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HomeMy WebLinkAbout01-5352 LOUISE SIGNOR Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 01- SJ-S"^-- CiQ,'L I~ CIVIL ACTION - LAW CUSTODY RANDY E. SIGNOR Defendant COMPLAINT AND NOW, comes Plaintiff, Louise Signor, by and through her attorney, James W. Abraham, Esquire, Abraham Law Offices, Harrisburg, Pennsylvania, and files the following: 1. Plaintiff, Louise Signor (hereinafter "Mother") is an adult individual who currently resides at 751 High Street, Apt. B, Lancaster, Pennsylvania. 2. Defendant, Randy E. Signor, is an adult individual who currently resides at 328 4th Street, New Cumberland, Cumberland County, Pennsylvania. 3. Father and Mother have one (I) child together as they are the natural parents of Tyler A. Signor, age 4, born December 18, 1996. There are three (3) other minor children involved hereto as follows: Amanda L. Amaker, age 11, born December 15, 1989 Eric R. Amaker, age 13, born May 12, 1988 Holly E. Signor, age 13, born August 5, 1988. Amanda L. Amaker and Eric R. Amaker are the natural children of Mother and the step-children of Father. Holly E. Signor is the natural child of Father and the step-child of Mother. 4. On August 11, 1998, an Order of Court was entered in the Court of Common Pleas of Dauphin County, which provided Father with primary physical custody of Tyler Signor, Amanda Amaker and Hollie Signor. The Order did not reference Eric Amaker. A true and correct copy of the Order is attached hereto as Exhibit "A". 5. In November, 1998, Mother commenced a custody action in Cumberland County which did not resolve in any court order as the parties eventually reconciled in May, 1999, after Mother's release from Dauphin County Prison, in which she was imprisoned on DUI and reckless endangerment charges from February through May, 1999. A true and correct copy of the Cumberland County Order terminating the custody action is attached hereto as Exhibit "B". 6. For approximately the past two (2) years, from May, 1999 through August 1, 2001, all four (4) children resided with Mother and Father at the former marital residence at 348 4th Street, New Cumberland, Pennsylvania. 7. On or about August 1, 2001, the parties separated and Mother moved to the aforesaid Lancaster, Pennsylvania address with Eric Amaker. Tyler Signor, Amanda Amaker and Hollie Signor remained with Father in New Cumberland, Pennsylvania. 8. The parties have a temporary Dauphin County Order dated August 30, 2001, pursuant to an Emergency Petition filed by Father, giving Father primary physical custody of Tyler Signor, Amanda Amaker and Hollie Signor and partial custody to Mother. Eric Amaker remains with Mother in Lancaster. A true and correct copy of the Order is attached hereto as Exhibit "C". 9. Mother believes and therefore avers that the parties agree that Mother shall have sole legal and physical custody of her natural child, Eric Amaker; and that Father shall have sole legal and physical custody of his natural child, Hollie Signor. 10. As to Amanda Amaker and Tyler Signor, Mother submits that the best interests of said children shall be served by granting Mother sole physical and legal custody of her natural child Amanda Amaker and primary physical custody of the parties' child, Tyler Signor. WHEREFORE, Plaintiff/Mother Louise Signor, respectfully requests Your Honorable Court, to grant Mother primary physical custody of Tyler Signor and sole physical and legal custody of Amanda Amaker and Eric Amaker; and to grant Father sole physical and legal custodian of Hollie Signor. Respectfully submitted: ~ James W. Abraham, Esq. Abraham Law Offices 513 North Second St. Harrisburg, PA 17101 (717) 232-7825 Attorney for Plaintiff, Louise Signor DATE: 9/10/01 I, JCfU/~ VERIFICATION {I G t10(C , the undersigned, hereby verify and confirm that I have reviewed the foregoing document and the statements therein are true and correct to the best of my knowledge, information and belief. I further understand that any false statements made herein are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. DATE: ~-3o ~DJ -d~ ~/~C7/ "'- -. J .:;. , '-' ~ RANDY E. SIGNOR, Plaintiff IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA v. CIVIL ACTION-DIVORCE-CUSTODY LOUISE SIGNOR, Defendant NO. 2815 S 1996 Mediation ORDER OF COURT AND NOW, th1s~day of __~l.~,,~t- , 1998, a CUStody Conference having oeen sChed~d, Plaintiff having appeared with counsel, and Dafendan; having failed to appear despite the effectuation of valid service, it is hereby ORDERED AND DECREED as follows: 1. The parties shall have shared legal custody of the subject minor children, Ranay E. S1gnor,Jr., born November 26, 1980, and Holly M. Signor, born August 5, 1988, Amanda L. Amaker, born December 15, 1989, and Tyler J. Signor, born December 18, 1995 . 2. Plaintiff Randy E. Signor shall have primary phys:cal custody of the subject minor children. 3. Defendant Louise Signor shall be entitled to reasonable, liberal, and frequent periods of partial custody, Wlth the exact details SUbject to the agreement and express consent cf both parties. 4. In ~ight of allegations regarding substance abuse prOblems, each of the partiu are specifically directed to take EXHIBIT J~ ',--- '-~,,-j"""~ ,J -- whatever steps are necessary to ensure the subject minor chlldren reside in an environment free from the use of alcohol and illegal narcotics, during their custodial periods. 5. This order is temporary in nature, such that in the event Defendant Louisa Signor should desire custody or additional periods of partial custody, then she may request an additionac CUStody mediation conference by filing the appropriate motion With the Office of the prothonotary. However, in the event that more .',.... ... than thirty days elapses after the date of this Order, she w~ll . then be required to file a Petition in the county of approprlate venue. 6. It is specifically agreed by Plaintiff and nlS attorney that any additional matters relative to this custody case shall be filed in Cumberland County I because that has been the residence of the children for a period in excess of six months, as well as the residence of the Plaintiff. Likewise, it is further noted that the mother resides in Baltimore, MarYland, BY THE COURT: foVk;CO -17IiG// JJi J~\,\' "'\ .\( ~~o 110 ; . 'tlJ I~ 19 98 I hereby ceFiil;>, that the (0:1::901"9 is a tl'II'" ')"'" '"'r-''''' ,~,-,. ',1 '..,,, r nna ' ' .I , . ,I,,~ - ,j ~ ~_", '. ,./J,.: If\l.,,-, 1.1 Iv 1....11 J81 I ~'(e~1 - i '. j,r'~C- hjCkvWJ Proth notar9 . " LOUISE SIGNOR, Plaintiff ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98-6615 CIVIL TERM RANDY E SIGNOR, Defendant CUSTODY NISIT A TION ORDER OF COURT AND NOW this tol-l day of d-1J ' 1999, having not heard from the parties since the filing of the Complaint in January, 1999, the undersigned Conciliator assumes the matter has been resolved and hereby relinquishes jurisdiction of the case. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, MICHAEL L. ANGS Custody Conciliator cc: James W. Abraham, Esquire Randy E. Signor 328 4th Street New Cumberland, P A 17070 EXHIBIT '-1L RANDY E. SIGNOR, Petitioner IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA VS. NO. 2816 S. 1996 LOUISE SIGNOR, Respondent ~%i CIVIL ACTION - CUSTODY 1..,_1 (..) ORDER u : ',-", AND NOW, this ?~ . ~ c.JU day of August, 2001 upon consideration of the ifi!:Chambers conference with counsel, the Court hereby ORDERS that the Petitioner, Randy Signor, shall have primary physical custody of Holly M. Signor, born August 5, 1988; Amanda L. Amaker, born December 15, 1989; and Tyler J. Signor, Born December 18, 1996 subject to the mother's partial physical custody every weekend from Friday at 6:00 p.m. until Sunday at 6:00 p.m. The mother shall provide the transportation on Friday for pick up and father shall pick up the children on Sunday evening. The parties acknowledge that this Court does not have jurisdiction to hear any further matters related to this case and this matter shall be heard and filed in Cumberland County Court of Common Pleas as promptly as possible. AUG 3 0 2001 I hBrD:~Y wl!fy ttwt ths foregoing ~s a true and correct copy of the p',rj~mal fltad Q.,t.1),~J c., ' C"I~ ~t Prolhollotary BY THE COURT: ~~~ Distribution: Roger R. Laguna, Jr., Esquire, 15 North Front Street, Suite 203, Steelton, P A 17113 James W. Abraham, Esquire, 513 North Second Street, Harrisburg, PA 17101 Deborah S. Freeman, Esquire, Deputy Civil Court Administrator EXHIBIT I "'-. CERTIFICATE OF SERVICE I, James W. Abraham, Esquire, the undersigned, do hereby certify that I have served a true and correct copy of the foregoing document, by first class mail, on the date indicated below, to the following person(s) : Randy E. Signor 328 4th St. New Cumberland, PA 17070 DATE: 9/10/01 v James W. Abraham, Esquire p~i,(} (:l~8 ~(J ~ f'v P-- --zg o ,J~ IT' -".,..1 . ;\ ~ (;.... ...,0 ;;:. .eel ~(J c:: Z =< ....... ....... ~ .c:: ~ C) I, :~) '~;'l en r'-q --:J (..) c -,\,") " ,::"~\ :!~l 6~~ ~:,l ~ ~'1j :~'i; ':-'1 co 'i"::: f'--' 8 r~:j LOillSE SIGNOR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. RANDY S. SIGNOR DEFENDANT 01-5352 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, September 18, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Seuate Aveuue, Suite 105, Camp Hill, PA 17011 on Tuesday, October 23, 2001 at 11:00 a.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. The court hereby directs the parties to furuish 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 Melissa P. Gre~y. Esqh 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . ~~$ ~w 46; It/-O(J./I --&--?' ~ 4- ~JV ~~ /~.(/P~ ~r~r~'rll(/'~/; 'v1N'v'i\lASNN3d AlNnoo O~ff1i:G8vVm ~11:01HV OZd3SIO AI:iV1CNGi.L.ni.:; .ii" ~'Jl'i :.-,.....-::-.-;:::,.....,.,'. '..1.--">..1 :j. :!J-!' !'i J..,j ,]::/ ~ - "" _"...s 1;. NOV 0 5 2001 \ OV LOUISE SIGNOR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-5352 RANDY S. SIGNOR, Defendant CIVIL ACTION - LAW CUSTODY TEMPORARY ORDER OF COURT AND NOW, this .fI-- day of U~, 2001, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. Randy S. Signor shall have sole legal and physical custody of Holly M. Signor, born August 5, 1988. 2. Louise Signor shall have sole legal and physical custody of Eric Amaker, born May 12, 1988. Eric may have contact with Mr. Signor as the parties shall mutually agree. 3. Louise Signor and Randy S. Signor shall have shared legal custody of Amanda Amaker, born December 15, 1989, and Tyler A. Signor, born December 18, 1996. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. S. S 5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, and the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full partiCipation in all educational meetings and medical/treatment planning meetings and evaluations with regard to the minor Children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational records, attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school night, and the like. 4. The Father shall have primary physical custody of Amanda L. Amaker and Tyler J. Signor. Mother shall have partial physical custody on three of four weekends per month, arranged as three consecutive weekends with Mother and one weekend with Father and rotating between the parents three weekends with Mother, and one weekend with Father. No. 01-5352 - Civil Term Mother's first custodial weekend under this schedule shall commence on October 27, 2001. Mother's partial custodial weekends shall be defined as follows: from Friday at 8:00 p.m. until Sunday at 6:00 p.m.,if Mother is working the 7:00 a.m. to 7:00 p.m. shift; from Saturday at 9:30 a.m. until Sunday at 6:00 p.m. if Mother is working the 3:00 p.m. to 11 :00 p.m. shift. The agreement of the parties with regard to Amanda's custody was based on the desire to leave Amanda in her present school and educational setting. Therefore, the arrangement for Amanda's custody has been agreed to by the parties contingent upon Amanda's remaining enrolled in the New Cumberland Middle School of the West Shore School District. If, however, because of Father's change of residence, Amanda will no longer attend New Cumberland Middle School and a change of Middle School becomes inevitable, then Mother retains the right to Petition per Modification of this Order with regard to the physical custody of Amanda. 5. TransDortation. Transportation shall be provided by Father unless otherwise agreed, until such time as Mother can provide her own transportation. At that time, transportation will be shared by the parties as they shall mutually agree. In the event that Father is not able to provide transportation to Lancaster on Friday evenings for the beginning of Mother's custodial visits, he will arrange with Mother to either bring the Children to her on Saturday morning or to meet Mother at the train station in Harrisburg with the Children. Father will confer with Mother by the Wednesday preceding her custodial weekend if this is the case. 6. Thanksgivina 2001. Mother shall have custody of Tyler and Amanda from 4:00 Thanksgiving Day until Sunday following Thanksgiving at 6:00 p.m. 7. Christmas. Christmas custody shall be arranged on an AlB schedule. Segment A is December 24th through December 25th Noon and Segment B is December 25th Noon until December 26th at Noon. In 2001 and subsequent odd-numbered years, Father shall have Segment A and Mother shall have Segment B. In 2002 and subsequent even-numbered years, Mother shall have Segment A and Father shall have Segment B. 8. During any period of custody or visitation the parties to this Order shall not possess or use controlled substances, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise ensure, to the extent Possible, that the other household members and/or household guests comply with this prohibition. 9. The non-custodial parent shall be entitled to one telephone contact per day with the Children. 10. This Order is temporary in nature and may be modified by an agreement of the parties. No. 01-5352 - Civil Term Disl: Roger R. Laguna, Esquire. 15 N. Front Street. Suite 302, Steelton, PA 17113 James W. Abraham, Esquire. 513 N. Second Street. Harrisburg. PA 17101 , ~ ~ \)~ ktJ"'- ~ J. ~1M/1\7),SIVN3d lJJvnOJ (Jlo'r//j::;9Vvno 2c:Z Hd r;-i1DIIID lL{j,r".. ""CV..L"ij\,';j~"';-i:';'f 3:;~:i~/O"{i.;t) :: 1,',\ .:.\..; ,.,,, -..., .. ~ !. ..",I> , . LOUISE SIGNOR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-5352 RANDY S. SIGNOR, Defendant CIVIL ACTION - LAW 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 Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Amanda L. Amaker Eric R. Amaker Holly E. Signor Tyler A. Signor December 15, 1989 May 12, 1988 August 5, 1988 December 18, 1996 Father Mother Father Father 2. The parties were seen for their first Cumberland County Custody Conciliation Conference with this Conciliator on October 23, 2001, with the following individuals in attendance: the Mother, Louise Signor, and her counsel, James W. Abraham, Esquire; the Father, Randy S. Signor, and his counsel, Roger R. Laguna, Jr., Esquire. 3. The parties reached an agreement as to a Temporary Order in the form as attached. Date !1/diDI ( JMr;]p, h Melissa Peel Greevy, Esquire Custody Conciliator LOUISE SIGNOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 01-5352 CIVIL ACTION LAW RANDY S. SIGNOR DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, June 11, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. at 301 Market Street, Lemoyne, PA 17043 on Thursday, July 17, 2003 , the conciliator, at 12:30 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or ifthis cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children a!!;e 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 couciliator 48 hours pdor to scheduled hearin~. FOR THE COURT, By: Isl Melissa P. Greev.y. Esq. Custody Conc:iliator 1/ 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 HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE 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) 249-3] 66 4..~ .jP' 7 ,i<?re ~~ ['o-e/'9 ~7fb ~X ft?1? ;Per..~'t/ ~~;.; [?? ~/ ~ ~/b. ~""'~e? 'r~ 20'0.? ~?F~~'//. VINV^lASNN3d UN'n"'~ -'. 'J'. '~", I . ,),; : i." "c"irli'1nO Bs" Hci (, I Nnr SO AeNJ.e"J dO AUGr 2003 LOUISE SIGNOR, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 01-5352 CIVIL TERM v. CIVIL ACTION - LAW RANDY S. SIGNOR, IN CUSTODY Defendant BAYLEY, J. ---- ORDER OF COURT AND NOW, this ~day of August, 2003, upon consideration of the attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows: 1. This Court's Order of November 5, 2001 is modified as follows. 2. Phvsical Custody. Father shall have primary physical custody of Eric Amaker, born May 12, 1988; Amanda Amaker, born December 15, 1989; Tyler Signor, born December 18, 1996; and Holly Signor, born August 5, 1988. Mother shall have partial custody of Tyler, Eric and Amanda in accordance with the following schedule: A. On July 19, 2003 from 9:00 a.m. to 1 :00 p.m., on July 27, 2003 from 3:00 p.m. to 7:00 p.m. and thereafter, effective August 2, 2003, each Saturday from 9:00 a.m. to 5:00 p.m. The parties shall meet for these visits at the park in Highspire, Pennsylvania. 3. It is acknowledged between the parties that they are experiencing serious divisions within their relationship, which are in turn having an adverse impact upon their ability to co-parent the subject minor children. In furtherance thereto, the parties shall participate in out-patient therapeutic family counseling to occur between Mother and the children and to occur with the parties together. The purpose of the co-parent counseling shall be to assist the parties in dealing with their communication skills and help them to better co-parent the minor children. The parties shall extend their complete cooperation to the therapist and follow any recommended course of evaluation and treatment. Failure to do so shall constitute a direct violation of this Order of Court. 