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06-0790
STATE OF MARYLAND PRINCE GEORGE'S COUNTY, TO WIT: I HEREBY CERTIFY that the aforegoing are the originals (and Certified copies) of record and transcript of proceedings in the enclosed described case. I FURTHER CERTIFY that awe copy of the docket entries and a complete index is included. IN TESTIMONY WHEREOF, I have hereto set my hand and affixed the Seal of the Circuit Court for Prince George's County, Maryland, this day of 1 R- 3 L. CLERK OF THE CI C IT COURT i • STATEMENT OF COSTS Clerk's Costs Paid-----------------------------------$ 140.00 Clerk's Costs Due------------------------------------ -0- Plaintiff's Appearance Fees Paid------------------- -0- Plaintiff s Appearance Fees Due------------------- -0- Defendant's Appearance Fees Paid---------------- 10.00 Defendant's Appearance Fees Due----------------- -0- Maryland Legal Service Fees Paid----------------- 25.00 Maryland Legal Service Fees Due----------------- -0- Master's Fees Paid----------------------------------- -0- Master's Fees Due----------------------------------- -0- Total Paid $175.00 Total Due $-0- • CIRCUIT COURT FOR P(S COUNTY CASE NO.: vs CONFIDENTIAL INFORMATION THE DOCUMENTS CONTAINED IN THIS ENVELOPE ARE NOT PUBLIC INFORMATION. THIS ENVELOPE SHALL NOT BE OPENED, AND THE CONTENTS SHALL NOT BE ACCESSED, BY ANY PERSONS OTHER THAN THE COURT, EMPLOYEES OF THE COURT, THE PARTIES TO THIS CASE, OR COUNSEL FOR THE PARTIES TO THIS CASE. SEE ANNOTATED CODE OF MARYLAND, STATE GOVERNMENT ARTICLE, SECTION 10-617(1). ANY PERSON VIOLATING THE PROVISIONS OF THIS SECTION ARE SUBJECT TO CRIMINAL PENALTIES AS PROVIDED BY LAW. DOCUMENT DATE FILED Plaintiff/Petitioner's Financial Statement -S13) `t?c Defendant's Financial Statement Other: Circuit Court for 1 t 1 C, ` C e o r- 0 CT" D0MF.STTC CAST TNr0 7ZN1ATV0N vrn?,rT Plaintiff.• This Information Report must be completed and attached An the complaintfiled with the Clerk of Court unless your case it exempted from the requirement by the Chief Judge ofthe Court cfAppeals pursuant to Rule 1-1 IL A copy must be incktded for each defendant to be served. Defendant: You museJUe an Information Report as required by Rule 1-313(h). THIS INFORMATION REPORT CANNOT BE ACCEPTED AS AN ANSWER OR RESPONSE. FORM FILED BY: JJQ PLAINTIFF O DEFENDANT CASE NUMBER: ff tCwmm.n> CASENAMB:0I]r-i?-Ih, ?Dr'1r%?P.- v , PARTY'SNAME:_tSr- ?(V) PHONE:R611 ?i)i1`? e33_ ADDRESS: I'7 S C7? C'J'Q v'" "10 TP Y'Y PARTY'S ATTORNEY'S NAME: r=l-,v ^ -PHONE: ATTORNEY'S ADDRESS: D I am not represenbd b an attorney Cq DV `?`? - RELATED CASE PENDING? Yes 13 No If a Court and Case #(a), if knows l' Special Requirements? CI Interpreter/communication impairment Which language (Attach Form 1-332 if Accommodation orinterpreter Needed) Which dialect 0 ADA accommodation: ALTERNATIVE DISPUTE RESOLUTION INFORMATION is this case appropriate for referral to an ADR process under Md. Rule 17-101? (Check all that apply) A. Mediation In Yes G No C. Settlement Conference 13 Yes E3 No B. Arbitration C1 Yes ? No D. Neutral Evaluation 0 Yee 0 No IS THIS CASE CONTESTED? Yee 13 No If yea, which issues appear to be contested? M Ground for divorce m Child Custody D Visitation 0 Child Support 0 Alimony 0 Permanent 0 Rehabilitative O Use and possession of family home and property Marital property issues involving: Valuation of business O Pensions ? Bank ac countsARA's ? Real Property 0 Other: 0 Paternity 0 Adoptio n/termination o f parental rights ,0 Other: Request is made for. 0 Initial order f] Modification 0 Contempt 0 Absolute Divorce 0 Limited Divorce For non-custodyMsitation issues, do you intend to request: O Court-appointed expert (name field) D Mediation by a Court-sponsored settlement program D Initial conference wit the Court 13 Other: For custody/visitation issues, do you intend to request: D Mediation by a private mediator D Appointment of couusel to repre sent child (not just to O Evaluation by mental health professional waive psychiatric privilege) O Other Evaluation 0 A conference with the Court then; allegation sexual child? Page 1 of 2 Effective January t, 2003 (IL V - EASE NUMBER: NAME: PY' Wf (Clek m lem) TIME ESTIMATE FOR HEARING OTHER THAN A MERITS HEARING: --hours __ days rdmtim, 86 A&WO cayra.mm Page 2 of 2 -31-OS Db Effective January 1, 2003 ?O 0 0 Circuit Court for ?Iri car r . G Case No4{ 9DO.5V YC; o? City or County t ?jrt5?tn? ?Or?pcar= ?ll,r? ?SPrtnSef ? Name Q ` 4509 C(C>V¢_r- ?t\\TtY, vs. Street Address Apt. # (? ?f1 D c?01 L) i?rA 33)3 City State Zip Code Area Telephone Code Plaintiff Name Hso(A C.),oJcr- ?AM .Ter r. Street Address Apt.# t') -L-X= S- Mb QJ-W (34 80RAA33! City State Zip Code Area Telephone. Code I Defendant No. l Street Address pt.# City State Zip Code Area Telephone Code Defendant No. 2 COMPLAINT FOR CUSTODY I, t r,, C r (DOMREL4) n n1? t fl°n.e r- representing myself, state that: My name I am thezotheiiQfather or (Check One) Relationship or example, aunt, grandfather, guardian, etc - of the following minor child(ren): Nom-, St?rt ncnr? J ' L(D namegf child 2- V _ date of birth 40 r (a-aZ?' 9 9 nave of ' d date of birth YYLcwh ,- oZ-?S-a0 name of child U date of birth name of child date of birth name of child - date of birth name of child date of birth 2. `u 'Et ZS) )[ tC5@?+re- -f- is the Qnotherolrather or e en ant V (check onel Relationship of the child(ren). Defendant No. 2 is the ElnotherElfather of the child(ren). (check one) 3. The child(ren) live(s) at 1 9 50ci C wcaress with 0'V-1 rim i r? ?1(J r?tl?va? Name of pera6 4. The child(ren) have lived in the following places, with the persons indicated during the last five years: a0 Time Period Place Naarne(s)/Current Address of Person(s) with whom Child Lived q/11 oc 01-rv5?ir'Q- r1 /14?? ??/5C?`t C?GRr}?'?? gCWCl1i 9I1am3- ;UDS Page 1 of 3 DR 4 - Revised 9 Jan 2D04 'L 1 0 8. FOR I know of the following cases concerning the child(ren) (such as domestic violence (protective order), paternity, divorce of the child(ren)'s parents, custody, visitation, or juvenile court cases): Court Case No. Kind of Case Year Filed Results or Status (if you know) L cuiG ?BOS TemP?l 6`ec}iVe r?1 xf O C?nLCCI _ ?1?`°So-? Attach the most recent court order for the above-referenced court cases. I have been a party, witness, or otherwise involved in the following cases about custody of the child(ren): State Court Case No. Year Filed Results or Status (if you know) rn? C.f'?. .? CflDvo6 - -{cn,P c?.sla?r?,`ve.? Attach the most recent court order for the above-referenced court cases. I know of the following people, not parties to this case, who have physical custody of the child(ren) or claims to have custody of visitation rights with the child(ren): It is in the best interests of the child(ren) to in my custody because: Ix Ve }?ecn o rwA 7heln all that apply): Grant meole7oint physical custody of the child(ren). check Grant mesole/?joint legal custody of the child(ren). (check one) IL L Allow to visit with the child(ren). Nam Page 2 of 3 DR 4 - Revised 9 Jan 2004 t Allow E visit with the child(ren) on -' ?1 the following terms: ? A.c.- e h ais a to-frfG t e- u: YV,,i tTl??zU Siyb? ?im }-o a?ot?' iIA.rc ?n -r6 4n 6 4- trw r+i a ?ys? _ I h? fit. 11 (1 VA- kt c4tii lc?rcr? ?rc crv, r S ?A I ?iL ?.w cg? NP, I cti c. 6 ti K.L Sf p 3 red Jed no idiot 9--k, d-k way Id n ?c l Sh(,? Gt ?1pyh, yql .t ?,? xiwld Sp¢c ? hesp?j to (be vr-fhe, w n Cs CS hr, e bra Uihw+e; Order k `t, Lprr f-,*g r- to pay health insurance for child(ren). `n + i U A A Name( s) Order lir r to pay child support (attach Financial Name(s) Statement. Use Form Dom. Rel. 30 or Dom. Rel. 31). (State other requests relating to the Order any other appropriate relief. Orr?fr Its?t?jr^,nsa¢r. }o Qa?- S`Oc?J??.. S-1i?c?. Q,- 3? o S CCvte ' Date Signatur Page 3 of 3 DR 4 - Revised 9 Jan 2004 13 ?? r-Lm,,? LI Judge rime I M? s MARYLAND CIRCUIT COURT ? DISTRICT CO T OF MARYLAND FOR..... 0 ...?1?' .. JUDIG1AFr ?y Located at . ....1..? - c qns Q ........................... ? ? ..?. Q.Z ..... . "' ... (ZI..LJI]?'.... o .t..it2 ............ vs. (L i ......?C1L ....? ... .......... // TIPORARY PROTECTIVE ORDR E After the appearance of 3 Petitioner 13 Petitioner's Counsel ? Respondent 13 Respondent's Counsel, and in consideration the petition d en the Court manke's/?'?,e following findings; A. alr lea r ..... ..(p? rI.. - .Q} ...................... who is a Person(s) Eligible for Relied is: The current spouse of the Respondent El A former spouse of the Respondent C3 A cohabitant with the Respondent ? A person related to the Respondent by blood, marriage, or adoption .................................................................... ? A patent, stepparent, child or stepchild of the Respondent or a Person Eligible for Relte?'ws5%ides or resided with the Respondent or Person Eligible for Relief for at least 40 days within the past year. ? A vulnerable adult ? who has a child(ren) in common with the Responderr ................................................................... ner is: Nu?r oriwia,m ma,.?, B. a =0 Eligible for Relie£ In the case of vulnerable adult or or d ??A State's Atzomey ? A local department of social services A relative ?rrU?Qi? ? An adult residing in the home C. ? That the Respondent consents to the entry of a Temporary Protective Order O That them are reasonable grounds to believe that Respondent committed the following abuse(s): ? Caused serious bodily harm ? /ISlaced Person(s) Eligible for Relief in fear of imminent serious bodily harm L?SJf Assault in any degree Rape or a statutory sexual offense (or attempt) in any degree Q False Imprisonment ,<Statutory abuse of a child ( Physical D Sexual Mental) (Forward to DSS for investigation.) ? Statutory abuse of a vulnenti aM/?t (Forward to h S for in on.......s?. ... ? i?? aft------ --- fi r D. where an order to vacate the home is requested, the Respondent Wd the Person(s) Elifor lied f mp t9kether at the time of the abuse and: '^ Are married, or \ ? Are not married, butte ?Cl U ? The name of a Person Eligible for Relief is on the lease or deed. G ? A Petson Eligjbk for Rehefhas resided in the home with the Respondent for at least days ' the past yea ? In the case of abuse of a child or vulnerable adult, an adult other than the Respondent lives in the home. E. This Order is denied ? Because there is no statutory basis for relief. ? Other ..................................................................................................._... --.._..---. CC-DClDV 2(Rev. 1012004) Page I of4 0 d?U.:.IS1.. .......Date O.... G.. ?:.V Bas on the foregoing findings, the Court hereby ORDERS: ? f . .... I. That de tSHALLNOT buse,thr toapuse, d/orhams... A ..'.?(S .,,....? ...,1.......... .. ............. . 2. That the Respondentt? HA-I NOT contact (in p on N by telephpp%4.1 e, ' writing,pr t,Y any other ans), attempt ?..1 ..•1`t 1SCt. L ti. ,r?P! to comact.Lytl .l$T1rK f. _ }.. ..0?7.1 ' ' "' "G. ce of ..... ...................;'..Yl...............................?..1........ 3. That tie ?e SHALL OT" the residen ................................ at._??..t 1.2.?1et?.... 1..L?L........ (Residence includes yard, grounds, outbuildings, and cornet n areas surrounding the dwelling.) ? An undisclosed location for reasons of safety. ? 4. That the Respondent SHALL STAY AWAY from ? (1) School: .................................................................................................................................................... (2) School: ....................................................... ..................................................................................... ...... (3) School: ................... .............................................................................................................. ---- ....... ? An undisclosed school for reasons of safety. ? (1)Chrldcarcprovider ................................................................................................................................... at .................................................................................................................................................................. while ..................................................................................... is/am in the care of the cbildcare provider. (2) Childcare provider C/5 while .............................. ..................................... is/am in the care ofthe cbtldcme provider. ? An undisclosed childcare provider for reasons of safety. ? (1) Place of employment .............................................................................................................................. (2) Place of employment: ? An undisclosed place of employment for reasons of safety. ? (1) The temporary residence of ............................................... at ............................................. (2) The temporary residence of at ............................................................................................ ? An undisclosed temporary residence for reasons of safety. ? (1) The home of another family member (2) The home of another family member at ................ ? An undisclosed home of another family member for reasons of safety. That the Respondent SHALL VACATE the home immediately includes yard, ds, o' dm commop areas rmding the dwelling) at....1.... t. ... ? ?.J 4 4 . I .....1..GK.?r1 . .GJ..W0. . ...................................................................................................................................... and remain away until the hearing provided for below. (P h 7 and g date on extensio£order.) Temporary use and possession of the home is granted to. 1.$ i!4.......... ................. ........ ..................................................................................................................... .................................. e Respondent, accompanied by a law enforcement officer, may rerun to collect clothin and personal necessities, only between the hours of ...............'='.... and .......? .. ................... on .... ? ..Q.? .......... or as directed by local law enforcement Time Time CC-DC/DV 2(Rev. 10/2004) Page 2 of 4 . .... 6. That azdedto custody Of. ..... .....? .. 1 . r y? isaw. ,r.?.S. Ye ....... l.h . (. ..• ............................................. ..................... .. .......... until the hearing providedlor in Paragrap below ? Custody shall remain joint Iaw enforcement officers are ordered to use all easonable and necessary force to return the minor child(ren) to the cu todial pazent at t me of service or as soon as possible after entry of this Order. Z7THAT A FINAL PF40TEC IVE.0RDER HEARING SHALL BE HELD 0>1- AT.I...4 .../zJ7..Y.....Mhl!1 8. This order supFtsedes and overrides This Order is extended for not more than 30 days until: ................_ ................ ....... New Heng DW ........ .._..._........ ..... Judge ........................................ ....... New Neuu,g flue ................................ 1?dge ...... .......................... ....... New Heuiug Due ... ...................... Jud .. NOTICE TO RESPONDENT aUE COPY'- ........... .......:........ .... Dane ........... ... .............: I ......D.... A Petition for Protection alleges that you have committed abuse. On the basis of the Petition this Temporary Protective Order has been issued. Violation of this Order may be a state and/or federal crime or contempt of court, or both, and result in imprisonment or fine or both. This Order may be enforced by another state or jurisdiction, which may impose additional or different penalties for the violation. In order to respond to the allegation that abuse occurred, you must appear in court at the Final Protective Ordi hearing provided for in this Order. If at the hearing the court finds by clear and convincing evidence that abuse occurred, the court will issue a Final Protective Order against you, whether you appear or fail to appear, and may order all or part of the relief requested by the Petitioner or granted in this Order. This relief may include temporary use and possession of your home, use and possession of jointly owned vehicles, Emergency Family Maintenance, child visitation, surrender of f rearm(s) to a law enforcement agency, and counseling or participation in a domestic violence program. A Final Protective Order may be effective for as long as twelve (12) months, and the court for good cause may extend the term of the Final Protective Order for an additional six (6) months after a further heariul If you fail to appear in court and a Final Protective Order is issued against you, you will be served by first-class mail at your last known address with the Final Protective Order and all other notices concerning the Protective Order. The Final Protective Order will be valid and enforceable upon mailing. It is your responsibility to notify the court in writing of any change of address. CC-DC/DV 2(Rev. 10/2004) Page 3 of 4 .?.,. .s?.....?/J. .U.....DatS...?? O.. NOTICE TO ALL PARTIES Each party may be represented by an attorney. At the Final Protective Order hearing, the petitioner will be required to prove the alleged facts by "blear and convincing evidence." This is difficult to do if you do not have law raining. Each party should see a lawyer. If you are the petitioner and cannot get a private lawyer, there are support agencies that may be able to help you. Although each party is not required to have a lawyer at the hearing, all of the Rules of Evidence will apply to the case. If you choose not to have a lawyer with you on the hearing date the Petitioner will still have to prove the case by "clear and convincing evidence" and each party will have to comply with the Rules of Evidence. Due to the emergency nature of the hearing, the hearing may be held even if a party requests more time to obtain an attorney. At the Final Protective Order hearing the court may order the Respondent to pay Emergency Family Maintenance and may pass an immediate and continuing withholding order for that purpose. If this Emergency Family Maintenance is requested, both parties should complete a Financial Statement (CC-DC/DV4) before the Protective Order hearing and bring it to court. You should also bring documents (such as pay stabs, copy of your lease, bills, etc.) to support the figures you supply. TRUE COPY RTIFICATION OF TEMPORARY PROTECTIVE ORDER Attestation of Cier ? I 1..1: .. .11 . ...... ./. Clerk of this Court in . r..:.. a..... y/County, lan d o h ereby c e r t i f y ibaf I have compared this Order with the original Order which is on file in my State of Mary office, and that this Order is a true and correct copy of the original, and the whole thereof. In testim whereof I j pereunto set my hand aan?n`d'' affixed the of Court at ....../..)?`.'.:..Q- c 1.5..5 rS1......... day Attestation of Judge Ulm /, L ................................................................ Judge of this Court in.......................................... City/County, State of Maryland, do hereby certify that ............. _........................................................................................................ whose name is subscribed to the foregoing certificate of attestation, now is, and/or was at the time of signing and sealing the same, a Clerk of this Court in ........................................................................................... City/County and that his/her attestation is in due form of law. CC-DCDV 2(Rev. 10/2004) Page 4 of 4 CIRCUIT CAT FOR PRINCE GEAE'S COUNTY Clerk of the Circuit Court Courthouse Upper Marlboro, Md. 20772-9987 WRIT OF SUMMONS Case Number STATE OF MARYLAND, PRINCE GEORGE'S COUNTY, TO WIT: TO: Name Address County You are hereby summoned to file a written response by pleading or motion in this Court to the attached Complaint filed by -_-__- (Name and Address) within ---- _---------- days after service of this summons upon you. WITNESS the Chief Judge of the Seventh Judicial Circuit of Maryland. Date Issued --------- -- -- -- - - - -------- - - --{ --- CLERK b TO THE PERSON SUMMONED: 1. PERSONAL ATTENDANCE IN COURT ON THE DAY NAMED IS NOT REQ01REb , 2. FAILURE TO FILE A RESPONSE WITHIN THE TIME ALLOWED MAY RESULT IN A JUDG- MENT BY DEFAULT OR THE GRANTING OF THE RELIEF SOUGHT AGAINST YOU. SHERIFF'S RETURN FEE SHERIFF NOTE: 1. This summons is effective for service only if served within 60 days after the date it is issued. 2. Proof of service shall set out the name of the person served, date and the particular place and manner of service. If service is not made, please state the reasnns. 3. Return of served or unserved process shall be made promptly and in accordance with Rule 2-126. 4. If this summons is served by private process, process server shall file a separate affidavit as required by Rule 2-126(a). CV-1 Z? t. CIRCUIT COURT FOR COUNTY CASE N0.0-A'1) ' ,. ? (',.S n rtn? vs CONFIDENTIAL INFORMATION THE DOCUMENTS CONTAINED IN THIS ENVELOPE ARE NOT PUBLIC INFORMATION. THIS ENVELOPE SHALL NOT BE OPENED, AND THE CONTENTS SHALL NOT BE ACCESSED, BY ANY PERSONS OTHER THAN THE COURT, EMPLOYEES OF THE COURT, THE PARTIES TO THIS CASE, OR COUNSEL FOR THE PARTIES TO THIS CASE. SEE ANNOTATED CODE OF MARYLAND, STATE GOVERNMENT ARTICLE, SECTION 10-617(1). ANY PERSON VIOLATING THE PROVISIONS OF THIS SECTION ARE SUBJECT TO CRIMINAL PENALTIES AS PROVIDED BY LAW. DOCUMENT ? Plaintiff/Petitioner's Financial Statement Defendant's Financial Statement DATE FILED q. Lie. Other: Circuit Court for_ -Pro n ce Gl t* Case No. CA 5- l oadt? Clty or County C YT I ? ?I fIA ?? Y-S -f Name r o Name C'? bye f I t Y T r(' , vs. W ' ,? u c)i(4Y Street Address i Apt.# m? -7o1(J('l?tl Sul-3333 Street Address n ??5v? city State Zip Code Area Telephone City State Zip Code Code Plaintiff Defendant A FFIDAV IT OF SERVICE (Private Process) Area Telephone Code ?tlrwi FS (M REL 55j b LA, I certify that I served r c r - a. ptm. Na a of person served Time Is One) on _ , , at I q dr ss /lea: n Ufa e Gate Lit- Street Address State Zip Code a copy of the L r' (' i ?s <f o? w5ttimn? Sn Name of L pleadingsidocuments served which were previously filed with this Court. Attached is a copy of any summons ("process") issued by the Court, the original of which I served upon the person served. I certify that I am over eighteen (18) years of age and I am not the Plaintiff or the Defendant. I SOLEMNLY AFFIRM under the penalties of perjury that the contents of the foregoing paper are true to the best of my knowledge, information, and belief. Date Name of Server (signature) La Name of Server (printed or typed) ?q-?&Dq 4pas?? tev? U1 C? 13E? Street Address City State Zip Code of Server Area Code Telephone Number of Server Page 1 of 1 OR 55 - Revised 8 Nov 2000 4)? I s?-()5 - Vz6aU? Circuit Court II 11 uty or county C J1T1Y IAA __?Y7r._1"?IrOpai Name Cl Street Address Apt. # T State Zip Code Area Telephone Code Plaintiff Case No. CA x 4F,-19 JQ2 vs. f snc l . J,'Ag- r I U -re /V1 _ Street Address Apt.