no other Court Orders in effect that would prohibit me from conferring the power to consent upon another person. !, -f'h PKr".-0I'.-L Y-- ne p P , do hereby confer upon ~b\e... ~()I) i (\~-\Df) . , now residing at ~~ n (\ I (\~--\on fit ,,;)~~ 5€.u..O<: (2 0. Sec..&on:\ ,~ 111~ , the power to consent to necessary medical or iUental health treatment for the following child(ren): I, , now residing at ;}j!4;,;(i':-! Ii :",< :'::';'~:',:'.":.i':," ;- : ':;';;iii"''< ~ti~.~,~ ".ill" :~bi~%J ~So,Jt~ ,"HI=" lqq?3 who was born on j \.ll'\e I I)" J :;)t:O'j ; ~t~~rAfl~~ , now residing at , PA , who was born on , now residing at , PA , who was born on and on the child(ren)'s behalf do hereby state that the power to consent, which lconfer, shall not be affected by my subsequent disability or incapacity. The power which I confer is specifically health care decision making, and it may be The person named not apply): medical, " .' ~' or,,:::\ ",', "," ",,,,10 any and all records, including but not limited to, in5~~~j!tlll.~: il'1ganysuch services. <~:t\~~er the, power to consent freely and knowingly in order to provide for the cblilll(re/ll)~ not as a result of pressure, threats or payments by any person or agency. This docwnentshall remain in effect until it is revoked by notifying my child(ren)' s medical, mental health care and insurance providers, in writing, and the person named above that I wish to revoke it. IN WITNESS WHEREOF, I, ~eJ\E'~ Vvnl::i>~ ' have signed my name to this medical consent authorization, consisting of two (2) pages on this ~(" day of -Sljl~ ' 200~L in Lel~)\:=: \-ol,.')1'\ Pennsylvania. ~,1,Q/J.1)'-.. '-1frr-w.pp (SEAL) Parent/Guardian/Custodian ' I- residing at tJJdiLl t, 4 rn..j ~ ' Lad <; fUliu YI P)-I :rcl..[ i/ residing at /I If U ,/J! ~~~,,~,liy#~~~~ilM.~!t,,:,i' 17(N-'~ ..,.....,.:.,.:L'..T..:.::..!+'..;l.::'.J::,:.'...: ,::',:'.,:'::,.:::.:.'... .....:'.:.::..><.... ',.. ,:'" . isel!l . only by the (SiSAl,,) ATTENTIONJlEALTH CARE PROVIDERS: Legal presumption exists that the power hereinabove granted has been lawfully conferred and shall be honored by all physicians, nurses, school nurses, mental health professionals, dentists, other health care professionals, hospitals, medical facilities, mental health facilities and insurance providers, in accord with the applicable provisions of the Medical Consent Act, Senate Bill No. 405, Session of 1999, of October 5, 1999, signed November 24, 1999, by Pennsylvania Governor Tom Ridge to date effect in ninety (90) days, or on February 22, 2000. Page 2 of 2 Pages RXHIB'Yrpr,' 'I ONR" Commonwealth of Pennsylvania County of /JJ I/'/Y /# anthis, the d6/11 day of ..:Jijt~ .,20 rf<l, before me \--fn-Altl,/J K ,,(//l-,(f'P'#PIMJ '.. ,... ,.e undersigned officer, personally appeared --rJI;:::-;i!If"SfI J6t/~/zCl Known to me (or satisfactorily proven) t{)>be the person _ whose name / .s subscribed to the wtthininstrument, and acknowledged that~he _ executed the sarne fdrthe purposes therein contained. whereof, I~~~;~~~"t\lilIty hand ,-;........:."'."...,;..\'..:'.'''....,.;.,'.::' ~ -R~!fJu~ /' Notary Pu lie Notarial Seal \ Sandra K. Narehood. Notary Public Lewistown Boro. Mifflin County My Commissio~_ Expires May 7, 2005 Member, Pennsylvania Assocfation of Notaries commonwealth of Pennsylvania County of JJJiffilN On this, the ~;'TH day of ::JIJLtj ,20 oL/, before me SfJ.--/V..oelJ F< AJ~E~OlJ , the undersigned officer, personally appeared 'j7t6<. ':S.