4. The parties shall sign releases of information sufficiently broad to permit the release of a report to counsel regarding the parties' progress and attendance. NO. 01-5352 CIVIL TERM 5. The Custody Conciliation Conference shall reconvene on September 23, 2003 at 10:30 a.m. at the office of the Custody Conciliator, Melissa Peel Greevy, Esquire, 301 Market Street, Lemoyne, PA 17043. ~\ ~ Edg~r B. ey1,- BY THE CotJRT: / Dist: Jeanne B. Costopoulos. Esquire. 5000 Ritter Road. Suite 202. Mechanicsburg. PA 17055 .LJJIJ.U4 .... "- Roger R. Laguna. Jr.. Esquire. 1119 N. Front Street. Harrisburg, PA 11'102 - --, ~- f_I)..03 CJ.-. s.. 0- f:::( ~)-'-~',.:~; :","-- (~f .' 0, C\ .., F::: '. ~3 D?t~ '-) .)~ ""$4 ;-,'0" ;:-l;;; t; [Jj ;.!} 0.: "'" a 6) ..~ ..~~~~ '.j c- -- "" AUG 1 1 2003 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5352 CIVIL TERM LOUISE SIGNOR, v. CIVIL ACTION - LAW RANDY S. SIGNOR, IN CUSTODY Defendant 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 THE CUSTODY OF Tyler A. Signor Amanda L. Amaker Eric R. Amaker Holly Signor December 18, 1996 December 15,1989 May 12,1988 August 5, 1988 Father Father Father Father 2. The parties were seen for their second Custody Conciliation Conference on July 17, 2003 with the following individuals in attendance: the mother, Louise Signor, and her counsel, Jeanne B. Costopoulos, Esquire; the Father, Randy S. Signor, and his counsel, Roger R. Laguna, Jr., Esquire. 3. attached. 2003. The. parties reached an agreement for a temporary Order in the form as The Order will be reviewed at a Conciliation whi ill be set for September, Me issa Peel Greevy, Esqui Custody Conciliator :216774 Plaintiff s~ 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5352 CIVIL TERM LOUISE SIGNOR, v. RANDY S. SIGNOR, CIVIL ACTION - LAW Defendant IN CUSTODY BAYLEY, J. ---- INTERIM ORDER OF COURT AND NOW, this dJ. day of of the attached Custody Conciliation Su follows: , 2003, upon consideration ary Report, it is hereby ordered and directed as 1. All prior Order's of this Court related to the custody of the minor children herein are hereby VACATED. 2. Phvsical Custodv. Father shall have primary physical custody of Eric Amaker, born May 12, 1988; Amanda Amaker, born December 15, 1989; Tyler Signor, born December 18. 1996; and Holly Signor, born August 5, 1988. In the event that Mother desires to have contact with the children, such contact shall be arranged through counsel and shall be supervised through the visitation program at the Dauphin County YWCA. 3. A hearing is scheduled in Courtroom Number 2 of the Cumberland County Courthouse, on the /3&1. day of 13e:bH'.-4'A, , 200 3 , at j; IV o'clock 1.M., at which time testimony will be taken. For the purposes of the hearing, the Mother, Louise Signor, shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for the parties or the parties pro se shall file with the Court and opposing counsellparty a memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the hearing, and a summary of the anticipated testimony of each witness. These memoranda shall be filed at least ten days prior to the hearing date. NO. 01-5352 CIVIL TERM 4. In the event that Mother is aggrieved by the terms of this Interim Order, Mother retains the right to file a Petition for Special Relief. BYTHECO;~ Edgar B. Bayley, J. Dis!: Jeanne B. Costopoulos. Esquire. 5000 Ritter Road. Suite 202. Mechanicsburg. PA 17055 ~ Roger R. Laguna. Jr., Esquire. 1119 N. Front Street, Harrisburg, PA 17102 I ~ 9. ,)9-03 9- .' >- C() ~ n:; c: :q 1-'. ~ J5s; LJJQ o~ .",);?- li.: L~ .:r:: :J~ 1_)- C.L ,:~)~ ;)f'~-, crl . ~ S~ U~J L. (\....' -" l'..... ')"':2 U:.: , uLJ.j 4.r '::tlu.. Cr.l ~ u~ cry ;::) 0 (:::> 0 SE~003 LOUISE SIGNOR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5352 CIVIL TERM v. RANDY S. SIGNOR, CIVIL ACTION - LAW 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 children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN THE CUSTODY OF Tyler A. Signor Amanda L. Amaker Eric R. Amaker Holly Signor December 18, 1996 December 15, 1989 May 12,1988 August 5, 1988 Father Father Father Father 2. The Custody Conciliation Conference was reconvened on September 23, 2003 as provided in this Court's Order of August 12, 2003. In attendance as counsel for the Mother, Jeanne B. Costopoulos, Esquire. Counsel for the Father, Roger R. Laguna, Jr., Esquire, participated by telephone. Neither party attended the conference. 3. Father's Position on Custody. Subsequent to the Conciliation Conference of July 17, 2003. Mother apparently took Tyler, Amanda and Eric to Las Vegas, Nevada. She was subsequently arrested for kidnapping. The children have been returned to Father. Mother had been incarcerated. However, Father's counsel reports that he had recent communication with Mother indicating that she was out of jail and coming to see the children. Father's counsel alleges that one of the children told him that Mother again had plans to sneak the children out of the house at midnight. Accordingly, Father requests that any contact Mother have with the children, pending hearing, be supervised. Father's counsel indicated that an order requiring supervised visits through the Dauphin County YWCA Program would be acceptable to his client. NO. 01-5352 CIVIL TERM 4. Mother's Position on Custody: Mother did not attend the conference. However, her attorney reported that she had e-mailed the Mother to advise her to either be present for the Conciliation Conference or call in during the time of the Conference. Mother's counsel reports that she has no basis to object to Father's request for supervised visitation in light of the circumstances and the ex parte communication from her client to the Conciliator. This letter has been shared with counsel for both parties. Mother's counsel advised the Conciliator that her client would not agree to supervised contact and that she wants a hearing before the Court because she believes that the circumstances in Father's home are so severe that the Court would agree with her request to return full physical and legal custody of Eric and Amanda to the Mother and to permit her to share physical custody of Tyler with the Father. Counsel further reported that the Mother intends to reside in Las Vegas, but is not known to have employment there. 5. Upon the request of counsel for the Father and with no objection from the counsel of Mother, an Order for supervised visitation will be recommended to the Court for its consideration, along with Mother's request for a hearing. In the event that Mother objects to the recommended Order, she retains her right to file a Petition for Special Relief. Counsel for Father would not object to scheduling a hea~~"r such petition should it be fiI'd. ~ Ii q /;:,} II! ') } M,';'" Pool re,"Y. E","'re Custody Conciliator :218755 LOUISE SIGNOR, Plaintiff V. IN THE COURj' OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RANDY S. SIGNOR, Defendant NO. 01-5352 CIVIL TERM ORDER OF COURT AND NOW, this 13th day of October, 2003, this hearing is continued for a full hearing on the ITerits commencing at 8:45 a.m., Tuesday, October 21, 2003. By 'he CO"7 ---- Edgar B. Bayley, J. Roger R. Laguna, Jr., Esquire For Defendant Louise Signor, pro se Plaintiff Sheriff prs Ylo..uu;,(l ~ lo\cl l:) G,\,),I.. ~o XJe... \\ere.. S\1e.- ~U<L"') \(\ l.9-5') \)~S \Ju~ I,:> ':)\.a.u.\0.~ If, D- "o~j W-cuf'd ~,e..re....- lX'rk \ \J&s-~ Doo~ ,^,rct.v W~ -to ~ '3e.~ o('l'je.r. \J\~N i;1.~SN\~J,r\ r'" " ,-,' \~"""'I\\""V-I \ \ ~\lIr-(', ",.:,"~ "",I~~i, ,\ I,.f l\:"! 0\ .,',,' - . 'I .'~ \ voL ,_ f' \ tj.l . LOUISE SIGNOR, PLAINTIFF IN THE COURT OF COMMON PLEAS OFI CUMBERLAND COUNTY, PENNSYLVANIf. ! V. RANDY S. SIGII!OR DEFENDANT 01-5352 CIVIL TERM ORDER OF COURT , this . 2~ day of October, 2003, following a hearing on RDERED: r custody orders are vacated and replaced with this order. (2) Rand S. Signor shall have legal custody and primary physical custody of Tyler Signor, bo n October 18, 1996, Amanda Amakelr, born December 15, 1989, and Eric Amaker, bo~n May 12, 1988. , (3) Durin~ each summer school vacation period, Tyler, Amanda and Eric shall visit with their m~ther for four continuous weeks with the time being set by Louise , , Signor and Randr S. Signor not later than June 1st each year. Transportation shall be provided by the ~other. I (4) The ~other shall be allowed to be with her children when she visits this are She shall provid1 Randy Signor prior notice of when these visits will occur.1 . By the urt, / 1 This order is pre ised on mother now living in Las Vegas, Nevada. I \t;i\]\:"i\lAS\!N3d f\ " -', '..'{.",r/\i!l] L I ::1 ,~, ., , ,C J "." ,vv :iC) Robert R. Laguna, Jr., Esquire 1119 North FrontiStreet Harrisburg, PA 1~102-3318 For Randy S. Sigror Louise Signor, Pf. se 4505 Paradise R ad Las Vegas, NV 9109 , :sal ~ /J'V'-lL.dd.. / ~ . ;l V. 03 (+. LOUISE SIGNOR, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW RANDY SIGNOR, Defendant NO. 01-5352 CIVIL TERM IN RE: CUSTODY HEARING Proceedings held before the HONORABLE EDGAR B. BAYLEY, J., Cumberland County Courthouse, Carlisle, Pennsylvania, on October 13, 2003, 8:47 a.m. in Courtroom Number Two. APPEARANCES: LOUISE SIGNOR, pro se Plaintiff ROGER R. LAGUNA, JR., Esquire For the Defendant FOR THE PLAINTIFF INDEX TO WITNESSES DIRECT 1. Louise Sophia Signor By the Court By Mr. Laguna CROSS 3 26 FOR THE DEFENDANT 1. Randy Signor By Mr. Laguna By Ms. Signor 60 73 DISCUSSION IN CHAMBERS 1. Eric Amaker By the Court EXAMINATION 86 2. Amanda Amaker By the Court 97 3. Holly Signor By the Court 101 2 1 October 21, 2003, 8:47 a.m. 2 Carlisle, Pennsylvania 3 (Whereupon, the following proceedings 4 were held:) 5 THE COURT: You may take the stand. Bring your 6 things up if you wish. 7 MR. LAGUNA: Your Honor, I was going to make a 8 motion to sequester any witnesses that she may have. 9 THE COURT: It is a custody case. I am not going 10 to sequester. 11 Whereupon, 12 LOUISE SOPHIA SIGNOR, 13 having been duly sworn, testified as follows: 14 BY THE COURT: 15 16 17 18 19 20 21 22 23 24 25 Q State your name. A Louise Sophia Signor. Q Where do you live? A Las Vegas, Nevada. Q Your address? A 4505 Paradise Road. Q Your age? A Thirty-nine. Q Are you married? A Yes, sir. Q To whom? 3 1 A Randy Signor. 2 Q What date? 3 A March 26, 1996 . 4 Q And you separated the last time when? 5 A 2000. 6 Q Do you remember the month? 7 A I left in August of 2000. 8 Q Where were you living at that time? 9 A In New Cumberland, Pennsylvania. 10 Q Do you have children with him? 11 A One child, correct. 12 Q And that is? 13 A Tyler Signor, age six. 14 Q When you were living with him, were there other 15 children in the household? 16 A That is correct. 17 Q And who were they? 18 A That would be Randy Si9nor, Jr. , Eric Amaker. 19 Q Randy Signor, Jr. , okay. His child? 20 A Correct. 21 Q His son Randy, how old is he, do you know? 22 A I think he's, like, 22 or 23 at this time. 23 Q And then the next one? 24 A Eric Amaker. 25 Q And whose child is that? 4 A Q A Signor. Q A Q A Q A Q A Q A Q of 2000? A Q A Q A agreement. Q A 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Eric was to remain with me in Lancaster. Amanda was to remain in Cumberland County, West Shore School District. Should Randy move from that residence and Amanda would be changing schools anyway, then she was to come to me. And in that course Q telling me. A I'm sorry. Hold on, ma'am. I can't take it as fast as you are Q Amanda would remain in school in the West Shore __ A School District, correct. Q What grade was she in at the time? A Sixth or seventh. Q And then what would happen to her? The agreement was? A The agreement was if he moved from the West Shore School District she was to come wit.h me because she would be changing schools anyway. Q What if he didn't move from the West Shore, what was going to happen? A She would stay in the West Shore School District. Q Period? A Q A Q A Correct, and she would come down on the weekends. What did you do with Amanda? Amanda stayed in the West Shore School District. I'm sorry. You told me Eric. Correct. 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q What happened to Tyler? A Tyler we were to have -- he was to bring Tyler to me on the weekends. Q He kept Tyler? A Correct. Q How long did that arrangement last? A Not long at all, maybe -- not even a month. Q Then what happened? A Christmas a friend and I took my son -- Christmas of 2001, I took my son Eric to my sister's in Baltimore for the Christmas holiday. Apparently my other children were down there along with Holly, and Randy took it upon himself to pick up my son from Baltimore, and that was the last I had seen any of my children until four months ac;ro. Q So at Christmas he took then which child? A Eric was in Baltimore, and my other two children were also in Baltimore at my sister's on vacation. And when Randy had gone down to pick his children up and Tyler, he also picked up Eric and never brought Eric back to me, and I didn't see my children on the weekends anymore. Q When is the last time you saw them after that, the next time? A Not until -- I believe we showed up June 11th at Melissa Greevy's. Q You did not see any of your children until 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 conciliation? A Correct. Q When was that? A Well, it would have been -- I believe it was Thursday, July 17th. Q Which year? A 2003. Q Hold on. A And the arrangements Q Hold on. In the interim, between Christmas 2001 and July 2003, you did not see the children. Where were you and what were you doing? A I was living in Lancaster and I was working. Q Working doing what? A I was working at Dart Container Corporation and Turkey Hill Minute Market. I was working two jobs. Q And you weren't even seeing the children on weekends? A Correct. Q Why didn't you do anything in that interim period? A He moved away from Cumberland County. He moved into Dauphin County. The phone number was changed and his family nobody would give me any information on where he was. Q How did you find out where he was? A He's also -- I was paying him 121 a week in child 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 support, and Domestic Relations, when I had it transferred from Cumberland County to Lancaster County, they sent me a document that was directed for the Domestic Relations, and they made the mistake of sending me his address. Q So in this entire period of time, you are saying you didn't know where he was so you didn't see the children? A Exactly. Q When you found out through support, then what did you do? A My supervisor immediately lent me money to hire Jeanne Costopoulos. I paid her $750.00, and she had me in front of Melissa in June. Q What happened then? A Okay. The old order was vacated, and we agreed until we could get back for another agreement Q You had a prior order, right? A Correct. That's the one that he didn't follow. Q Hold on. How did the you had gone and gotten an order on November 5, 2001, right? A Correct. Q And that order provided for what? A I believe that one is where Q Did that keep the status quo until Christmas 2001? A Yeah. In November 1998, mother commenced a custody action in Cumberland County which did not resolve in any court 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 order. Q After November 5, 2001, you still had Eric, right? A In what year, Your Honor? Q You still had Eric? A In what year? Q After that court order, November 5, 2001. A Until December, correct. Q And he had? A Amanda, Holly, and Tyler. Q And then at Christmas he took Eric despite what the court order said? A Correct. Q And then the next time you got into court was July 2003? A Correct. Q Now, did that change anything in July of 2003? I see an order on August 12, 2003. Is that the order that came out of that? A Okay. Yes, Your Honor. Q Did that change anything? A She said it vacated the prior order. Q What happened to the children after that? A They still remained with Randy, and I was seeing them on Saturdays. Q All of them? 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A All of them except for Holly. Q Hold on. On Saturdays? A Correct. Q Except for Holly. What about Holly, she wasn't involved? A She wasn't involved, no, sir. Q And then what happened? A I was seeing my children on Saturdays at a park in Dauphin County. Q Supervised? A No. Q But you were coming up here? A I was driving up to Dauphin County. Q Not taking them down to Lancaster? A No, sir. And that was to reunite mom with children because it had been so long since 1 had seen them. The old agreement, the one that he did not follow, she said that would be vacated and we would meet back sometime in September. But until we met back and made another agreement, I was to see the children on Saturdays. Q And did you do that? A Yes, I did. Q And the children you were seeing then were what children? A Eric, Amanda, and Tyler. 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q And then did that change at some point? A Yes, sir, it did. Q When? A It was the fourth Saturday. Of course, you know, reuniting me with the children I saw the state that my six year old was in. He's skin and bone. I asked my daughter what's going on in the house. There's a whole bunch of situations going on in the house they live in. And it came up Paul and I were moving to Nevada, and I had discussions with the children and I said I had made -- I had called so many different people. I called Dauphin County Children and Youth. I even called the Highspire Police Officer Friday night. Q Just tell me what happened first, ma'am. A Okay. So I wanted to remove them from the situation that they were in, and I made numerous e-mails to my lawyer. Q Just tell me what happened, ma'am. A And I took the children to Nevada with me. Q Which children? A Eric, Amanda, and Tyler. Q You weren't living in Nevada at that time, right? A No, we were moving out. Q You alone were moving out? A Paul and I. 