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HomeMy WebLinkAbout06-1035JAMES R. BRENNEMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO.OL- IWS CIVIL TERM RENEE L. BRENNEMAN, Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, James R. Brenneman, by his attorneys, Irwin & McKnight, and presents the following Complaint for Custody. 1. The Plaintiff, James R. Brenneman, is an adult individual with an address of 1805 Willow Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Renee L. Brenneman, is an adult individual with an address of 16 Valley Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of three (3) children, namely, James R. Brenneman, Jr., born December 24, 1994, age 11; Zachary D. Brenneman, born January 10, 1999, age 7; and Kaiden J. Brenneman, born September 6, 2001, age 4. 4. The Plaintiff desires that the parties have shared legal custody of said minor children 5. The Plaintiff desires shared physical custody of said minor children. 6. The best interests and permanent welfare of the minor children requires that the Court grant the Plaintiffs request as set forth above. WHEREFORE, the Plaintiff, James R. Brenneman, respectfully requests that he be awarded shared physical custody and shared legal custody of James R. Brenneman, Jr., Zachary D. Brenneman, and Kaiden J. Brenneman, as provided herein. Respectfully submitted, IRWIN & McKNIGHT By. ?'I J Zeus Knight, III, Esquire West fret Street az isle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I. D. No. 25476 Date: February 21, 2006 . 1 VERIFICATION The foregoing document is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4404, relating to unsworn falsification to authorities. R.BRENNEMAN Date: February 21, 2006 7CJ ? 4Q JAMES R. BRENNEMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. RENEE L.BRENNEMAN DEFENDANT 06-1035 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, February 24, 2006 upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle Oil Tuesday, March 28, 2006 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /sacqueline M. Verney, E? Y 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 A'T'TORNEY 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 ???? ? ? ?? r? ? „? ?;' " ..,? ;;j:, _.. i! 'AT 1 MAR 2 b zoos BY:_ JAMES R. BRENNEMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-1035 CIVIL ACTION - LAW RENEE L. BRENNEMAN, Defendant IN CUSTODY ORDER OF COURT AND NOW, this-7-AA day of V L1 a% c, L 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, James R. Brenneman and the Mother, Renee L. Brenneman, shall have shared legal custody of James R. Brenneman, Jr., born December 24, 1994, Zachary D. Brenneman, born January 10, 1999 and Kaiden J. Brenneman, born September 6, 2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. The children shall remain in the South Middleton Township schools until the end of the 2005-2006 school year. 2. The parties shall have shared physical custody, with Father having the following times and Mother having all other times: A. Every Tuesday from after work to Thursday morning. B. Beginning Friday, March 31, 2006 alternating weekends from after school on Fridays to Monday mornings. C. Such other times as the parties agree. 3. Mother shall have physical custody of the children on Mother's Day at times agreed by the parties and Father shall have physical custody of the children on Father's Day at times agreed by the parties. 4. Holidays, including Thanksgiving and Christmas, shall be shared as agreed by the parties. 5. Transportation shall be shared as agreed by the parties. r1l 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. - - ? , ? ^_ ?.: ,__. ?,. :- -_ ?. ;:... ., ??- ? t ._ ' !! l ? 4::?= 4:i __) `~ ??.1 BY THE COURT, cc:.IGlyaCus A. McKnight, III, Esquire, Cinsel for Father epee L. Brenneman, pro se 16 Valley Street Carlisle, PA 17013 J. O JAMES R. BRENNEMAN, Plaintiff V. RENEE L. BRENNEMAN, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-1035 CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I . The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF James R. Brenneman, Jr. December 24, 1994 shared Zachary D. Brenneman January 10, 1999 shared Kaiden J. Brenneman September 6, 2001 shared 2. A Conciliation Conference was held in this matter on March 28, 2006 with the following in attendance: The Father, James R. Brenneman, with his counsel, Marcus A. McKnight, III, Esquire, and the Mother, Renee L. Brenneman, pro se. The parties agreed to an Order in the form as attached. Date 1?acq ine M. Verney, Esquire Custody Conciliator V JAMES R. BRENNEMAN, IN THE COURT OF COMMON PLEAS Plaintiff/Respondent OF CUMBERLAND COUNTY PENNSYLVANIA VS. CIVIL ACTION - CUSTODY RENEE L. BRENNEMAN Defendant/Petitioner NO. 2006-1035 MOTION TO TRANSFER A CASE TO PERRY COUNTY AND NOW COMES, James R. Brenneman, Plaintiff in the above captioned matter and request the Court to transfer this case to Perry ou ty and in support of the Motion avers as follows: 1. Plaintiff/Petitioner is James R. Brenneman who resides at 191 Kathryn Drive, New Bloomfield, Perry County, Pennsylvania 17068. 