>> /{~pjJ -f lk/;~/;c; LjlAW kAIAI/,(/6-77J/I/, Known to me (or satisfactorily proven) to be the person s whose name s I}j( (=- subscribed to the within instrument, and acknowledged that IPeJj- executed the same for the purposes therein contained. '.', 'If-'yIPWlhrWtI1I!Ij!llll1lilIj'!1 ........ ',. i"<}!~lJft11~~~' !i , ;" ,if!'" r!~,' ,"; hA/M/ ~ )i~ , Notary Pub}' c Notarial Seal sa~dra tK. Narehood, Notary Public M aWlS ,?w\l Bora, Mifflin County Me y CommIssion Expires May 7, 2005 mber, Pennsylvania ASSOciation of Notaries r ,.--., t -fA- -- -- -- s- V'1 "<;;) D ...0 -0 W ......n r ~ ~ - ~ -L. ~ o c: -z ~~ ;;~,"~: rr"\(- . -7 "1' &1\:T'~ c;':' ~.:; ~ :,;~~ 3- ~ = oJ' 'Po -.) ....' f'.l 7" :;:t;; l..,C' Q. ~ ("~ -tim ::}'7 lJ{'-' .:" ~((? ~\~ ('<.~T''\"\ ';:....\, ;~~ en I"" .. ~J,S - C/ f,J.s (at<./ IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY, PENNSYLVANIA DEBBIE PENNINGTON, Plaintiff CP-44-1037-2004 VS. THERESA A. KNEPP, ERIC DECKER, JR., Putative Father I, CLAIR COVER, JR., Putative Father 2, Defendants 4< ORDER AND NOW, this J--\ day of v\1> \le..'^"-'v.1u-: 20 t>~pon consideration of Petitioners Eric Decker Sf. and Rickey Decker's Petition for Clarification of Custody Order, this Court clarifies its August 11, 2005 Order in the above captioned action as follows: This Court GRANTS primary physical and legal custody of the child, Cheyanne Marie Decker, date of birth 6/1 5/05, to the paternal grandparents, Eric Decker Sr. and Rickey Decker, with whom the child now resides at 119 South Chestnut Street, Mechanicsburg, Cumberland County, P A, 17055. This court relinquishes jurisdiction of this case and transfers jurisdiction to Cumberland County where the child and grandparents now reside. cc: NOTICE OF ENTRY OF ORDER OR DECREE PURSUANT TO PA. R.C.P. NO. 236 NOTIFICATION - THIS DOCUMENT HAS BEEN FILED IN THIS CASE. PROTHONOTARY, MIFFLIN COUNTY, PA DATE: (f fJ-( /6S. /fA..:c- -8~~,," },/I. e.:..),~ <Jr~ /_ li'1~.~~~'h...l..,~~ PA /'7 "'5 Dickinson Family Law Clinic J .J / 4v ]45 North Pitt Street, Carlisle PA 17013 /Michael A. Roselle. Esq. /' Theresa A. Knepp, /'152 West Fourth Street, Lewistown, PA 17044 and 82] West Fourth Street, Lewsitown PA 17044 /C]air Cover ] 28 Valley St., Apt.5., Lewistown, PA ] 7044 /~\(~~J1~\--dSt/lLwv~~~F \'lol/Lj ~ ~~ TIMOTHY S SEARER PRESIDENT JUDGE " IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY, PENNSYL VANIA DEBBIE PENNINGTON, Plaintiff CP-44-1037-2004 VS. THERESA A. KNEPP, ERIC DECKER, JR., Putative Father 1, CLAIR COVER, JR., Putative Father 2, Defendants PETITION FOR CLARIFICATION OF CUSTODY ORDER NOW COME Petitioners, Eric Decker, Sr. and Rickey Decker, through their counsel, The Family Law Clinic, and respectfully request that this Court clarify its August 11, 2005 Order in the above captioned custody action, which granted custody of the child to the Petitioners, so that the Order refers to the Petitioners by name and refers to the subject child, Cheyanne Marie Decker, by name, and specifies that the Petitioners have primary physical and legal custody of the subject child. In support of their Petition, Eric Decker Sr. and Rickey Decker aver: 1. In August 2004, Plaintiff, Debbie Pennington, a friend of the natural mother of the subject child, Cheyanne Marie Decker (D.O.B. 6/15104), brought the above captioned action by filing a Complaint for Custody of the child. The child's natural mother is Defendant Theresa A. Knepp. Defendant Clair Cover Jr. is one of two putative fathers of the child, but to the best of the petitioners' knowledge he has not participated in this action other than to sign the Stipulation to Entry of Order for Custody described below. Defendant Eric Decker Jr., the other putative father, is named as the child's father on the child's birth certificate, a copy of which is attached hereto as Exhibit A, and incorporated '. herein by reference. 