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Paul. You had been l:~ving with a man? A Correct. Q What's his name, last name? A Rompalo, R-o-m-p-a-l-o. Q Since when had you been living with him? A 2001. Q Any other children living in the household? A No, sir. Q Does he have any other children? A He has a 14 year old. Q Living with the mother? A Correct. Q And you had been living with him in what, Lancaster? A Correct. Q What was the purpose of the move to Nevada? A We had gone out -- we had taken our vacation to Las Vegas, and the tours and talking to people it's a wonderful financial Q You just decided to go out? A Yes, after we came back. We were going to sell the house, which he did. We just moved a little quicker when I found out what was going on with the kids. Q Did you move into this Paradise Road address? A Yes. 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Is that a -- A Well, I moved right into jail. Paul moved into __ Q You moved into jail. Hold on. Paradise Road, what kind of home is it, rented? A Yeah, it's rented. Q How big? How many bedrooms? A Three. Q A three bedroom apartment? A Yeah. That's not where we're going to stay. Q And so what date did you leave with these children to Nevada? A It was Saturday, August 9th, 2003. Q Did either of you have a job out there? A No, sir. Q Does he now have a job out there? A No, sir. Q When you got out there, what happened? A The first night I went -- I got into Vegas, our destination was to meet at the University of Nevada of Las Vegas, and I got there first. He was driving the big truck. I got in there at 8:30. Security became suspicious Q Did you get arrested? A Yes. Q What date were you arrested? A I believe that would have been the 12th. 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q On August 12 when you arrived? A Correct. Q What happened to the children at that point? A The children were placed into Child Haven. Q By the authorities? A Correct. The car was impounded. Q What happened, were the children sent back? A The children were sent back. That was a Tuesday. The children were sent back Friday. Q Did the father come out and get them? A I assume. I was in jail. I assume he's the one who came. Q So that was Monday, four days, up to the 13th. When did you get out of jail? A I believe it was Septerooer 15th. Q What were you charged with? A Three counts of kidnapping and interfering with a custody order. Q From Pennsylvania? A Correct. Q Did you make bail? What were the conditions? Did they bring you back? What happened? A Pennsylvania did not come and get me, so I was released after 35 days, and then I called -- we hired a criminal attorney and I 15 Q A Q County? A Q A Q A Friday. Q A Q A Q A Q A Q A Q A Q 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I want to return to Vegas with Eric Amaker, Amanda Amaker, my two children, my biolo,rical children. Q Eric? A And Amanda Amaker. Q Yes. A Holly Signor. Q Hold on. You want to take his daughter? A Correct. Q Anybody else? A Tyler Signor. Q Your child together? A Our child together, correct. Q Now, at the moment do you know where these children are in school and what grades they are in? A They are in Steel High in Dauphin County. Q All of them? A Correct. Well, the three older ones. Tyler is in, I guess, first grade. All of them are in school? In Dauphin County. What school district is that, do you know? Not really. Out of Steel ton where they are living with the Q A Q A Q father? A Correct. 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Now, tell me what grades they are in. A Holly and Eric are in, I believe, ninth grade or tenth. Q You don't know for sure? A No. Amanda is in, I believe, eighth, and Tyler's in first. Q Have any or all of these children ever -- have any or all of these children ever been under the care or supervision of a child welfare agency? A Yes. Q Are they currently? A Not that I'm aware of. Q When have they in the past? A There was an incident when my husband and I had a violent argument, fight, and both of us were arrested and charged with simple assault and they became involved. It was Cumberland County. Q Were you living with him at the time? A That is correct. Q Were the children removed from the household? A No. Q They were never removed? A No. Q Children and Youth was involved? A Correct. 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q That involvement has ended? A Correct. Q Why do you want to take these children to Las Vegas with you? A Okay. Before Officer Cant field knew of my custody situation, he was more than willing to give me -- he confirmed everything that I had called him about the Friday night prior to my leaving. He introduced me to neighbors. I spoke at a lengthy -- Paul and I spoke a lengthy hour with a neighbor confirming he is on record at the Highspire Police Department, but they need proof. They just can't go barging into his house, and I just feel it's not a safe environment. Of course, I don't knmv what's going on in the house, but by looking at my husband, he does not look well and I just I just feel I'm a good mother, and I just feel that they need a female role model. And once -- she was going to come, the neighbor. Q The neighbor isn't here? A No. Q Well, you can't tell me what the neighbor is going to say then. Do you intend to go and live in Las Vegas whether you have the children or not depending on what this court order is, whether you have all or none of them or part of them? A Correct. Q You are going to go out there no matter what? 19 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Correct. We're part of a wonderful church. Q Do you intend to work in Las Vegas? A Absolutely. We have :Iobs waiting for us when we go back. Q What job do you have waiting? A Mine is going to be -- we got them through our pastor. He's going to have Paul in real estate and heating and air-conditioning, and I'm going to be in public relations at RMA. Q What's RMA? A It's a revenue -- I don't have the card. It's a revenue company. Q What does a revenue company do? I don't know what that is. A Well, it's merchandising, dealing in finances, keeping track of -- it's, like, makeup. Q He's going to work in what field? A Real estate, heating and air-conditioning. They pay $22.00 an hour out there. Q A Q A Q Is he here tOday? Yes, he is. How old is he? Forty-two. From the time that you married the father until you in 1996 until you moved to Lancaster in August moved to 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2000, were you always living with him and were the children always living in your family? A The children were always in my care, but they weren't always with Randy. Q Had you been separated more than once? A Correct. Q And the children were with you during those separations? A Correct. Q Do you have any idea what the dates of the separations were? A Okay. I had all three children from May 10th -- my three, Eric, Amanda, and Tyler. Tyler wasn't even born. I'm sorry. I had Eric and Amanda when I left him in 1996, and I had taken them to South Carolina. Q How long did you have them? A I had them with me until December of 1996. Q So you had separated in May 1996? A Correct. Q To September '96? A To December. Q December '96? A Correct. Q And the two girls were with you in South Carolina? A Correct, until he realized I wasn't coming back, 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and then he came and he snatched Holly out of school and brought her back to Pennsylvania, but Eric and Amanda remained with me. Q And then when -- you came back and reconciled in December '96? A That is correct. I was pregnant with Tyler. Q And then was there any other separations? A Yes. Q Until 2000? A Yes. Somehow when I was in South Carolina there was an order that came up in Dauphin County, and I was not present for. So this is how this infamous Dauphin County order came to be. I wasn't even in the State of Pennsylvania. I had left him then in '97 and had gone to my sister's in Baltimore. Q Who were you living with in South Carolina? A My ex-husband. Q Is that Amanda and Eric's father? A That is correct. Q Is he still down there? A No, sir. I don't know where he is. Q He's disappeared? A Correct. Q What is the family in Baltimore? A My sister. Q Does she still live down there? 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A That's correct. Q Now, there was another period of separation? A That's correct. In 1997, I was down with my sister for a few months and -- Q Where were the children? A Eric was with me and then Randy had -- Eric and Tyler and Amanda were with me, and then Randy had brought an order in 1997 taking Amanda and Tyler away from me. Q He got a Dauphin County order? A That is correct. Q Removing Amanda and Tyler? A Correct, and leaving Eric. Q And then did you reconcile? A Yes, we did. Q When was that? A That was in 1999. Q Was there any other separation involving you and he and the children until the final one? A Yes. I had gone into a rehabilitation center in Maryland and I had Tyler. Q When? A In 1998. Q This is before this incident? A Correct. Q Let's go forward for a moment. After the 1999 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 reconciliation, was there any further splitting up of these children or family until the final separation? A No. Q Now, back in 1998, you went into rehab for what? A I had a DUI. Q Alcohol? A Correct. Q Do you have any drug problem? A No. Q Never had any? A No. Yeah, in school and with my husband, not this husband, my first husband. Q This was in 1998, did you say, you went into rehab in Maryland? A Correct. Q How long? A Thirty days. Q The children stayed with him? A Tyler was with me, and the other three were with him. Q He was with you in the rehab? A Tyler, yes. Q And then did you reconcile? Did you go back home after the 30 days? A No. He walked out of a counseling session, took 24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Tyler, came back to Pennsylvania. I went to my sister's in Baltimore. Q You went to your sister's alone in Baltimore? A Right. My son, Eric, was already there. Q And then when did you reconcile? Did you reconcile? A Oh, yeah. In 1999, I had -- Q How long -- in 1998, after your 30 days, how long did you stay down in Baltimore before you got together again? A I came back in February. Q Of? A Of 1999. Q I understand. A Because due to that DUI I had Tyler -- Q And when did you go down to the rehab in 1998? A In 1998. Oh, I believe it was August or September. Q So you were separated from August of '98 until February of 1999? A Correct. There's another Dauphin County order. This is so confusing. There's another Dauphin County order. I was in rehab when that conference took place. Q Do you know when the --- was that before or after that? MR. LAGUNA: I'm sorry,. Your Honor? THE COURT: I'm asking her. 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. LAGUNA: I'm sorry. THE WITNESS: The parties separated and moved -- BY THE COURT: Q That's okay. Let that lag for awhile. Now, come up to current. Is there anything else you want to tell me as to why you feel you should be allowed to take these children get custody of all of these children and take them to Las Vegas? A I believe that they have been away from me entirely too long not by choice but by just down right ignoring something that we agreed upon, you know, and was signed, and, I mean, he's had them out of my life for so long. Our marriage is failed, but, you know, I suppose -- Q Is there a divorce pending or don't you know? A No, because they said to wait until I do the custody. Q There is no divorce pending? A No. I do have papers though since I am a resident of Nevada to file. THE COURT: All right. Cross-examine. CROSS EXAMINATION BY MR. LAGUNA: Q Now, Ms. Signor, you've gone by several last names throughout the last several years, correct? A Well, my maiden name, my married name, and this 26 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 married name. Q Which is what, Louise Signor? A Signor. Q Amaker and Fleming? A When I sign my name, I sign Louise Signor. Q So have you ever used Amaker or Fleming otherwise? A Yes. Q Okay. Over the last several years? A I know when you brought me the divorce papers I signed Louise Fleming. Q Okay. THE COURT: So there is a divorce pending here? THE WITNESS: Until he cancelled it. THE COURT: Okay. Go ahead. BY MR. LAGUNA: Q You, in fact, accepted certified mail and a divorce from our office? A Yes, you delivered it to me. Q All right. But you told the Judge there was none pending. A Well, to my knowledge that was dropped. We didn't get divorced. We reconciled. Q You reconciled. Okay. But you're aware that Mr. Signor filed a divorce, he wanted 1:0 divorce you? A At that time. 27 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Okay. Now, you indicated -- you told the Judge that there was this one DUI in, I guess, Maryland, or where was that? A One was in Maryland. One was in Pennsylvania. Q Well, actually there .,ere three or four, correct? A There was three, one in 1999 and two in 1998. Q But you told the Judge about one. A Well, because that's what he was asking me at that time. Q Well, you explained that that's what got you into counseling, the one? A The benefits of being institutionalized, I believe that was your words, institutionalized and incarcerated is because, yes, I had a bounty of counselors at my disposal. Q A bounty? A A bounty. Q You have been in counseling at many different institutions on many different occasions, fair? A I think three would be fair. Q And -- A Incarcerated and -- three. Q What three institutions? A Are you calling a rehab an institution? Q Well, anywhere where they put you in and you don't walk out the doors because the Court has ordered it. 28 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I believe it was three institutions and my incarcerations, and at one point I was not allowed to return to Randy because they knew that our marriage was too volatile. THE COURT: Wait, ma'am. He just asked you how many times you have been in counseling. Go ahead. Next question. BY MR. LAGUNA: Q And when you say institutions, which institutions are you referring to? A Does it matter? An institution's an institution. THE COURT: Tell me where you got your counseling. It doesn't matter whether THE WITNESS: Mountain Manor, Marworth, Pennsylvania, or up in Scranton. I believe that's where it was. THE COURT: What is the third one? THE WITNESS: Actually, I can't remember a third one. I know it was incarceration and the two rehabs. BY MR. LAGUNA: Q Deer Run? A Do I what? Q Does Deer Run sound familiar? A White Deer Run. We're not up to there yet. That takes us up to when I left him again in 2000. Q Okay. So that was much later in 2000. Now, you 29 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 said incarcerated. Are we talkin9 about Dauphin County Prison? A That is correct. Q How many times? A Oh, let's see, two parole violations. Well, actually, it was three parole violations because every time they came to the house there was either alcohol in the house or it was something that Randy -- it was because of our marriage, because of the violence in our marriage. THE COURT: Ma'am, he did not ask you that. He asked you how many times have you been in prison, separate times. BY MR. LAGUNA: Q Now, Dauphin County -- THE COURT: I am asking it. Besides sentencing and going to prison and parole violations, how many times have you separately been sent to prison? That is the question. THE WITNESS: I believe safely to say three times. BY MR. LAGUNA: Q Now, that's in Pennsylvania? A Correct. THE COURT: Total. BY MR. LAGUNA: Q What about Baltimore? A I've spent overnight for the DUI. Q Wasn't there a DUI where you hit an ambulance or 30 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 something? A That was the DUI in Maryland. Q Did you have children in the car? A No. Q Okay. The one in Pennsylvania, you had the child? A I had Tyler in the car with me, that is correct, and I have to live with that for t.he rest of my life. Q You were drunk, you had an accident, a serious accident, and you had -- at that point he was just an infant? A He was two. Q He was two. And he WCIS in the car as well? A Correct. Q Okay. Now, in 1998, on April 24th of '98, you were charged with simple assault and harassment, correct? A That is correct, and you were my lawyer. Q On April 7th, you were charged with public drunkenness, correct? A I'm sure. Q You're sure? A I know a lot happened in this marriage. Q That was his fault? A I believe we both played a part. It takes two. It's not just one. Q Well, let's talk about that. In fact, this Friday you told the Judge that you went to a funeral, your mother's 31 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 funeral? A Correct. Q Now, you have somebody new, not him, not Mr. Signor, correct? A Do you mean as far as a partner in my life? Q Yes. A Yes. Q And this last Friday, even after we were here in court, you appeared at the funeral staggering drunk? A Oh, that is not true. That is not true at all. That is not true at all. Q Were you drunk? Absolutely not. A It was my mother's funeral. Q So if we have two or three witnesses come in here and say you were visibly drunk, they would be lying? A I believe that they would, yes, because Paul was right there. Paul knows I wasn't drinking. Q Sure. Now, on June 5t.h, 1997, you were charged with disorderly conduct or engaging in fighting and you pled guilty, correct? A Yes. Q And you were also charged with public drunkenness and you were remanded to the -- you were remanded to prison because also there was a capias already on you for a parole violation, a detainer was issued because you had violated 32 