# ?n 1J. e rh,L? ly Stake Zip Code Area Telephone Code Defendant ,¢7evDE0 COMPLAINT FOR LIMITED DIVORCE (DOM REL 21) I, L b f i A, p.e , 3X7 r- t' r representing myself, state that: My ame_ 1. The Defendant and I were married on - o th Day Year in in a civil eli ious ceremony. City/Cou S t here Married (Girt 2. Check all that apply: C y- S{ I have lived in Maryland since: ?1P.lIJ?., l7xa c Q? MonthlYear /' /??y ? My spouse has lived in Maryland since:_1?)yL,m kAL2' Cly ) MonthlYear The grounds for divorce occurred in the State of Maryland. 3. Check one: ? We have no children together (skip paragraphs 5 and 6) or My spouse and I are the parents of the following child(ren): NOc1_k u / - X10 -?i(p c N Date B' Name Date 91 Birth Na Date of Birth Name - ' Date of Birth r a d, un Name Date of Binh Name Data of Birth 4. I know of the following related cases concerning the child(ren) or parties (such as domestic violence, paternity, divorce, custody, visitation, or juvenile court cases): Court Case No. Kind of Case Year Filed Results or Status (if you know) C L^c.wa I$plQ ?reF< Or?.e.^ o20J5 ?f`G p?lr? 5. The child(ren) are currently living with C h r) <i)45? 'SIJr 1n 4-- 'Name -I-' 6. It i n the best interests of the child(ren) that I have (check all that applv): joint sole circle one) physical custody of tVbj-l, I a a.mea Idren ? 1hs fc "?Ofln, .? `\ ?(S J joint sole(circle one) legal custody of ? k Imo" t, M,? h y yea n? Name of Children T ?T 71 visitation with f ,t ldlllu Ul VI111U.C', ` \ / 7. I am am not (circle one) seeking alimony because .Zhuuv_??, (> (,?, ram , v vC/ ?_ - -`--(}_. C h,,Wrcn rn+ ?trhQt S )x%cl rS Is "t W-016-? t?uc.rwge`Y6f2;. "F, v??.?? OR 2P?FhvtSkd?t ov 1y{wr< Colic- a E1w1 vn e_ c T a hS ?V w?_ u e .? b to ?Vri?_ aiE_1wa3pc.;?,wM.-?ctd.„ctd?z,,, Tnvl,.vuD` `q cS'....t. oritcaT? armostbt-dl.?f;.,., ?'o Y<-..P h"+- J- A 1 8. (You do not have to complete paragraph 8 if you are not asking the court to make decisions about your property.) My spouse and/or I have the following property (check all that apply): .01 Motor Vehicle(s) Bank account(s) and investment(s) Furniture Other: msniLYM-L1?14? 9. My grounds for limited divorce are: (Check all that apply) Cruelty/Excessively Vicious Conduct Against Me - My spouse has persistently treated me cruelly and has engaged in excessively vicious conduct rendering continuation of the marital relationship impossible if I am to preserve my health, safety, and self-respect. X Cruelty/ Excessively Vicious Conduct Against My Children - My spouse has persistently treated my minor child(ren) cruelly and has engaged in excessively vicious conduct against them rendering continuation of the marital relationship impossible if I am to preserve my minor child(ren)'s health, safety, and self-respect. ? Actual Desertion - On or about , my spouse, without just cause or reason, Month/Dayffear abandoned and deserted me, with the intention of ending our marriage. This abandonment has continued without interruption up to and including the time of filing of this complaint. Constructive Desertion - I left my spouse because his/her cruel and vicious conduct made the continuation of our marriage impossible, if I were to preserve my health, safety, and self- respect. This conduct was the final and deliberate act of my spouse and our separation has continued without interruption up to and including the time of the filing of this complaint. ? Voluntary Separation - From on or about my spouse and I by mutual Month/DaylYear and voluntary agreement have lived separate and apart from one another in separate residences, without interruption, without sexual intercourse, with the express purpose and intent of ending our marriage, and there is no reasonable expectation that we will reconcile. FOR THESE REASONS, I request (check all that apply): 91 A Limited Divorce. J9 Sole `oint (circle one) physical custody of the minor child(ren). Mtr o joint (circle one) legal custody of the minor child(ren). ? Visitation with the minor child(ren). Child support (attach Form DOM REL 30 or DOM REL 31). Health insurance for the child(ren). Health insurance for me. ? Use & possession of the family home for up to three years from the date of the limited divorce. Use & possession of the family use personal property for up to three years from the date of the limited divorce. Alimony (attach Form Dom.Rel.31). Resolution of personal property issues. Any other appropriate relief. date c ?? Signat re Page 2 or 2 DR 21 - Revised 21 Nov 2000 0 a Aau IN THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLAND CHRISTINE SPRINGER, Plaintiff, VS. KURT C. SPRINGER, Defendant Case No.: CAD05-18208 LINE Madam Clerk: E3 o o CD CD C A 0% Please enter the appearance of the undersigned as counsel of record for Defendant, Kurt C. Springer. Enclosed with this filing is the $10.00 fee. RESPECTFULLY S 1 4a' Lisa Merchant Oct _s The Law Office of Lisa Merchant 14300 Gallant Fox Lane, Suite 103 Bowie, Maryland 20715 (301) 464-3900 Counsel for Defendant CERTIFICATE OF SERVICE / .., ? 3u'4 rw: err. I HEREBY CERTIFY that a copy of the foregoing was mailed, postage prepaid, this 1 " day of October, 2005, to: Perry Becker, Esquire 14300 Gallant Fox Lane, Suite 218 Bowie, Maryland 20715 Ol, ? Lisa Merchant Leg)) IN THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLANII, CHRISTINE SPRINGER, Plaintiff, VS. KURT C. SPRINGER, Defendant m Case No.: CAD05-18208 C- O a ) ) J ANSWER TO COMPLAINT FOR CUSTODY AND COUNTER-COMPLAINT NOW COMES Kurt Springer, Defendant in the above entitled matter, by and through his undersigned counsel of record, Lisa Merchant, who answers Plaintiff's Complaint for custody and in support thereof, respectfully states: 00 nm r ? O O C CD 1. The allegations in Paragraph 1 are admitted. 2. The allegations in Paragraph 2 are admitted. 3. The allegations in Paragraph 3 are denied The Plaintiff, without notice, removed the children and all belongings from the family home on or about August 30, 2005 and left the family home empty. 4. The allegations in Paragraph 4 are partially admitted in the children of the parties did live in Bowie Maryland from September 1, 2003 through August 30, 2005. Defendant neither admits nor denies the residence of the children from November 1, 2000 through September 1, 2003. Defendant denies that a Temporary Protective Order was granted on September 6, 2005. A Final Protective Order was granted; however, the Order did not prevent Defendant from having contact with Plaintiff. He was ordered not to harass Plaintiff and was granted reasonable rights of visitation with the minor children. 1- 4 6. The allegations in Paragraph 6 are admitted. The allegations in Paragraph 7 are admitted. 8. The allegations of Paragraph 8 are denied in their entirety. The parties have both been the caregivers to the minor children and Plaintiff. Defendant has never verbally, mentally or physically abused his minor children. Defendant uses practical approaches to reasoning with and disciplining the children. Plaintiff engages in useless banter and humiliation of Defendant which likely will affect the children in the future. WHEREFORE, Defendant respectfully requests that this Court: A. Deny Plaintiff s Complaint for sole physical custody of the minor children; B. Deny Plaintiffs Complaint for sole legal custody of the minor children; C. Deny Plaintiff s request for a psychiatric evaluation on the basis that she cannot prove abuse; D. Deny Plaintiffs request for family vehicle which is not the basis of a custody proceeding; E. Deny Plaintiff s request for spousal support as this is not a divorce proceeding; F. Deny Plaintiffs request for child support for the reasons that she has not filed a financial statement; G. Grant Defendant shared physical and joint legal custody of the minor children; H. And such other and further relief as the nature of his cause may require. -2- IN THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLAND CHRISTINE SPRINGER, ) Case No.: CAD05-18208 Plaintiff, ) vs. ) KURT C. SPRINGER, ) Defendant ) oO COUNTER-COMPLAINT FOR CUSTODY ? C3 N n C-) h Defendant/Counter-Plaintiff, Kurt Spinger, by and through his counsel, int, Lisa gerc _ C: D7 files this action for Custody and respectfully states: =+ c ED v Defendant/Counter-Plaintiff is the father of three minor children, Noah Springer, born January 20, 1996, Leah Springer, born December 28, 1997 and Micah Springer, born February 25, 2000. 2_ Counter-Defendant/Plaintiff, Christine Springer is the mother of the before referenced minor children. 3. Counter-Plaintiff/Defendant resides at 14509 Clover Hill Terrace, Bowie, Maryland 20720 while Plaintiff and minor children's residence is currently outside the state in Pennsylvania. 4. Counter-Plaintiff/Defendant is a fit and proper person to have custody of the minor children as he is fully capable of managing a household, feeding the children, preparing them for school, helping with their homework, spending quality time with them, giving them a stable Christian upbringing and assigning their chores. Vo) 5. Counter-Defendant/Plaintiff has taken all necessary steps to prevent Defendant from having strong valuable relationship with his children by removing them from the family home and giving him limited access to them. 6. Counter-Plaintiff/Defendant is a loving and supporting father who adores his minor children. 7. Counter-Defendant/Plaintiff has taken the minor children of the parties out of the state of Maryland to Pennsylvania without the consent of Counter- Plaintiff/Defendant. Counter-Plaintiff/Defendant has received information from the minor children that they are being emotionally and physically abused as a result of this departure from the family home in Bowie, Maryland. Specifically, his minor children advise that Counter-Defendant/Plaintiff has slapped the minor child, Leah Springer and insulted the minor child Noah regarding his abilities to do long-division Math in the presence of the other minor children. 9. Counter-Plaintiff/Defendant believes the minor children are not being schooled as they were in the past because Counter-Defendant/Plaintiff is unemployed and needs to find employment to support herself and the minor children if they are to remain in her care temporarily or permanently (as the case may be). 10. The minor children were previously home-schooled by Counter-Defendant/Plaintiff but are not being home-schooled at this time. Counter-Plaintiff/Defendant further believes that Counter-Defendant/Plaintiff is not fit to be a home-school teacher and thus, should either return the minor children to Maryland with their father so that he -5- 0 f _ IN THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLAND CHRISTINE SPRINGER Plaintiff CaseNo.CAD05-18208 KURT C. SPRINGER Defendant ANSWER TO COUNTER-COMPLAINT FOR CUSTODY .. COMES NOW the Plaintiff> Christine Springer, by and through her attor c?ey ferry:.., _ Becker, and in Answer to the Counter-Complaint for Custody states to the Court Wfo}tkws 1. The Plaintiff admits the allegations contained in paragraphs 1, 2 and 3- _- 2. The Plaintiff denies the allegations contained in paragraphs 4, 5, 6, 7, 8, 9, 10, 11, 12 and 13 WHEREFORE, the Plaintiff prays: 1. That the Defendant's Counter Complaint for Custody be denied. 2. That the Defendant be ordered to pay Plaintiff s counsel fees for defending this action. 3. And for such other and further relief as this cause may require. I%JT Perry Becker 14300 Gallant Fox Lane, Ste. 218 Bowie, MD 20715 (301) 262-6000 Christine Springer 6\1-- i LJ CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing was mailed, via first-class mail, postage prepaid, this L L!T 'day of October, 2005, to: Lisa Merchant The Law Office of Lisa Merchant 14300 Gallant Fox Lane, Ste. 103 Bowie, MD 20715 Perry Becker QR? Vol, oN 1 PERRY BECKER, ESQ. 14300 GALLANT FOX LANE, STE 218 BOWIE , MD 20715 0 IN THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLAND CHRISTINE SPRINGER Plaintiff I. : Case No. CADO5-18208 KURT C. SPRINGER Defendant MOTION FOR REMOVAL AND TRANSFER OF PROCEEDINGS COMES NOW, the Plaintiff, Christine Springer, by and through her attorney, Perry Becker, and seeks removal of this case and a transfer of the proceedings to a more appropriate g i venue and for reasons state as follows: ?g 00 m g 0 1. That the Plaintiff, Christine Springer, who has custody of the minor children, e currently resides with the minor children in the State of Pennsylvania. Y 0 0 00 ro v 2. That the Defendant, Kurt Springer, has recently relocated to the State of _ m ?I Pennsylvania also. 3 I 3. That neither party, nor the minor children involved in this case, reside within the State of Maryland and lack any and all substantial or significant contacts with the State of I Maryland. 4. That pursuant to Section 9-207 of the Family Law Article, this Court "may decline to exercise its jurisdiction at any time if it determines that it is an inconvenient forum under the circumstances and that a Court of another state is a more appropriate fonml." That the Court of Common Pleas for Cumberland County, Pennsylvania is now a more appropriate forum for the exercise of jurisdiction in this case. s 6. That a Triple Seal Copy of the this Order is requested to be sent to the Court of Common Pleas for Cumberland County, Pennsylvania for recording. 7. That the Defendant, Kurt Springer, consents to this Motion. WHEREFORE, the Plaintiff prays that this Court: I .Determine that it is an inconvenient forum in this case due to the parties and children having moved to the State of Pennsylvania; and Recognize and determine that the Court of Common Pleas for Cumberland County, Pennsylvania as the more appropriate forum in this case; and 4. Grant this Motion for Removal and Transfer of this case; 5. And for such other and further relief as to this Honorable Court may deem just and proper. Perry BAer 14300 Gallant Fox Lane, Ste. 218 Bowie, MD 20715 (301) 262-6000 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing was mailed, via first-class mail, postage prepaid, this _k day of December 2005, to: Lisa Merchant The Law Office of Lisa Merchant 14300 Gallant Fox Lane, Ste. 103 Bowie, MD 20715 Perry Beck r I IN THE CIRCUIT ORT FOR PRINCE GEORGE'S CT",- FAMILY V, MARYLAND i DIVISION CASE DISPOSITION/DAIHEET n CASE NO: (.1-t U 1 HEARING DATE: PLAINTIFF PRESENT: DEFENDANT PRESENT: GAL: Name: OTHER: SCHEDULED EVENT: CONF-ADR CONF-Pretrial CONF-Scheduling CONF-Settlement CONF-Status ISSUES: HRG-Bail/Bond HRG-Contempt HRG-ExParte HRG-Exceptions HRG-Master's Merits ALIMONY CONTEMPT ANNULMENT CUSTODY CHANGE OF NAME-Adult DIVORCE-Absolute CHANGE OF NAME-Minor DIVORCE-Limited CHILD SUPPORT EWO VISITATION OTHER: ACTION: RELIEF DENIED(DEND) DISCHARGED (DISC) DISMISSED (DISM) RELIEF GRANTED (GRTD) HELD (HELD) NON EST (MOOT) RE-ISSUE SCO (REIS) BODY ATTACHMENT (WRIT) L /D Z7L,?c??- DAY: COUNSEL PRESENT: Yes/(q Name: COUNSEL PRESENT: Yes?q Name: PRESENT -NOT PR HRG-Motions HRG-Pendente Lite HRG-Post Jdgmt HRG-Pre-Trial HRG-Review EMANCIPATION EMERGENCY EVAL EXCEPTIONS FAMILY Leg/Med PATERNITY HRG-Scheduling TRIAL HRG-Settlement HRG-Show Cause HRG-Uncont. Div. HRG/TRIAL-Remand PENSION DIST PROPERTY DIST REG FOREIGN ORD RESTORE FORMER NAME USE & POSSESSION NOT SETTLED (NSET) CONTINUED (CONT) SETTLED/TBH FD JD (PJST) POSTPONED (must check reason) PTLY SETTLED/TBH MSTR (PMST) CONSOLIDATED (w/case SETTLED (SETT) MERGED PltPs/DePs Counsel to Submit MOOT Court Completed UNDER ADVISEMENT (UNDR) OUT OF ASSIGNMENT (OUTA) REASON: oh D ??li /??? DURATION: 10 MINUTES (M) 1-1/2 FIR (S) 5 R (F) 30 MINUTES OR LESS (N) 2 HR HR (G) ) OTHER:' (O) 1 FIR (Q) TRACK NUMBER V o TRACK 0 (SCH'G CONE PENDING) TRACKV (PATERNITY) TRACK I (UNCONTESTED MASTER) C1 T CK VI (TPR - CONTESTED) TRACK II (CONTESTED MASTER) 1 ?K VIT (MODIFICATION) TRACK III (CONTESTED CUSTODY/VISITATION) yHC ° ARACK IX (STAY-MILITARY, BANKRUPTCY,ETC TRACK IV (CONTESTED JUDGE) EgK of ??pR?S ?p W/6 MTH REVIEW HRG) PARTY/WITNESS UNAVAIL./FTA (650) BY CONSENT OF PARTIES (651) FOR SETTLEMENT (652) MORE TIME NEEDED (657) REFERRALS NOT COMPLETED (659) COUNSEL UNAVAILABLE (660) NEXT SCHEDULED EVENT: 1) NEXT SCHEDULED EVENT: DURATION: ISSUES 2) NEXT SCHEDULED EVENT: DURATION: ISSUES 3) NEXT SCHEDULED EVENT: DURATION: ISSUES: BEFORE: JUDGE MASTER DATE: TIME: BEFORE: JUDGE MASTER GRANT INFORMATION (FOR OCSE CASES ONLY) (Check all that apply): PATERNITY ESTABLISHMENT CHILD SUPPORT MODIFICATION CHILD SUPPORT ESTABLISHMENT CHILD SUPPORT CONTEMPT/COMPLIA J NO Form #: FDDS- Rev. 11/05 Page 1 of 2 T REPRESENTED: DATE: DATE: QR?NCE E?BTAIN COUNSEL (655) SETTLEMENT REACHED (656) _ SCH'G CONE-1sT REQUEST (661) _ FILE SUPPLEMENTAL PLEADINGS (658) SOLIDERS&SAILOR'S RELIEF ACT (662) COURT CLOSING/UNSCHEDULED (999) PARTY FAILED TO PROD NECESSARY EVID (653) REQUEST FOR DNA (300) INTERPRETER (663) OTHER (654) TIME: BEFORE: JUDGE MASTER TIME: -7? I •- r IN THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLAND CHRISTINE SPRINGER Plaintiff V. CAD05-18208 KURT C. SPRINGER Defendant ORDER OF COURT Upon consideration of the Plaintiff's Motion for Removal and Transfer, the Defendant's failure to respond thereto, and the Record herein, it is this _16y of January, 2006, by the Circuit Court for Prince George's County, Maryland, ORDERED, that the Plaintiff's Motion for Removal and Transfer, pursuant to Md. Code Ann., Family Law Article § 9.5-207, be and is hereby GRANTED; and it is further, ORDERED, that the above-captioned case is hereby transferred to the Court of Common Pleas for Cumberland County, Pennsylvania; and it is further, ORDERED, that the Plaintiff is to pay the transfer fee to the Clerk of the Court in the amount of Sixty Dollars (560.00) within thirty (30) days and this case is closed statistically. William D. Miss Administrative Judge Seventh Judicial Circuit 1 i. ? COPIES MAILED BY THE COURT TO: Perry Becker, Esquire Walsh, Becker, Spears & Moody 14300 Gallant Fox Lane, Suite 218 Bowie, Maryland 20715 Lisa Merchant, Esquire The Law Office of Lisa Merchant 14300 Gallant Fox Lane, Suite 103 Bowie, Maryland 20715 Donald P da Date Law Clerk to the Honorable William D. Missouri {?Y S QSjG t ?pN $ e s 9 0 (DOCK) DATE PRINTED: 01/06/06 CASE STATUS: COMPLETED IN THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLAND ------------------------------------------------------------- ************* * CASE ASSIGNED TO JUDGE ************* SPRINGER VS SPRINGER PARTIES: SPRINGER, CHRISTINE SPRINGER, KURT CASE TYPE: CUSTODY COUNSEL: MERCHANT, LISA CASE NO: CAD05-18208 PARTY TYPE: COUNTER CLAIM: PRO SE - PLAINTIFF DEFENDANT FILING DATE: 08/31/05 REPRESENTING: LAST APPR: DEFENDANT S C H E D U L E D D A T E S v u DATE PRINTED: 01/06/06 CASE NO: CAD05-18208 D 0 C K E T I N F O R M A T I O N DATE: NUMBER: DOCKET ENTRY: 08/31/05 001 (058) COMPLAINT FOR CUSTODY,ATTACHMENTS,AND PLE'S FINANCIAL STATEMENT,FILED.ACR 08/31/05 002 (058) PLAINTIFF'S INFORMATION SHEET, FILED. ACR 08/31/05 003 (058) SUMMONS ISSUED FOR DEF. ACR 09/06/05 004 (052) AMENDED COMPLAINT FOR LIMITED DIVORCE W/FINANCIAL 09/06/05 005 (052) AFFIDAVIT OF SERVICE,FD DHC 09/06/05 006 (052) PER PLA CHANGE OF ADDRESS TO PUT IN SYSTEM,FD DHC 10/05/05 007 (052) SUMMONS ISSUED FOR DEF. DHC 10/11/05 008 (052) LINE ENTERING OF APPEARANCE OF L.MERCHANT,FD DHC 10/11/05 009 (052) DEFENDANT'S ANSWER FILED. DHC 10/11/05 010 (052) COUNTER COMPLAINT FOR CUSTODY,FD DHC 10/21/05 011 (052) ANWSER TO COUNTER COMPLAINT FOR CUSTODY,FD DHC 11/18/05 012 (69 ) ORDER AND NOTICE OF HEARING, FD./MLK 12/07/05 013 (052) MOTION FOR REMOVAL AND TRANSFER OF PROCEEDINGS,FD DHC 01/05/06 014 (41 ) DAILY DISPOSITION SHEET FILED. (QS) 01106106 015 (41 ) ORDER OF COURT DATED 01/04/06, JUDGE MISSOURI, ORDERED, THAT THE PLAINTIFF'S MOTION FOR REMOVAL AND TRANSFER, IS HEREBY GRANTED; ORDERED, THE ABOVE CASE IS HEREBY TRANSFERRED TO THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA; AND THIS CASE IS CLOSED STATISTICALLY. FD. CC MAILED TO P. BECKER, ESQ. & L. MERCCHANT, ESQ. (QS) DATE PRINTED: 01/06/06 CASE NO: CAD05-18208 (END OF DOCKET ENTRIES) o MARK A. MATEYA ATTORNEY AT LAW, P.C. P.O. Box 127 Boiling Springs, Pa 17007 - `' Phone: 717-241-6500 Fax717-241-3099 January 20, 2006 Clerk of Court of a l `' Prince George's County MD 14735 Main Street C W ` _ Upper Marlboro MD 20772 `•? _ i' Re: Springer Y. Springer CAD05-18208 To Whom It May Concern, I have been retained by the Plaintiff in the above-referenced matter. An Order dated January 4, 2006, has been entered in the present matter transferring the above-referenced case to Cumberland County, Pennsylvania. I am enclosing herewith a copy of the Orderr' E2, 88 convenience. Additionally, I enclose a check in the amount of $60.00 for the tr e 60.00 completed filed should be transferred to the Prothonotary of Cumberland County,T ia, 60.E at the following address: Re t kFR 1 650 f,?F B11: 4 L4a3 Curtis R. Long Jan 1'1:41 P® Cumberland County Prothonotary One Courthouse Square Carlisle PA 17013-3387 Thank you for your immediate attention in this regard. If you are in need of additional information or have any questions, please feel free to contact me. I may be reached at (717) 241- 6500 or by e-mail at mmateyakverizonmail.com. Sincerely, Mark A. Mateya, Esq. MAMIaa Enclosure Leave a Legacy 1W • D IN THE CIRCUIT COURT FOR PRINCE GEORGE'S C:ND, pMARYLANID Y CHRISTINE SPRINGER Plaintiff V. KURT C. SPRINGER Defendant CAD05-18208 ORDER OF COURT Upon consideration of the Plaintiff's Motion for Removal and Transfer, the Defendant's failure to respond thereto, and the Record herein, it is this iy of January, 2006, by the Circuit Court for Prince George's County, Maryland, ORDERED, that the Plaintiff's Motion for Removal and Transfer, pursuant to Md. Code. Ann., gamily Law Article § 9.5-207, be and iq hereby GRANTED; and it is further. ORDERED, that the above-captioned case is hereby transferred to the Court of Common Pleas for Cumberland County, Pennsylvania; and it is further, ORDERED, that the Plaintiff is to pay the transfer fee to the Clerk of the Court in the amount of Sixty Dollars ($60.00) within thirty (30) days and this case is closed statistically. William D. Miss Administrative Judge Seventh hidicial Circuit EXHIBIT 11 E- I S21V3dS`83A039'HS1VM EMIPZ9ZTOE VE:bT 900Z/90/10 IN THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLAND CHRISTINE SPRINGER Plaintiff V. CAD05-18208 KURT C. SPRINGER Defendant ORDER OF COURT Upon consideration of the Plaintiff's Motion for Removal and Transfer, the Defendant's failure to respond thereto, and the Record herein, it is this y of Jar. p_,:;W -icy the Circuit Court for Prince George's County, Maryland, L,ts r s }" r-. ORDERED, that the Plaintiffs Motion for Removal and Transf ,'?dis t_ t t8`? & i r r Ann., Family Law Article § 9.5-207, be and is hereby GRANTED; and it is Krtter, ORDERED, that the above-captioned case is hereby transferred to the Court of Common Pleas for Cumberland County, Pennsylvania; and it is further, ORDERED, that the Plaintiff is to pay the transfer fee to the Clerk of the Court in the amount of Sixty Dollars ($60.00) within thirty (30) days and this case is closed statistically. William D. Miss Administrative Judge Seventh Judicial Circuit ? r7 f? ,y _- u. -? I-'^?