2. On October I, 2004, the parties filed a Stipulation to Entry of Order for Custody with this Court. The parties' stipulation granted shared legal custody of the child to all of the parties, with Plaintiff Debbie Pennington having primary physical custody. This Court adopted the stipulation of the parties as an Order of this Court on October 5, 2004. A copy of the October 5, 2004 Order and the Stipulation of the Parties is attached hereto As Exhibit B, and incorporated herein by reference. 3. In February 2005, Plaintiff Debbie Pennington and Defendant Eric Decker Jr. entered into an informal custody arrangement whereby they shared physical custody of the child. At that time, Eric Decker Jr. was residing with his parents, the Petitioners, Eric Decker Sr. and Rickey Decker, at 119 South Chestnut Street, Mechanicsburg, Cwnberland County, P A, 17055. 4. On May 24, 2005, Defendant Eric Decker Jr. and Petitioner Rickey Decker filed a Petition for Modification of a Partial Custody or Visitation Order with this Court, without assistance of counsel. They requested that this Court award Eric Decker Jr. and Rickey Decker "full custody" of the child. 5. This Court, upon consideration of Eric Decker Jr. and Rickey Decker's Petition, ordered that a Custody Conference be scheduled for July 20, 2005, at the Mifflin County Courthouse. , 6. In June of 2005, Plaintiff Debbie Pennington was evicted from her residence and the child began residing on a full-time basis with Defendant Eric Decker Jr. and Petitioners Eric Decker Sr. and Rickey Decker at 119 South Chestnut Street, Mechanicsburg, Cumberland County, P A, 17055. 7. On July 13,2005, Defendant Eric Decker Jr. began serving a prison sentence at Lebanon County Prison for failing to provide child support for another child who is not involved in this custody action. He is scheduled to be released on January 12, 2006. 8. On July 20,2005, Petitioners Eric Decker Sr. and Rickey Decker, and Plaintiff Debbie Pennington and her counsel attended the Custody Conference that this Court had scheduled. The natural mother, Theresa A. Knepp, Defendant Eric Decker, Jr., and putative father number two, Clair Cover, Jr, did not attend the conference. 9. On August 11,2005, this court issued an Order granting "primary custody (of the child) to the paternal grandparents with whom the child resides." This Court also transferred jurisdiction of this matter to Cumberland County, where the child now resides with Eric Decker, Sr. and Rickey Decker. A copy of the August II, 2005 Order is attached hereto as Exhibit C and incorporated by reference. 