2. Defendant/Respondent is Renee L. Brenneman, whose last known permanent address was 7432 Spring Road, New Bloomfield, Perry County, Pennsylvania 17065. 3. The parties are the parents of three minor children: a. James R. Brenneman, Jr., date of birth December 24, 1994 b. Zachary D. Brenneman, date of birth January 10, 1999 C. Kaiden J. Brenneman, date of birth September 6, 2001 4. The children are the subject of an Order of Court filed to the above docket number. 5. Since the entry of the Order, both parties have resided in Perry County since the fall of 2006. 6. All of the children have been attending school in Perry County since the fall semester started in 2006. 7. All of the academic information pertinent to this case and the attendance records are located in Perry County. 8. All of the criminal complaints filed against the Defendant herein are lodged in Perry County, Pennsylvania. 9. Some but not all of the physicians of the children are located in Perry County, Pennsylvania. 0. The friends and the relatives of the parties who may be called to testify, in the main, reside in Perry County. 1. Teachers who may be called to testify are believed to reside in Perry County. 12. Simultaneously with the filing of this Motion to Transfer, Plaintiff herein has field a Petition to Modify Custody, a copy of which is attached as Exhibit "A". 13. In the interest of judicial economy and in the interest of convenience of the witnesses, this matter should be transferred to Perry County. 14. All of the significant contacts of the children and the parties herein for the past two years have been almost exclusively in Perry County, Pennsylvania. WHEREFORE, it is respectfully requested that this matter be transferred to Perry County along with the Petition to Modify Custody which was filed simultaneously with this action. Respectfully Submitted, DISSINGER AND DISSINGER Mary A. Etter Dissinger Attorney for Plaintiff/Petitioner Supreme Court ID #27736 400 South State Road Marysville, PA 17053 (717) 957-3474 VERIFICATION I, James R. Brenneman, verify that the statements made in the foregoing document 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. ames R. Brenneman JAMES R. BRENNEMAN, IN THE COURT OF COMMON PLEAS Plaintiff/Respondent OF CUMBERLAND COUNTY PENNSYLVANIA VS. CIVIL ACTION - CUSTODY RENEE L. BRENNEMAN Defendant/Petitioner NO. 2006-1035 PETITION TO MODIFY CUSTODY AND NOW COMES, James R. Brenneman, the Plaintiff in this action and request the Court to modify custody in accordance with the and in support of the Petition to Modify Custody avers as follows: 1. Plaintiff/Petitioner is James R. Brenneman who resides at 191 Kathryn Drive, New Bloomfield, Perry County, Pennsylvania 17068. 2. Defendant/Respondent is Renee L. Brenneman, whose last known permanent address was 7432 Spring Road, New Bloomfield, Perry County, Pennsylvania 17065. 3. Recently, Plaintiff has been advised that Defendant /Respondent does not have a permanent address and that the children spend some of their evenings or nights at Defendant/Respondent's mother's home, at her grandmother's home, or at a camp site. 4. The children have been crying and complaining that they do not have any clothes and that they have to borrow clothing from other people because their clothing is packed away. 5. Zachary needs his glasses for school and they are packed away and Defendant/Respondent refuses to get them for the child. 6. The children have told the Plaintiff/Petitioner herein that they do not have a place to shower and that most times they are not spending time with their mother, but rather with other people. 7. The parties are the parents of three minor children: a. James R. Brenneman, Jr., date of birth December 24, 1994 b. Zachary D. Brenneman, date of birth January 10, 1999 C. Kaiden J. Brenneman, date of birth September 6, 2001 8. The children are the subject of an Order of Court filed to the above docket number. 9. The most recent Cust ached hereto as Exhibit EXHIBIT "An "A" which is dated March 31, 2006. 10. Since the entry of the Order, both parties have resided in Perry County since the fall of 2006. 11. All of the children have been attending school in Perry County since the fall semester started in 2006. 12. Defendant has failed to make sure that James R. Brenneman, Jr., attends school regularly and she has failed to make sure that he attends school timely. 13. The Plaintiff herein has been notified and has had suits filed against him at the District Magistrate level because of Defendant's refusal and failure to make sure that James R. Brenneman, Jr., attends school. 14. James R. Brenneman, Jr., has been diagnosed with ADHD and LD and has an IEP. 15. When James R. Brenneman, Jr., misses school it is of greater consequence to him than it would be to some children, and it is harmful to his academic development to miss class. 16. Defendant herein has also been fined for failure to get her oldest son (not related to Plaintiff herein) to school as well. 17. The minor child of the parties has been overheard to brag about how he does not have to attend school when he is in the custody of the Defendant herein. 