-I ?_?_ -L T .i _.. ?.J .?: c .r. ... i i ? ' C7 Q ? ? ?? =s -a Vv '? .? `?] _ C??'? -C 4?1 ?? i? ?_ ?@ _ c9 -.-? r ? t? ?l} `- CHRISTINE SPRINGER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. . NO. : CIVIL ACTION - LAW KURT C. SPRINGER, . Defendant :CUSTODY PETITION TO MODIFY CUSTODY NOW COMES, Plaintiff[Petitioner, Christine Springer, (hereinafter referred to as Petitioner), by and through her counsel, Mark A. Mateya, Esquire and avers the following: 1. Petitioner herein is Christine Springer, presently residing at 110 S. 27' Street, Camp Hill, Cumberland County, Pennsylvania, and is the natural mother of the minor children, namely Noah Springer, born January 20, 1996, age9, Leah Springer, born December 28, 1997, age 7 and Micah Springer, born February 25, 2000, age 5. 2. Defendant/Respondent herein is Kurt C. Springer, presently residing at 3016 Dickinson Avenue, Camp Hill, Cumberland County, Pennsylvania, and is the natural father of the minor children, namely Noah Springer, born January 20, 1996, age9, Leah Springer, born December 28, 1997, age 7 and Micah Springer, born February 25, 2000, age 5. 3. The parties herein are the parents of the following minor children: Name Present Address Age DOB Noah Springer 110 S. 27"` Street 9 1/ 20/1996 Camp Hill, PA Lea Springer 110 S. 27"' Street 7 12/28/1997 Camp Hill, PA Micah Springer 110 S. 27"' Street 5 2/25/2000 Camp Hill, PA 4. A Complaint in custody was initiated in Prince George's County, Maryland on August 31, 2005. See Exhibit "A" attached hereto and incorporated herein. 5. Defendant filed an Answer to the Complaint for Custody and Counter-Complaint on or about October 7, 2005. See Exhibit "B" attached hereto and incorporated herein by reference. 6. Plaintiff filed an Answer to the Counter-Complaint for Custody on or about October 21, 2005. See Exhibit "C" attached hereto and incorporated herein. 7. A Protection From Abuse Order was filed against Defendant on August 29, 2005. See Exhibit "D" attached hereto and incorporated herein by reference. 8. From the time of the pleadings filed to the present, Plaintiff with her Children and Defendant have relocated to the Commonwealth of Pennsylvania. 9. On or about December 5, 2005, a Motion was filed to relinquish jurisdiction in the Circuit Court for Prince George's County, Maryland, relinquishing jurisdiction from Prince George's County, Maryland to Cumberland County, Pennsylvania, Maryland Case No. CAD05- 18208. See Exhibit "E" attached hereto and incorporated herein by reference. 10. The Children are presently in the custody of Plaintiff, pursuant to the Protection From Abuse Order. See Exhibit "D" attached hereto and incorporated herein by reference. 11. The Children have resided for the previous five (5) years with the following individuals at the following addresses: Date Address With Whom 9/05 - Present 110 S. 27`h Street Christine Springer Camp Hill, PA 9/03 - 9/05 14509 Clover Hill Terrace Christine Springer Bowie, MD 20720 Kurt C. Springer 11/00 - 9/03 2315 Boas Street Christine Springer Harrisburg, PA 17103 12. Plaintiff has been the primary care giver to the Children since birth until the present. 13. The Children have resided with Plaintiff since Plaintiff's relocation to Pennsylvania in September, 2005. WHEREFORE, Petitioner requests this Honorable Court enter an Order as follows: 1. Grant temporary full custody of the Children to Plaintiff pending a custody conciliation; 2. Order the appointment of a Custody Conciliator at the earliest possible convenience. Respectfully submitted, Mark A. Mateya, quire Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 Date: z I0 ?D VERIFICATION I, Christine Springer, verify that the statements made in this Petition to Modify Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann. § 4904 relating to unworn falsification to authorities. Christine Springer Date: 1 - 9 " (-) Lo' Circuit Court for ri r? Dry«De? ?e..5x?? Case lvflyQS" LYr? 1 T1lArk r'In r,.e e- - Name Name Z 1450y Uove.r ?A& TpM, vs. P-{504 1 1 C, 0Je-r, 1 1 Y i?1 1Crf Street Address ? Apta street Addn" " - AptN Y>? i?- m D ?7? (?dt, ?t ? ?rs: t? ? 137 D X7 r3?iLf?1?,? city State Zip Code Telephone Chy state CAred% Sip Code C ea Telephone e tle Plaintiff Defendant No. T I, h r` t7srf lro- P r-i n5..e r-- representing myself, state that: My a,amee .r 1. I am the?ftothei0father or ' iC odt Otrel on tp or exempla aunt, gran a r, g raA, etc of the following mirror child(ren): street Address Aptd Ciry state Zip Coda ? qa Telephone Defendant No. 2 e COMPLAINT FOR CUSTODY' C (DOM IIEL 4) otter-1 '(Jr- ?'1Car?D` _(p name ;Id dato ol6nth e ?= la-ate n e of d date of birth YYltc r- ,?'-a6-oo name otchll date of birth mme el child date of bi0h name of child dale of birth name of child data of birth 2 x i.%- l.r e._5 G? l n.4 aC ig thel txt otherL?ytather or -Veen anT-"'?" icheckone? a ans p of the child(ren). Defendant No. 2 is the QmotherEfather of the child(ren). Iehesa nnT 3. The child(ren)live(s)at 1y509 c?oge,f- i? 1tr(??? Cf11?r Address with Lh r 1 k-i neL f it ma of pe 4. The ohild(ren) have lived in the following places, with the persons indicated during the last five years: 9'ime Period Place Namefs HCurrent Address of Person(s) With Whdm CAlld t.lved 4bom- e bon NCR Onrfs?;ca. z +r?cna it I dScPI clcx- la:(l B d, 9?ILa w3_ z05f?D I' is' s 6/lQ l TT/10 39ad DR4 RDY=,10Jan2004 saa3ds`a3??3a` E0VVZ9ZT0E LEST 900Z/9T/ZT S. I know of the following cases concerning the child(ren) (such as domestic violence (protective order), paternity, divorce of the child(ren)'s parents, custody, visitation, or juvenile court cases): Court Case No. Kind of Cane Year Filed Results or Status (If von know) L Uc G C'ppDJ05" Attach the most recent court order for the above-referenced court cases. 6. 1 have been a party, witness, or otherwise involved in the following cases about custody of the child(ren): State ourt Case o. Year Filed Results or St?atus?s Of you know) rni> e i 1i 1 Ro n aOaS Sc?^P__ / .'erL Attach the most recent court order for the above-referenced court cases. 7. I know of the following people, not parties to this case, who have physical custody of the child(ren) or claims to have custody of visitation rights with the child(ren): fy R. it. is in the best interests of the child(ren) to be in my custody because: -a lv? 6.cn Tx?Fcv? P,,e? Qt1vm.?_?r?l Eirr.-*b r.ro?tt?n 5iec b,rth. FOR TBESE ASONS, I request the court (check aU that apply): LQI Grant rn Ole oiut physical custody of the child(ren). gyp(, mock IGiV Grant me?Rsole/[Ijoint legal custody of the child(ren). check one) Allow e to visit :. th the child(ren). ?m TT/Z0 Page 2 M A OR 4. Revised 9 Jan 2004 39Vd 'S?Jti3dS'N3A33fi'HS-1VM E067L9ZT0E LEST S00L/ST/ZT Allow L% the following 4 o rn c o visit with the child(ren) on a f israis?lyo?.>c ?y-Ft>? I,?in` ?crr,ww,,"1S1=z"li wova?' ;431a spy r? eta m? ?;? 0&-&-ttv?- C-6"vuk-hc.J - qJ? Order yl?_i C pay health insurance for child(ren). r Nameta) Order ?l, r , es? r to pay child support (attach Financial Name(s) Statement. Use Form Dom_ ReL 30 or Dom. Rel. 31)• (State other requests relating to the children) Ci ry j 6,x tmdbg L, jo ?tc Order any other apprupriate to-Lc,. tar?tr (1???,?r.rv?lr' ?-c Qa? SpaJSCS? S-rY?_ R- 31--oS Cf? Date ?Igna Page 3 of 3 OR 4. Revised 9 An 20D4 SL/E0 39Vd `S6a3dS`83M03VHSIGM E0bbZ9ZZ0E L£-SL S00Z/SL/Zi Circuit Court for?r(f)p- Ge6re Case No. //?? LiN ri s± City orCoul? cn r in" e- t'f ?b_r- a C ;h 51 \c o r b None 1. f 509 Glove ,- ?: ?I Ter. vs. Name W S09 c7 W T rr =1` Street Address Apt.4 street Address Aptx ?.. i. D o`ZA7?(309¢09 3 rQ 0?bU-) N405-3A?l City state ZW COde Crcz 'telephone Gay 9bb Lp Code Cone Tebphow Plaintiff Defendant FINANCIAL STATEMENT (Short) 1 C (DOM 11EL 90) I, 4\ r 5 ?' 1 C> t^i h,p? ?' I am they ty name N father or Chary One of the minor child(ren): ?1?, sl?r?rllar, r-- i Nam !` Nora? d , state that: stair Relationship (for example, ount gnmdrarher, guardian, etc) f- ao- pate of Birth Nume Date of Binh Date of Birth Name Date of Birth a-asoo Data of Birth Name Date of Birth The following is a list of my.income and expenses (see below*): See deflnttions on back before filling ou[. Total monthly income (before takes) Child support I am paying for my other child(ren) each month - U - Alimony I am paying each month to U Name 01 Parson(e) Alimony I am receiving each month from o Name W Person(a) For the child or children listed above: Monthly health insurance premium ? Work-related monthly child care expenses - 0 - Sxtrao"artaty monthly medical oxpmocs School and transportation expenses ? --_? 40 lwn.,sct ?4 ? -To agave the awntmy amount of exprnses, veex,y expenses should he mulnpnrd by 4-5 and ycariy exprnses should be divided by 12. tt you do nor pay the same amount each month fdr any of the camgories listed, fig= what your average monthly expense is. I solemnly affirm under the penalties of perjury that the contents of the foregoing paper are true to the best of my knowledge, information and belief. os \ Date 8 _ gbaAe Sp nw Pape I of 2 DR 30 - Revised a Nov 2000 TT/t10 3OVd `S8V3dS`213A03$`HS1t1M £0VVZ9ZT0£ L£:ST 5007/ST/7T IN THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLAND CHRISTINE SPRINGER, ) Plaintiff, ) YS. ) ) KURT C. SPRINGER, ) Defendant ) Case No.: CAD05-18208 ANSWER. TO COMPLAINT FOR CUSTODY AND COUNTER-COMPLAINT NOW COMES Kurt Springer, Defendant in the above entitled matter, by and through his undersigned counsel of record, Lisa Merchant, who answers Plaintiff's Complaint for custody and in support thereof, respectfully states: 1. The allegations in Paragraph 1 are admitted. 2. The allegations in Paragraph 2 are admitted. 3. The allegations in Paragraph 3 are denied The Plaintiff, without notice, removed the children and all belongings from the family home on or about August 30, 2005 and left the family home empty. 4. The allegations in Paragraph 4 are partially admitted in the children of the parties did live in Bowie Maryland from September 1, 2003 through August 30, 2005. Defendant neither admits nor denies the residence of the children from November 1, 2000 through September 1, 2003, Defendant denies that a Temporary Protective Order was granted on September 6, 2005. A Final Protective Order was granted; however, the Order did not prevent Defendant from having contact with Plaintiff. IIc was ordered not to harass' Plaintiff and was granted reasonable rights of visitation with the minor children. TT/90 39Vd 'S2N3dS'2l3>1O3a £0bbZ9ZT96 L£:ST S00Z/ST/ZT r 6. The allegations in Paragraph 6 are admitted. 7, The allegations in Paragraph 7 are admitted. 8. The allegations of Paragraph 8 art; denied in dicir viiiiicty_ The parties have both been the caregivers to the minor children and Plaintiff. Defendant has never verbally, mentally or physically abused his minor children. Defendant uses practical approaches to reasoning with and disciplining the children- Plaintiff engages in useless banter and humiliation of Defendant which likely will affect the children in Lhe future. WHEREFORE, Defendant respectfully requests that this Court: A_ Deny Plaintiff's Complaint for sole physical custody of the minor children; B. Deny Plaintiff s Complaint for sole legal custody of the minor children; C. Deny Plaintiff's request for a psychiatric evaluation on the basis that she cannot prove abuse; T) Deny PlaintifPs request for family vehicle which is not the basis of a custody proceeding; R Deny Plaintiff's request for spousal support as this is not a divorce proceeding; F. Deny Plaintiffs request for child support for the reasons that she has not filed a financial statement; G. Grant Defendant shared physical and joint legal custody of the minor children; H. And such other and further relief as the nature of his cause may require. _y TT/90 30VCA 'S6d3dS'd3A035'HS7VM E0VVZ9ZT0E LEST 500E/ST/ZT I HEREBY CERTIFY TINDER THE PENALTIES OF PERJURY THAT THE FOREGOING STAT'EMENT'S ARE TRZJE TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, KUR C. S Respectfully submitted: Lisa Merchant The Lnw Off ut: of Llsa MGrcha ut 14300 Gallant Fox Lane, Suite 103 Bowie, Maryland 20715 (301) 464-3900 CER'1'1F1CAT'E OF SERVIGE I HCREBY CERTIFY that a copy of the foregoing Answer to Complaint for Custody was scrved upon Perry Becker, Counsel for Plaintiff, at his office, 14300 Gallant Fox Lane, Suite 2.1§, Bowie, Maryland 20715 by depositing same in U.S. Mail, postage prepaid on this the d`sy of October, 2005. Lisa Merchant -3- LL/L0 30Cd `S'JC3dS`d3)i339'HS1VM £0bbZ9ZL0£ L£:91 5002/SL/7L IN THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLAND Case No.: CAD05-18208 COUNTER-COMPLAINT FOR CUSTODY DefendenL/Cvwiter-Plaintiff, Kurt Spinger, by and through his counsel, Linn. Merchant, CHRISTINE SPRINGER, ) Plaintiff, ) YC. ) ) KURT C. SPRINGER, ) Defendant ? - files this action for Custody and respectfully states: 1. Defendant/Counter-Plaintiff is the father of three minor children, Noah Springer, born January 20, 1996, Leah Springer, born December 28, 1997 and Micah Springer, born February 25, 2000. 2. Counter-Defendam/Plaintiff, Christine Springer is the mother of the before referenced minor children. 3. Connor-Plaintiff/Dcfendant resides at 14509 Clover Bill Terrace, Bowie. Maryland 20720 while Plaintiff and minor children's residence is currently outside the state in Pennsylvania. 4. Counter-Plamtiff )efendant is a fit and proper person to have custody of the minor children as he is fully capable of managing a household, feeding the children, preparing them for school, helping with their homework, spending quality time with them, giving them a stable Christian upbringing and assigning their chores, -4- TT/80 39Vd `SdV3dS`d3AD39'HS1VM EOWKTOE LEST S00Z/ST/ZT 5. 6. 7 Counter-Defendant/Plaintiff has taken all necessary steps to prevent Defendant from having strong valuable relationship with his children by removing them from the family home and giving him limited access to them. Counter-Plaintiff/Defendant is a loving and supporting father who adures his winor children. Counter-Defendant/Plaintiff has taken the minor children of the parties out of the state of Maryland to Pennsylvania without the consent of Counter- 8. 9- 10, Plaintiff/Defendant. Counter-Plaintiff/Defendant has received information from the minor children that they are being emotionally and physically abused as a result of this departure from the family home in Bowie, Maryland. Specifically, his minor children advise that Counter-Defendant/Plaintiff has slapped the minor child, Leah Spriagcr and insulted the minor child Noah ruywdiag his abilities to do long- division Math in the presence of the other minor children. Counter-Plaintiff/Defendant believes the minor children are not being schooled as they were in the past because Counter-Defendant/Plaintiff is unemployed and needs to find employment to support herself and the minor children if they are to remain in her care temporarily or permanently (as the case may be). The minor children were previously home-schooled by Counter-Defendant/Plaintiff but are not being home-schooled at this time. Counter-PlaintiffMcfendant further believes that Counter-Defendant/Plaintiff is not fit to be a home-school teacher and thus, should either retum the minor children to Maryland with their father so that he -5- TT/60 39tid `SaJV3dS`?]3AO39`HS-IVM £Obt7Z9ZT0£ L£:91 5002/ST/ZT can enroll them in school or place them in school in Pennsylvania until such time as their father is able to come and get them per the Court's order. it, Counter-Plaintiff/Defendant was recently diagnosed with sleep apnea and back problems has been medicated for the diagnosis, but is fully capable of being a full- time father to his minor children based on the advice of his physicians. 12. Counter-Plaintiff/Defendant is in the process of being separated from the military and therefore, his earnings will substantially decrease whereas Counter- Defendant/Plaintiff is currently unemployed. 13. Counter-Defendant/Plaintiff is able to find a job and earn a living, but has failed to so; instead she relies on the support of Counter-Plaintiff/Defeadant for all of her support which is unfair given Counter-Plaintiff/Defendant's medical condition and future disability rating by his employer, the United States Military. WHEREFORE, Defendant/Counter-Plaintiff respectfully requests: A. Joint shared and joint legal custody of the parties' minor children; B. Child support based on a shared custody schedule and based on the Plaintiff's ability to earn an income (as a result of her voluntary impoverishment); C. The return of the minor children back to the state of Maryland immediately; and D. Such other and further relief as the nature of his cause shall require. -6- TT/0T 3OV,d `SdV3dG'2J3A03a'HS-VM E0bbZ9ZT0E LEST 900Z/ST/ZT I HEREBY CERTIFY UNDER THE PENALTIES OF PERJURY THAT THE FOREGOING STATEMENTS ARE TRUE TO THE BEST OF MY KNOWLEDGE.. INFORMATION AND BELIEF, KU T C. SYR Respectfully %vbmitted Lisa Merchant The Law Office of Lisa Merchant 14300 Gallant Fox Lane, Suite 103 Bowie, Maryland 20715 (301) 464-3900 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing Countcr-Complaint was scrvcd upon Fcrry Becker, Counsel for Plaintiff, at his office, 14300 Gallant Fox Lane, S e 218, Bowie, Maryland 20715 by depositing same in U.S, Mail, postage pre-paid on this the day of October, 2005. Lisa Merchant -7- LS/IL 39gd 'S8V2dS'213A039'HS1VM E0VN,9ZT0C LC:ST 900,7/9L/ZL • • IN THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLAND CHRISTINE SPRINGER Plaintiff V. : CaseNo.CAD05-18208 KURT C. SPRINGER Defendant ANSWER TO COUNTER-COMPLAINT FOR CUSTODY COMES NOW, the Plaintiff, Christine Springer, by and through her attorney, Perry Becker, and in Answer to the Counter-Complaint for Custody states to the Court as follows: 1. The Plaintiff admits the allegations contained in paragraphs 1, 2 and 3. 2. The Plaintiff denies the allegations contained in paragraphs 4, 5, 6, 7, 8, 9, 10, 11, 12 and 13. WHEREFORE, the Plaintiff prays: That the Defendant's Counter Complaint for Custody be denied. 2. That the Defendant be ordered to pay Plaintiff's counsel fees for defending this action. 3. And for such other and further relief as this cause may require. l Christine Springer S-` Perry Becker 14300 Gallant Fox Lane, Ste. 218 Bowie, MD 20715 (301) 262-6000 E • 9 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing was mailed, via first-class mail, postage prepaid, this ) ') day of October, 2005, to: Lisa Merchant The Law Office of Lisa Merchant 14300 Gallant Fox Lane, Ste. 103 Bowie, MD 20715 i Perry Becker Judge Time: n Mnmuxo CIRCUIT COURT ? DISTRICT OU T OF MARYLAND FOR.., , ....At.... t, .?........... Ity Muni Located at ...1. ................... ?1.....(...W.v. Z....... coo Addw......... Cf?IJILL.IST/.I).t' . .. .itl.C -1.'............ vs. .?t?ilLr?.t...1.......... TEMPORARY PROTECTIVE ORDER v After the appearance of LM Petitioner ? Petitioner's Counsel ? Respondent ? Respondent's Counsel, and in cons E7T?,-k n thtition Td d Court es following findings: A. a . Y.... ..... ... r) . ... .. .................. who is a Person(s) Eligible far Relief, is: current spouse of the Respon It ? A former spouse of the Respondent ? A cohabitant with the Respondent ? A person related to the Respondent by blood, marriage, or adoption .................................................................... ? A parent, stepparent, child on stepchild of the Respondent or a Person Eligible for Rehef'wro &sides or resided with the Respondent or Person Eligible for Relief for at least 40 days within the past year. ? A vulnerable adult ? ' 'vidual who has a child(ren) in common with the Respondent ................................................................... Nwrber ofChildxea end Agra B, Tho/die Petitioner is: Person Eligible for Relief. in the case of vulnerable adult or or . d?!r ? State's Attorney Q A local department of social services A/I A relative ?mU Q An adult residing in the home C. ? The the Respondent consents to the entry of a Temporary Protective Order O 10 That there are reasonable grounds to believe that Respondent committed the following abuse(s): ? Caused serious bodily barn ? laced Person(s) Eligible for Relief in fear of imminent serious bodily harm Assault in any degree Rape or a statutory sexual offense (or attempt) in any degree 3alse Impnsonmen tatntory abuse of a child (Physical ? Sexual Mental) (Forward to DSS for investigation.) ? Statutoryabuse of a vulnerab ylhtlt (Forward to D S for in tiara. on.......... (.a? ......... ........ ..?. .......... ....... . ............ ... .. ... .. ,.. .... ..i........l.f-Q. ... ... ..... ........ ......... D. where an order to vacate the home is requested the Respondent d Person(s) Eligrl far elief r ether at the tone of the am and: ezo Are married, Q Are not married, but V I! ? The name of a Person Eligible for Relief is on the lease or deed ? A Pasat Eligible for Relief has resided in the home with the Respondent for at least days the past yes. ? In the case of abuse of a child or vulnerable adult, an adult other than the Respondent lives in the home. E. This Order is denied ? Because there is no statutory basis for relief. ? Other ................................................................................................................................................................... EXHIBIT D CC-DCJDV 2(Rev. 10/2004) Page 1 of4 0 Bas on the foregoing findings, the Court hereby ORDERS: 1. That tft R de SHALL NOT base, thr to abuse, lh d/ar harass . ....?,....? .,.?°?.aa,,.. 11 x That the Respondent =SL NOT contact (in .. by te pep wti 3 to contact ?.k N .lS f.A? ?.. .?1f.•Q 1?.I Qa> . 3. That the RMOodenl SHALL OT the resilience of ...... f, ................ (Residence includes yard, grounds, outbuildings, and corm e ? An undisclosed location for reasons of safety. ? 4. That the Respondent SHALL STAY AWAY from ? (1) School: ................................. ............... ................... (2) School: ............................................... -- ...... ........... (3) School :..................................................................... ? An undisclosed school for reasons of safety. any areas surrounding the dwelling.) ? (1) Childcare provider ............................................................................................................................. at ...... ............. .......................................... .................................... ...................... :............ ........................ while ..................................................................................... Ware in the care of the childcare provider. (2) Childcare provider while ..................................................................................... is/are in the care ofthe childcare provider. ? An undisclosed childcare provider for reasons of safety. ? (1) Place of employment:........... .................................................. (2) Place of employment ........... ? An undisclosed place of employment for reasons of safety. ? (1) The temporary residence of ..................................................................................................................... at .................................................................................................................................................................. (2) The temporary residence of ..................................................................................................................... at... ...................................... I ........... ....................................... ..................... .............................................. ? An undisclosed temporary residence for reasons of safety. ? (1) The home of another family member at ................................................................................................... ..................................................................................................................................................................... (2) The home of another family member at ................................................................................................... ..................................................................................................................................................................... ? An undisclosed home of another family member for reasons of safety. That the Respondent SHALL VACATE the home im?rnlediatdy o includes yard ds, oy? uildin 0151 undmg the dwelling} az....1..'.?.J?'..Q......lx?.?l:4!??.,1.. 1...:.1.??.??i??. T27=117 ...................................................................................................................................... and remain away until the hearing provided for below. (P b 7 and hFarmg date on extensi o?gtder.) Temporary use and possession of the home is granted to. Ie?I.S?ir ...._ rlt 1? ............... ............................................................................................................................ .................................. e Respondent, accompanied by a law enforcement officer, may return to collect clothing and perwzW necessities, only between the hours of...... ....r :..... and .......... .......?............... on ....g(..Q?` .......... or as directed by local law enforcement. CC-DCIDV 2(Rev. 1012004) Page 2 of4 • E t?s+.?...?.?i?Q....... Date.F:Z ?,D.s That custody of ...... .. . .. Le (!L . ? \ . .. ...... C dl? ?I ..................... is awazded to./..?. ? tr .. .. . until the hearing provided or in Paragrep below. ? Custody shall remain joint Law enforcement officers are ordered to use all reasonable and necessary force to; twn the minor child(ren) to the custodial parent at time of serv cc or as soon as possible after enof this Order. Z7THAT A FINAL PitOTECTIVEiDRDER HEARING SHALL BE FIELD OX----, 8. This Order des and overrides any Piously - c ................... c l?'1.... This Order is extended for not more than 30 days until: ....................... ......... New He WW Date ..l.dge ....................... .............................. New Hm Due ng Due Judge Judge NOTICE TO RESPONDENT lRU6 COP-Y'' ' ' _ Due ................. D' ... nue .... A Petition for Protection alleges that You have committed abuse. On the basis of the Petition this Temporary Protective Order has been issued. Violation of this Order may be a state and/or federal crime or contempt of court, or both, and result in imprisonment or fine or both. This Order may be enforced by another state or jurisdiction, which may impose additional or different penalties for the violation. In order to respond to the allegation that abuse occurred, you must appear in court at the Final Protective Ord, bearing provided for in this Order. If at the hearing the court finds by clear and convincing evidence that abuse occurred, the court will issue a Final Protective Order against you, whether you appear or fail to appear, and may order all or part of the relief requested by the Petitioner or granted in this Order. This relief may include temporary one and possession of your home, use and possession of jointly owned vehicles, Emergency Family Maintenance, child visitation, surrender of firearm(s) to a law enforcement agency, and counseling or participation in a domestic violence program. A Final Protective Order may be effective for as long as twelve (12) months, and the court for good cause may extend the term of the Final Protective Order for an additional six (6) months after a further hearing If you fail to appear in court and a Final Protective Order is issued against you, you will be served by first-class mail at your last known address with the Final Protective Order and all other notices concerning the Protective Order. The Final Protective Order will be valid and enforceable upon mailing. It is your responsibility to notify the court in writing of any change of address. CC-DC/DV 2(Rev. 1012004) Page 3 of4 • L ?.?..Q.s?..:.?l2. ..... Date...2? Q.. NOTICE TO ALL PARTIES Each patty may be represented by an attorney. At the Final Protective Order bearing, the petitioner will be required to prove the alleged facts by "blear and convincing evidence." This is difficult to do if you do not have law training. Each party should see a lawyer, if you are the petitioner and cannot get a private lawyer, there are support agencies that may be able to help you. Although each party is not required to have a lawyer at the hearing, all of the Rules of Evidence will apply to the case. If you choose not to have a lawyer with you on the hearing date the Petitioner will still have to prove the case by "clear and convincing evidence" and each party will have to comply with the Rules of Evidence. Due to the emergency nature of the hearing, the hearing may be held even if a party requests more time to obtain an attorney. At the Final Protective Order hearing the court may order the Respondent to pay Emergency Family Maintenance and may pass an immediate and continuing withholding order for that purpose. If this Emergency Family Maintenance is requested, both parties should complete a Financial Statement (CC-DC/D V4) before the Protective Order hearing and bring it to court You should also bring documents (such as pay stubs, copy of your lease, bills, etc.) to support the figures you supply. TRUE COPY RTIFICATION OF TEMPORARY PROTECTIVE ORDER ' j??/. Attestation of Cie (jam 1, !..( .. .1.?. ....... ...., Clerk of this Court in ........ r :...?..1.:A. S.City/County, State of Marylan do hereby certtfy I have compared this Order with the original Order which is on file in my office, and that this Order is a true and correct copy of the original, and the whole thereof. In tesu hereof, I hSVgpereunto set my hand and affixed the ofsa Court at.........r..,..:.aG. QI.`.?..?...`.i,!........ day L .......................................................... State of Maryland, do hereby certify that... whose name is subscribed to the foregoing c sealing the same, a Clerk of this Court in ... that his/her attestation is in due form of law. Attestation of Judge u. ...... Judge of this Court in ..........................................City/County, ......... _ ........................................................................................................ ertificate of attestation, now is, and/or was at the time of signing and ....................................................................................... City/County and CC-DCDV 2(Rev. 10/2004) Page 4 of 4 v,. L?1 ?voE-/(?Z Judge Time RE C O V E Hours Minuets , Maar?aNO ? ? CIRCUIT COURT A /DISTRICT COURT OF MARYLAND FO? ................. iuoiciaav ' Located at .............. V.Lt.[M.t.........,.......,........... ?? Court Address Z.QQS..AUG, 1?E.... ?......... ..Ill"'........ _... ....Il...v.......... (NOTE: Fill in the following, checking the appropriate boxes. I? t?qn Lt nM A5ive an address if doing so risks further abuse or reveals the confidential address ofa shelter. IfYhi:q, ,1 1- MMeck here D Ifyou need additional pa er, ask the clerk.) F1f .?s,1?n. ....??.?.....__............ vs. ......!.!..U. .. .._??PT.I: ? ............................ Pet loner ponde ..,r ............ !.'SOQre.....N?....(T Street Address, Apt Home: tree[ Address, ApL, No. Home :30 9og3333 wor - X33 ork: ,.? m?.. aaa........ rn?....ao.a. ....... Gay, State, Zip Code Telephone N Umlmr(s) ity, State, Zip Code Telephone PETITION FOR PROTECTION FROM 14 DOMESTIC VIOLENCE W CHILD ABUSE ? VULNERABLE ADULT ABUSE 1. 1 want relief for 9 myself)4 minor child ? vulnerable adult, from abuse by ....... .. ... f' 1Ah.? r....... ?,?, II __R?ppspo ay?p?,f(? The Respondent committed the f 11 wing acts of abuse a a nst..LV f.S Yl... 1.[1.?T1(m- r" g 1'? vtchm r on or about, ? ...-...D..f .Pa.1?6. .......... (check all that apply) El kicking ? punching- El choking Dam ice/ .?? slapping El shooting ? rape or other sexual offense (or attempt) yeu hitting with object ? stabbing cy shoving 9 threats of violence mental injury of a child ? detaining against will ? other ................................... ........................................................................................... .............. .......:........ ................. The details of what happened are: (Describe injuries. State when and where th e acts occurred. Be as speci c as you can.): IN?..C?17.1d(SY1..£.. .. 4? ? .:??-oY1n.. 4n ....0.f.,cr ... ..?Q.1.k?... ..1vEt...4r?t? .•....t?--IS..n?t?.bkc?a to Rt,bv ,. ?. . 4v5 I. rtt. ?...,4?Ay,? S a 1r_ , -rk_ Je,rbzQ ?a Fps o..boz aµ . sa. ................ ii•Q...z+£sL € h,m ? . Sav . ?Q `? _ ...... o ? C.1 2.4? ,Q t? ?t >.. U4, ...5?- ?-?- N,tA? ..... .8. ?.os..± -. ...a.. 2. (If the victim is a child or vulnerable adult, fill in the following.) I_amt asking for protection for a child ?. .._ ..............._ ?vulnerableadultwhosenameis.....IVn(yw-Il..1...L. ...??,...!.!.ILCv.-X1.1...4. ... C1 .. q-(-........ At this time the victim can be found at .Y q.., ......... I am ? State's Attorney ? DSS 0 a relative Aan adult living in the home. +ne, 3. The person(s) I want protected are (include yourse f Ifyou area victim): Name(s) N 061-x.... 1.n 6Q "y ............ L ?.•h....t? r..irllbe.? ................ C.N.Tf ............... CC-DC/'DV I (Rev. 10/2003) Birthdate !..7.?-o.79.6. ........................ Page I ofa Relationship to Respondent J ...a1.0.h........... I........ ....?. ?... Soh .... .............5 ... ................................................ ??1 • Case No ........................................................................ r t ?i CC '/ L h..... s... n ......J.. .c..?.r?. e G ........... vs. .........1 ........................... Pertio.'e Respon[ i 4. The person(s) I want protected now lives, or has lived, with the Respondent for the following period of time during the past year: ........ I..... Ll-f . . .......................................................................................................................... There ? are 0 are not additional persons living in the home. 5. I know of the following court cases involving me, or the person I want protected, and the Respondent. (Examples include: paternity, child support, divorce, custody, domestic violence, juvenile cases, criminal cases) Corot Kind of Case Year Filed Results or Status (if you know) 6. Describe all past injuries the Respondent has caused the victim, and give date, if know ......................................... ...Car....! .m..&irt... 1 .. ...?! 1Q., . ..... .............................................................. .............. ......... ................................................ ................. ................... ............ .1--.11.1 .............................................................................................................................................................................. 7. The Respondent owns or has access to the following firearms: .................................................................................. ........................................................................................................................................... -............................................. ........................................................................................................................................................................................... 8. I want the court to order the Respondent: (NOTE: Petitioner need not give an address if doing so risks further cils) gel NOT to abuse or threaten to abuse ..... ?..1.y.. Nanime s rl, . 4r' etY NOT to contact, attempt to contact, or harass .../?/.(?.?.......4... ....R.!'Y?...>y . Name sJ '? p.c.r.LY Z-41 _ ....................??.//..........:.._.......:.....................L.I.....L,,.............._.........?...(...?...........ry..?...... ?.. X NOT to go to the residence(s) at ....r).7.50...... 0\1.9 !?.....i !.1..1 Address ....... ........................................................... ........ .... ... ........................................ (?i-ij + C.S. ?)(yy?? NOT to go to the sekee?(s}al ................... ......................................... ?? T /7 tN?a ofsdhwl and address ................................................ ....?... ...JJ......... ...1......... ....... j. ]........... ...................... ...... ...(...................... t?Jf? NOT to go to the ra??der(s) ... ?6f'?Q. f...4`0 .....!.l. .S.4a'N 8 ...V.9.. ...... Name of l.d carep vi ra ad ss ?b??.....Antl .{poY ....? s.........?....?.???\2 ? NOT to go to the work place(s) at _....._ ...... ..................... ........_.......... ......................... .............. _...................... _. _(........Q... _.............. _........................ ?.... _..... _........ _.......\......__.._ ?/.'..]....... To leave the home at ._(.`?.5?.`1.. c.'.U.VC('....N1..1.L....1. rn`......?dWier...._ 11.....,x!.2.d Address and give possession of the home to ....... I,,,;f.1r.1.5.7..1.Q.(...QCr.- ........ The name(s) on the deed or lease are:....... Kurt.....,5?,? r.1.?C.c, r ..... ................................... _.....- ? To turn over firearm(s) to a law enforcement agency. To go to counseling 'Ekdomestic violence ? drug,'alcohol ? other. ....._ ......... ...._.......... ............ .............. To pay money as Emergency Family Maintenance (maybe taken from Respondent's paycheck). CC-DC/DV 1 (Rev. 10/2003) Page 2 of 3 • Case No ........................................................................ Ch?SLS.jt r ?n?cr ............ vs. ......?? r ..... Pttuioner R?Prudent 9. I also want the Court to order: ?} h .ri..... /? .. ... . ... !.!..L'cCQ`!.).. ....................... O L... ? . NCusstodY of ......... Children' .......... s names .i.... ??Y.. L. ?.gr.l . ................................_............................................... be Name (? ' Use and ranted possession to ......?..?C ehicle be granted to...C....? of the following jointly-owned ? (zo -t- I Name], .. ..................... rL- QZ.?Q . .... ... ?Q.i.:.....l...b ??... 60111 ,? Yfi ony?ou",t e s??wng ?e 1',Fnmily? amt-e7ttrnce) The Respondent has the following financial resources: > Income from employment in the amount of $..W.'1?! ..:..............fm;"?'every 0 week Q 2 weeks month ........................ ? other .... ..................... ...... ....... ..................... ............... ...................,.11.................................._................... Source of employment ncome fl 2r {??' S{? M Q AlJG MFp-e , I..b.....k? us ? 20.?o .. ............... ......... .... .J......... a Name and address of source and amount(s) rec ed8A0n". P ......... Income from other source ......................... ........... ....... .......e ..................................................... ...... ...---.......__........ Nam and address of source and anrounq) received su3 The Respondent also owns the following property of value: Automobile(s) $..... H.Q..)..Qdv ..........................._... pp ??Q M Irr,, C Estinnate Value ..........._................... Home $.....`lg10..000 `. 00 ...................... ..... Bank Account(s)$......?l..QU.....,..... Value } Estimate V Line Estmiate Other: ...??.A.154l1r?xTay. .1.1? ........... ........ ................. ._:.............. ................ Estimate Value I solemnly affirm under the penalties of perjury that the contents of the foregoing Petition are true to the best of my knowledge, information and belief. -a.i..-os............,.? ........ .......... late ioner Pent I have filled in the Addendum (Description of Respondent), CC-DC/DV IA. NOTE If you believe that you have been a victim of abuse and that there is a danger of serious and immediate injury to you, you may request the assistance of a police officer or local law enforcement agency. The law enforcement officer must protect you from harm when responding to your request for assistance and may, if you ask, accompany you to the family home so that you may remove clothing and medicine, medical devices, and other personal effects required for you and your children, regardless of who paid for them. CC-DC1DV 1 (Rev. I W2003) Page 3 of 3 • • ? CIRCUIT COURT ? DISTRICT COURT OF MARYLAND FOR ...................................................... city/county s?ar,lc:nfir Located at .................................................................................... Case No................................................. .............. . .......).uS ?..., .f !y1 e 1..................... Pe r er /t'es ondent? PROTECTIVE ORDER ADDENDUM Failure to provide information in any of the shaded areas will prevent law enforcement from processing the Court's Protective Order. This may endanger your safety or the safety of another protected party. Please provide as much information as possible. - Kh5VUNUtNI (Alleged Abuser) G PETITIONER (Person Requesting Assistance) Full Name: Date of Birth: Approximate Age: Ch(741 LOV tS?? (p- ace: Sex: ?+ Height: Weight: T )cal) 16s . Full Name: 1\llT`J_ " ? Dateoff Birth: Approximate Agee \O.,C L? ?t{j r Race: W it Sex?':y? Qw' I Height: (a'a w eight: 1bs- 245 Hair Color: Eye Cola: Skin Tone (LghuMediurzMark): " s I j r t_ Scars, Tattoos (where on body and description) 91 'A Home Address/Phone Number: I ?? (::AQ . ?' ve r T??? a0la? ark Address/Phone Number: rot ??r,? {,? y I Ov ?jlvV rl, D.) r l03 6- (0c) Vehicle Make: Model/Color: G c Se G Year: 000 Tag#: Z 2 Sta Driver's License #: r r. e o Cat S?GTOY * catioAn ?or mformation about Respondent: V J<1??cr eta. no V?, S? S -LRvtS II It?i C INFORMATION ABOUT OTHER PERSONS PETITIONER WANTS PROTECTED Full Name: 1 " A, M Sex: Date of Birth: A e: Full Name: f Q? 1 L Race; ?s.. Sex: ? 'ate of Birth: Wye Age: Full Name: r M I'c c_ rl' c : W Sex: M Date of Birth: d -d5-doW Age: Full Name: Race: Sex: Date of Birth: Age: Petitioner's Signature ....?, . ? . . . Date C:?.... t5 o..? .. .. ... ... _?.. ..... CC-DC/DV 1A (Rev. 2/2003) ?? . Mr, 0 M ? CIRCUIT COURT ? DISTRICT COURT OF MARYLAND FOR ............................................................................... roK-tr Located at....?..i ..........................................dada.................................................. Case No.................................................... vs hr' ? ,. ?......... C , y<. -............ . r ........................ ..........l.illq .. ..l ,, n.. ped . h REPORT ON SUSPECT?EIDffiL1D ABUSE ? VULNERABLE ADULT ABUSE 1. Name of child/vul rab a adult .......! ?......J,.,?, ?. m i Date of Birth ....... b q???n.//rn..fA.A;'4,a ................. E) aMe 0 Female rn 2. Permanent Address......... Q.6.Y..4, )r.....[ f..l:.?.?..?.Zr.r. ......................................... .......................................tea...........sn.........o.a............................................................................ Temporary Address if not at permanent address 3. If alleged victim is a child: Name and address of child's school... e.... Scb0z' . .................................. r ..................................................................................... Grade:.................. Name and address of daycare provider.... .I.A9 .................................................................................................................. 4. Other persons who usually live in household: Name .................................. v . ....................... Age Relationship to Child/Vulnerable Adult . . ............................................. A). tf. ........................................... 5. Person(s) who supervise or care for child/vulnerable adult: Name Age l? h r°11? ..Y .?Y a¢ ................. .4...0....... ...................................................................................... ................... Relationship to Child/Vulnerable Adult ....... rnuI V,-1 ....................................... ..................................................................................... ................... ........................................................................ 6. Name of suspected abuser:...... 6.4..... s /rt . .?' ........................................................................................... a 7. His/Her relationship to child/vulnerable adult: ........f.. G41. ..................................................................................... DV-5 (Rev. 9194) T Judgp Time 1 -1 (rpm Minukc. MAR"ANG ? CIRCUIT COURT ? DISTRICT COURT OF MARYLAND FOR ...... .......... nracwtr ?,,? ?r / Loma ed at ................................ . . .................................... Case Nd/?w..l.`.iS.& 5d.?.....A........... Addax FINAL PROTECTIVE ORDER After the appearance of the Petitioner 5EPetitioner's Counsel Altespondent CKRespondent's Counsel, and i consideratio Peti?tign,?y? evidence, the Court makes the following findings: A. net.....lNY.f . .............................................................. who is a Persou(s) Eligible for Relief, is. 0 The current spouse of the Respondent ? A former spouse of the Respondent ? A cohabitant with the Respondent ? A person related to the Respondent by blood, marriage, or adoption ........................... ? A parent, stepparent, child or se7a .,......... resided with the stepchild of the Respondent of a Person Eligible for Relief who who resides or resided Respondent or Person(s) Eligible for Relief for at least 90 days within one year before the filing of the Petition. ? A vulnerable adult ? An individual who has a child(ren) in common with the Respondent ....................... B. That the Petitioner is: I5wn6a:'o!t%iidren":od t 14 The Person Eligible for Relief. K in the case of a vulnerable adult or minor child: ? A State's Attorney ? A local department of social services 0 A relative ? An adult residing in the home C. ? That the Respondent consents to the entry of a protective order without a finding of abuse. OR ? That there is clear and convincing evidence that the Respondent committed the following act(s) of abuse: ? Caused serious bodily harm ? Placed Person Eligible for Relief in fear of imminent serious bodily harm ? Assault in any degree ? Rape or a statutory sexual offense (or attempt) in any degree ? False Imprisonment ? Statutory abuse of a child (? Physical ? Sexual ? Mental) ? Statutory abuse of a vulnerable adult on .......... ............. n:K.......................... .. ............... T ........................................................ ._................ ............................................................. net, where an order to vacate the home is requested, the Respondent and Person(s) Eligible for Relief resided together at the time of abuse and: ? Are married, or ? Are not married, but ? The name of a Person Eligible for Relief is on the lease or deed, ? APmmEligtI* rR6efhasmsdedindwhmtewnhftRrspordenf tkast9odao,,%6rthepestyrs ? In the case of abase ofa child or vuLtaableadult, an aduk other tltm the Respordere lives in the home. E. This Order is denied ? Because there is no statutory basis for relief. ? Other ................................................................... ................................. F. The parties have agreed to waive the Temporary Protective Order hearing. CC-DCWV 3(Rev. 10/2004) Page t of4 • • Case No ...........................................Date..................... Based on the foregoing findings, the Court hereby ORDERS: CC 1. That unless stated otherwise below, this Order is effective until ....l?.?3???. 1K 2. That the Respondent SHALL NOT abuse, threaten to abuse, and/or harass...J.?.(? ............................... ? 3. That the Respondent SHALL NOT contact (in person, by telephone, in writing, or by any other means) or attempt to contact .............................................. except to facilitate any child visitation ordered in #8 below. ? 4. That the Respondent SHALL NOT enter the residence of ................................................................................ at ................................................................................................................................... ...................................... (Residence includes yard, grounds, outbuildings, and common areas surrounding the dwelling.) ? An undisclosed location for reasons of safety. ? 5. Respondent SHALL STAY AWAY from: ? (1) School :....................... ................................................................................ ....................... .................... (2) School: ..................................... -- .................................................... ......... ......... ........... ............ ....... (3) School: .... .................................................................................................... - ...................................... ? An undisclosed school for reasons of safety. ? (1) Childcare provider ................................................................................................................................. At-- ..................................................................................................................................................... while ............................................................................................ is in the cam ofthe childcare provider. (2) Childcare provider ................................................................................................................................. at ........................................................................................................................................................... while ............................................................................................ is in the care of the childcare provider. ? An undisclosed childcare provider for reasons of safety. ? (1) Place of employment :........................................................................................................................... .............................................................................................................................................................. (2) The home of another family member at ................................................................................................. .............................................................................................................................................................. ? An undisclosed home of another family member for reasons of safety. ? 6. That the Respondent SHALL VACATE the home immediately (home includes yard, grounds, outbuildings, and common areas surrounding the dwelling) at ............................................................................................... ............................................................................................................................................................................ and remain away. In the meantime, use and possession of the home is granted to ............................................ ............................................................................................................................................................................ ? The Respondent, accompanied by a law enforcement officer, may return to collect clothing and personal necessities, only between the hours of ...........%W** ....... and ........ r'm:....... . on ......................ice ..... ........... or as directed by I otnem {??? 7. ? Custody of....... .............. is awarded to.... J?IN?.....:l..r`1.,t?M1- ......................................................................... ? Custody of ................................................................................................................................................... is awarded to ............................................................................................................................................... CC-DGDV 3(Rev. 10/2004) Page 2 of 4 • 0 Case No. . ........................................ Date ..................... ? Custody shall remain as set forth in ....................................................................... . ? The child(ren) shall primarily reside with ............................................................ C:u........__ ................... ..................................................................................................................................................................... ...................................................................................................................... _ ................................ ? Custody shall remain joint. ? Law enforcement officers are ordered to use all reasonable and necessary force to return the minor child(ren) to al tat time of service or as soon as possible after entry of this Order. if 8. Visitation with mw:. .......vaaioi?iiaii ..................................................... ..................... is granted 13 ? every other weekend from ...................... ? every ........................................................ „?, .. . tom,,, r yr [ .. ........ .....................??ou... s?L........................ The following additional visitation tams also apply (eg. transportation, exchange location, name of visitation coordinator, etc.): ? Visitation shall be supervised by ............................................................................................................. (Name) ? 9. That the Respondent SHALL PAY Emergency Family Maintenance in the amount of ........................................ every ? week ? 2 weeks ? month to ................................................................................................................. beginning ..............................................................................(Date) and ? mail payment to the following address: ? ................................................................................................................................................................................. ? Emergency Family Maintenance shall be paid by way of an Earnings Withholding Order. ? 10. That exclusive use and possession of the vehicle described as .............................................................................. is granted to .......................................................................................................................................................... ? 11. ? That the Respondent SHALL participate in andmeettherequirements ofthafollowingdomesticviolence and/or otherprofessionally supervised counseling program(s): .......... ............................................ ................... ............................................................................................................................................................................ ? That the Petitioner SHALL participate in and meet the requirements of the following domestic violence and/or otherprofessionally supervised counseling program(s): .... - .................................................................... ? That the Child(ren) SHALL participate in and meet the requirements ofthe following domestic violence and/or other professionally supervised counseling program(s) :................................. ......................................... ............................................................................................................................................................................ ? 12. That the Respondent SHALL immediately surrender all firearm(s) to law enforcement agency .......................... ................................................................ for the duration of this Protective Order. ? 13. That the Respondent SHALL pay costs, including costa for out-of-state service. ? 14. This Order supersedes and overrides any previously entered T;ktsl Protective Or ...................... .. `....??.......... ore Each party shall be served with a copy of this Final Protective Order. Tim clerk shall trail 1 ................ ; &E COI 3 .................................................................................... 4. CC-DGDV 3(Rev. 102004) Page 3 of4 .................... the following: if- • 0 Case No ...........................................Date .................... CERTIFICATION OF ISSUING JUDGE It is certified that under the laws of Maryland: (1) The issuing court has jurisdiction over the parties and the subject matter. (2) The Respondent was given reasonable notice and an opportunity to be heard at a Protective Order hearing. (3) In the case where mutual Protective Orders have been issued, the court has made a detailed finding of fact that each party was entitled to such an order. 15W ......................................... ..................... ............ Court: ................................................................................................................................................................................ Address: Phone: .......................................................................... Fax: NOTICE TO RESPONDENT: PENALTIES Violation of this Order may result in criminal prosecution, imprisonment and/or fine, and contempt of court. Law enforcement shall arrest a person whom the officer has probable cause to believe is in violation of this Order, Maryland Code, Family Law Article, § 4-508. This Protective Order shall be recognized and enforced by the court of another state or jurisdiction, 18 U.S.C.A.§ 2265. NOTICE TO RESPONDENT: FIREARMS It is a Federal crime for you to possess any firearm U.S.C.A. 18 § 922 (g) (8). If you have been ordered to surrender any firearm in your possession to law enforcement authorities, failure to comply is a misdemeanor crime, Maryland Code, Family Law Article, § 4-509 (a). Questions regarding this notice should be directed to your attorney, local police department, or the Maryland State Police Firearms Enforcement Section at 410-290-0050. TRUE COr ye., RTIFICATION OF FINAL PROTECTIVE ORDER •r//Attestatlcn cf Clerk I G I "?.1.. :. .?........ . ClerkofthisCourti. ................ Ci oun fate of 14laryland, do y certify that I have compared this Order with the ori ginal Order, which is on file o cc, and that this Order is a true and correct copy of the original, and the whole thereof, In testimony whereof, I have er to t my hand and affixed G7G4 {L'f the seal of said Court at ..........:.. .:.. .1:....................... Maryland, this ..(tt.......... day .,? cnb.7n., O?f .......................L?.c .. .................................... Attestatlon of Judge clak t ......................................... Judge ofthis Court in.................................................................. City/County, State of Maryland, do hereby certify that .................... ......... whose name is subscribed to the foregoing certificate of attestation, now is, and/or was at the time of signing and sealing the same, a Clerkofluscaatin ............. ........... ...... ......... City/CoumyaMtlmhisilwattestatim is mdueformoflaw. .............................................................. om Court :.................................................... Address: ........ ......... ....................................................................... Judas Phone: .................................................................. ... ..Fax:............................................................................... To request a foreign language interpreter or a reasonable accommodation under the Americans with Disabilities Act, please contact the court immediately. CC-DC/DV 3(Rev. 10/2004) Page 4 of 4 IN THE CIRCUIT COURT FOR PRINCE GEORGE'S COUNTY, MARYLAND C14RIST'lNE SPRINGER Plaintiff t/. KURT C. SPRINGER Defendant CAD05-18208 ORDER OF COURT Upon consideration of the Plaintiff s Motion for Removal and Transfer, the Defendant's failure to respond thereto, and the Record herein, it is this _e&y of January, 2006, by the Circuit Court for Prince George's County; Maryland, ORDERED, that the Plaintiff's Motion for Removal and Transfer, pursuant to Md. Code. Ann., gamily Law Article § 9.5-207, be and is hereby GRANTED; and it is further, ORDERED, that the above-captioned case is hereby transferred to the Court of Common Pleas for Cumberland County, Pennsylvania; and it is further, ORDERED, that the Plaintiff is to pay the transfer fee to the Clerk of the Court in the amount of Sixty Dollars ($60.00) within thirty (30) days and this case is closed statistically. C7 William D. Miss Administrative Judge Seventh.hidicial Circuit EXHIBIT Z0/T0 39Vd `Sbd3dS`213X03VHS'1dM E0VVz9Z10E bE:bT 900Z/90IT0 COPIES MAILED BY THE COURT TO, Perry Becker, Esquire Walsh, Becker, Spears & Moody 14300 Gallant Fox Lane, Suite 218 Bowie, Maryland 20715 Lisa Merchant, Esquire The Law Office of Lisa Merchant 11300 Gallant Fox Lane, Suite 103 Bowie, Maryland 20715 Donald P da Date Law Clerk to the Honorable William D. Missouri 39Vd `SNV3dS`?J3N039`HS1VM £0VVZ9ZS0E VENT 900Z/90/L0 Ze/z0 n C') ?FNI 5i CHRISTINE SPRINGER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KURT C. SPRINGER DEFENDANT 06-790 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, February 16, 2006 upon consideration of the attached Complaint, it is hereby, directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, March 23, 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, Bv: /s/ Hubert X. Grlrov,_Esq. I; ({ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 roll/- -7 So :11 NY 9 1 113 904! CHRISTINE SPRINGER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-790 : CIVIL ACTION - LAW KURT C. SPRINGER, Defendant :CUSTODY AFFIDAVIT OF SERVICE AND NOW, this 17th day of February, 2006, comes Mark A. Mateya, Esquire, Attorney for Plaintiff, Christine Springer, who, being duly sworn according to law, deposes and says that: 1. A Petition to Modify Custody was filed to the above term and number on February 8, 2006. 2. On February 9, 2006, a certified copy of the Petition to Modify Custody was sent to the Plaintiff/Respondent via certified mail, restricted delivery, return receipt requested pursuant to Pa. R.C.P. 1920.4. A copy of the Certified Mail Receipt is attached hereto as Exhibit "A" and is incorporated herein by reference. 3. On February 9, 2006, a certified copy of the Petition to Modify Custody was sent to the Plaintiff/Respondent via first class mail, postage prepaid. A copy of the Certificate of Mailing is attached hereto as Exhibit "B" and is incorporated herein by reference. 4. On or about February 16, 2006, undersigned counsel for Plaintiff received the return receipt card signed by the Defendant. Said receipt is attached hereto as Exhibit "A" and is incorporated herein by reference. Respectfully Isubmitted, Mark A. Mateya, E uire Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 (717) 241-3099 Fax Attorney for Plaintiff CJ US. POSTAL SERVICE CERTIFICATE OF MAILING MAY DE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE - POSTMASTER Received From: AEEyA PC 0 . )?I -FOlLWCr 5Pie I)Vil PA Ir7oOr7 One piece of ordinary mail addressed fo: aT SPRr V GEC. &oIL, D ICk1f'15o1v AVE mP J4 iLL PA Plod Cl 0 0 0 o{ff :G a BALD aLT7 8IN ma Cp a^ 0 m Dm Z z v ? "1;' C" OON l ce 0 L v in M PS Form 3817, Mar. 1989 =; ?; r•? -- 7r '. i`J c C C e ?? S tl CHRISTINE SPRINGER Plaintiff V. KURT C. SPRINGER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 2006-790 : CIVIL ACTION - LAW CUSTODY/DI V o,2C e NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle PA 17013 (717) 249-3166 Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a ]as demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y pueda entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle PA 17013 (717) 249-3166 n CHRISTINE SPRINGER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-790 : CIVIL ACTION - LAW KURT C. SPRINGER, Defendant :CUSTODY AMENDED COMPLAINT FOR DIVORCE COMES NOW the Plaintiff, Christine Springer, by and through her counsel, Mark A. Mateya, Esquire, and affirms the pleadings filed to the above-term and number regarding custody and divorce, including the Petition to Modify Custody filed with this Honorable Court on February 8, 2006 and avers the following: COUNTI COUNT FOR DIVORCE UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE In order to make the pleadings previously filed in Prince George's County, Maryland, comport with Pennsylvania law, and to further give adequate notice to all parties involved, the following paragraphs of the Count in Divorce are tendered. 1. Plaintiff herein is Christine Springer, an adult individual, presently residing at 110 S. 27" Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant herein is Kurt C. Springer, an adult individual, presently residing at 3016 Dickinson Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant were married on August 8, 1987, in Harrisburg, Dauphin County, Pennsylvania. 4. Defendant previously served in the armed services of the United States and was discharged in October 2005. Plaintiff is not a member of the armed services of the United States or any of its allies. 5. Plaintiff and Defendant are presently residents of Pennsylvania, Plaintiff moved to her present address on September 3, 2005. 6. The marriage between Plaintiff and Defendant is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests that the Court enter a Decree dissolving the marriage between Plaintiff and Defendant. COUNT II CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER THE DIVORCE CODE 8. Paragraphs 1 through 7 above are incorporated herein by reference. 9. Plaintiff and Defendant are the owners of various items of real property, personal property, furniture and household furnishing that may be subject to equitable distribution by this Court. 10. Plaintiff and Defendant are the owners of various motor vehicles, bank accounts, investments, insurance policies and retirement benefits which may be subject to equitable distribution by this Court. WHEREFORE, Plaintiff requests the Court to enter a Decree: a. Dissolving the marriage between Plaintiff and Defendant; b. Equitably distributing all property owned by the parties hereto; C. In the event that a written Separation Agreement is reached between the parties hereto prior to the time of hearing on this Complaint, Plaintiff respectfully requests that pursuant to §304(a)(1) and (4) and §401(b) of the Divorce Code the Court approve and incorporate, but not merge such Agreement in the Final Divorce Decree; d. For such further relief as the Court may determine equitable and just. COUNT III CLAIM FOR ALIMONY PENDENTE LITE UNDER 3104, 3323, 3701, 3702 AND 3704 OF THE DIVORCE CODE 11. Paragraphs 1 through 10 above are incorporated herein by reference. 12. Plaintiff is unable to sustain herself during the course of litigation. 13. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. 14. Defendant has the means and ability to pay Alimony Pendente Lite to Plaintiff. WHEREFORE, Plaintiff requests the Court to enter an award of alimony pendente lite until a final hearing. Date: ?- 90 6 Respectfully submitted, I II nn 1Uh, Mark A. Mate) , Esquire Attorney ID No. 78931 PO Box 127 Boiling Springs, PA 17007 (717) 241-6500 (717) 241-3099 Fax VERIFICATION MARK A. MATEYA, ESQUIRE, verifies that he is the attorney and agent for the Plaintiff herein, that the Plaintiffs verification cannot be obtained within the time allowed for the filing of this pleading, that as attorney for the Plaintiff, he has sufficient knowledge and information concerning the contents of the within document and that the facts set forth in the foregoing are true and correct to the best of his knowledge, information and belief. He understands that false statements made therein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities. Lu'k-?? MARK A. MATE , ESQUIRE Dated: -1to 0 CERTIFICATE OF SERVICE I, hereby certify that I have served a copy of the foregoing Amended Complaint on the following person(s) by depositing a true and correct copy of the same in the United States Mail, first class, postage prepaid, at Boiling Springs, Cumberland County, Pennsylvania addressed to: Kurt C Springer 3016 Dickinson Avenue Camp Hill PA 17011 awx'? 9-' ? `?dt Mark A. Mateya, Esquire P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 'il Olc Dated: =ii C-L CHRISTINE SPRINGER Plaintiff V. KURT C. SPRINGER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. 2006790 : CIVIL ACTION - LAW : CUSTODY CUSTODY STIPULATION AND AGREEMENT AND NOW, this 2a4day of March, 2006, Christine Springer (Mother") and Kurt C. Springer ("Father"), stipulate to the following provisions being made an Order of Court: 1. Mother and Father shall share legal custody of their children Noah Springer, born January 20, 1996, age 10, Leah Springer, born December 28, 1997, age 8 and Micah Springer, born February 25, 2000, age 6. Both parents realize that it is critical for the child's health development to feel good about, and loving toward, both parents and that both parents play a major role in helping to achieve this goal. 2. The parties agree and acknowledge that Legal Custody shall mean the legal right to make major decisions affecting the best interests of the child, including, but not limited to, medical, religious, and education decisions. Each parry shall notify the other of any activity or circumstance concerning the child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. 