10. The August 11,2005 Order does not specify who has legal custody of the child. , II. Eric Decker Sr. and Rickey Decker fear that they will encounter problems in caring for the needs of the child while she is in their custody because neither they nor the child are named in this Court's August II, 2005 Order, and because the Order does not indicate whether they have legal custody of the child. WHEREFORE, in order to assist them in caring for the needs of the child while she is in their physical custody, Eric Decker Sr. and Rickey Decker respectfully request that this court issue an Order clarifying its August II, 2005 Order in the above captioned action so that the Order: a. refers to Eric Decker Sr. and Rickey Decker by their respective names, b. refers to the child, Cheyanne Marie Decker, by her name, c. indicates the address of their residence, and d. indicates that Eric Decker Sr. and Rickey Decker have primary legal custody as well as primary physical custody of the child. Respectfully Submitted, 11,?rJ;'~ Robert Lascher Certified Legal Intern Counsel for Petitioners ---i:,,"~h~ J r <TJri~ I,:~. ains Thomas M. Place Anne MacDonald-Fox Lucy Johnston-Walsh Supervising Attorneys Counsel for Petitioners F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717)243-2968 VERIFICATION We verify that the statements made in the foregoing Petition for Clarification of Order are true and correct, to the best of our knowledge, information and belief. We understand making any false statement would subject us to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date 1/- 7"-- -7" oS ) " ~' . i li /) c-: Date liAr, l }d' J llJ COt'l r'- ~ ,.-. rr1 ...D _0 <il ru ,...., "-'I" l/'l ~ 0 0 ~ 0 0 " J . N N I 0 I I c CO 0-- . ~ E ~ "<""' 0 Ul t m I I ...J ~ ..- ro .i +-> 0 '" '" '" ~ ~g .- 0 0 0 :E: ~m ,.D Ul -~ ~ .- ~ m" ...c1 lL. SN ~ <lJr; ~JD '" OLe c.." ) ;>< ~~~o Ww 0 >-w "=0 0, =2 2~ "'uo ~ ~ o~. ->: X ~:o l.U . E = (j) - w, 7 \I) o w 0 0< OJ <:!?f.i 0 -cm > U 0 ~ ~0 ., a:: a:: 12~ S o~ ~ l.U ...., o~ 0 iE'.o ::.c OU ~ ro (..) a:: - > _0 0' Ul l.U 0.. 0 ~~ CI ::.c 0.. ~ro 0 I u" (..) l.U l.U ~g Ii Ul Ul :E: z "'-' 2' mOL a:: CI ~ ::.c w " f ci -<0 d' H Z w<O i,- ~ Z Z _0 \J 0'" .< z :E: 0 z z oS.:;; " (/.lQ) I-l \I) l.U ~ "", f~I t <V 0- ...J l.U l.U ...J 0 . 0 >0 o c "c m lL. Z :E: l.U H ~ 0" C)~ - :; . e- lL. Z ~ Z ~ (,0') ~ g '0 ~~ :E: "' m I-l ~ Z l.U .2 rom f- S O[J) :E: >- u a:: Ul \I) H Vl l.U ::c a:: a:: a:: ::c ~ u l.U W W f- OX w>- :5 l.U ::c ::c >-<'0 0-'" "<co :E: f- f- '" ,,>- 2<'0 ::>co ~ ~ 0 0 Z lL. :a: '" ~~ ~~ ~ 'iJj ~~ r:;:l ~:~ ~+~ ~~ ~ .~~~ I .~~.. ~~~~ ~i~ ~ ~~ ~: ~I _:~~ f$~ ~~ ~~ ;t;~ C;cl ~~~ ~,..."'s ~~~ ,@ ?:"Jd itZ:; t;i ~:~ t.~ r~~~ "':,~~~ . (I cOpy IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY. PENNSYLVANIA DEBBIE PENNINGTON, Plaintiff YS. CP-44..CY-I037-2004 THERESA A. KNEPP, ERIC DECKER, JR., Putative Father 1 CLAIR COYER, JR., Putative Father 2, Defendants ORDER AND NOW, this II th day of August, 2005, after review of the file and a custody conference on July 20, 2005, this court hereby GRANTS primary custody to the paternal grandparents with whom the child now resides. This court hereby relinquishes jurisdiction ofthis case and transfers jurisdiction to Cumberland County where the child and grandparents currently reside. NOTICE OF ENTRY OF ORDER OR DECREE PURSUANT TO PA. R.C.P. NO. 236 NOTIFiCATION - THIS DOCUMENT HAS BEEN FILED IN THIS CASE. PROTHONOTARY, MIFFLIN COUNTY, PA DATE: i/I":J..jr6 CC: f Michael A. Roselle, Esq. / Debbie Pennington, 104 North G~and Street, Lewistown, PA 17044 {Theresa A. Knepp, 152 W. Fourth Street, Lewistown, P A 17044 and . 