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 parole? A Each time that I was r"emoved from the house it was due to Randy and I fighting. Q I understand that. A And then that would turn into -- you represented me on the simple assault. THE COURT: He is only asking you did you wind up in jail? THE WITNESS: Yes. THE COURT: Next question. BY MR. LAGUNA: Q On March 24th, 1997, you were arrested for simple assault in that you attempted to cause bodily injury with a deadly weapon, a knife, correct? A That's a lie. Q Were you charged with that? A It was brought down to harassment. Both of us were fighting. Q Are you sure? A Not one hundred percent. There's a lot that happened in the marriage. Q Well, let me -- A I can't remember each detail. I did a lot of jail time and a lot of institutionalize when I was with him. Q Do you remember chasing Holly Signor and Randy 33 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 around with a knife on -- A That is Randy's version. Q Let me finish the question. On March 24th, 1997, do you remember chasing Randy and Holly around with a knife while you were drunk? Just yes or no. A No. Q Do you remember the New Cumberland Police coming in and pointing a gun at you, two of them -- A Yes. Q -- and telling you to drop the knife? A I had no knife and they saw that. Q Did they point their (:run at you? A I was sitting at the top of the stairs. They came around the corner. Q Did they point A I was upstairs when Randy -- THE COURT: Ma'am, it is such a simple question. Did they point a gun at you? THE WITNESS: No, it vlasn' t pointed. BY MR. LAGUNA: Q Was it out? Were they holding it? A Yes, I could see it but it was not pointed. Q In fact, they displayed it for you to see? A Yes, he had it down. Q You were also charged with aggravated assault 34 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 during that incident, correct? A I believe I was charged with aggravated assault on Randy, but that was brought down. Q Okay. And, in fact, Randy sustained a cut, and he went to the hospital for the cut, correct? A I had my teeth knocked out, and Randy had a cut. Q So the answer is? A Both of us were injured. Q And you were also charged with harassment for physically striking and kicking Holly? A I have never touched any of my children in that way. That's his word against mine. And at that point and time in Holly's life Randy put a wedge in between Holly and I. THE COURT: Hold on. You are beyond the scope. He is just threshing out criminal stuff. Next question. BY MR. LAGUNA: Q On April 12th, 1996, you were charged with aggravated assault when you injured two police officers, correct? A No. Only one police officer was injured, and that's because I was dead weight because I was drunk. They were putting me in the car, and my head fell back on her nose. Q And she had a fractured nose? A I'm not sure what she had, but I know the testimony was given that she knew that it was not intentional. That was 35 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the bottom line in that case. Q Testimony was given about that? A That she knew it was not intentional. THE COURT: What, if anything, were you convicted of or pled to, do you remember? THE WITNESS: I really, to be honest with you, don't know. There was so much. Were you convicted of some offense? I was convicted of some offense, yes. Next question. THE COURT: THE WITNESS: THE COURT: BY MR. LAGUNA: Q You were also charged with resisting arrest, disorderly conduct and THE COURT: The charges aren't what is important to me. Convictions are what are important. MR. LAGUNA: Well, she was convicted of all of them. THE COURT: Well, you are not asking her that. If you want to ask her whether she was convicted of something, ask her that. BY MR. LAGUNA: Q You were convicted of all of those charges, correct? THE COURT: Wha t char~res? 36 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. LAGUNA: Q Of the aggravated assault, the assault? A Which incident? Q In fact -- THE COURT: Which inci.dent? MR. LAGUNA: I'm sorry, Your Honor. BY MR. LAGUNA: Q You were convicted of aggravated assault because you broke the nose of a police officer who was arresting you, correct? A No, that is not correct. Q Okay. You were convicted of resisting arrest for the same incident, correct? A That could be correct. Q Disorderly conduct, correct? A That would be correct. Q Public drunkenness, correct? A That would be correct. Q You were about seven, eight months pregnant when this happened? A No, no, no. Q When you appeared for sentencing A Seven months pregnant? Q When you appeared for sentencing, you were pregnant, very pregnant? 37 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A With Tyler. Q With Tyler? A Right. Well, that incident didn't happen when I was pregnant with Tyler. Q Okay. A I didn't even find out I was pregnant with Tyler until July. Randy didn't even knew until July. Q On November 2nd, 1995, you were convicted for disorderly conduct and public drunkenness, correct? A I believe you're reading the same charges over and over and over. Q Well, I'm talking about a different date, November 2nd. That's why I'm using the date, Miss Signor. On November 2nd, 1995, you were convicted of a misdemeanor disorderly conduct and public drunkenness? JOust yes or no. A I believe that there "ras four incidents that I was convicted, yes, only four incidents. And since being on probation, that is what kept me going back and forth, in and out of jail. Q And as a result of the DUI and the accident in Baltimore, you were on probation or parole there for sometime, correct? A I was on probation -- it was all one probation. Q Well, I'm talking about Baltimore. A No, I wasn't on probation -- oh, yes, I was. Yes, 38 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I was, but I didn't have to, like, go down there or anything, and then I was released off probation. The two went hand in hand. Q Now, on a couple of these occasions with the public drunkenness, an ambulance had to be called to your home to take you to the hospital, correct? A Because I was passed out. Q In fact, your children came home from school on two occasions, they saw you passed out once in the yard and once on the back porch and they called 911? A I believe that is correct. Q And you were hospitalized? A I don't deny that. I admit being a drunk in that marriage. I admit that. You have a copy of that. I do not deny that at all. Q You were also arrested in Florida? A For a speeding ticket? Q Excuse me. A For the speeding ticket? Q No, ma'am. On March 31st, 1986, under the name Louise Fleming for obtaining substance by fraud? A That was trying to obtain a prescription, and that was dropped because that was not my prescription and there was no -- I didn't even have a child then. Q And that was before you were married to Mr. Signor? 39 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I was married to my first husband. The first child didn't come along until 1988. Q Was that arrest your husband's fault, your prior husband's fault? A My actions I am totally responsible for. THE COURT: That is not a proper question. Next question. MR. LAGUNA: THE WITNESS: THE COURT: me ask you a question. Sorry. But I had custody Ma'am, stop, stop. Next question. Do you still drink alcohol? Let THE WITNESS: THE COURT: Not to the point of intoxication. So the answer is you still drink alcohol? THE WITNESS: Yes, I do. BY MR. LAGUNA: Q And, in fact, during the short period that you had Eric Amaker in Lancaster, you became intoxicated to the point where pOlice had to be called there as well? A I recall the incident. The police were called but only due to Randy, and they spoke to Eric and they realized -- they knew that I was not intoxicated. Q And as a result of wha": happened in Lancaster, Eric came and he lived with Randy, correct? A Randy took Eric from the designated vacation place 40 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that I dropped Eric off. Why Randy -- what Randy's intentions were or why he did what he did, I have no clue. I know that he stopped bringing my kids to me on the weekends, and I know that he took Eric and did not bring Eric back to me. Q Did you file anything with your attorneys to correct that situation? A We didn't know where he was, and I was working two jobs at the time. I don't have that kind of money. He's taking $121.00 a week out of my paycheck. THE COURT: The answer is you did not, right? You did not file with attorneys? THE WITNESS: No. I had no money. THE COURT: Listen to the question. BY MR. LAGUNA: Q Did you have Mr. Abrat.am, who was your attorney at that point, did you have him telephone me or write a letter or say anything? A He wanted $250.00 that I did not have. THE COURT: The answer is no, right? THE WITNESS: The answer is no. THE COURT: She has answered that. BY MR. LAGUNA: Q And then as a result once Eric Amaker went with Randy from Lancaster A From Baltimore. 41 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Excuse me? A Randy took him from Baltimore, not Lancaster. Q I thought Lancaster was after Baltimore. A No. Q Okay. A Randy took Eric 2001, December. Eric was down at my sister's in Baltimore on Christmas vacation. Randy took it upon himself to pick my son up with the rest of his children and not bring my son back. Q And since that time Eric has lived with Randy? A He had no choice. I didn't know where he was. Q You didn't know where he was? A No, I did not know where he was. And there is a woman standing right out there that can tell you I called her. She said they were living somewhere in Highspire. Q Did you pick up the phone book by chance and call? A Yes, as a matter of fact I did. And then a lawyer got in contact with him, and he disconnected the phone number. He said to call you, which then a Paula Kunzman (phonetic) -- I was going through legal aide called you. Q So you picked up a phone book and you found out where he was? He was in the phone book? A And then he disconnected his phone number. No, his phone number was unlisted. Q It was unlisted. You knew where he worked for 42 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 about, what, 15 years, 11 years? A And when I would call there, Linda would say he was either out on the road or she does not want to get involved. People were sick of our relationship. Q So when you tell the ~rudge that you had no idea where he was and that's why you didn't take action, that's not really accurate or fair, is it? A I believe it is accurate and fair. Q You knew he was in Hic:rhspire, you knew his phone number, you knew his attorney? A He changed his phone number. Q You knew his attorney? A I even took my cell phone to my daughter which was taken from her. That's when Paul gave me the money to hire another lawyer. Q Exactly. You took A And we got back in front of Melissa. Q You took a cell phone to your daughter during the period where you say you don't know where he lived? You took the cell phone -- A Well, then I found out where he lived. Q So my point is it's not really fair to tell the Judge that Randy somehow disappeared? A Randy disappeared with the children. When you leave out of the home that we resided in for how many years and 43 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 then you change your phone number and you move out of the county, he's hiding my kids. Q He's hiding them. In fact, he purchased a home for the kids in Highspire, correct? THE COURT: If you know. THE WITNESS: Not that I'm aware of. THE COURT: Next question. BY MR. LAGUNA: Q Now, you said they do not live in a safe environment, is that correct? A That's what I am told. Q Do you have any personal knowledge that the environment in Highspire on Market Street is not a safe environment? A From the police reports and from my daughter, yes, I believe that it's an unsafe environment because this is a life that my husband of today has never lived, and when I heard about it, I was shocked. Yes, it's not a good environment. Q Do you have any personal knowledge THE COURT: She answered your question as she understood it. I understand what she is saying. BY MR. LAGUNA: Q Now, you say your husband didn't look well. A No, he looks -- look at him. He looks, what, 120 pounds. 44 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Q Okay. He works full-time and a part-time job? THE COURT: Well, he can tell me whether he is well or not. I am looking at him. Go ahead. Let's proceed. BY MR. LAGUNA: Q Now, you say they need -- one of the reasons -- the prime reason, I think, that you told Judge Bayley that you want to take these kids with you to Las Vegas, Nevada, is because they need a female role model. Is that fair? A My children have always been with me until I met this man. My children were safe. I am their mother. I love them. Q Okay. And I wrote down you said -- A All these -- Q Ma'am, I wrote down that you said they need a role model, a female role model. A That's one of the things I said, yes. They need many things. That's one of many things that they need. Q You agree that the role model should be a positive role model? A I think both their parents should have a positive role model in their life, absolutely. Q Do you believe that you are a positive role model for these children? 24 A Yes, I believe I am. My life has changed. My life 25 is not the way that it was when I was married to Randy. It was 45 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 a bad marriage, and whatever he's doing with his life he's moving on. I want to move on. I want to share our children. Q You want to move on to Las Vegas because you think that's going to provide some new opportunity for you, correct? A That's where we chose to live. There's many parents who are living apart from their children, and you work it out, three months -- my first custody order with my first husband worked out well. THE COURT: Hold on. You have chosen to live in Las Vegas for a new opportunity for the two of you. Is that a fair statement? THE WITNESS: That's a fair statement. BY MR. LAGUNA: Q Now, you cannot afford to hire a lawyer to represent you today, correct? A That is correct. Q You cannot afford to pay support in a timely manner, correct? A That is correct. Look at everything that's happened. Q How do you propose to transfer children back and forth if you guys work it out? A Through Paul Rompalo. Q Excuse me? A Through Paul Rompalo. Paul Rompalo is paying for 46 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 all of this. Q Paul Rompalo. How long have you known Paul? Let me ask you this. How long have you been dating with Paul? A About a year and a half. Q Okay. And after a year and a half, Paul Rompalo is prepared to finance all of this, and you're prepared to base your decision on that? A Well, so far the man has lost a car. We've had to fly twice. He had to hire the criminal attorney for me. Thirty days while I was in jail he was there for me. He had to rent a car. We had to rent a van. Now we're living in a hotel room. We had to stay an extra week. Yes, I trust anything that Paul is doing, any decision. Paul is a wonderful person. God put him in my life, and we belong to a nice church. Q You've had many other men in your life since Mr. Signor, correct? A That is not correct. I had two. Q And that didn't work out? A No. Q What if this doesn't work out with Paul? THE COURT: Well, that. is the future. I have got to deal with the present. She is telling me what her current plans are. BY MR. LAGUNA: Q So Paul doesn't have a job, you don't have a job, 47 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 but -- A Not until we get back there. Q Somebody is going to hook you up when you get back there? A Well, sure. Paul and I had jobs before we left for Nevada, and we plan to have jobs when we go there. Q I understand. You worked for a temp service is what you told support at the last support conference? A I told them I was working for three temps. THE COURT: Well, you tell me. Before you left for Nevada -- when did you go to Nevada again? THE WITNESS: August 9th of 2003. THE COURT: Where were you working? THE WITNESS: Dart Container and Turkey Hill. THE COURT: Where was he working? THE WITNESS: Paul? THE COURT: Yes. THE WITNESS: He was a supervisor at Dart Container for over ten years. THE COURT: Okay. Go ahead. BY MR. LAGUNA: Q Were you placed at these locations through a temp service? A In the beginning, yes. Q Now, you were on pretrial release through Dauphin 48 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 County, correct? A When? Q Because of these kidnapping charges. A Correct. Q Now? A Correct. Q You have bail conditions? A Correct. Q And you have pretrial release supervision? A I call in once a week, and I'm allowed to go to Vegas. They don't have a problem with that. I brought myself back to Pennsylvania to face the charges. THE COURT: Hold on. You answer his questions. He is threshing out what I need to know. BY MR. LAGUNA: Q Now, let me ask you this. We have been to several, I think four or five, conciliation conferences, true? A That is correct, somet.hing like that. Q Many agreements have been reached, correct? A Yes, we've been throug-h quite a bit. Q It was not until after you were charged with kidnapping that you told your attorney to pursue this hearing here today, and that was Jeanne Costopoulos? A That is not true. Q Is it true that at the most recent conciliation 49 A signed. Q A Q A Q A Q A 50 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 That e-mail was not even opened until the 25th, and she took it upon herself to go to the conciliator hearing. Q Okay. A And she said -- and I had written -- THE COURT: Hold on. You answered the question. Next question. BY MR. LAGUNA: Q Miss Signor, at some point in front of Melissa Greevy you said that you would meet with the children in the park in Highspire, correct? A Yes. Q And you were