18. The boys are enrolled in athletic pursuits after school and Defendant/Respondent herein refuses or fails to get them to their practices. 19. The boys are on medication that is necessary for their ADHD, and Defendant/Respondent herein is not making sure that they get their medication. 20. The household of the Defendant herein has been relocated several times in the last two years. 21. The current environment in which the children reside with the Defendant herein is not conducive to their safe upbringing and development. 22. The household in which the three minor children reside with the Defendant is unstable. 23. Mother's current boyfriend, Nathaniel Gregory Michael, was recently charged with aggravated assault and related offenses, which Plaintiff believes arose out of an attempted police stop of a visibly intoxicated Mr. Michael. 24. Domestic violence is a common theme in the household of Defendant herein, and the minor children of the parties have witnessed it and have been terrorized and terrified by the consequences of the fighting between Defendant herein and her friends. 25. Plaintiff herein was actually involved tangentially in one of the incidents between Defendant and one of her friends, because when he arrived to pick up his children, there were threats of the utilization of a sawed-off shotgun, and Plaintiff herein removed the shotgun from the residence so that the parties that were fighting would not utilize it although one of them had retrieved it. 26. One of the minor children of the parties has reported to the school that he is tired at school because his mother, Defendant herein, and her boyfriend keep the children up all night with their fighting and arguing. 27. The counselor and support teachers have noticed that James R. Brenneman, Jr.'s, performance and attention in school is significantly impaired when he is in Defendant's primary physical custody. 28. Individuals employed by the school district where James R. Brenneman, Jr., attends are familiar with "trouble" in Defendant's household. 29. On many occasions, Defendant herein has had difficulty managing the behavior of the minor children of the parties and has split them up between her grandmother's residence and herself. 30. Plaintiff herein has no trouble managing any of the minor children of the parties collectively or in conjunction with his step children. WHEREFORE, Plaintiff believes that it is in the best interest of the children to have primary custody transferred to him and have supervised visits with Defendant so that the children may attend school regularly, on time, and be well rested for their academic responsibilities, and be safe and unfrightened while in Def'endant's care. Respectfully Submitted, DISSINGER AND DISSINGER Mary A. Etter Dissinger Attorney for Plaintiff/Petitioner Supreme Court ID #27736 400 South State Road Marysville, PA 17053 (717) 957-3474 JAMES R. BRENNEMAN, Plaintiff/Respondent i vs. RENEE L. BRENNEMAN Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY NO. 2006-1035 CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, hereby certify that on the date set forth below I served a true and correct copy of the Petition j for Custody upon Renne L. Brenneman, Defendant, by First Class United States mail addressed as follows: Renee L. Brenneman 7432 Spring Road New Bloomfield, PA 17065 Date: 2'b 2- Mary Etter Dissinger ? y . c? N r i?"' r •-, ? C? C'7 rn JAMES R. BRENNEMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW RENEE L. BRENNEMAN, Defendant NO. 06-1035 CIVIL TERM ORDER OF COURT AND NOW, this 16'' day of September, 2008, upon consideration of Plaintiffs Motion To Transfer a Case to Perry County, it is ordered that: 1. A Rule is issued upon Defendant to show cause why Plaintiff is not entitled to the relief requested; 2. Defendant shall file an answer to the motion within 21 days of the date of this order; 3. The petition shall be decided under Pa. R.C.P. 206.7; 4. Depositions shall be completed within 49 days of the date of this order; 5. Argument shall be held on Monday, December 29, 2008, at 3:15 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. 6. Briefs shall be submitted at least seven days prior to argument. BY THE COURT, ? Mary A. Etter Dissinger Esq. 400 South State Road Marysville, PA 17053 Attorney for Plaintiff J. Z Z1 WA 91 83 BOOZ 34 ?O Renee L. Brenneman 7432 Spring Road New Bloomfield, PA 17065 Defendant, pro Se :rc O-Of t4ex MtULCL 4 I4/08 fCO4 Z :Z! Wd 9 ! d3S 84OZ 3011-'L?O-Qglu JAMES R. BRENNEMAN, IN THE COURT OF COMMON PLEAS Plaintiff/Respondent OF CUMBERLAND COUNTY PENNSYLVANIA VS. . CIVIL ACTION - CUSTODY RENEE L. BRENNEMAN Defendant/Petitioner NO. 2006-1035 PETITION TO MODIFY CUSTODY AND NOW COMES, James R. Brenneman, the Plaintiff in this action and request the Court to modify custody in accordance with the and in support of the Petition to Modify Custody avers as follows: 1. Plaintiff/Petitioner is James R. Brenneman who resides at 191 Kathryn Drive, New Bloomfield, Perry County, Pennsylvania 17068. 