821 West Fourth Street, Lewistown, PA 17044 (Eric Decker, 119 South Chestnut SI., Mechanicsburg, PA 17055 ,.Clair Cover, 128 Yalley St.. Apt, 5, Lewistown, PA 17044 Certified fi'om the I8COrd sa entered and filed In this ollice. IN TESTIMONY WHEREOF, thereunto set my hand end _ the Seel of tr,> Court be Alii ad /his I~-IA d~ ( A.D., 2 l'S- File Exhibit C [] COpy IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY. PENNSYLVANIA CIVIL DIVISION DEBBIE L. PENNINGTON, Plaintiff CIVIL ACTION NO. /631 OF 2004 vs. IN CUSTODY =t '"q , "r"1 ,--., ,- I :--" .~,'_ :;/:: r= ~)r~ .> go :~c .-.9 ~i r~n -.< THERESA A. KNEPP, ERIC DECKER, JR., Putative Father I, CLAIR COVER, JR., Putative Father 2, Defendants ORDER {-tl- AND NOW, this ::2 day of Oc.. ~~ R..", 2004, the within Stipulation having been presented, read and considered, it is ORDERED AND DECREED that the provisions set forth in said Stipulation regarding custody of CHEYNNE M. DECKER, are hereby adopted as the Order of this Court and the parties are directed to abide thereby. BY THE COURT: Date:~O ,t\/O~ t:m.~W1t, ~. /. ~ <::: {~ P.J, NOTICE OF ENTRY OF ORDER OR DECREE PURSUANT TO PA. R.C.P. NO. 236 NOTIFICATION - THIS DOCUMENT HAS BEEN FILED IN THIS CASE. PROTHONOTARY, MIFFLIN COUNTY, PA DATE: (dJ L/tJj Exhibit B (J COpy IN THE COURT OF COMMON PLEAS OF MIFFLIN COUNTY. PENNSYLVANIA CIVIL DIVISION CIVIL ACTION NO. 1037 OF 2004 DEBBIE L. PENNINGTON, Plaintiff IN CUSTODY " r-",-. Pl::t." :no ;0<;-, C):t: ..,,0 2: no g~ ::0::0 --<-< V> = n ~ vs. ~ = ~~ = :r " " r- -.." ;z:- r- c,,,., Ot:> c: ;z: --< -<: THERESA A. KNEPP, ERIC DECKER, JR., Putative Father 1, CLAIR COVER, JR., Putative Father 2, Defendants '(J '" U1 STIPULATION TO ENTRY OF ORDER FOR CUSTODY DEBBIE L. PENNINGTON and THERESA A. KNEPP and ERIC DECKER, JR, and CLAIR COVER, JR. , parties named above, hereby consent and stipulate to the entry of an Order of Custody in the above captioned matter: 1, The legal right to make major decisions affecting the best interests of the Defendants' daughter, Cheynne M. Decker (D.O.B. 06-15-04), includmg, but not limited to, medical. religious and educational decisions, shall be shared by the parties. For the pUI]>ose of medical and educational decisions, each party shall be considered to be custodial parent and shall have his or her right to access all information concerning these matters, including all hospital, doctor and school records. 2, DEBBIE L. PENNINGTON. in Loco Parentis ofthe child, shall have primary physical custody of the minor child, 3. Defendant!M:other, THERESA A. KNEPP, shall have partial custody rights as agreed by the Plaintiff and Defendant/Mother, 4. DefendantlPutative Father 1. ERIC DECKER, JR.., shall have partial custody rights as agreed by the Plaintiff and DefendantlPutative Father I. 5. DefendantlPutative Father 2, CLAIR COVER, JR., shall have partial custody rights as agreed by the Plaintiff and DefendantlPutative Father 2. . 6. Ifit is determined at any time who the natural father of the minor child is, the other named Putative Father shall no longer have any legal custody or physical custody rights to the minor child which have been granted under this Order. Nothing in this Stipulation shall preclude one or all parties from petitioning the Court for a modification of this Order or Agreement. . Dateo/cr! otj ~bbiCLJ. L"b ~ Debbie L Pennington, Plaintifr=dv ~ Date: ';(/) '<./0'1 --!Ap/],o), 1'<-- 'f~~~ Theresa a, Knepp, Defen t/Mother Date: '/.. 7-30 -() '1 'f... r!:' ~ :1 Eric Decker, Jr" DefendantfPuta Date$/ 2~~L/ CI 0- ,r L.O lv8(' Clair Cover, Jr., DefendantfPutative Father 2 r) "J ", r,,) ...., ,t'\} <... '"I !') " .~;::J ii- ,