there? A Yes. Q And, in fact, you followed through with that and you did meet with them in Highspire? A Correct. Q And that was on Saturday? A Correct. Q And you were with an attorney? Yes or no. A I agreed to meet with the children on Saturdays. THE COURT: The questi.on is, when you met with them, did you have an attorney along? THE WITNESS: When I met with the kids? THE COURT: At the park. I thought that's what the question was. Next questi.on. Maybe I misunderstood it. 51 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. LAGUNA: Q There was a conciliation conference -- THE COURT: Wait a minute. You followed through from the conciliation conference and met these children at the park how many times? THE WITNESS: Four times. THE COURT: Next question. BY MR. LAGUNA: Q So you understood there was a custody agreement that required the children to stay with Randy and you to meet them in the park? Yes or no. A No, no. I will not agree to that. I agreed that we agreed to meet with the kids on Saturdays and then we were going to reach another -- we were going to reconvene in September. We were all going to reconvene in September. Q But that didn't happen, did it? A I wasn't in the State of Pennsylvania. I was in Nevada because I took it upon myself to take my children. Q You were in jail in Nevada? A I got arrested for taking my children. I took it upon myself to take my children, a.nd I will have to deal with that. Q And, in fact, you wrote a letter to Melissa Greevy from Nevada saying, I know I was wrong; I will deal with the consequences; I knew I shouldn't have taken them? 52 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A No. Q Et cetera. A No, no, no. I wrote Melissa Greevy a letter but I I apologized for my actions, and I stated why I did did not it, who I called, Dauphin County Children and Youth, the Highspire Police Department, and I had told her that the children were most anxious to talk to a judge or talk to her. Q Did you say in that letter, I don't regret what I have done; I don't feel shame in what I have done; I knew the risks involved; and I knew there could be consequences; I would do it all again? A If I had to I would do it again. Q Did you say all of what I just said? A If that's my letter, that's what I said. Q Did you say that you had been deprived of your children for at least the last year and a half? A Something to that effect. I don't have the letter in front of me. If you have it in front of you, then that's what I wrote. Q Well, I'm asking you if you remember writing that. A I wrote various letters. I don't remember every word. Q Did you write I was just a horrible wife? A If that's what it says, that's what I wrote. Q But you don't recall that? 53 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I recall stating it was a horrible marriage. Q Do you recall telling her that Eric and Amanda A Can I read the letter? THE COURT: Wait a minute. He is asking you something. If you do not recall, then say you do not recall. If you do recall, then, fine. Question. BY MR. LAGUNA: Q Do you recall telling Melissa Greevy that Eric and Amanda do not want to live with Randy; Eric and Amanda want to move out here to Nevada with me? A After the four day drive with Eric and Amanda, that is what they told me. Now, what kind of hold he has over Eric right now, I don't know, but I know Amanda wants to go with me and his daughter wants to go with me. Q Okay. So you remember writing that? Was that a yes? A Probably. Q And you say that Eric and Amanda want to be heard? A Yes, that's what I wrote. Q So you want Judge Bayley to hear what Eric and Amanda have to say? THE COURT: I am going to hear what they have to say. THE WITNESS: I wanted them to tell the Judge what they told me. 54 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Next question. BY MR. LAGUNA: Q You stated in the letter that you had to pull the convoy over, and that Tyler essentially was having a fit that he wanted to go back home, and that you were going to arrange that? A I think I had a little bit more sympathy than that. No, that's not what I wrote. I didn't write he had a fit, and, yes, I wanted to return him to his father. Q Why? A Because he hadn't seen me in so long. Q And A And my -- it was tearing my heart apart. Q He was a toddler. He hadn't seen you in two years A I have feelings. Q until you kidnapped. him? He hasn't seen you in two years, and you yank him and put him in a car and take him to Las Vegas? A That was very selfish. Q Yeah. So he's having a fit so you say you have to return him? A I wanted to return him, that is correct. Q And you say you tried to hook up the computer to send an e-mail that you were going' to return him but you 55 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 couldn't do it? A The hotel we were at my son couldn't figure it out. I couldn't figure it out. We could not get the computer hooked up. Q Could you figure out how to pick up the phone or maybe call collect or call the police? A Well, the kids didn't know the number, and I don't know his number. They felt he was using our cell phone. Q Did you know my number? A No. Q You have called me many times over the years. A I don't know your phone number off the top of my head. THE COURT: She says she doesn't know. Next question. BY MR. LAGUNA: Q Did you write in the letter to Melissa Greevy, I know I should not have taken Tyler, but how could I leave him; he is a baby, my baby, and I missed him? A That sounds fair, yes. Q So you missed him so you took him? A Now, that sounds a little selfish there. No, it was not because -- well, it was part of the reason. But I took him because I believe the children were not in a safe environment. That is the majority of the reason why I took the 56 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 kids because I sincerely felt with everything my children have told me that it was not a safe environment. Q Okay. And you stated you have no personal knowledge to back up the statement? THE COURT: That is what she stated. Don't go over what she already stated. MR. LAGUNA: All right. BY MR. LAGUNA: Q Now, you told Judge Bayley that you have never had a problem with drugs, it's just alcohol? A No, I told him my firs.c husband and I did drugs. Q Oh, okay, I missed tha~. Heroin? A It was heroin and cocaine. THE COURT: THE WITNESS: When did that divorce take place? 1995 when I met Randy. But I left him in '89 because of the fact he .wuldn't stop doing drugs, and I had Eric and Amanda with me from 1989 by myself until '95. THE COURT: Ma'am, I understand. BY MR. LAGUNA: Q Do you recall filling out a, I guess, outline for Gaudenzia Common Ground? A It's already been -- no. It's already been established that I was a drunk. THE COURT: She said no. Next question. Ma'am, 57 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 you must answer the questions. One of the things pro se clients always do is they want to argue. Answer questions. BY MR. LAGUNA: Q Do you remember providing Randy with a list of 25 things which you felt was wrong with your marriage and you and him? A No. Q In an effort in an ongoing part of the -- A No. Q -- evaluation? A No. Q Now, I guess you say you hired a criminal attorney? A That is correct. Q And -- A I did not hire him. Paul hired him. Q You didn't have the finances to hire him yourself? A No, I did not. Paul hired him. Q Now, before this kidnapping charge, you had never requested a hearing in front of a judge, correct, over what are we talking close to ten years, four conciliation conferences? A I'm not sure. Q And isn't it true that the most recent request for a hearing is to obtain custody as a tactic to help avoid conviction for the kidnapping char';,e? A How could that possibly be when I took the children 58 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 before we met back in September not present. How was I to know on September 23rd that I was I knew that it could be a possibility that I could be arrested, but that happened before I was arrested. Q Well, I thought you said that you A I requested to come in front of a judge when I was in jail out in Nevada. THE COURT: Hold on. She says it is not a tactic. Next question. BY MR. LAGUNA: Q You said when you took them you knew it was a possibility that you would be arrested. A Well, sure. When you get in your car -- Q Just say yes or no. THE COURT: Well, she said yes. THE WITNESS: Yes. BY MR. LAGUNA: Q But earlier you told the Judge that you thought there was no pending order and you were allowed to do that? A And that's what I sincerely believe. I was meeting with the children on Saturdays. Q And you thought if you met with them on Saturday you could take them to Las Vegas, Nevada, and now you're telling the Judge you knew then that you might get arrested? THE COURT: She already told me she knew she might 59 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 get arrested. I understand what her position is. Next question. I understand what her position is and what she did. BY MR. LAGUNA: Q Your children have been going to the Steel High School District for how long? A I'm not sure. School just started back up. Q Years? A No. THE COURT: MR. LAGUNA: THE COURT: She is not sure. Next question. I have nothing further, Your Honor. You may step down, ma'am. I am going to take a break. Reconvene at quarter after. (Whereupon, a brief recess was taken.) THE COURT: You may take the stand. I want to hear from the father. Whereupon, RANDY EUGENE SIGNOR, SR., having been duly sworn, testified as follows: DIRECT EXAMINATION BY MR. LAGUNA: Q Randy, can you say your -- Mr. Signor, can you say your full name and spell your last name. A Randy Eugene Signor, Sr. , S-i-g-n-o-r. Q Where do you live, Randy, Mr. Signor. I'm sorry. Mr. Signor, where do you live? 60 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Repeat that. Q Where do you live? I'm sorry. A Highspire. Q What's the exact address? A 233 Market Street. Q How long have you lived there? A About a year and a half. Q Can you hear me okay? I know you have some hearing -- A Yeah, I can hear you. Q You can hear me okay? A Yeah, I can hear you now. THE COURT: Speak up loud. BY MR. LAGUNA: Q Where did you live before Market Street? A It was New Cumberland. Q What was the address there? A 389 Market Street -- or Fourth Street. Q And how long did you live there? A It was about five years. Q Now, did you own -- did you own 389 Market Street? A Yes, I did. Q And do you own 233 Market Street in Highspire? A Yes, I do. Q Of course you have a ~ortgage on it but it's -- 61 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Right. Q Now, I want to talk MS. SIGNOR: THE COURT: MS. SIGNOR: THE COURT: Excuse me. Can I object to something? What are you objecting to? The house was -- That is not a proper objection. You may object, but you have got to make proper objections. Next question. You will have a chance to cross-examine. MS. SIGNOR: Okay. BY MR. LAGUNA: Q Now, where is 233 Market Street in relation to Harrisburg and Highspire? A It's Highspire. Q Is that a residential area? A Yes, it is. Q Suburbs? A It's a residential area. Q You live close to a park. The park that we've been hearing about where the visitation occurred, how far do you live from the park? A It's about two to three blocks away. Q Walking distance for the kids? A Yes, it is. Q Do they spend time there? A Yes, they do. 62 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 What kind of a home, how many bedrooms? I have a four bedroom home. THE COURT: THE WITNESS: How old are you? I'm 42. Go ahead. THE COURT: THE WITNESS: THE COURT: BY MR. LAGUNA: Q Now, where do you work? A Eureka Lubricants. THE COURT: You have got to spell that one for me. THE WITNESS: It's E-u-r-e-k-a Lubricants. THE COURT: Eureka Lubricants? THE WITNESS: Yes. THE COURT: Go ahead. BY MR. LAGUNA: Q What is that? What do you do there? A I'm a warehouse person, a truck driver and mixer of products. Q Chemical products? A Chemicals. Q How long have you worked there? A About seven years. Q Full-time? A Full-time. Q Do you have health insurance? A Yes, I do. 63 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Does it cover the kids? A Yes, it does. Q Have you ever been laid off or unemployed during those seven years? A No. Q Now, the children -- when I say children, I mean all of them. They go to school where? A Steel High, and Tyler goes to Steel ton Elementary. Q The kids going to Steel High, how are their grades? A Their grades are real good. Q Do they participate in any extracurricular activities? A Yes, they do. Q Like what? A Eric's involved in weight lifting. He's gone out for -- I think he's had basketball he wants to go for and football. Tyler's involved in student council, and Amanda's getting involved in several things. Q Now, do the kids go to church? A Eric and Amanda goes to church on a full basis, yes. Q With whom? A A lady named Barb Hawk. Q Okay. How often do they go to church? A Every Sunday. 64 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Isn't there some extra church activities? A There's always church activities. I know they had bells on Wednesdays. Q Hang on. Bells on Wednesdays. What's that mean? A They play bells for the choir. Q You mean musical instruments? A Yeah. Q And that's Eric and Amanda? A Yep. Q They do that every Wednesday? A Every Wednesday. Q And what else were you going to say? A Whatever the church they are involved in, you know, so much with the church. THE COURT: What grades are these kids in? THE WITNESS: Eric's in tenth grade. Amanda's in eighth, and Holly's in ninth. THE COURT: How about Tyler? THE WITNESS: He's first grade. THE COURT: First grade. Okay. BY MR. LAGUNA: Q Now, you said -- now, you receive -- well, let me back up. I'm sorry. All the kids have been living electively with you for how long about? A Five, six years. 65 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Now, full-time, they sleep there? A Yes. Q And Christmas and holidays you all participate as one family? A Yes, we do. Q Do you spend time with relatives on any of these holidays, or how does that work out? We do visit relatives on holidays. Now, what do they call you? Do these kids call you What do they call you? They call me Randy and dad. All of them? All of them. Do you go to the school as part of -- well, do you have occasion to go to their school and meet with their teachers or do anything like that? A I go to the meetings. Q What meetings would they be? A Like the PTA, open house. Q About how often does that happen you go to their schools? A Three, four times a year, parent/teacher conference. Q And you say they are doing well in school? A Doing real well. A Q Randy, dad? A Q A Q 66 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q How do the kids interact with one another? I'm going to ask you to describe are they like brother and sister or are there two separate families or how do they -- A Oh, no, they are like brothers and sisters, you know. They protect each other. Q Do they make any distinction between whose side of the family they're on? A No. Q I want to talk about last Friday. There was a funeral? A That's correct. Q Did you go to that? A Yes, I did. Q Who went with you? A That was me and the chL~dren, Eric, Holly, and Amanda. Q Did you have another -- you have another son that is not involved in this, he is an adult, correct? A Yes, I do, Randy, Jr. Q Did Randy, Jr., go with you to the funeral? A No, he was working. Q He's on his own? He's got his own family? A Yes, he does. Q Is he in the area? A Yes, he is. 67 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Do you guys spend time together with his family? A Yes, we do. Q Now, when you say you took the other kids, we're talking about everybody but Randy, Jr., went to the funeral? A Right, and Tyler, okay. He's not allowed out right now. Q Why not? A He had his tonsils and adenoids taken out, so he's at home. Q And you had that done, the tonsils and adenoids? A Yes, I did. Q Did your insurance cover that? A Yes, it did. Q At the funeral did you have the occasion to contact Louise Signor? A I seen her but I did not talk to her. Q How close did you get to her? A About as far as we are right now. Q Did the kids have the occasion to get close to her? A Holly and Amanda did. Q Did you observe her demeanor to be unusual? A Yes. We wasn't even out of the vehicle, and she got out before we did, the vehicle, she was Q Well, what did you see? A She got out of the car, and she started stumbling 68 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and almost fell, and the kids says we think mom's drunk. Q Did you have the opportunity to observe her during the funeral? A Yes, I did. Q Did she appear to be drunk? A Yes, she did. Q Now, do you plan on moving anytime soon? A No. Q You plan to have the kids finish eleventh and twelfth grade and graduate here if they remain with you? A Yes. Q Your job doesn't take you away or anything like that? A No, it don't. Q The kids have friends in this area? A Yes, they do. Q They play with those friends? A Yes. Q Visit with them? A Yes. Q Now, I want to talk about MR. LAGUNA: Well, I have nothing further. THE COURT: I've got a few questions. BY THE COURT: Q Do you live alone or do you live with a woman? 