2. Defendant/Respondent is Renee L. Brenneman, whose last known permanent address was 7432 Spring Road, New Bloomfield, Perry County, Pennsylvania 17065. 3. Recently, Plaintiff has been advised that Defendant /Respondent does not have a permanent address and that the children spend some of their evenings or nights at Defendant /Respondent's mother's home, at her grandmother's home, or at a camp site. 4. The children have been crying and complaining that they do not have any clothes and that they have to borrow clothing from other people because their clothing is packed away. 5. Zachary needs his glasses for school and they are packed away and Defendant/Respondent refuses to get them for the child. 6. The children have told the Plaintiff /Petitioner herein that they do not have a place to shower and that most times they are not spending time with their mother, but rather with other people. 7. The parties are the parents of three minor children: a. James R. Brenneman, Jr., date of birth December 24, 1994 b. Zachary D. Brenneman, date of birth January 10, 1999 C. Kaiden J. Brenneman, date of birth September 6, 2001 8. The children are the subject of an order of Court filed to the above docket number. 9. The most recent Custody Order is attached hereto as Exhibit "A" which is dated March 31, 2006. 10. Since the entry of the Order, both parties have resided in Perry County since the fall of 2006. 11. All of the children have been attending school in Perry County since the fall semester started in 2006. 12. Defendant has failed to make sure that James R. Brenneman, Jr., attends school regularly and she has failed to make sure that he attends school timely. 13. The Plaintiff herein has been notified and has had suits filed against him at the District Magistrate level because of Defendant's refusal and failure to make sure that James R. Brenneman, Jr., attends school. 14. James R. Brenneman, Jr., has been diagnosed with ADHD and LD and has an IEP. 15. When James R. Brenneman, Jr., misses school it is of greater consequence to him than it would be to some children, and it is harmful to his academic development to miss class. 16. Defendant herein has also been fined for failure to get her oldest son (not related to Plaintiff herein) to school as well. 17. The minor child of the parties has been overheard to brag about how he does not have to attend school when he is in the custody of the Defendant herein. 18. The boys are enrolled in athletic pursuits after school and Defendant/Respondent herein refuses or fails to get them to their practices. 19. The boys are on medication that is necessary for their ADHD, and Defendant/Respondent herein is not making sure that they get their medication. 20. The household of the Defendant herein has been relocated several times in the last two years. 21. The current environment in which the children reside with the Defendant herein is not conducive to their safe upbringing and development. 22. The household in which the three minor children reside with the Defendant is unstable. 23. Mother's current boyfriend, Nathaniel Gregory Michael, was recently charged with aggravated assault and related offenses, which Plaintiff believes arose out of an attempted police stop of a visibly intoxicated Mr. Michael. 24. Domestic violence is a common theme in the household of Defendant herein, and the minor children of the parties have witnessed it and have been terrorized and terrified by the consequences of the fighting between Defendant herein and her friends. 25. Plaintiff herein was actually involved tangentially in one of the incidents between Defendant and one of her friends, because when he arrived to pick up his children, there were threats of the utilization of a sawed-off shotgun, and Plaintiff herein removed the shotgun from the residence so that the parties that were fighting would not utilize it although one of them had retrieved it. 26. One of the minor children of the parties has reported to the school that he is tired at school because his mother, Defendant herein, and her boyfriend keep the children up all night with their fighting and arguing. 27. The counselor and support teachers have noticed that James R. Brenneman, Jr.'s, performance and attention in school is significantly impaired when he is in Defendant's primary physical custody. 28. Individuals employed by the school district where James R. Brenneman, Jr., attends are familiar with "trouble" in Defendant's household. 29. On many occasions, Defendant herein has had difficulty managing the behavior of the minor children of the parties and has split them up between her grandmother's residence and herself. 