3. Mother shall have primary physical custody of the child. Father shall have periods of partial custody as follows: A. Every other weekend, beginning March 24, 2006; Weekend is defined as Friday from 6 PM to Sunday at 6 PM. B. Tuesday evenings from 4 PM to 8 PM. C. Thursday evenings from 4 PM to 8 PM during the week followed by Father's custodial weekend. Thursday evening from 6 PM to Friday morning no later than 10 AM during the week not followed by Father's custodial weekend. D. Summers: Each party shall have ten (10) days of vacation with the children, not to be taken in more than seven (7) continuous days. Each parry shall notify the other, in writing, of the dates he or she wishes to exercise his or her custodial vacation time with the children no less than thirty (30) days in advance of said time. Mother shall exercise her custodial vacation time July 7th through July 15th and From May 9`h through May 1 Ph nll 5chCo(A j1de EederA( (..hd Ayl, S E. Holidays: The parties shall alternate custody on : labor W"r, Thanksgiving, Christmas, Easter, The 3 Hfl(1 ye Spe-F AS de 5U 16-d 6-e Icw, Ye5c 5 times that Father shall have custody of the children on his holidays is from 11:00 a.m. to 7:00 p.m. , e' ent a th ?1 5plif eyuntlY htFwUw fPt pt+f,.cs its hh? aec/CS 1. Christtjnas is to be defined as Cl?rpttt? Day at 3?BA p * 1 1? ? r ^y,CCS/ k". A+'Itl p. M. CuS Eody e,ACH ye.w' . / ?S 27th L M ??--ftc-obvpzu.? ?c5•/c5 SpenFw YH iVlrihe. A-wn 5eq-nn of day:.nf, 1l.aaAr# 2. Thanksgiving is to be " 5-p-41H h pdh,er 4?,m, I, ad A.M. un4 l 4:ooFM. ,w? refwwed ? c... ;7 ?t 6.00 , e&,,e e- Cs K"I cs EAfee s3 6.6e-> 81:(-, 4N he- ?vtaen fy- QA-fteS All ee-nnh49 3. 1 A.M. fl?l p.M, Gu5>'edye40hY'eA MMT4"-R . 4. Father and Mother shall alternate custody of the children on the children's birthdays every other year. 4. Each party understands that this custody schedule can be modified at any time with mutual consent, and can be permanently modified by mutual written consent in the form of an Amended Custody Agreement. 5. Both parents shall provide the other with all applicable telephone numbers, including home, work and cell phone numbers. Both parents shall provide the other addresses where the children will be residing. 7. The parties shall share transportation, with each party being responsible for arranging transportation to begin his/her custodial period. 8. During any period of physical custody, the parties shall not possess or use any controlled substance (other than legally prescribed medicines), nor shall they consume alcoholic beverages to excess. The parties shall ensure, to the extent possible, that others in the presence of the child comply with these prohibitions. 9. Each party agrees to not attempt to alienate the affections of the child from the other and will make a special effort to promote the relationship of the child with both parties. Both parties shall refrain from making derogatory comments about the other in the presence of the child and, to the extent possible, shall not permit third parties from making such comments in the presence of the child, whether the child is sleeping or awake. WITNESS CHRISTINE SPRINGER IZrx,-i ?n.?i WITNESS KURT C. S GE,R ?, t, t?4 l ?f( ?p l r-J n ?-, ?.? C; -, "n r .- -, } _ ? r;? T ?, ._ ? W ? ,' '! ,, ?.? ..?; _ L)1 D ?{ CHRISTINE SPRINGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v NO. 06-790 CIVIL ACTION - LAW KURT C. SPRINGER, IN CUSTODY Defendant ORDER r? AND NOW, this day of March, 2006, the Conciliator being advised that the parties have reached an agreement in the above matter, the Conciliator relinquishes jurisdiction. Hubert X. Custody C RFC.`F??,r?? NEAR Z 9 2096 I3Y:,_ Esquire II „gin r. _. ... _? ? ? ? '1?,?, . -i'; J .. RECENED APR 0 tG?6 a CHRISTINE SPRINGER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-790 : CIVIL ACTION - LAW O KURT C. SPRINGER, Defendant :CUSTODY ORDER AND NOW, this ,r day of 4A , 2006, upon presentation of the within Child Custody Stipulation and Agreement, entered into by the parties on March 22, 2006, a copy of which is attached as "Exhibit A", IT IS HEREBY ORDERED that the terms and provisions of the same are hereby approved and incorporated by reference in the present Order of Court, as fully as though, and with the same force and effect as if such Order had been entered after Petition, Notice and Hearing. %?? BY THE OOURT, J. is `?? .n i i;"? ? ?: u .? - .. ?, ? , <? ,?i CHRISTINE SPRINGER Plaintiff V. KURT C. SPRINGER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-790 : CIVIL ACTION - LAW :CUSTODY PLAINTIFF'S PETITION FOR SPECIAL RELIEF 1. Petitioner is Christine Springer, mother of the children Noah Springer, born January 20, 1996, age 10, Leah Springer, born December 28, 1997, age, 8 and Micah Springer, born February 25, 2000, age 6, in the above-captioned matter; Petitioner currently resides at 110 S. 27'' Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Respondent is Kurt C. Springer, father of the children, Noah Springer, born January 20, 1996, age 10, Leah Springer, born December 28, 1997, age, 8 and Micah Springer, born February 25, 2000, age 6, and Defendant in the above-captioned matter; Respondent currently resides at 3016 Dickinson Ave., Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant entered into a Custody Stipulation and Agreement dated March 22, 2006, and an Order of Court was entered on April 5, 2006, approving the Custody Stipulation and Agreement. A copy of the Order of Court and Custody Stipulation and Agreement is attached hereto as Exhibit "A" and is incorporated herein by reference. 4. On or about April 29, 2006, Respondent came to the home of the Petitioner to exercise his custodial visitation privileges with the children. A confrontation ensued regarding the division of the parties' possessions and Respondent left the Petitioner's residence without the children. 5. Shortly thereafter, Respondent returned to Petitioner's residence to pick up the children and advised Petitioner that she could no longer have use of the parties van and told her that he had placed a locking device on the steering wheel making the vehicle inoperable. 6. Petitioner owns a 1992 vehicle which is inoperable and requires extensive repairs all of which far exceed the value of the vehicle and Petitioner does not have sufficient financial means to obtain another vehicle or have the repairs completed on the 1992 vehicle. 7. Respondent now has in his possession and control the parties 2000 Jeep Cherokee and the 2004/2005 Chrysler van. 8. Petitioner was away from her residence on a group outing during the weekend of April 29' and 30`s. Upon returning home on April 30', the van which Respondent placed the locking device on the steering wheel was no longer at Petitioner's residence; Respondent telephoned Petitioner on the evening of April 30' and apologized for his actions and said that he would let Petitioner use the van. 9. Since that exchange, Petitioner has requested the use of the van from Respondent on several occasions and Respondent has refused to return the van to Petitioner. 10. Petitioner is in need of the vehicle for the following reasons: a. All three (3) of the parties' children have recently been diagnosed with asthma and with the recent increase in pollen count have encountered medical complications and she is unable to readily take them for medical treatment and/or obtain medication for them; b. Leah Springer broke her ankle on April 19, 2006, and has had doctors appointments associated therewith; The children are involved in sporting events and extra curricular activities and Petitioner has been forced to walk with the children to those events and because Leah Springer has a broken ankle, Petitioner has been forced to push her on a bicycle while the other children carry her crutches; d. Petitioner has not been able to attend church services or sporting events which she helps coach; e. As recent as May 4h, Petitioner has had to carry her daughter on her back to a friend's work place in order to borrow a vehicle in order to take Petitioner's son to his speech therapy session; f. Petitioner has had to cancel speech therapy for her son on May 11fl' because Respondent would not let her use the van and would not return her telephone calls when asked if he could possibly take the parties' son to his speech therapy; g. Petitioner is unable to adequately care for her children and provide for their medical and social needs. WHEREFORE, Petitioner respectfully requests that this Honorable Court Order Respondent to immediately grant to Petitioner the use of one of the vehicles pending the resolution of the equitable distribution of the parties assets involved in the divorce action presently pending. Petitioner further requests Respondent pay attorneys fees and costs associated with the filing and prosecution of this Petition for Special Relief plus any other remedies this Court deems appropriate. Respectfully submitted, Mark A. Mateya, Bdquire Attorney ID No. 78931 P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 Counsel for Petitioner '- Ir b? Date: 1 E EI ED APR 0 22006 CHRISTINE SPRINGER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-790 : CIVIL ACTION - LAW KURT C. SPRINGER, Defendant :CUSTODY ORDER KLL AND NOW, this. day of , 2006, upon presentation of the within Child Custody Stipulation and Agreement, entered into by the parties on March 22, 2006, a copy of which is attached as "Exhibit A", IT IS HEREBY ORDERED that the terms and provisions of the same are hereby approved and incorporated by reference in the present Order of Court, as fully as though, and with the same force and effect as if such Order had been entered after Petition, Notice and Hearing. BY THE COURT, 15AMo?6?&11)111 CHRISTINE SPRINGER s IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006790 CIVIL ACTION - LAW KURT C. SPRINGER, a o Defendant :CUSTODY rr.- -'o CUSTODY STIPULATION AND AGREEMENT n l n 7 AND NOW, this day of March, 2006, Christine Springer (Mother") ank rt Cw Om Springer ("Father', stipulate to the following provisions being made an Order of Court: 1. Mother and Father shall share legal custody of their children Noah Springer, born January 20, 1996, age 10, Leah Springer, born December 28, 1997, age 8 and Micah Springer, born February 25, 2000, age 6. Both parents realize that it is critical for the child's health development to feel good about, and loving toward, both parents and that both parents play a major role in helping to achieve this goal. 2. The parties agree and acknowledge that Legal Custody shall mean the legal right to make major decisions affecting the best interests of the child, including, but not limited to, medical, religious, and education decisions. Each party shall notify the other of any activity or circumstance concerning the child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. 3. Mother shall have primary physical custody of the child. Father shall have periods of partial custody as follows: A. Every other weekend, beginning March 24,2006; Weekend is defined as Friday from 6 PM to Sunday at 6 PM. B. Tuesday evenings from 4 PM to 8 PM. C. Thursday evenings from 4 PM to 8 PM during the week followed by Father's custodial weekend. Thursday evening from 6 PM to Friday morning no later than 10 AM during the week not followed by Father's custodial weekend. D. Summers: Each party shall have ten (10) days of vacation with the children, not to be taken in more than seven (7) continuous days. Each party shall notify the other, in writing, of the dates he or she wishes to exercise his or her custodial vacation time with the children no less than thirty (30) days in advance of said time. Mother shall exercise her custodial vacation time July 7a' through July 1 Sa' and From May 9a' through May 11 eu ,ras C III Sdwd roe/or Eedee"I kul ld"y S E. Holidays: The parties shall alternate custody on the follewing : i bar Berl, Thanksgiving, Christmas, NFWVW"4%y, Easter, . The S I+ 0 ye Tfe..l AS deSce 161J .66iaw. I(-3/CS times that Father shall have custody of the children on his holidays is from 11:00 a.m. to 7:00 p.m. e - Pnr c nrh --...,7 }, t gPlrl eq_ukgy IIehvelrw +P-& IOJt+f:it h ?^`hr'9 aa??CS .An 1. Christinasis to be defined as Ghri9l?nas Day ar-I m , u *I n b r "'AgAs A.M. -emd P.M. et-sW-j e-.*cH y-e w. 1,e"ICS CS gpenE..wt Y>'. ?'V1 after. Fi-wr be9,nn,„9 aF day un'l, ? 1 L'. oaArk 2. Thanksgiving is to be pn! sQsh?wrl+ Fnh et. p^an, lI-_Ov &^. Unfr'1 4:QOP(A, w?-' re{"nkd k4W/c5 rLC?/ En 4ee .S b? S l h n rtll yeJwae? fiue- P)144t 4 fte,"hn9 3. A.M. Ai4 P.M. Cushedy e4ch yam.-, xeS/C? mmrd??. 4. Father and Mother shall alternate custody of the children on the children's birthdays every other year. 4. Each party understands that this custody schedule can be modified at any time with mutual consent, and can be permanently modified by mutual written consent in the form of an Amended Custody Agreement. 5. Both parents shall provide the other with all applicable telephone numbers, including home, work and cell phone numbers. Both parents shall provide the other addresses where the children will be residing. 7. The parties shall share transportation, with each party being responsible for arranging transportation to begin his/her custodial period. 8. During any period of physical custody, the parties shall not possess or use any controlled substance (other than legally prescribed medicines), nor shall they consume alcoholic beverages to excess. The parties shall ensure, to the extent possible, that others in the presence of the child comply with these prohibitions. 9. Each party agrees to not attempt to alienate the affections of the child from the other and will make a special effort to promote the relationship of the child with both parties. Both parties shall refrain from making derogatory comments about the other in the presence of the child and, to the extent possible, shall not permit third parties from making such comments in the presence of the child, whether the child is sleeping or awake. 1 WITNESS CHRISTINE SPRINGER 44,14 WITNESS KURT C. S GER VERIFICATION MARK A. MATEYA, ESQUIRE, verifies that he is the attorney and agent for the Plaintiff herein, that the Plaintiffs verification cannot be obtained within the time allowed for the filing of this pleading, that as attorney for the Plaintiff, he has sufficient knowledge and information concerning the contents of the within document and that the facts set forth in the foregoing are true and correct to the best of his knowledge, information and belief. He understands that false statements made therein are made subject to the penalties of 18 Pa. C. S. §4904, relating to unworn falsification to authorities. MARK A. MAT A, ESQUIRE Dated: S CERTIFICATE OF SERVICE I, hereby certify that I have served a copy of the foregoing Petition for Special Relief on the following person(s) by depositing a true and correct copy of the same in the United States Mail, first class, postage prepaid, at Boiling Springs, Cumberland County, Pennsylvania addressed to: Kurt C Springer 3016 Dickinson Avenue Camp Hill PA 17011 Mark A. Mateya, Es ire P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 Dated: 5-1([ 0 n C c> c^ r -a CHRISTINE SPRINGER, PLAINTIFF V. KURT C. SPRINGER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 06-790 CIVIL TERM ORDER OF COURT AND NOW, this E_ day of May, 2006, a hearing on the within petition for special relief shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania at 4:00 p.m., Tuesday, May 16, 2006. By Edgar ff. Bayley, J. Mark A. Mateya, Esquire -- For Petitioner Y Kurt Springer a 3016 Dickinson Avenue Camp Hill, PA 17011 :sal n `--.2 ° PA G v ?. c t ` -?c r p - ? ? C ? t`} ?. M CHRISTINE SPRINGER, PLAINTIFF V. KURT C. SPRINGER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 06-790 CIVIL TERM ORDER OF COURT AND NOW, this L.._ day of May, 2006, a hearing on the within petition for special relief shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania at 4:00 p.m., Tuesday, May 16, 2006. Mark A. Mateya, Esquire r p8ascuuadr q l vfA? For Petitioner Kurt Springer C1 op/ m ? 3016 Dickinson Avenue ' Camp Hill, PA 17011 :sal n ° CZ? - gn 0 ?' .-c , - - 13 -c G DO CHRISTINE SPRINGER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-790 : CIVIL ACTION - LAW KURT C. SPRINGER Defendant :CUSTODY DEFENDANT'S REQUEST TO DENY PLAINTIFF'S PETITION FOR SPECIAL RELIEF AND COUNTER REQUEST FOR SPECIAL RELIEF 1. Paragraph 1 is admitted. 2. Paragraph 2 is admitted with the clarification that Petitioner and Respondent reside only a few blocks apart within easy walking distance of one another. 3. Paragraph 3 is admitted. 4. Paragraph 4 is denied. Respondent went to the Petitioner's home at 9:00 A.M. on April 29, 2006 as per Petitioner's specific request to have the children picked up at that time and place. Respondent called at 8:30 A.M. for the purpose of determining whether the children would be ready to depart promptly. Respondent's phone call went unanswered and he left a message on Petitioner's answering machine requesting that the children be ready promptly at 9:00 A.M. Unfortunately, the children were not ready to depart at the predetermined time. There was no confrontation. Respondent simply asked for the return of an item Petitioner removed from the home when she abandoned Respondent and the marital home. When she refused the request, Respondent left indicating that he would return shortly to pick up the children, with respect to whom he once again requested be readied for departure as per the agreed upon time and place. 5. Paragraph 5 is denied. After waiting what he believed to be a sufficient amount of time for the children to be ready, based on his earlier observation of the children, returned to Petitioner's residence as he had stated he would. At that time, Respondent repeated his prior notification, clearly communicated to Petitioner on April 8, 2006 and at other times that Petitioner would not be able to continue to operate his 2005 Chrysler Town & Country van unless she was willing to bear the costs of operating and purchasing the vehicle. Accordingly, respondent rendered the vehicle inoperable. Petitioner had induced the Respondent to purchase this van in mid-July of 2005 all the while knowing that she intended to abandon the Respondent and the marital home, which she did at the end of August 2005. Petitioner herself located this vehicle and convinced the Respondent under false pretenses (i.e., that the parties would continue to remain married and an intact family) to purchase the vehicle. However, she refused to be a party to the financing of the vehicle, which at the time seemed odd to Respondent, who proceeded to purchase the vehicle individually and not jointly. When Petitioner acted to change the underlying circumstances and living arrangements, Respondent's hidden agenda became readily apparent, as did the fact that Respondent would no longer be able to afford to make the finance loan payments for the 2005 Chrysler Town & Country van. Petitioner's subterfuge is even more malicious considering that the vehicle purchased had a salvage title, meaning that for all intents and purposes, the vehicle is not able to be resold and Respondent is stuck with the vehicle. Petitioner has refused all requests to contribute to either the finance loan payments of the vehicle or the costs of insuring the vehicle, despite being permitted by Respondent to operate the vehicle up until this time. 6. Petitioner does own a 1992 vehicle, but the other allegations of Paragraph 6 are denied. The purchase of the 2005 Chrysler Town & Country van was meant to be a replacement of a 1992 Dodge Caravan titled in Petitioner's name. The older Caravan had been involved in an accident and the insurance proceeds of approximately $2,000 were intended to, and agreed upon by the parties, to go toward the purchase of the new vehicle. But for such an agreement regarding the use of the insurance proceeds in this manner and the implicit assumption that the marriage and family would remain intact, Respondent would not have consented to the purchase of the new vehicle. However, Petitioner kept the insurance proceeds and failed to apply these to the new vehicle purchase as agreed. Following her abandonment of the Respondent and the marital home, Petitioner then insisted and continues to insist that she did not wish to purchase the new vehicle but instead desired to apply the insurance proceeds to the repair of the 1992 Dodge Caravan. On April 8, 2006 Respondent specifically advised Petitioner that he could not afford the costs of two vehicles and it was therefore necessary to sell the 2001 Jeep Grand Cherokee, since the 2005 Chrysler Town & Country van was not saleable due to the salvage title. Again, Petitioner restated her plan to repair the 1992 Dodge Caravan and provided Respondent the extra set of keys so that he would be able to sell the 2001 Jeep Grand Cherokee. However, she made no attempt to repair the 1992 Dodge Caravan, despite the advance notification provided her and her understanding and agreement demonstrated in providing Respondent the keys for the sale of the Jeep. Only after Respondent recovered the 2005 Chrysler Town & Country van did the Petitioner make any attempt to pursue her stated course of action. Petitioner, in fact, does have the means to repair the 1992 Dodge Grand Caravan as she retained the insurance proceeds specifically for that purpose. Petitioner also receives approximately $633 per month in Social Security payments for the children as well as $1,370.15 from respondent in child and spousal support (see PA SCDU information, attached) for a total of over $2,000 per month in disposable income. She also has the ability to seek and retain employment but has elected not to do so. Respondent, on the other hand, is a totally disabled individual entirely dependent upon his $1,267 social security check each month, out of which he must provide the aforementioned $1,370.15 and meet his own needs and those of the children while in his care. 7. Because of Respondent's dire financial situation, as noted above, he must sell his only remaining saleable vehicle, the 2001 Jeep Grand Cherokee, to avoid repossession of the 2005 Chrysler Town & Country van, as well as meet his basic living necessities, and continue to make the child and spousal support payments. Respondent is in the process of selling the 2001 Jeep Grand Cherokee but this task has been difficult in light of respondent's disabilities and Petitioner's attempt to keep available to her either option of assuming responsibility for the 2005 Chrysler Town & Country or repairing the 1992 Dodge Caravan. Respondent had asked the Petitioner for a definite answer as to whether she wished to assume financial responsibility for the 2005 Chrysler Town & Country. Petitioner had suggested recent uncertainty to Respondent as to whether she was going forward with repairs to the old van. Respondent offered the new van to Petitioner provided she was able to be financially responsible for ownership. On or about May 8, 2006, Petitioner finally notified Respondent that she did not wish to assume ownership of the 2005 Chrysler Town & Country. Respondent therefore is now preparing the 2001 Jeep for sale. While this sale is pending, Respondent does not desire for the Petitioner to use the 2005 Chrysler Town & Country van for fear of what she might do to it, her unwillingness to assume or even contribute to the costs of ownership of this vehicle, and the demonstrated untrustworthiness of Petitioner. Respondent is personally aware of numerous occasions in which Petitioner has driven the vehicle in a reckless and dangerous manner. For example, on or about March 10, 2006, Petitioner followed Respondent's vehicle in a threatening and close manner. On that same date, she also sped through the streets of Camp Hill borough with the van door open and the children, not only out of their safety restraints, but out of their seats as well! This incident was reported and a record is on file with the Camp Hill Police Department. Petitioner also has removed herself from the insurance policy covering both the Jeep and Chrysler Town & Country vehicles (paid for entirely by Respondent) further evidencing her desire to repair and revert to use of the 1992 Dodge Caravan (for which she then established a separate insurance policy). Petitioner suggested writing a specific agreement covering any permissible use of the 2005 Chrysler Town & Country van by her, and Respondent was amenable to this possibility and indicated that he perhaps would contemplate the shared use of the Town & Country. However, Petitioner never created such a document, or at least, never presented it to Respondent and has apparently pursued the matter via her Special Relief action instead. 