69 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes, I do. Q What, which one? A I live with the children. Q The children. You don't live with another woman? A There's a woman stayinq with me right now until she gets on her feet to get a place. Q How long has she been there? A Two weeks. Q Two weeks? A Uh-huh. Q But generally there is no woman living there? A No. Q Is she a friend of yours? A She is a friend, yes. THE COURT: Do you have any questions? MS. SIGNOR: Yes, I do. MR. LAGUNA: Your Honor, may I -- first, may I do a redirect? THE COURT: You can follow-up. BY MR. LAGUNA: Q Mr. Signor, you have two witnesses that you brought to court here today, two women as character witnesses. Who are they? A One's Evelyn Bupp. Q Who is that? 70 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Evelyn is -- I call her my nanny. She helps take care of the kids, if I need anythi~g, you know. She's there for, you know, to do it for me. Q Daily, weekly, monthly? A Weekly, daily, I mean, whenever I call her. Q Who is the other person? A The other one is Q You have Miss Bupp who is the nanny. You have somebody else, not the church? A My mother-in-law to my first wife. Q And who is she? A Shirley Uhler (phonetic). Q Does she spend a lot -- well, how much time does she spend, if any, with the children? A Whenever she can she spends time with the children. She's working a lot right now. Q How often do you think she sees the kids? A Once, twice a week. MR. LAGUNA: Nothing further. THE COURT: Do you have questions? MS. SIGNOR: Yes, I do. THE COURT: I alert you before you start, this is the time to question him, not make statements. Question, elicit questions. If you want to make a statement, I will let you do that at the end of the case. Proceed. 71 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. SIGNOR: For the record, it was Three 24th Street in New Cumberland. THE COURT: See, you are making a statement already. Ask him questions. CROSS EXAMINATION BY MS. SIGNOR: Q You said this Inga's only lived with you for two weeks. That's not the complete truth. THE COURT: You are making a statement. Ma'am, I will let you do this but only if you ask questions. Ask questions, statements later. Question. MS. SIGNOR: Am I allowed to say __ THE COURT: You are allowed to ask questions. You know what a question is. Go ahead. MS. SIGNOR: Okay. BY MS. SIGNOR: Q When is the last time that you had them to see their southern family? A About a month ago. Q And who was that? A Nicki Fleming. Q No, no, no, I mean their southern family, Eric and Amanda's. MR. LAGUNA: Your Honor, I would ask for a foundation. I'm not sure what southern family __ 72 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Name the people. Who are you talking about? MS. SIGNOR: Ann and Dred Kaminskas, Uncle Kam in Florida. The kids have family __ THE COURT: When is the last time you have taken them down there? THE WITNESS: Probably the last time they seen them was when they were in South Carolina with her. BY MS. SIGNOR: Q And I was in South Carolina with all three of the children, correct, Holly, Amanda, and Eric? A You was in South Carolina with Eric and Amanda. I left Holly come down and visit you, yes. Q And Holly was enrolled in school, correct? A She was enrolled in school for, what, a month or less. Q No, it was two. When is the last time you had Eric to a doctor? A His last physical. Q A couple weeks ago? A Yeah, a couple weeks, not even a month ago. Q But you didn't take him to a doctor the whole time that he was away from me, correct, until a couple weeks ago? A That's correct. Q And the same with Amanda? 73 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Correct. They weren't sick. Q Are you using drugs in your house? A No. Q You're under oath. THE COURT: He said no. BY MS. SIGNOR: Q You agree that we had a bad marriage? A Yes, we did. Q Were you arrested in York County for MR. LAGUNA: Your Honor, it's beyond the scope of direct. THE COURT: No. I will allow it. BY MS. SIGNOR: Q Were you arrested in York County for -- what was your charges? He was your lawyer. THE COURT: Let's put it this way. Were you convicted of any offenses in York County, and if so, what and when? THE WITNESS: It was York County. I was convicted of theft. THE COURT: How long ago? THE WITNESS: Three years ago. Let me think. MR. LAGUNA: Your Honor, it was not a conviction. THE COURT: Wait. You are making a statement now. He is telling me what his perception of it is. I asked a 74 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 question. He answered. MR. LAGUNA: I'm sorry, I just wanted __ THE COURT: You can redirect if you want. MR. LAGUNA: Okay. BY MS. SIGNOR: Q You've often made statements that I'm a darn good mother. Do you deny that? A I did not make the statements. You made the statements of that. Q We've been together since 1995, correct? A That's correct. Q You've not -- I understand you've not ever heard me make that -- that you've never made that statement? A What was the statement? Q That she's a darn good mother. A I might have made that statement a few times. Q But when I was intoxicated I was not a good mother, and I should not have been around the children, correct? A That's correct. Q And the majority of our marriage I was intoxicated, correct? A Correct. Q I left safely -- it's true that I left you at least five or six times? A It might have been more. 75 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q And I took the children with me, is that correct? A That's not correct. Q Are you denying the fact that when I met you in 1995 Amanda and I left and went back down to South Carolina? A In 1995, you and Amanda left and went to Baltimore. Q That was another time. I'm getting there. In 1995, then Amanda and I returned to you, correct? A That's correct. Q Okay. In 1995, Amanda and I went down to Baltimore, correct? A Correct. Q Also in 1995 I left you -- I'm sorry. And at that point I had Eric and Amanda with me in South Carolina, correct? A Q A Q May 10th? A Q That's correct. Okay. In 1996, we married in March, correct? Correct, March the 25th. And I left you two months later, correct, it was Somewhere around there. Amanda and I got on a bus and went back down to South Carolina, correct? A That's correct, I think. Q So at this point do you agree that I had Eric, Amanda, and Holly in South Carolina? 76 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I left Holly come down and visit you. Q Do you think visiting 'Nould mean being enrolled in school? A You wanted to put her in school down there __ Q And she was? A -- for a little bit while she was down there, and I agreed on that. Q And is it not true that you were going to move down to South Carolina to buy a house? A That is true. Q We were looking for a house in South Carolina, is that true? A That's correct. Q And the marriage was no-: working, correct? A That is correct. Q And I would have stayed in South Carolina had I not found out I was pregnant with Tyler, correct? A I don't know that one. I don't know. Q You deny I came back because I was pregnant with Tyler, and we decided to work it out? Do you deny that? A You came back but I don't know __ Q I was pregnant with Tyler, correct? A You were pregnant with Tyler. Q And we bought the house in New Cumberland? A Correct. 77 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Because we had moved out of Dauphin County, correct? A Correct. Q Okay. And the whole family at that point was living in the house on Three 24th Street, New Cumberland, correct? A Correct. Q Do you deny that you don't know anything about this York County custody order? A Which one was that? Q The York County custody order. THE COURT: Do you know anything about a York County custody order off the top of your head? THE WITNESS: Not off the top of my head, no. BY MS. SIGNOR: Q Do you deny paying for t:he divorce of my first husband and myself? THE COURT: That is not relevant. Next question. BY MS. SIGNOR: Q This was part of that. You do not remember you paid for the divorce? THE COURT: Wait, wait, wait. Hold on. To your knowledge, were you involved in a York County custody order? THE WITNESS: Cumberland County but not York County. 78 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Next question. BY MS. SIGNOR: Q Do you deny the fact that you picked Eric up in Baltimore in December of 2001? A It was January of 2003. Q This is 2003. A Well, yeah, yeah, 2001. Yeah, it was January. Your sister called me. Q But while we were in the courtroom here you made the statement that you picked Eric up after being left alone at my house for four days and Eric called you? A That's correct. Q So now you're changing that story, and you're telling the Judge that now you did pick Eric up in Baltimore? A I did pick Eric up in Baltimore. Q You stated he called you from Lancaster. A He did call me from Lancaster. Q He was in Baltimore. How could he call you from Lancaster if he was in Baltimore? A It was in November, early November when Eric was in Lancaster. Q Do you remember when I was in rehab up in Marworth? A Yes. Q Do you recall not being allowed to come back home to you? 79 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I don't recall that. Q The probation officer, Julie Hall, stated to you I could not return to you? A I don't recall that because I picked you up from Marworth. Q You don't recall leaving the house? A I left the house several times. Q You were staying at your dad's, correct? A That's correct. Q So then you left the house, you knew that I was not allowed to come back to you, and you voluntarily left the house and left me with the three children? A That's correct. Q Okay. We did a lot -- "hen we weren't fighting, when I wasn't drinking, when you weren't cheating, we did a lot with the children, did we not? A Excuse me, I didn't understand that cheating part. THE COURT: Let's forget all that. During the course of your marriage, did the twc of you do a lot with your children? THE WITNESS: I done a lot with the children. I can't say we done a lot with the children. THE COURT: Next question. BY MS. SIGNOR: Q Do you deny the fact that you were to be going to 80 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 counseling and you took Eric, Amanda, and Tyler and Holly to Evelyn Bupp's house when you were supposed to be going to counseling? Do you deny that? A I took -- Evelyn Bupp "as watching the kids. They were not supposed to be going to counseling. Q Are you denying that that was the time for you to spend with the kids? A Yes, I am. Q Not to spend with Evelyn Bupp but to spend with you? A Evelyn Bupp didn't spend time with them. Q Do you deny cheating on me with Evelyn Bupp? THE COURT: That is not relevant. Next question. MS. SIGNOR: It's going to be relevant when she comes in to testify against me. THE COURT: It is not relevant. BY MS. SIGNOR: Q Do you deny the fact that you beat me? A I deny that as self-defense. Q According to you and your attorney. THE COURT: He told me what his position is. BY MS. SIGNOR: Q Do you deny smacking my head against the dashboard of the Jeep? A I deny. Not that I remember or recall. 81 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Do you deny emptying --- do you deny the fact that I was baby-sitting when we were living in Steel ton? A Would you repeat that. Q Do you deny the fact that I had a baby-sitting jOb inside the home that we lived in in Steelton? A You watched a kid or two. Q Pardon? A You did watch a child or two. Q Do you deny the fact that I had them sitting waiting for their parents and you dumped empty beer cans in their little circle while they were waiting for their parents? A I picked the trash cans up to empty them. You were intoxicated. I didn't want the parents to see the cans laying around. Q Do you deny the fact that I then walked these seven children five blocks to the first parent because I did not feel that it was safe to be in the house with you? A I don't recall that. Q Did any of the parents come to the house to pick the kids up? A I seen one or two. Q Do you deny the fact that you're lying to me right now? THE COURT: Wait, wait. Next question. He is answering questions. He is under oath. 82 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MS. SIGNOR: Q Do you deny the fact that when I was in rehab you refused to bring the children to see me? A Could you tell me what rehab that was? Q Do you deny calling me a drunk and a horrible person? A I have called you that. MR. LAGUNA: Your Honor, I object. Perhaps she could say when. MS. SIGNOR: Because he wants me __ THE COURT: Wait, wait, wait. He said he might have called her that. You say you might have called her that? THE WITNESS: Yes, I did. THE COURT: Next question. I will allow it. BY MS. SIGNOR: Q Do you feel then in a rehab setting that that would be a safe setting to have children visit their mother or their father? A The rehab is the one that told me do not bring the children. MS. SIGNOR: I wish I could zap him for every time he lied. I have nothing further, Your Honor. THE COURT: Any further questions? MR. LAGUNA: Nothing, Your Honor. THE COURT: Sir, you may step down. I want to see 83 1 some of these children. I want to see them all. Are they all 2 here? 3 MR. LAGUNA: Yes, Your Honor. 4 THE COURT: I want to meet them all. I want to do 5 it just with myself in chambers. 6 MR. LAGUNA: That's fine. 7 THE COURT: With my stenographer. In a few 8 moments, I will send my secretary out. I want to see Eric 9 first, Amanda second, Holly third, and then I will just say 10 hello to Tyler. He is six, right? 11 MR. SIGNOR: Tyler's not present, sir. 12 THE COURT: Tyler is not here? 13 MR. LAGUNA: He's home sick, Your Honor. 14 THE COURT: He had his ':onsils out. That's okay. 15 He is only six, right? 16 MR. LAGUNA: Yes, sir. 17 THE COURT: Eric first. I will send my secretary 18 out in a few moments. 19 MR. LAGUNA: Would you like them in the courtroom 20 to wait? 21 THE COURT: No, no. I will send my secretary out. 22 She can bring each one back individually. Five minutes. 23 (Whereupon, a brief recess was taken.) 24 (Whereupon, the following discussion was held 25 wi th Eric Amaker in chambers.) 84 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY THE COURT: Q My notes say you are 15, right? A Yes. Q That sounds like a good age. Do you like being a teenager? A Yeah. Q What grade are you in? A I'm in tenth. Q At Steel High? A Yes. Q How do you like school? A It's good. I'm doing real good. Q What is your favorite s~bject? A Biology. Q Is it really? A Yeah. Q You like science stuff? A Yeah. Q What is your least favorite stuff? A English. Q English is a little hard? A Yeah. I don't mind reading, but we have to do book reports and everything and that just -- I don't know. I mean, I can do it, but it just doesn't interest me too much. Q Are you into sports at all? 85 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yeah. I don't play on a team. I mean, I did back in my younger years, but then I was, like, moving back and forth. I've always missed sign-ups and everything. And then I did start to play again, like, in E;eventh and eighth grade and then I just -- and then I went to ~:teel High, and I didn't get a chance to. Q What do you like? What kind of sports do you like? A I play football, baseball, basketball. I played just about everything, tennis. I like tennis. Q Good. What kind of a sister is your sister Amanda? Is she a good sister? A Yeah, she's good. Q Is she going to tell me you are a good brother, or is she going to hedge on that? I don't know. I hope she says I'm a good brother. Good for you. Let's see, Holly is living with you, A Q right? A Q A Yes. Do you get along with her? Yeah, we get along. She's like my sister also. I get along with her. Q What type of a kid is this Tyler little guy? A He's my younger brother. He's my younger brother. I don't know. Q Is he trouble on occasions? 