30. Plaintiff herein has no trouble managing any of the minor children of the parties collectively or in conjunction with his step children. WHEREFORE, Plaintiff believes that it is in the best interest of the children to have primary custody transferred to him and have supervised visits with Defendant so that the children may attend school regularly, on time, and be well rested for their academic responsibilities, and be safe and unfrightened while in Defendant's care. Respectfully Submitted, DISSINGER AND DISSINGER Mary A. Etter Dissinger Attorney for Plaintiff/Petitioner Supreme Court ID #27736 400 South State Road Marysville, PA 17053 (717) 957-3474 VERIFICATION I, James R. Brenneman, verify that the statements made in the foregoing document 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. .- • ,& JAMES R. BRENNEMAN, Plaintiff/Respondent VS. RENEE L. BRENNEMAN Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY NO. 2006-1035 CERTIFICATE OF SERVICE I, Danielle R. Van Horn, paralegal, hereby certify that on the date set forth below I served a true and correct copy of the Petition for Custody upon Renee L. Brenneman, Defendant, by First Class United States mail addressed as follows: Renee L. Brenneman 7432 Spring Road New Bloomfield, PA 17068 Date :' Q?l ` t C+11 JAMES R. BRENNEMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. RENEE L. BRENNEMAN DEFENDANT 2006-1035 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Wednesday, October 01, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, November 04, 2008 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. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ ac ueline M. Verne Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ea<? $-P-V -.Jl- ^-Ilp? 7el row Ak;? C :I d 1- 130 OOOZ + IPA 0 NOV 0 4 2008?b JAMES R. BRENNEMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-1035 CIVIL ACTION - LAW RENEE L. BRENNEMAN, . Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of N env. , 2008, upon consideration of the attache Custody Conciliation Report, it is ordered and directed as follows: The prior Order of Court dated March 31, 2006 is hereby vacated. 2. The Father, James R. Brenneman and the Mother, Renee L. Brenneman, shall have shared legal custody of James R. Brenneman, Jr., born December 24, 1994, Zachary D. Brenneman, born January 10, 1999 and Kaiden J. Brenneman, born September 6, 2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to medical, dental, religious or school records, the residence address of the children and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. Father shall have primary physical custody of the children. 4. Mother shall have periods of partial physical custody every weekend from Friday after school to Monday morning when she shall be responsible for getting the children to school, except on the third weekend of every month, when Father shall have physical custody of the children. z 5. The parties shall share or alternate holidays as agreed. 6. Mother shall be responsible for all transportation, unless otherwise agreed. 7. During Mother's periods of physical custody, she shall assure that the children are taken to their school/extracurricular activities, practices and games. 8. The Prothonotary of Cumberland County is directed to transfer this case to Perry County as both parties live in Perry County and the children attend school in Perry County and have done so for the last two years. 9. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J. W sley Oler, Jr., J. cc: Mary A. Etter Dissinger, Esquire, Counsel for Fatherv Renee L. Brenneman, pro se C/O Scott Morrison / - o s - 6? 400 Mountain Road Newville, PA 17241 I C :21 Wd S- AON BOOZ 11t l?J?Vr _L:l`ruyCJ ?'Hi J0 JAMES R. BRENNEMAN, Plaintiff V. RENEE L. BRENNEMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-1035 CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody. Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH James R. Brenneman, Jr. December 24, 1994 Zachary D. Brenneman January 10, 1999 Kaiden J. Brenneman September 6, 2001 CURRENTLY IN CUSTODY OF Mother Mother Mother 2. A Conciliation Conference was held in this matter on November 4, 2008 with the following in attendance: The Father, James R. Brenneman, by telephone, with his counsel, Mary A. Etter Dissinger, Esquire, and the Mother, Renee L. Brenneman, by telephone, pro se. 3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court dated March 31, 2006 providing for shared legal custody with Mother having primary physical custody and Father having periods of partial physical custody. 4. The parties agreed to an Order in the form as attached. Date cqu e M. Verney, Esquire Custody Conciliator JAMES R. BRENNEMAN, Plaintiff V. RENEE L. BRENNEMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 06-1035 CIVIL TERM ORDER OF COURT AND NOW, this 12th day of November, 2008, upon consideration of the attached letter from Mary A. Etter Dissinger, Esq., attorney for Plaintiff, and this case having been transferred to Perry County by order filed on November 5, 2008, the argument previously scheduled for December 29, 2008, is cancelled. v4ary A. Etter Dissinger, Esq. 28 N. 32nd Street Camp Hill, PA 17011 Attorney for Plaintiff nee L. Brenneman c/o Scott Morrison 400 Mountain Road Newville, PA 17241 Defendant, pro Se rc BY THE COURT, F i J. Wesley Olen Jr., J. S .2 Wd E i AON 00OZ 3HI :10