8. Respondent did remove the 2005 Chrysler Town & Country van from the public street it was parked on and recovered the vehicle to his residence. There was a significant amount of trash left in the vehicle, but everything of value as well as the registration and insurance cards had been purposefully removed (the registration card only was returned to the Respondent, but only after he requested the return of both documents) . The vehicle was also past due for maintenance service. However, Respondent denies apologizing for the actions taken as they were consistent with his previously stated intentions and Petitioner's demonstrated understanding and agreement. Respondent denies saying that he would let Petitioner use the van but he was hopeful they could come to some amicable resolution regarding use of the 2005 Chrysler Town & Country until the Petitioner followed through with the repair of the 1992 Dodge Grand Caravan. 9. Petitioner has asked the Respondent for use of the 2005 Chrysler Town & Country van on a few occasions. Each of these times Respondent indicated that he was in the process of selling the 2001 Jeep and attempted to address the lack of trust and what limits might be placed on the use of the van, when and how it will be returned, whether Petitioner is willing to assume loan and insurance payments for the vehicle, etc. Petitioner is unwilling to constructively discuss such issues or else has proposed solutions that are either unworkable or not followed through on by Petitioner (e.g., a written agreement regarding her use of the van). Respondent as legal custodian of the children is available 24 hours a day, 365 days a year to meet any transportation need the children may have. Respondent is not employed due to his disability and is therefore available all the time and this fact has been repeatedly communicated to the Petitioner while she has been in the process of having the 1992 Dodge Grand Caravan repaired. Respondent has made himself available always to take the children places either alone or with Petitioner. Respondent has repeatedly asked for advance notice regarding the children's scheduled activities for each particular week, this was a regular practice even before it became necessary to sell the 2001 Jeep. Unfortunately, Petitioner, in an apparent attempt to limit the Respondent's participation in the children's' lives has repeatedly and consistently failed to notify him at all, or in a timely manner, with respect to scheduled activities. This is in direct violation of the parties' custody agreement where it is agreed that "[e]ach parry shall notify the other of any activity or circumstance concerning the child that could reasonably be expected to be of concern to the other." (Paragraph 2 of Custody Agreement, attached). It is also the primary reason Petitioner has placed herself in a position of being without transportation. 10. While it is not denied that Petitioner ownership of a vehicle would make her life easier, it is inequitable and patently unfair for the Respondent to be required to provide and be financially responsible for any such vehicle in addition to the significant financial support he is already providing. This is especially true given the disingenuous and mean- spirited manner in which Petitioner acted in intentionally misleading the Respondent to purchase a vehicle which she knew he would be unable to afford and resell, if necessary. Respondent's financial responsibility to Petitioner and the children has been established. Petitioner is entirely able to afford the repair and ownership costs of the 2002 Dodge Grand Caravan (as she originally desired), the 2005 Chrysler Town & Country, or any other vehicle she desires to own. As shown earlier, she retained approximately $2,000 in insurance proceeds specifically for that purpose and has an income stream of over $2,000 per month - all the while the Respondent continues to go further into to debt to meet only his minimal living expenses. Respondent is financially incapable of meeting his own needs, let alone any excessive expenses that petitioner simply wishes not to pay for, despite her demonstrated ability to do so. Petitioner has willfully prevented Respondent from making any additional money other than his monthly $1,267 social security check. Respondent has frequently stated the intention of selling certain of his personal items on EBay, but Petitioner has refused numerous requests to provide the computer and connecting cables which she removed from the marital home, without the knowledge or consent of the Respondent, when she abandoned the marital home and marriage in August 2005. Despite Respondent's numerous documented severe medical conditions resulting in his total disability, Petitioner abandoned the marital home and removed most of the marital property from the home when she left. With respect to the reasons listed for petitioner's need of a vehicle, these have been so greatly exaggerated and significantly limited in explanation as to require comment. For example: a. With respect to the children's asthma, Petitioner utilizes the Giant store pharmacy which is approximately four blocks away from her home. Petitioner has frequent opportunity to pickup medications while the children are in the custody of respondent each week. Respondent is also available for this task and has, in fact, gone to this same pharmacy to pick up prescription medication for the children. In reality, the children have not missed any doctors' appointments or been delayed in obtaining any medication (other than when Petitioner failed to notify the pharmacy of her insurance information, resulting in Respondent being unable to obtain medication for the children). Respondent has taken the children to scheduled medical appointments on at least two occasions. On one occasion, he was required to do so since petitioner had made the appointment for during respondent's scheduled time with the children. Petitioner notified Respondent of this particular appointment only the night before despite knowing for weeks that she had scheduled the appointment during Respondent's time with the children. Petitioner has continued to act in bad faith and contrary to the custody agreement in this regard. Respondent has clearly communicated his willingness and availability to meet the children's medical needs at any time or place. With respect to the children encountering "medical complications," only Micah Springer developed an allergic reaction in the late afternoon one day, which Respondent properly recognized and for which he presented a medically appropriate treatment plan until Micah was able to be seen by the doctor at the next available appointment on the following day. b. Leah Springer has missed no doctors' appointments related to the treatment of her broken ankle. The treatment of her broken ankle has concluded. c. To Respondent's knowledge, the children have missed no known sporting events due to a lack of transportation. Respondent has transported the children to numerous other such activities this spring. Respondent has also communicated his constant availability to drive the children to such activities. If, at any time, Petitioner walked to such events she did so voluntarily after refusing Respondent's offer for transportation or else declining other available transportation from friends and family. d. Respondent and Petitioner attend the same church, as do many of their friends and family. If, at any time, Petitioner decided not to attend any church service she did so after refusing Respondent's offer for transportation or else declining other available transportation from friends and family. Petitioner stated to Respondent that she would discontinue her assistance in coaching Leah Springer's softball team since Leah would be unable to participate due to her broken ankle. Respondent has finally succeeded in extracting information from Petitioner regarding the children's' schedule of activities. Respondent wonders why he is only now able to obtain this information and questions whether Petitioner's recent willingness to disclose such information is somehow related to this most recent legal action. e. Respondent was provided information about Noah Springer's recently scheduled May 4th speech therapy appointment, but only was able to obtain this information after exhaustive questioning of Petitioner. Respondent offered to take Noah and Petitioner to this appointment. Not only did she decline this offer but she apparently made other arrangements to take him. Certainly, had Respondent been notified that Petitioner had alternate travel arrangements he would have been willing to take them to this friend's workplace. If, at any time, Petitioner walked to such a place she did so voluntarily after refusing Respondent's offer for transportation. f. If Petitioner had to cancel a speech therapy session for Noah Springer on May 11'x', she did so voluntarily after refusing Respondent's offer for transportation or else declining other available transportation from friends and family. Petitioner did leave messages on Respondent's answering machine very late the evening prior and very early the day of the appointment. Had Respondent been notified in advance or received even the late notice, he would have gladly voluntarily taken Noah and Petitioner to this appointment. If any such appointment were canceled it was done so by Petitioner after failing to notify Respondent of the time and place of the appointment. Petitioner has had available to her not only the offer of assistance from Respondent but also the actual use of at least two vehicles belonging to friends and family while she is in the process of having the 1992 Dodge Grand Caravan repaired and is currently in possession of a vehicle. 11. Because of Plaintiff s continuing violation of the parties' custody agreement by refusing to inform Defendant about the children's activities and appointments in advance, Defendant has asked Plaintiff on numerous occasions to communicate these to him on a weekly basis in advance. She refuses to comply with this reasonable request with any degree of regularity. 12. Plaintiff has retained the insurance proceeds received for the damage to the 1992 Dodge Grand Caravan contrary to what she agreed to do with these funds. If Plaintiff elects not to repair the 1992 Dodge Caravan, then Defendant would request that she provide these funds to defendant so that he might apply the funds toward payment of the 2005 Chrysler Town & Country as per the parties original intention and agreement. WHEREFORE, Respondent respectfully requests that this Honorable Court immediately deny Petitioner's Petition for Special Relief filed by Plaintiff based upon a lack of sufficient cause shown. Based upon the facts, Plaintiff possesses the means to adequately and specifically provide for the costs of ownership, maintenance and insurance of a vehicle of her own. If this Honorable Court is unable to immediately deny Petitioner's Petition for Special Relief, Respondent requests a hearing before this Honorable Court to decide whether, after consideration of all facts and circumstances, Plaintiff should be required to provide for the costs of ownership, maintenance and insurance of a vehicle of her own. Respondent further requests that Petitioner pay all reasonable fees and costs associated with the preparation, filing and prosecution of Defendant's Request to Deny Plaintiffs Petition for Special Relief and Counter Request for Special Relief in addition to any other remedy this court deems appropriate. WHEREFORE, Respondent respectfully counter requests that this Honorable Court order the Plaintiff to comply with the parties' custody agreement by informing Defendant, in advance, on a weekly basis in writing, via email or other acceptable written means of correspondence the exact nature, time and place of all scheduled activities and appointments for the children, to include but not limited to doctors' appointments, sports activities, library activities and all other such activities that a father in Defendant's position might reasonably be expected to be informed of and to attend. And further, if Plaintiff elects not to repair the 1992 Dodge Caravan, that she be ordered to pay to Defendant a verifiable sum equal to the insurance proceeds received for the damage to the 1992 Dodge Grand Caravan. Respectfully Submitted, A-a C Kurt C. Springef, ?e Respondent 3016 Dickinson Avenue Camp Hill, PA 17011 (717) 737-3075 Date: 5-11?l©t I hereby certify that I have served a copy of the foregoing Defendant's Request to Deny Plaintiff s Petition for Special Relief and Counter Request for Special Relief on the following person, attorney of record, by depositing a true and correct copy of the same in the United States mail, first class, postage prepaid, at Camp Hill, Cumberland County, Pennsylvania addressed to: Mark Mateya P.O. Box 127 Boiling Springs, PA 17007 Kurt C. Springef, re Respondent 3016 Dickinson Ave. Camp Hill, PA 17011 (717) 737-3075 Dated: S / 5 0? Form:cpolk Pennsylvania State Collection and Disbursement Unit (PA SCDU) IMPORTANT INFORMATION 1. Remit a signed check or money order payable to PA SCDU. DO NOT ENCLOSE CASH OR CORRESPONDENCE. Write the Member ID on the check or money order. Remit coupon with payment. 2. Print the amount paid in the field marked "AMOUNT ENCLOSED". 3. If the address is no longer valid, mark the CHANGE OF ADDRESS box and indicate the changes on the PAYMENT COUPON. 4. Please use the envelopes and coupons provided to remit support payments. DISCARD ANY UNUSED COUPONS. 5. If you have any questions regarding this bill, contact your Domestic Relations Section. 125.212 ?n??llnrl?Innnllnrll?I?lu?Irlnl?Ilnln??llrl?n???„I C01_126.3 KURT SPRINGER 3016 DICKINSON AVE CAMP HILL PA 17011-5228 VISA / Mastercard now accepted at 1-800-955-2305 If you would like information on additional payment options via credit card payments, recurring automatic withdrawals, or pay-by-phone, contact the PA SCDU Customer Service Unit at 1477-PASSCDU. Other electronic options are available at: • ExpertPay.com (Bank Account Holders) • Western Union PAYER MEMBER ID: 8423100777 SSN: 205-56-6713 AS OF: 05/05/2006 AMOUNT DUE: $1,370.15 IREPOW MONTHLY STATEMENT OF ACCOUNT Contact 1-800-829-1040 or www.irs.gov/eitcfor more information on the IRS Earned Income Tax Credit (EITC) Program. Cpol_l26.3 3002 F..;::cess our on-line sevices at www. childsupport. state. pa. us CASE ID # CURRENT AMOUNT ARREARS BALANCE 588103430 $1,370.15 $2,691.55 Notice: Effective 1/6/03 all bank returns are being sent to CSI for private collection. These collection efforts can include electronic collection from your account as well as traditional methods. M 1 E I ED FAPR 0 Y420( CHRISTINE SPRINGER : IN THE COURT LE Plaintiff OF COMMON PLEAS :CUMBERLAND CO UNTY, PENNSYLVANIA V. : NO. 200&790 KURT C. SPRINGER, CIVB? ACTION - LAW Defendant :CUSTODY DR "E AND NOW, this. l day of 2006, upon Presentation of the within Child Custody Stipulation and Agreement, entered into by the parties on March 22, 2006, a copy of which is attached as "Exhibit A", IT IS HEREBY ORDERED that the terms and provisions of the same are hereby approved and incorporated by reference in the present Order of Court, as fully as though, and with the same force and effect as if such Order had been entered after Petition Notice and Hearing. BY THE COURT, tuV ?' c CHRISTINE SPRINGER : IN THE COURT OF COMMON PLEAS Plaintiff s CUMBERLAND COUN•ry PENNSYLVANIA V. : NO. 2006.790 KURT C. SPRINGER, = CIVIL ACTION. LAW s Defendant s CUSTODY r_ cm O R M CUSTODY STIPULATION AND AGREEMENT % =V -C w V AND NOW thi ,y' - v -r_' Y. Lb4dday of March, 2006, Christine Springer (Mother an ?y C,m '? (&W C'W o c? Springer ("Father'), stipulate to the followin x' 8 Provisions being made an Order of Court C' I . Mother and Father shall share legal custody of their children Noah Springer, born January 20, 1996, age 10, Leah Springer, born December 28, 1997, age 8 and Micah Springer, born February 25, 2000, age 6. Both parents realize that it is critical for the child's health development to feel good about, and loving toward, both parents and that both parents play a major role in helping to achieve this goal. 2. The parties agree and acknowledge that Legal Custody shall mean the legal ri ght to make major decisions affecting the best interests of the child, including, but not limited to, medical, religious, and education decisions. Each party shall notify the other of any activity or circumstance concerning the child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. 3. Mother shall have primary physical custody of the child. Father shall have periods of partial custody as follows: A. Every other weekend, beginning March 24, 2006; Weekend is defined as Friday from 6 PM to Sunday at 6 PM. B. Tuesday evenings from 4 PM to 8 PM. C. Thursday evenings from 4 PM to 8 PM during the week followed by Father's custodial weekend Thursday evening from 6 PM to Friday morning no later than 10 AM during the week not followed by Father's custodial weekend. D. Summer': Each party shall have ten (10) days of vacation with the children, not to be taken in more than seven (7) continuous days. Each party shall notify the other, in writing, of the dates he or she wishes to exercise his or her custodial vacation time with the children no less than thirty (30) days in advance of said time. Mother shall exercise her custodial vacation time July 7a' through July 15" and From May 90` through May 11 th. E. Holidays; The parties shall alternate cu 11 Schod ??a/or Ee4e?l Hold y.e„ C atody on iabW fie Her, Thanksgiving, Christmas, NEW40 Is , Easter, S 4(1 ?e Spe•.l' qS descr j bid 64 (aw. (C3/CS Mewmfir? times that Father shall have custody of the children on his holidays is from 11:00 a.m. to 7:00 p.m. S pI rp eq-u'&qY .ht?H ? J+ P4.1 A*-JJ+h n? Kcc/CS 1. Chris as is to be k ? r A?iCCS?? A. M. oamd Pm• C.us kad-j e,*ch ye,w . f?G'r/CS .; 11GS?c5 , ` e•+F w? f? 1'N dfNr. F?-o,?? be9?n h H9 o f al,?r Lhf, i 1 L : cap 2. Thanksgiving is to be Sp efined (is being P q 4 a e - '9'eWv I I . a 0 k . A l i i.1 4 : 60 pM, w 1,% re{w? Ot iA SUP64 at • ' ' IM ° ,e e,4C,51CS Kc-71cS FA fie. 15 4 be S 1: 1L 3. 4 ,t 11 b&4-41-0e,% fly, P^htt U P- h* A as . M. Cu $4* y e4c, y -e.* r S • 4. Father and Mother shall alternate custody of the children on the children's birthdays every other year. 4. Each party understands that this custody schedule can be modified at any time with mutual consent, and can be permanently modified by mutual written consent in the form of an Amended Custody Agreement. 5. Both parents shall provide the other with all applicable telephone numbers, including home, work and cell phone numbers. Both parents shall provide the other addresses where the children will be residing. 7. The parties shall share transportation, with each party being responsible for arranging transportation to begin his/her custodial period. 8. During any period of physical custody, the parties shall not possess or use any controlled substance (other than legally prescribed medicines), nor shall they consume alcoholic beverages to excess. The parties shall ensure, to the extent possible, that others in the presence of the child comply with these prohibitions. 9. Each party agrees to not attempt to alienate the affections of the child from the other and will make a special effort to promote the relationship of the child with both parties. Both parties shall refrain from making derogatory comments about the other in the presence of the child and, to the extent possible, shall not permit third parties from making such.comments in the presence of the child, whether the child is sleeping or awake. ej, _WITNESS CHRISTINE SPRINGER WITNESS KURT C. S GER VERIFICATION Kurt C. Springer, verifies that he is the Respondent herein and that the facts set forth in the foregoing document are true and correct to the best of his knowledge, information and belief. Respondent understands that false statements made therein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. I<ic Kurt C. Sprin er spondent Dated: ? ? /u? ` - to ?; , l- +, v cri `?--? r_a ?r j CHRISTINE SPRINGER, Plaintiff V. KURT C. SPRINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ©b, CIVIL ACTION - LAW 06-0790 CIVIL TERM ORDER OF COURT AND NOW, this 16th day of May, 2006, this matter having been called on a petition for special relief, it is ordered that pending further order of court or private agreement of the parties, temporary possession of the 2001 Jeep Cherokee shall be with husband, and temporary possession of the 2005 Chrysler van shall be with wife. ,Xark A. Mateya, Esquire For Plaintiff VKurt C. Springer, pro se 3016 Dickinson Avenue Camp Hill, PA 17011 Sheriff prs d c> ? a ? 