86 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A No, he's -- he looks up to me a lot because I play wi th him a lot. Q Good. How many years have you now been going over in the Steel ton School District? A I started my first year in ninth grade. Q In ninth grade? A Last year. Q Before that you were in New Cumberland? A Yes. Q I understand. Now, how long, from your perspective memory wise, has it been since you have actually lived with your mother? Was that back in New Cumberland? A I haven't lived with my mother since Lancaster. Q Since Lancaster. You were in Lancaster for awhile with her? A Yes. Q Then there came a time when your stepdad came down and got you? A Well, actually I went to -- she let me go to my aunt's in Baltimore for Christmas. And after New Year's, Randy got me because mom had called and there was all this fuss there was this guy she was with, I forget his name, that said she had gotten really drunk and everything and had, like, (inaudible) allover his bike and everything, and she called him and was drunk. And I was fed up with it because when I 87 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 lived in Lancaster I dumped a lot of her beer out in the sink because she promised me she would quit and she wouldn't. Q She wouldn't at the tit1e? A At the time, yes. Q She tells me she drinks now but doesn't get drunk anymore. I don't know whether that's true or not but let's hope it is. A And so Randy after -- when he picked Amanda up, I went with him, and mom didn't do anything about it. She didn't try to fight for me or anything, but she said she didn't give up on me or anything, but she was working everything out. And Randy got -- I believe Randy has custody of me now. He did get custody of me but not until -- it was awhile after that he got me from New Year's before he got custody of me, but I believe he does have custody of me now. Yeah, I'm pretty sure he does. Q How do you get along with him? Does he treat you good? A Yeah. He treats me jus~ like I was his son. Q Does he. Good. Good. Now, I heard that apparently there was a period of time when you were meeting your mother in the Highspire Park for awhile? A Yes. Q That was the first time after a long time you had not seen her for awhile, had you? 88 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A No, I haven't seen her for a long time. I was actually kind of scared to go see her because, I mean, I had left from Lancaster, just left, and I didn't really know how she would feel about that. But the first couple times she was okay. I mean, she said, hi, I love you, and we ate at the park and played games at the park and everything, had fun. And so I guess maybe it~ was the second week she said that Paul was leaving for Las Vegas on a job. He was getting a new job there, and she is tagging along, and we need to make a decision if we want to go or not, it's up to us. And she is such a persuasive person, and she talks so much about how good it would be, and she was mostly pointing out towards it is Las Vegas. Q Yeah, it sounds good, doesn't it? A Yeah. And it kind of, like, just filled my head. I mean, I loved her and everything, and I was really happy to see her, but it was such a spur of the moment thing that I was just thinking without thinking. Q Okay. And you went? A And I went. Q It didn't last long because as soon as you got there I hear you got sent back? A Yeah. Q Did Randy come out and qet you? A Yes, Randy flew out and brought us all back, flew 89 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 us back. Q And did you miss some school during this? A No, this was -- Q Was this during the sunwer? A Yeah, this was during the summer. It was before school, yes. Q So you came back. So you had, in effect, a one week jaunt out there. Did you drive out? A Yeah, we drove out. It took us four days. Q Well, you saw some of t.he country. A Yeah. Q You'll see a lot more in your time. What did you do this summer other than your little jaunt to Vegas? Did you have a job at all? Were you just playing around enjoying yourself? A Every weekend we go to Barb Hawk's. She's our youth advisor, and she's been a close friend of the family. Her son's my best friend, and her daughter is my sister's best friend. So we've known them for six years ever since we first moved to New Cumberland. So we got really involved with the church with them. Every weekend on Saturday we go over to their house and do stuff with them, and then we go to church on Sundays, and then we come home. Q Do the three of you, you and Amanda -- does Holly 90 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 come along? A Holly used to come years ago. Like, maybe a year or two ago she used to come. But she doesn't -- she hasn't been going to church with us anymore but she goes -- like, we have camps in the summer. We go to camps every summer. She went to that one. She didn't go this year, but she usually goes to those. Q I got a pretty good feel where you are. Anything more you want to say to me while you have got me? A Do you need to know anything else? Q I don't want to put you on the spot. Your mother wants to take you out to Las Vegas, have you move out to Las Vegas. How do you feel about that? A I don't really want to move out there. I prefer to stay here. Q I understand that. Let's hope and assume your mother is improving her life and all. Would you be adverse to going out there to visit her? A Yes, I would really like -- I would like to visit her during vacations and stuff like that, but I don't want to live with her full-time. I would like to live with Randy and stay here. Q Okay. A And go to school here. THE COURT: It is nice meeting you. You are a 91 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 fine, young man. Would you send your sister back here. ERIC AMAKER: Yes. (Whereupon, the discussion with Eric Amaker was concluded.) (Whereupon, the following discussion was held with Amanda Amaker in chambers.) THE COURT: Come on back. Nice to meet you. I was just talking to your brother, and I was saying what a nice lad he is. Have a seat right over here in the corner, right here. BY THE COURT: Q I am Judge Bayley. YO\;. tell me what kind of a big brother is this? Is he a good guy? Eric? Yeah. Sure. Okay. What do you think he said about you, good A Q A Q sister? A Q Maybe. Maybe, okay. He said you are a pretty good sister. How about this little guy, Tyler? A Yeah, he's a good brother, kind of, but he gets annoying. Q I understand that. He is a little guy. Do you get along with Holly? A Um-hum, sometimes. 92 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Sometimes. Teenagers. What grade are you in? A Eighth. Q At Steel High? A Uh-huh. Q How do you like school? A Not that well. I don't. like Steel High very well. Q Really. Now, let's see, you had been in New Cumberland. You were in, what, elementary in New Cumberland? A New Cumberland and I was in middle school. Q In middle school. Did you like the middle school? A Um-hum. Q You don't like Steel High that much? A Not really. Q What's your favorite subject? A Science. Q What's your least favorite subject? A Math. Q Do you play some sports'? A No. I did play basketball in New Cumberland, but I don't play for Steel High. Q Any other activities you do that you like? A I like playing sports, but I don't really like playing at school sports. Q On teams, okay. You have been living with -- I guess you have been living with Randy now and not your mother 93 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 for a few years, right? A Yeah, I think two, three, four. I don't know. Q You are not even sure. A long period of time that you did not see your mother? A Yeah. Q How does this family get along, Randy and you and the kids get along? A Well, sometimes it's really bad but -- Q Does he treat you well? A Um-hum. Q I understand that you and your brother and sometimes Holly go to a church, and you have a friend that takes you to church activities. Tell me about that. A Holly doesn't really go anymore because well, I work on Saturdays. So it's hard to go because they usually pick Eric up around Saturday, like, in the daytime, and I don't get off work until like 4:00 or 5:00. Q Where do you work? A Saturdays Plunkett. Q Just to get a few dollars in your pocket? A Yeah. Q I bet you like that? A Yeah. We go to church and, like, we go to camps and stuff over the summer, and then we do, like, lock-ins and stuff, and great escape we are doing in November. It's, like, 94 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 all these churches go to -- I don't remember what hotel it is. It is a hotel. I'm not sure where it's at though. We stay there for the weekend, and then, yeah, we do a lot of different stuff with camps and churches and stuff, and we do a lot of fund-raisers to raise the money to go. Q Good. When it came about -- I guess it was in the summer that you started seeing your mother on Saturdays at a park. Did you and your brother do that? A Um-hum. Q Were you happy to see her again? A Yeah. Q Tell me from your perspective how it came about that she took you out to Las Vegas and how you felt about that. A Well, she was leaving with Paul, and she wanted us to come with her. She just wanted to know if we wanted to come, and we both said, yeah, because I wanted to go live with her and Eric wanted to too. But I don't know why we left because now it seems kind of stupid that we just left instead of having permission and stuff, but I wanted to go live with her. I really didn't like Steel High, so I thought it would be a good chance to go, and so we both went with her. Q You got to drive across the country, but it didn't last long, did it? A Yeah. 95 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Would you like to visit her in Las Vegas? Would you like to see her? A Yeah, a lot. Q How do you feel about she wants you to move out there with her now at this point? How do you feel about that? A Well, if I did move out~ there, I don't want it to be now, like later on or something, maybe in the middle of the school year or something, like next. year or something, but I don't want it to be right now. Q I understand. A But if I do move out there with her, I would like to come down here and visit over holidays and summers or something. Q Okay. But you would like to reestablish a relationship with her? A Um-hum. Q I can understand that. She wants that very bad. Hopefully she is doing better now than she did in the past. Do you remember much about the past and the difficulties she had and Randy had together when they lived together? A Well, it was fun some days, and then some days were really bad. I didn't want -- like, I wanted them to split up like once, but then they were fine together a lot of days and I was happy about that. But then some days they were, like, really bad and always getting in a fight, and I really wanted 96 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 them to split up or something. Q Anything else you want to tell me while I'm here trying to work this out? A Not really. THE COURT: It is nice to meet you. Do me a favor and send your big sister Holly in. Nice to meet you. AMANDA AMAKER: You too. (Whereupon, the discussion with Amanda Amaker was concluded.) (Whereupon, the following discussion was held with Holly Signor in chambers.) BY THE COURT: Q Another teenager. Are you IS? A Yeah. Q What grade? A Ninth. Q A Q A Q A Q A Q At Steel High or at middle school? No, it's high school. A four year high school? Yeah. Middle school last year? No, there ain't no middle school. So right into high school this year? Yeah. How do you like it? 97 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A It's good. Q What is your favorite subject? A Math. Q What is your least favorite subject? A History. Q What's your favorite things when you are not studying or something, sports or activities, what do you like to do? A Go to football games and hang out with friends. Q Do they have a good team this year? A Yeah, we only lost onc(~ . Q That sounds pretty good. Is the big game at the end of the year with Harrisburg Hiqh? A Probably. Q I'm not a big football fan. A Camp Hill is in the lead, and we're in second lead, and we lost to Camp Hill our homecoming game. Q How do you get along with Eric and Amanda? A Good. Q And the little guy Tyler? A Yeah. He's everything to me. Q Is he? A Yeah. Q Do you like having a little brother? A Yeah. 98 Q Good. A He's spoiled though. Q Do you remember much about the days when you lived in New Cumberland with your dad and Louise? A Yeah. Q How do you get along --- well, there was a long period you didn't see Louise, am I right? A Yeah. Q Generally, how did you get along with her? A When she was sober, we got along good, great and everything, but when she was drink:.ng, like real drunk and everything, we fought. Q She tells me she is doing better now. We hope she 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 is. A That's what I heard. I heard she changed from Amanda and Eric, well, mostly Amanda. Amanda really talks about her mom. But I heard she changed and everything. I I don't talk to her. Were you along -- did she take you out to Vegas? No, I was not with them. Did you know it was going to happen? No. It was all a shock. They were gone? Yeah. You didn't know? don't know. Q A Q A Q A Q 99 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Amanda talked about going to Vegas but not until this coming summer. So I think it was a code for last summer. Q Okay. If at some point~ the kids go out and visit their mother in Vegas, would you want to go along and join that, or how do you feel about that~ right now? A I don't know. It depends because I want to see, like, how she changed and stuff. I mean, there was things in the past that made me lose trust for her. But, I mean, yeah, I mean, I would go if it was all right with my dad maybe. Q Do you get along good with your dad? A Yeah. Q You have a good relationship? A Yeah, that's my dad. I mean, I'm not going to leave my dad to go live with her. Q I understand. A I mean, that's my only father, real parent, that I got left. I mean, so -- I mean, if it comes down to visitation, I'm cool with that, but it's not like I don't know how to pick up a phone if something went down, and the same with one of them. Q Anything more you want to tell me while you have got me? A No, not really. THE COURT: I know whc.t I need to know. I am happy to meet you. Good luck in school. I will root for Steel High 100 1 on your behal f . 2 HOLLY SIGNOR: Thank you. 3 (Whereupon, the discussion with Holly Signor 4 was concluded.) 5 (Whereupon, the following was held in the 6 courtroom. ) 7 THE COURT: Do you have any other witnesses you 8 wish to call, ma' am? 9 MS. SIGNOR: No. 10 THE COURT: Do you have any other witnesses you 11 want to call? 12 MR. LAGUNA: No, Your Honor. 13 THE COURT: The record is closed. These kids have 14 been through a lot, but they are terrific kids, terrific kids. 15 Of f the record. 16 (Whereupon, argument was held off the record.) 17 (Whereupon, the hearing was concluded at 18 11:23 a.m.) 19 20 21 22 23 24 25 101 10 11 1 CERTIFICATION 2 I hereby certify that the proceedings are 3 contained fully and accurately in the notes taken by me on 4 the above cause and that this is a correct transcript of 5 same. 6 -..-'" ", ~ d: 0~ Pamela R. Sneaffer Official Court Reporter 7 8 9 ------------------------------ The foregoing record of the proceedings on 12 and the hearing of the within 13 directed to be filed. 14 15 Edgar B. Bayley, J Ninth Judicial Dist 16 17 ( 18 19 20 21 22 23 24 25 102 - -- \f!f\!\~~/\l)\ St'~I\!:Jd -'. "".-^JnJ -/"'-'--;;-"!. ", -.-,.." ;:l'j :c,J . ,'-,1 Ii >,. r ,,':oJ .,:'rJ \~" . "'~j'V,~,_,," ;.,U\"l'-;,..... :.JO LOUISE SIGNOR, PLAINTIFF " ~~uJC(V~0(o/ . , IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. RANDY S. 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RANDY S. SIGNOR, DEFENDANT 01-5352 CIVIL TERM AND NOW, this ORDER OF COURT <"2~ day of December, 2003, the custody order of October 23, 2003, is modified to provide that defendant, Randy S. Signor, shall not interfere with Louise Signor having phone contract, mail and email contract, with Tyler, Amanda and Eric, or with their receiving any gifts from Louise Signor. Robert R. Laguna, Jr., Esquire 1119 North Front Street Harrisburg, PA 17102-3318 For Randy S. Signor / Louise Signor, Pro se 4505 Paradise Road Las Vegas, NV 89109 .t&tJ . . I ....<..-j ~"L /,2, ).2.03 ~ :sal I I, b/:'~':'J" "'l.!iL't\_.,: ;'I! L/0.', I' , f{ /../, '_;'/"':':.'.:'/.<:~/ C 1:/ !.l-j /1:7.) " "( 22 J:J(} I'n /""Pi"'.' "V cljf1> '" ""'/"111IC' lie "'7 "-'17-.l. jl'.--J ~j./'V..J :...., .>'(."v ::)!...J. v...oU"7'_', ". 7.!. .l() .....::J,if.:! ..j( LOUISE SIGNOR, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. RANDY S. SIGNOR, DEFENDANT 01-5352 CIVIL TERM ORDER OF COURT AND NOW, this 23rd day of March, 2004, a Rule is entered against defendant Randy S. Signor, to show cause why he should not be adjudicated in contempt. Rule returnable at a hearing to be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania, on Monday, April 19, 2004, at 3:30 p.m., at which time defendant is ordered to appear. ~lJ'1~ Edgar B. Bayley, J. YR:~bert R. Laguna, Jr., Esquire 1119 North Front Street Harrisburg, PA 17102-3318 Fo~andY S. Signor vG>uise Signor, Pro se 4505 Paradise Road #2409 Apt. Las Vegas, NV 89109 :sal b fI b h I ~ I ~';;)~ 00'091 orodUlo(J tJ ~ ~ rd 5'F'1 t. 6.3 o.s 0 hh 'll-f'JO ~UOW Ie' 'i.- i." -;> )""J en"> ".. '... -:J. ',(~ I,::' .,'i' "Iu{l(, LOUISE SIGNOR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - Ll,W RANDY S. SIGNOR, Defendant 01-5352 CIVIL TEEM ORDER OF COURT AND NOW, this 19th day of April, 2004, upon consideration of the Plaintiff's request that the Defendant, Randy S. Signor, be held in contempt, and neither party having appeared at the hearing scheduled for this date, the request that the Defendant be held in contempt is dismissed. By the Court, ~uise Signor, Pro Se 4505 Paradise Road #2409 Apt. Las Vegas, NV 89109 ~obert R. Laguna, Jr., Esquire 1119 North Front Street Harrisburg, PA 17102-3318 For the Defendant , , . ..' /1 J. w'e~l~; ~lk':~. '- v > ~ 0<&,0 oL\' /'- pcb d~ o/h --<-c: /:" ~ .s /'.. ""-Z- . W~\1^1.,'SNr~3d 'LNI'C"-" -,', '" ""-'''n'' ,'- l-,'I.J !"..;' ',',' ~L;:::rt1~ 1t l,J LS:IIHV BGMdV~OOZ AtN1ONOHlOtld 3Hl ;10 30l:L-o-CJ31l:l o .,. . ..~........",...... ... *II UIL6~ 5. .5 ~~ PLAI IFF FAMILY COlJRT DIVISION Ys. CIVIL ACI'ION ( {}.fIr! J ~iJtDr , EFENDANT D.R. NO. ~- os35~ PETITION FOR EMERGENCY RELIEF -- ClJSTOny ~(... 3. Petitioner's relationship to the following minor child(rcn) is_ ;/1 td (rJo+hefG - -, .. ~- ;---<-- LIST FULL NAME(S) AND DOB(S) OF CHILD(REN). 7j ler Jon4-#lan -.S!Jnoy ~d(.(, ~e.r aye Iii Qj~ /~ ra.--Mif /5f~ -t-lber I 4. Respondent's relationship to the child(ren) is 5. CIRCLE ONE: A. No custody order exists concerning thi~e child(ren). B. A custody order was entered on (J ber ;;1003 (date) that states the following: II ~ ,....~...., 6. CIRCLE ONE: o complaint/petition is being filed with this petition. ~ complaint/petition was filed on (date) and a hearing has been scheduled on (date). 7. Petitioner believes that a situation exists that requires an emergency listing because: a. -rf;!- chi /clre.n CLr~ r1o-f Su-r~ b. 7he ch//d(/en h IA ve.' 11 f 0-.11 J ~()d c. /hey f1lrMj ()() I- tv) ~fe~/Y~;1y he / ( it f J?j / n a VI eJlvtY/J/l1?H .yt f WHEREFORE, petitioner respectfully requests that this honorable court grant the following relief Date: 9k/o(p , , x~ 0irncrr pentioner I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties ofPA. c.S.A. 94904 relating to unsworn falsification to authorities. Date: q/~OL/oV , cl~ J ~I?t'r ltIoner (") c s: -rJO:~ ~;.~~ (/) .:t. i~, z ~ 7r1'$ '-..~. r-..> = = =- (,1) rrl -0 N N -0 ::J.i:: ~ ~ n,:n r- '-om ::09 Sc\ ;1; =n \~-t-- :cO om ~ --< w U1 ex> -------- /Dll\S{ S'l J ViOV' VS' f\D~ oy o5JSd-. ~Q.0 d ~ Sj'floJ ~o+r 0 Vl -tv -PrOC e-e-d Sn rO( (Y16- Pc.. lA ped' j 5. -J- j!)f-J5; (1 5 jr/k 10 pi eftS L tAJ01' (; L fr1J \ v.- ~.'h. ~' rid\5 +~e- '{if J huUL j l<j-l h~j i<-tl \ 12 r"f;/o 1 <ef Me1r/- 0-(176 /Luve. (10 ~d5 {{.-f -th;S ff />.- 'L · R~8'Jed*,J1 ~t/0"'( /yUC)C 5~5{d ~ S~y~, c (::. --I" ..-:~, --{)\.i-- \"'1\". -'l.~ .~,~ ~r" 13.~ ~:\';" /Si .3. ~ ~ ~ ~ ~~ ~ ~~ '~ t:?... ~?" .;, \~ .--(: "'1."\ ?~'6 .