7Tl ''O L ° ets '- < CHRISTINE SPRINGER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-790 CIVIL ACTION - LAW KURT C. SPRINGER, Defendant : DIVORCE/CUSTODY PLAINTIFF'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND ANSWER TO INTERROGATORIES TO THE HONORABLE JUDGES OF THE SAID COURT: Plaintiff, Christine Springer, by and through her attorney, Mark A. Mateya, respectfully represent the following: 1. Plaintiff is Christine Springer, who currently resides at 110 S. 27th Street, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant is Kurt C. Springer, who currently resides at 3016 Dickinson Avenue, Camp Hill, Cumberland County, Pennsylvania, 17011 3. In accordance with Pa. R. Civ. P. 4009, on June 1, 2006, Plaintiff served Interrogatories and a Request for Production of Documents upon Defendant. 4. Plaintiffs Interrogatories sought information regarding Defendant's employment, any ownership in real estate, any and all assets, as well as any other financial information, to be provided within thirty (30) days of the date of service. 5. Plaintiff's Request for Production of Documents sought any and all documents relied upon in answering the Interrogatories, to be produced within thirty (30) days of the date of service. 6. Repeated attempts to request a response to the discovery documents have gone unanswered. 7. Defendant is a graduate of the Dickinson School of Law and has practiced law and is, therefore, well aware of the law concerning discovery and the requirement to respond to the discovery requests. WHEREFORE, Plaintiff moves this Honorable Court to enter an Order as follows: a. directing Defendant to answer Plaintiff s Interrogatories within ten days of this Court's Order; b. directing Defendant to produce any documents relied upon in answering the Interrogatories so that Plaintiffs attorney may review said items; c. Such other relief as this Honorable Court deems appropriate. Respectfully submitted, t',A-&A _ 692;z Mark A. Mateya, Esq e Attorney I.D. No. 789 1 P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 (717) 241-3099 Fax Counsel for Plaintiff -3 110(167- Date: CERTIFICATE OF SERVICE I, hereby certify that I have served a copy of the foregoing Motion to Compel Response to Discovery on the following person(s) by depositing a true and correct copy of the same in the United States Mail, first class, postage prepaid, at Boiling Springs, Cumberland County, Pennsylvania addressed to: Kurt C Springer 3016 Dickinson Avenue Camp Hill PA 17011 "'? - C: .... Mark A. Mateya, q ire P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 r= Dated: 0 -7 v ° 7. " ?v Um -n t?.? :3 L CHRISTINE SPRINGER Plaintiff/Petitioner V. KURT C. SPRINGER, Defendant/ Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-790 CIVIL ACTION - LAW :CUSTODY PETITION TO MODIFY CUSTODY NOW COMES, Plaintiff/Petitioner, Christine Springer, (hereinafter referred to as Petitioner), by and through her counsel, Mark A. Mateya, Esquire and avers the following: 1. Petitioner herein is Christine Springer, presently residing at 3016 Dickinson Ave., Camp Hill, Cumberland County, Pennsylvania, and is the natural mother of the minor children, namely Noah Springer, born January 20, 1996, agel3, Leah Springer, born December 28, 1997, age 11 and Micah Springer, born February 25, 2000, age 9 (hereinafter the "children"). 2. Defendant/Respondent herein is Kurt C. Springer, presently residing at 3008 Harvard Avenue, 2nd Fl, Camp Hill, Cumberland County, Pennsylvania, and is the natural father of the children. 3. The parties herein are the parents of the following minor children: Name Present Address Age DOB Noah Springer 3016 Dickinson Ave 13 1/ 20/1996 Camp Hill, PA Lea Springer 3016 Dickinson Ave 11 12/28/1997 Camp Hill, PA Micah Springer 3016 Dickinson Ave 9 2/25/2000 Camp Hill, PA 4. A Custody Order was entered on April 5, 2006, in the case sub judice. See Exhibit "A" attached hereto and incorporated herein. 5. The Honorable Judge Edgar B Bayley has previously presided over the instant matter. 6. Defendant/Respondent herein is unrepresented by counsel and has participated as a pro se litigant. 7. Plaintiff/Petitioner's counsel sought concurrence from Defendant/Respondent in filing the instant Petition for Modification. To date, Defendant/Respondent has failed to communicate with Plaintiff/Petitioner's counsel and either give his concurrence or non-concurrence. It is therefore believed that Defendant/Respondent does not concur with the filing of this Petition to Modify Custody. 8. Since the entry of this Order, there have been changes in circumstances, referenced in Paragraphs 9 and 10 below, which Petitioner believes and therefore avers call for a change in the Custody Order. 9. Respondent has health issues which make it difficult for him to properly assist and supervise the children during his prolonged times of custody, especially the overnight visits. 10. Petitioner believes and therefore avers that Respondent has mistreated the children during overnight visits. I 1. Petitioner wishes to reduce the overnight visits with Respondent to one overnight weekend per month. WHEREFORE, petitioner requests the present Order be ratified in all respects except the following changes: 1. Paragraph 3A shall read, in pertinent part ": Weekend is defined as Friday at 6 PM to Sunday at 6 PM. Every-other weekend of father's visitation shall include overnight with father. Father's non-overnight alternating weekend shall be until 9 PM Friday evening, 9 PM Saturday evening, and 6 PM Sunday evening. " 2. Paragraph 3C shall read "Thursday evenings from 4 PM to 8 PM." 3. Paragraph 3D shall remain the same, with the removal of the final sentence which begins "Mother shall exercise her custodial vacation time July 7th..." 3. The remainder of the Order shall remain unchanged. Date: L 1 Respectfully submitted, "A - k-IZ-_ Mark A. Mateya, Esq e Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 (717) 241-3099 VERIFICATION I, Christine Springer, verify that the statements made in this Petition to Modify Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann. § 4904 relating to unsworn falsification to authorities. Christine Springer (LtiI Date: - " 1q, 0 S t CERTIFICATE OF SERVICE I, hereby certify that I have served a copy of the foregoing Petition to Modify Custody on the following person(s) by depositing a true and correct copy of the same in the United States Mail, first class, postage prepaid, at Boiling Springs, Cumberland County, Pennsylvania addressed to: Kurt C Springer 3008 Harvard Ave 2nd Floor Camp Hill PA 17011 Mark A. Mateya, Esq i e P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 Zz d Dated: HI FILED iA OF THE: P" - 1'_ (TARY, C ?'? j i 2P,09 APR 24 A;i 11: 58 $U-00 PO A7rY CLV 83h Vr* aayaa3 CHRISTINE SPRINGER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KURT C. SPRINGER DEFENDANT 2006-790 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, May 04, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, June 11, 2009 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR. THE COURT, By: /s/ Hubert X. GAro Es T. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 RLLLr' i 2 009 VIA -? Aft 10: ?s M9V JUN '41 r) 10(),q CHRISTINE SPRINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW KURT C. SPRINGER, NO.2006-790 Defendant IN CUSTODY PRIOR JUDGE: Edgar B. Bayley COURT ORDER AND NOW, this b.6[ day of , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A hearing is scheduled in Court Room No. 2 of the Cumberland County Courthouse on the aday of_ GQ&, 2009 ate p.m. At this hearing, the father shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. Pending further Order of this Court, the existing Custody Order entered in this case shall remain in place. BY THE CO4Bayle Judge cc: Mark A. Mateya, Esquire Thomas D. Gould, Esquire LO l DES l7'l d 1, 1OY CHRISTINE SPRINGER, Plaintiff vs. KURT C. SPRINGER, Defendant PRIOR JUDGE: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.2006-790 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Noah Springer born January 20, 1996, Lea Springer born December 20, 1997, and Micah Springer born February 25, 2000. 2. The Conciliator conducted a Conference a number of weeks ago and the parties were to indicate whether they wanted to proceed with a hearing or have a Custody Evaluation performed. The parties have since advised the Conciliator that a hearing is necessary. 3. Father is seeking to increase his time with the children. He suggests that he has a Military disability and is unable to work and, therefore, is available to provide additional time as a father. The mother, on the other hand, wants to maintain the present custody schedule while eliminating some of the father's overnight visitation. Mother suggests the father is unable to care for the children because of his disability. 4. A hearing is necessary in this matter and the Conciliator recommends an Order in the form as attached. Date: , 2009 Hubert X. Gilroy, Es ire Custody Conciliato RLEfCf JF THE " 2009 JUL -7 III P: 42 CHRISTINE SPRINGER, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KURT C. SPRINGER, DEFENDANT 06-0790 CIVIL TERM ORDER OF COURT AND NOW, this 30th day of July, 2009, following a hearing on the merits, the requests to modify the current custody order of April 5, 2006, ARE DENIED. ? Mark A. Mateya, Esquire For Christine Springer Thomas D. Gould, Esquire For Kurt Springer :sal Ccr £.s Mix LL Fl [I D', ?N OF THE Y 2 -U L 30 P i i 12: 26 7 - l j t.1, CHRISTINE SPRINGER, : Plaintiff V. KURT C. SPRINGER, ; Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO.: 2006-790 CIVIL ACTION - LAW IN CUSTODY PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw- the appearance of Mark A. Mateya, Esquire, as counsel for Plaintiff, Christine Springer, in the above-captioned :natter. ?? n N Q o ^. 'tl m Mark A. Mateya, quire Hi Attorney I.D. 4878931 P.O. Box 127 ' Boiling Springs, PA 17007 rr, Date: , 2010 (717) 241-6500 ?., PRAECIPE FOR ENTRY OF APPEARANCE Kindly enter the appearance of Goldberg Katzman, P.C., and Paul J. Esposito, Esquire, as counsel for Plaintiff, Christine Springer, in the above-captioned matter. Date: '2010 GOLll ERG ' 'ZMAN, P.C. GOLD/ Paul J. E osit Attorney I.D. 25454 320 Market Street, P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 lob ~ Paul J. Esposito, Esquire I.D. #25454 GOLDBERG KATZMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161; (717) 234-6808 (facsimile) Counsel for Plaintiff CHRISTINE SPRINGER, Plaintiff V. KURT C. SPRINGER, Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA N NO.: 2006-790 p 1 ? CIVIL ACTION - LAW IN DIVORCE cn PETITION FOR RELATED CLAIMS UNDER DIVORCE CODE The Petition of Christine Springer, by her attorneys, Goldberg Katzman, P.C. and Paul J. Esposito, Esquire, respectfully represents that: Petitioner is the Plaintiff in the above-captioned divorce matter. 2. Petitioner requests that this Court preserve her claims for alimony, alimony pendente lite, counsel fees, costs and expenses in this matter. WHEREFORE, Petitioner prays this Honorable Court to preserve her claims for alimony, alimony pendente lite, counsel fees, costs and expenses, whether or not a decree in divorce terininating the parties' r .usage is catered pricr to the final res zludon of thest claims. Respectfully submitted, GOLDBERG KATZMAN, P.C. Pau J. Es ito Attorney I'D. #25454 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 gq.OO p0 AT" Date: , 2010 Attorney for Plaintiff dew 97137 p#, G `7 01 VERIFICATION I verify that the statements contained in the foregoing PETITION FOR RELATED CLAIMS UNDER DIVORCE CODE are true and correct to the best of my knowledge, information and belief. I understand that false statements contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: --3 113 / 0 CHRISTINE SPRIN R CERTIFICATE OF SERVICE On this, day of , 2010, I certify that a copy of the foregoing was served upon the following counsel of record by delivering same in the in the manner indicated, addressed as follows: VIA FIRST CLASS AMIL Thomas D. Gould, Esquire 2 East Main Street Shiremanstown, PA 17011 Attorney for Defendant GOLDBERG KATZMAN, P.C. Paul J. Esposito Supreme Court ID #25454 Attorneys for Plaintiff - CHRISTINE SPRINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006-790 CIVIL TERM KURT C. SPRINGER, CIVIL ACTION - LAW Defendant CUSTODY ORDER OF COURT AND NOW, this 9th day of March, 2011, the custody stipulation agreement entered on March 22, 2006, is temporarily vacated and replaced with the following: 1. Mother shall have sole legal and primary physical custody of their children, Noah Springer, born January 20, 1996; Leah Springer, born December 28, 1997; and Micah Springer, born February 25, 2000. 2. Mother shall have primary physical custody of the children. Father shall not have any physical custody with the children until further Order of Court. 3. Mother and father shall both obtain psychiatric evaluations within 60 days of today's date. Cumberland County Children & Youth Services (the "Agency") shall be entitled to have input with the psychiatrist and shall be given copies of the evaluation. 4. The children shall continue in individual counseling as needed. 5. Father may have contact with the children in a therapeutic counseling venue. The parties are airectea to enroll the children in family counseling so that father and the children may work on their relationship. If the parties are unable to agree to an appropriate family counselor, the Agency shall make that decision. 6. Father may have unlimited contact with his r \ i i children by way of e-mail, letters, cards, et cetera. Mother shall assure that each child e-mails father on a daily basis. 7. Both parties shall cooperate with the Agency in connection with its provision of services to the children as a result of the finding of emotional abuse. By the Court, i _J Edward E. Guido, J. -= 7, u. Lindsay Dare Baire, Esquire For CCC&YS Sean M. Shultz, Esquire = i For the Father John J. Mangan, III, Esquire For the Mother Jacqueline M. Verney, Esquire G.A.L. for the Children CCC&YS 4- f CASA srs qn CHRISTINE SPRINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. KURT C. SPRINGER, NO. 2006 - 0790 CIVIL TERM Defendant CIVIL ACTION -CUSTODY ORDER OF COURT AND NOW, this 11TH day of APRIL, 2011, Michael J. Whare, Esquire, is hereby court appointed guardian ad litem to represent the juveniles in the above captioned matter. The Guardian ad litem is hereby authorized, pursuant to 42 Pa.C.S.A. § 6311(B)(4), to timely access to all relevant court and Children and Youth records, reports of examination of the parents or other custodian of the child and medical, psychological and school records. This order shall act as an Entry of Appearance for Michael J. Whare, Esquire, whose office address and telephone number is as follows: Michael J. Whare, Esquire 37 East Pomfret Street Carlisle, Pennsylvania 17013 (717) 243-3561 Supreme Ct # 89028 B e Court, Michael J. Whare, Esquire For the Juveniles CCC&YS CASA Edward E. Guido, J in older T41"111 616 C11) i4r-- c CJ Q Q ?h ,rr7 Paul J. Esposito, Esquire 1 -7 I.D. #25454 l1 g ; ; t '-J GOLDBERG KATZMAN, P.C. J 4250 Crums Mill Road n 7 g 4J 'j {W P. O. Box 6991 .? d ? PJ Harrisburg, PA 17112 (717) 234-4161; (717) 234-6808 (facsimile) a r r, Counsel or Plamti ? 1 E R L,. A;N D C O U 1 ' CHRISTINE SPRINGER, '.' URT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-790 KURT C. SPRINGER, CIVIL ACTION - LAW Defendant IN DIVORCE MOTION FOR APPOINTMENT OF MASTER CHRISTINE SPRINGER, Plaintiff, moves the Court to appoint a Master with respect to the following claims: (X) Divorce (X) Distribution of Property ( ) Annulment ( ) Support (X) Alimony (X) Counsel Fees (X) Alimony Pendente Lite (X) Costs and Expenses and in support of the Motion states: 1. Discovery is complete as to the claim(s) for which the appointment of a Master is requested. 2. The Defendant has appeared via his counsel: None 3. The statutory ground(s) for divorce are: Irretrievable breakdown - § 3301(c) or § 3301(d) 4. Check the applicable paragraph(s): ( ) The action is not contested. Cl> r.11 --- ( ) An agreement has been reached with respect to the above-referenced cl `f ( X) The action is contested with respect to the above-referenced claims. - The action does not involve complex issues of law or fact. `•+ ? The hearing is expected to take % to 1 day. Additional information, if any, relevant to the Motion: n +: ?r? l Date: a LO I Z Paul J. -C e.p AND NOW, A , 2012,f Yi?-" 9;4w, -F _j s appointed Master with respect to e claims: divorce, distribution of property, alimony, alimony pendente lite, counsel fees, costs and expenses.. Pa.- I 4v &i. BY THE COURT q'L+•i J. ,ev 4 Paul J. Esposito, Esquire I.D. #25454 GOLDBERG KATZMAN, P.C. 4250 Crums Mill Road, Suite 301 Harrisburg, PA, 17] 12 (717) 234-4161;(717) 234-6808 (facsimile) Counsel (or Plaintiff CHRISTINE SPRINGER, Plaintiff v. KURT C. SPRINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-790 CIVIL ACTION -LAW IN DIVORCE NOTICE -, t.,,, If you wish to deny any of the statements set forth in this affidavit, you must fi~"e a -`~=' y' c^1 ~.. counter-affidavit within twenty (20) days after this Affidavit has been served on yo~ths ~ ~ +~ statements will be admitted. ~- r.~ z~• ~ ~ - : ~-~ a- .. AFFIDAVIT UNDER - ~ i_.,, SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action have been separated since on or about September 1, 2005 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: v "~ ~ CHRISTINE i =,-k ~; ~~ . _, ,-.- ~.:::; -,.. _=' _., . {00609414;v1} Paul J. Esposito, Esquire I.D. #25454 GOLDBERG KATZMAN, P.C. 4250 Crums Mill Road, Suite 301 Harrisburg, PA, 1?112 (717) 234-4161; (717) 234-6808 (facsimile) Counsel for Plaintiff CHRISTINE SPRINGER, Plaintiff v. KURT C. SPRINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-790 CIVIL ACTION -LAW IN DIVORCE COUNTER AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because: Check (i), (ii), or (iii): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. (iii) The Plaintiff requests that the Court refrain from entering a final Decree in Divorce until the economic issues have been fully and finally resolved. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees o~ expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce dec may be entered without further notice to me, and I shall be unable thereafter to file any econor claims. {00609413;v1} I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: KURT C. SPRINGER NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. {00609413;v1} i ? qI M AR 18 PPS 2-- 25 "paoa c+ ar�3cut,rc. CUMBERLAND COOT'( 42socWmawlea PENNSYLVANIA + P.O Baas dM to 17112 am 161:f�'17)2 (om) C.errrtfbrli�irtl' CHRISTW SPRINGER, : IN THE COURT OF COMMON PLEAS OF Plefiltiff CUMBERLAND COUNTY,PENNSYLVANIA NO. 2006-790 KURT C. SPRINGER, CIVIL ACTION—LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT—AND WAIVER OF COIRMLOW j1. An Amended Complaint in Divorce under 63301(c)of the Divorce Code was filed on February 23,2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety(90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce alter service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling and I understand that I may request that the Court require that my spouse and I participate in counseling. I understand that the Court maintains a list of marriage counselors,which list is available to me upon request. Being so advised,I do not request that the Court require my spouse and I to participate in counseling prior to a divorce being handed down by the Court. 5. I acknowledge that I received'a copy of the Amended Complaint in Divorce on or i about Feb wy 27,2006,via Acceptance of Service. I versify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 P&C.S. Section 4904,relating to unworn f dsifrcation to authorities. Date:,,2013 kfJRT CAPPiMAW (U0590697,w1} P*A L N*osil:&fie KATZMAJK P.C. "Al,ti� i P.O.Dm 6991 SPA M12 f {71161�-,C717)2340 I CI;IRISTINE SPRINGER, IN THE COURT OF COMMON PLEAS OF � Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. NO. 2006-790 KURT C. SPRING CIVIL ACTION—LAW Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A IIIV'ORCE DECREE M e1 OF TIN DIVORCE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony,division of property,lawyees fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by ft Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswarn falsification to authorities. ! Rate: L .2013 KURT GAR i �OOS9U6+17;v1} t i t } r Paul 1.Esposito,Esquire I.D.#25454 GOLDBERG KATZMAN,P.C. 4250 Crums Mill Road,suite 301 Harrisburg,PA,17112 (717)234.4161;(717)234-6808(facsimile) Counsel orPlaintff CHRISTINE SPRINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006.790 KURT C. SPRINGER, CIVIL ACTION—LAW Defendant IN DIVORCE 'zy co w:r PRAECIPE TO TRANSMIT RECORD 7C'C,, ;'; fQ TO THE PROTHONOTARY OF DAUPHIN COUNTY: Transmit the record,together with the following information,to the Court for entry of a divorce decree: Code. 1. Ground for divorce: irretrievable breakdown under § 3301(c)of the Divorce 2. Date and manner of service of the Complaint: 3. (a) Date of execution of the Affidavit of Consent required by § 3301(c)of the Divorce Code: by Plaintiff on September 28 2012 Defendant on March 10 2013. by (b)(1) Date of execution of the Affidavit required by § 3301(d)of the Divorce Code: (2) Date of filing and service of Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: None. 5. (a) Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached: {00615220;v1} ti (b) Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: October 2. 2012. (c) Date Defendant's Waiver of Notice in §3301(c)Divorce was filed with the Prothonotary: March 18, 2013, Respectfully submitted, GOLDBERG KATZMAN, P.C. Date: March 18, 2013 By: Paul 1 o ' o, Esquire Attorney I. #25454 4250 Crums Mill Road, Suite 301 Harrisburg, PA, 17112 (717)234-4161 Attorney for Plaintiff, Christine Springer {00615220;vl} 2 . ...._.-... ._ . _. _ _ f s CERTIFICATE OF SERVICE On this 18 day of March 2013, I certify that a copy of the foregoing document was served upon the following individual(s) by placing the same in the United States mail, first class, postage prepaid, addressed as follows: Kurt Springer 3121 Harvard Avenue Camp Hill, PA 17011 Respectfully submitted, GOLDBERG KATZMAN, P.C. By: Paul J. spo to Attorney I. . #25454 {00615220;v 1} IN THE COURT OF COMMON PLEAS OF CHRISTINE SPRINGER CUMBERLAND COUNTY, PENNSYLVANIA V. KURT C. SPRINGER NO. 2006-790 CIVIL ACTION DIVORCE DECREE AND NOW, hc&,�-,0 A ��'�l°QM 0X , it is ordered and decreed that CHRISTINE SPRINGER , plaintiff, and KURT C. SPRINGER , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (if no claims remain indicate "None.") AND IT IS FURTHER ORDERED AND DECREED, that the terms, provisions and conditions of a certain Marriage Settlement Agreement between the parties dated September 21, 2012, are hereby incorporated in this Decree by reference as though the same were set forth herein at length. Said Agreement shall not merge with, but shall survive this Decree. By the Court, Attest: J. V !D D. 3u fo� Prot notary' Awlew