-0 /h"t'0 "'> ~ ~? ~ ~ .. LOUISE SIGNOR, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. RANDY S. SIGNOR, DEFENDANT 01-5352 CIVIL TERM ORDER OF COURT AND NOW, this -Z1 day of September, 2006, the petition to proceed in forma pauperis by filing a petition for special relief, IS DENIED.1 /,~~ /' ,I ,-- ~ Edgar B. Bayley, / / ~ndy S. Signor 455 Thundergust Mill Road Wellsville, PA 17365 :sal fb'D \D cfrp ~uise Signor, Pro se ~ 2312 Pennyroyal Terrace Baltimore, MD 21209 1 We will not proceed on a petition for special relief based on the general allegations set forth therein. Petitioner may prepare a petition to seek modification of the custody order, and concurrently file a petition in forma pauperis utilizing a form attached. ';:>:" ~ \~ -:s ~ "c<) ..... S-. \~~=.' 6(6: ~~ '6 C"') - 8:> cs::> c-..J (?;'~1 '(J1 .g, ~ (.:: '-f /,.- -"j "~!, "1' ...... 4 ... . . :) \ CO f1 7 ~~ .. L.._ + h fA e.. C ouv-f of C OVJ:1/YJ1)1) : pleas o-f Cc.<..-mkrl6-nd Ut.ull!J L (\ / : jJe-11 I1S J I Ua-n ( ~. Plaintiff ou-"t5'L t JeJvtj'J : VS. NO. bt-S3S~ C,vi ( ~rf'Y} Defendant Pr.n4J 5 i 3110r APPLICATION FOR LEAVE TO PROCEED IN FORMA PAUPERlS I, L..oWSL S~i4.. fJktniny. due to my financial condition? am unable to pay the cost of this action, wherefore, I request I be pennitred to fue in Fonna Pauperis. <i~ OdjJhlt<-}k,i:5 ~tJ;1o.r) 9/; % ~ Date . - .- ~ .. .. + 1. I am. the (plaintiff) (d~fenda.nt) in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone) including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and. correct: L. Q 1..' ,jY inti / SiJnor J (~) Name: 0 Le,se VDp fJ /4- leflt L L' . Address: -=1.3/ B. ,,)Cleo nJ~ fl) j ~( 7i-r/r~ e r;.lall-/t/?'Jove fiJ d c2/cJ-O Y Social Security Number: J -7 ~~ S-~ - <I;/.3? (b) Employment If You~are presently ~plo;ed, s~. _ ~&/eS . 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I ...(; -4 . . .. , .. pate: + (g) Persons dependent npon you for support (Wife) (Husband) Name: Children, if any: Name: fJ('"j" C- .A--(h4.-~ e.r ~l\dCc ~'er ~Ier (5jnQ/ Other persons: + if' Name: C 9 e- \[ eif\ em IVl Relationship: 0 ~ I) W j c 'c;' Age:~ tG /0 ;;t~ 0~ltL IrUniV7J Petitioner ~_ ~ j ~~jn()~ 906/0{, Proth. - 71 C) ~; "'::, " ',. r-0 c:? = cr" C-;) ("; _._..~; () -n ::;:1 1_-r1 rl1p ]~~: ~l~ {l~ :'::'1 ~'~ "'rJ :< I 01 C"J .r;".- 0C1 ;J Z006 Person Filing Motion: Name: Louise Sophia Fleming (Signor) Daytime Telephone No. 410-664-5432 Mailing Address: 2312 Pennyroyal Terrace. Baltimore. Maryland 21209 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, FOR THE STATE OFPENNYSYLVANIA ) ) ) ) ) ) ) CASE NO. 01-5352 Civil Term ) MOTION TO CHANGE CUSTODY, SUPPORT OR VISITATION 1. PARENT INFORMATION Father: Full name:Randy S. Signor Date of Birth: 5/1/61 Mailing address:455 Thundergust Mill Road. Wellsville. Pennvslvania 17365 Residence address (if different): Daytime phone number: Most recent employer: Not Employed Dates of employment: Employers address: Mother: Full name:Louise Sophia Fleming Date of Birth: 10/18/64 Mailing address: Residence address (if different): Daytime phone number: Most recent employerMarv Eooler Racing Stables Dates of employment:August 22. 2006 Employers address:Pimilico Race Track. Baltimore. Marvland Custodian (other than oarent): Full name: Date of Birth: Mailing address: Residence address (if different): Daytime Phone number: 2. CHILDREN List the names of all children covered by your most recent court order. Tyler Signor Amanda Amaker Eric Amaker Holly Signor 12/29/96 12/15/89 05/12/88 08/05/88 Who is Child Living With? Randy Signor Randy Signor A. Nikki Fleming Unknown -runaway Child's Name Date of Birth [Attach extra pages for any additional children.] Is the custody and visitation arrangement for each child the same as ordered by the court in its most recent order? Yes_No X If your answer is "no" for any child, explain in detail how the child's current custody and visitation arrangement is different from what the court ordered. [Attach extra pages ifnecessary.] Eric Amaker removed himself from Randy's care in 2003 because of the continued violent confrontations between his steofather and himself. He moved in with my sister and her son at 2312 Pennyroyal Terrace. Baltimore. Maryland 21209. There he was enrolled by my sister in Cardinal Gibbons. a private Catholic boys school. from which he graduated in 2006. He is currently enrolled in his freshman year at West Virginia University. Holly Signor. after spending the entire summer without seeing her father. ran away from home because of his drug use and fear of his violent reaction to her pregnancy. While Amanda Amaker and Tyler Signor remain in Randy's legal custody. they spend much of their time at his sister. Janice Signor's residence in Highspire. Pa. because there is often no adult supervision in the home and no food for the children. In reality. although Amanda is supposed to be at Janice's she actually is spending unsupervised time at her teenage friend's residence nearby. 3. CHANGE IN CUSTODY OR VISITATION NOTE: A change in custody will not be granted unless there has been a substantial change in circumstances since the last order was entered. Also, the requested change must be in the best interests of the children. See page 3 of the Instructions about "best interests." Do you want the custody or visitation order changed? (Check all that apply.) X Custody ---X- Visitation _ No change in custody or visitation Explain in detail what changes you want the court to order and why. [Attach extra pages if necessary.] I am urging the Court to grant my request for an immediate hearing to assess the living situation of my minor children. I wish the Court to hear from them the horror of their currently living situation under the custody of Randy Signor. Randy has repeatedly gone against the Court's order for custody and visitation and continues to do so. The children are anxious to speak to the Court on their own behalf and will give the Court a fIrst-hand account of how the situation has changed since the Court issued the original order. Specifically: Amanda. at age 16. is' in immediate danger and in a vulnerable position because of the company Randy habitually keeps. their questionable character. and their anti-social behavior. Amanda can attest to the fact that she is often in the company of adult males who either have active warrants. are on parole or probation. or who have spent time in jail for major offenses. Randy is not providing a supervisory role because he is rarely there - most nights he does not come home until 3 or 4 a.m.. disturbing her sleep with in appropriate and irrational rantings and ravings. Randy has also allowed known prostitutes to live at the farm until my sister found out and insisted that they be removed from the premises because of the negative impact on the children. Tyler's educational progress has also been hindered by this environment. In addition to the obvious social implications. his educational progress has been impacted by lack of parental involvement. Tyler exhibits behavior that is indicative of ADHD and is unable to perform educationally at the appropriate level. Ifhis needs continue to be ignored. and his education is not seen as a priority by a family where few. if any. members have gotten a high school diploma. I am afraid he will become increasingly discouraged to the point that he will stop trying and will be doomed to a life of underachievement or criminal behavior. These brief examples of changes in the custodial situation since the Court's original order are the basis for my request for a change in that order. The custodial parent has not met the Courts order to provide for the needs of the children. The children have been emotionally and physically neglected. Mr. Signor has been unable to provide for the basic needs of the children. often relYing on my family for monetary support in addition to the free living Quarters he has been supplied with since 2003. Had it not been for my sister. the children would not have had food. would not have had clothing. the electricity would have been turned off many times. the phone bill would have gone unpaid. and there would not have been any means of transportation. I ask that the Court S!rant me custody of the minor children and to modify the child support order as is appropriate (due to Mr.SiS!nor's emplovment status~ I am not seekinS! support at this time). If it also please the Court. I wish to request supervised visitation for Tyler SiS!nor with his father. I feel it would be detrimental and traumatic to sever the ties between father and son but because of the dangers inherent in the irrational behavior of substance abusers. I feel suoervision is necessary. I also request that the Court not order visitation between Amanda and Randv. Because of his past physical and emotional abuse. Amanda has expressed the desire to "never see him again". She is anxious to express her wishes directly to the Court and I suspect that there may be more abuse than she is ready to acknowledge. Notice to Parties: If there is a change in custody or visitation, the court is required to consider whether the child support order must also be changed. Travel Expenses. Travel expenses necessary to exercise visitation should be allocated between the parties as follows: 4. CHANGE IN CmLD SUPPORT NOTE: In order to obtain an increase or decrease in support payments because of a change in income of the person making the payments, the change in income must be both long term and significant. The court will not modify a support order because of a minor or temporary increase or decrease in income. The general guideline for determining whether a change in income is significant is if the change is enough to raise or lower the support payments by 15% or more. You must attach any documentation you have that supports your request. Examples include pay stubs, tax returns, and proof of social security or disability benefits. Do you want the support payments for the above children to be: increased decreased no change in support payments Check all of the following boxes that explain why you are requesting an increase or decrease. [Attach extra pages if necessary.] a. The income of the person making the child support payments has increased or decreased. (If you check this box, attach documentation of the increase or decrease and explain why it has occurred.) b. Support payments should be changed because there has been a change in where the children are living. (If you check this box, list the dates when the living arrangements changed, explain what the current living arrangements are, and attach any documents you have to support your claim. ) c. Support payments should be changed because there has been a change in the availability or cost of medical insurance for the children or because medical expenses for the children have increased or decreased. (If you check this box, attach all available documents that support the requested change.) , .. d. Other (Be specific and attach any supporting documents. ) Income Withholding. If your current support order in this case does not require immediate income withholding but CSSD is enforcing the order, the court will be required to order immediate income withholding in its modification order unless one of the three exceptions authorized by Alaska Statute 25.27.062(m) applies. For an explanation of those exceptions, see form DR-10, pages 13- 14 (available at the court). Is CSSD currently enforcing your support order Yes No If yes, is there a reason why the court should not order immediate income withholding? 5. REQUIRED ATTACHMENTS. Each of the items listed below MUST be attached to this motion. Check each box to indicate that you have completed and attached the item. A copy of your most recent child support order Child Custody Jurisdiction Affidavit (form DR-150) Child Support Guidelines Affidavit (form DR-305) Shared Custody Child Support Calculation (form DR-306) (required only if shared custody has been ordered or is being requested) or form DR-307 (for divided custody) or form DR-308 (for hybrid custody). All documentation needed to support your request for a change in custody, visitation or support. OATH OR AFFIRMATION NOTE : You must sign this in front of a notary. A court clerk can provide this notary service for you at no charge. Bring a photo ill with you for the notarization. I swear or affirm that the above statements and any attachments are true to the best of my knowledge and belief. Date Signature of Person Filing Motion Printed Name Subscribed and sworn to or affirmed before me at , Alaska on . Date Clerk of Court, Notary Public or other person authorized to administer oaths. (SEAL) My commission expires: [You must complete the Certificate of Service on the next page.] CERTIFICATE OF SERVICE [MUST BE COMPLETED] I certify that I served a copy of this motion and all the documents checked in paragraph 5 as shown below: On Other Parent (Instroctions: You must also send a Response Packet to the other parent.) I mailed (first class mail) hand delivered to the other parent a copy of (1) this motion and all documents checked in paragraph 5 and (2) a Response Packet. Name of Other Parent: Address: Date mailed or delivered: . .. On Other Parent's Attorney (Instructions: If the other parent was represented by an attorney within the last year, you must send the attorney a copy of this motion and all the documents checked in paragraph 5.) I mailed (first class mail) hand delivered to the attorney a copy of this motion and all the documents checked in paragraph 5. Name of Other Party's Attorney: Address: Date mailed or delivered: On the Child Support Services Division (Instructions: If the Child Support Services Division (CSSD) is enforcing this order, you must send a copy of this motion and all the documents checked in paragraph 5 to the Attorney General ~ Office.) I mailed (first class mail) hand delivered a copy of this motion and all the documents checked in paragraph 5 to: Attorney General's Office Collections and Support Section 1031 West Fourth Avenue, Suite 200 Anchorage, AK 99501 Date mailed or delivered: Signature of Person Filing Motion (~ ~ [g~+ l"-.J t..-::~ c::.._ Ci"' C) ("') ~, I U; () -;-, ::::! n-3'-1 :D i-- in U l.....i. ~~ t' -u ....:').., C" ..l. .. t- \1 OCT 0 6 2006 ~ r. - PLANTIFF MlJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOUISE (SIGNOR) FLEMING V. RANDY SIGNOR DEFENDANT 01-5352 CIVIL TERM ORDER OF COURT AND NOW, this 1/ .It day of () v~J..c.r- 2006, the petition to Proceed in forma pauperis byfiling a petition for modification of child custody has been; ,.... ~1V?t~ By the Court, fort. Louise (Signor) Fleming, Pro se - ~&h~. M. _ /J. 2312 Pennyroyal Terrace 7 '~ Baltimore, MD 21209 4;;L Randy E. Signor 455 Thundergust Mill Road. Wellsville, Pa 17365 (" I ..,., c. I 'v ,.\t:i\/1C,. "\1;;::1 P-j Illr.7"C-~Z _ "_ "".1 ) ~ IJ LOUISE (SIGNOR) FLEMING PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 01-5352 CIVIL ACTION LAW RANDY SIGNOR DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, October 13, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at MD~ Mllnlove, 190_~_State St., CampH!!!~__!,A 17011 on___}Vednesday, November 15, 2006 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Melissa P. Greevy, Esq. Custody Conciliator Mt/ 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 cOUli, 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 ~ -fz? -~ ~.#' ~/ .~;?~~. ~-P~ ~ ~ ~2?1V46c? -~ .;.-, . I (" I 'r 11.1 'I 1'-"0 C!rz '.... ..~J l'~',,' ~_ ~f,'.'" .;....L '/0' (/. 0/ ~o.U.o/ 7r7-LI- c7/ '\ 0" NOV 21 2006 LOUISE SIGNOR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5352 CIVIL TERM v. RANDY S. SIGNOR, CIVIL ACTION - LAW IN CUSTODY Defendant ORDER OF COURT AND NOW, this 15TH day of November, 2006, neither party having appeared for the Custody Conciliation Conference scheduled for this date at 8:30 a.m. by this Court's Order of October 13, 2006, the Motion to Change Custody, Support or Visitation filed by Louise Fleming, flk/a Louise Signor, is continued generally and will be reschedule in the normal course upon petition. J. Dist: .x;)uise Sophia Fleming, 2312 Pennyroyal Terrace, Baltimore, MD 21209 ~andy S. Signor, 455 Thundergust Mill Road, Wellsville, PA 17365 >- 0 ~ ~ ..:r wO ::::><1: 05 ~ 0.,.....- .,-)2; u-r.= -a::: -- <( " ~J :::J 6 ,- 60 CJ'\ ~5~ a:; N ~o.. :> ::c:z a:::LU 0 UJ LJ.J .j:!: Z OJ a.. u.. ... ~ c:::> :J 0 = 0 ~ LOUISE (SIGNOR) FLEMING, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5352 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY v. RANDY S. SIGNOR, Defendant 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 CURRENTL Y IN THE CUSTODY OF Tyler A. Signor Amanda L. Amaker December 29, 1996 Father December 15, 1989 Father 2. Mother filed a Motion to Change Custody, Support or Visitation on October 5, 2006. A Custody Conciliation Conference was scheduled in an Order dated October 13, 2006. The Conciliation was to convene on November 15, 2006 at 8:30 a.m. Neither parent attended the Conciliation. Neither parent requested a continuance or was otherwise in contact with the Conciliator's office regarding the Conference. It is also noted that the Pleading which Mother filed was not verified. 3. Inasmuch as neither party attended the Custody Conciliation Conference scheduled for November 15, 2006, Mother's Motion to Change Custody, Support or Visitation was continued generally. An Order to that effect is attached. 4. Approximately one hour after the scheduled conference time, the Petitioner appeared at the Conciliator's office expecting the Conference to go forward. She was directed that because of her failure to attend the Conference at the proper place and time, and because the Defendant had also failed to appear, it w e necessary to make a new filing with the Court in order to have the matter resched ed for c stody co ciliation. //11/0 t, Da e . / Melissa eel Greevy, Esquire Custody Conciliator :286983