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HomeMy WebLinkAbout06-2528JEFFREY KROUSE, PLAINTIFF V. STEPHANIE LYNN KROUSE, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. D G - ; d,2 2 CIVIL ACTION - CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes Plaintiff, Jeffrey Krouse, by and through his counsel SMIGEL, ANDERSON & SACKS, LLP, and files the following Complaint for Custody: 1. Plaintiff is Jeffrey Krouse, currently residing at 153 Garland Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Stephanie Lynn Krouse, currently residing at 1151 Easy Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff seeks custody of the following children: Name Present Residence Age Sarah Jane Krouse 153 Garland Drive, Carlisle, PA 17013 12 years Hannah Katherine Krouse 153 Garland Drive, Carlisle PA 17013 9 years 4. The children were not born out of wedlock. The children are presently in the custody of Plaintiff. 5. During the past five (5) years, the children have resided with the following persons and at the following addresses: Persons Addresses Dates Jeffrey Krouse 153 Garland Drive, Carlisle, PA 17013 04/21/06-present Jeffrey & Stephanie Krouse 153 Garland Drive, Carlisle, PA 17013 12/29/93 - 04/21/06 6. The mother of the children is Defendant. She is currently marred to the father of the children, Plaintiff Jeff Krouse. 7. The relationship of Plaintiff to the children is that of Father. Plaintiff currently resides with the children at 153 Garland Drive, Carlisle, PA 17013. 8. The relationship of Defendant to the children is that of Mother. Defendant currently resides with the following persons: Name Relationship Dora Jean Gribble Defendant's Mother Glenn L. Gribble Defendant's Stepfather 9. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another Court. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or who claims to have custody or visitation rights with respect to the children. 10. The best interest and permanent welfare of the children will be served by granting the relief requested because: A. Plaintiff is a fit parent. B. Placing primary custody with Plaintiff will provide continuity, stability and certainty to the children's lives. 11. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant shared legal and primary physical custody of the children to him. Date: Zi' D(0 Respectfully submitted, SMIGEL, DERSON & SACKS, LLP By: LeRc Smigel, Esquire I.D.#: 09617 Ann V. Levin, Esquire I.D. #: 70259 4431 North Front Street, are Flr. Harrisburg, PA 17110-1778 (717) 234-2401 Attorneys for Plaintiff VERIFICATION I, Jeffrey Krouse, verify that the statements contained in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date: ? Iff Je use n c ur J ? ?C o ?a 1J ?\ G r ? r# to b m Sl7 ? CD JEFFREY KROUSE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. STEPHANIE LYNN KROUSE DEFENDANT 06-2528 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 11, 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 on Tuesday, June 13, 2006 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. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Jacqueline M. Verney, Esq.I y(1 Custody Conciliator yr` 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 V;I\I'AlkSNN d 0£ -£ Wd s 1 AVW 90oz AdViONO?LIOUd 3'Ni A0 ]OH-110-0311i JEFFREY KROUSE, PLAINTIFF V. : STEPHANIE LYNN KROUSE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2528 DEFENDANT CIVIL ACTION - CUSTODY ACCEPTANCE OF SERVICE I, Nathan C. Wolf, Esquire, counsel for Defendant Stephanie Lynn Krouse, accept service of the Complaint for Custody on behalf of Defendant and certify that I am authorized to do so. Date: ,, than C , Esquire Wo o 10 West High Street Carlisle, PA 17013 L? CD iff JUN 1 5X906 JEFFREY KROUSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-2528 CIVIL ACTION - LAW STEPHANIE LYNN KROUSE, . Defendant : IN CUSTODY ORDER OF COURT AND NOW, this I L I day of ,- , Cie, , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Jeffrey Krouse and the Mother, Stephanie Lynn Krouse, shall have shared legal custody of Sarah Jane Krouse, born December 29, 1993 and Hannah Katherine Krouse, born January 24, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa.C.S. §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. 2. Beginning June 16, 2006, the parents shall have shared physical custody on a week on/week off schedule with transfers occurring Fridays at 6:30 p.m. Father shall have the first week. 3. In the event that either party is in need of a babysitter for more than three hours, they shall contact the non-custodial parent and offer said babysitting opportunity to the other parent, except that Mother is not bound by this paragraph if the maternal grandmother will provide the babysitting. Lit Z i LL c.':? rte.. w 4. The parties shall cooperate with a custody evaluation. The cost of said evaluation shall be paid for by Father, however, the cost shall ultimately be prorated among the parties. 5. The parties shall have liberal telephone contact with the children. 6. Nothing herein shall prejudice either party from pursuing primary physical custody in the future. 7. 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. Either parry may contact the Conciliator within two weeks from the date of the custody evaluation and request another Conciliation Conference. BY THE COURT, J. cc: Ann V. Levin, Esquire, Counsel for Father ' 1\ Nathan C. Wolf, Esquire, Counsel for Mother JEFFREY KROUSE, Plaintiff VS. STEPHANIE LYNN KROUSE Defendant, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 - 2528 CIVIL ACTION - LAW IN CUSTODY PRAECIPE TO SUBSTITUTE COUNSEL TO THE PROTHONOTARY: Please enter the appearance of Pamela L. Purdy, Esquire for Defendant Stephanie Lynn Krouse, and withdraw the appearance of Nathan C. Wolf, Esquire and Wolf & Wolf, as counsel for the Defendant in the above captioned action. A" -L/.- - 2? Pamela L. Purdy, Esquire 115 Pine Street 10 W. High Street Carlisle, PA 17013 (717) 241-4436 Attorney I.D. #87380 Date: Harrisburg, PA 17101 (717)221-8303 Attorney I.D. #85783 7a_ ?O :j l S w ? N ? t DEC 14 2006 pty JEFFREY KROUSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-2528 CIVIL ACTION - LAW STEPHANIE LYNN KROUSE, . Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of pF c _ , 2006, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. , of the Cumberland County Court House, on the R94 day of YYX1b k - , 2007, at1 o'clock, _Q . M., at which time testimony will be taken. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Order of Court dated June 16, 2006 shall remain in full force and effect with the following additions and modifications: 3. The non-custodial parent shall have physical custody of the children on Tuesday either after school or after work, overnight until the beginning of school on Wednesday. 4. For the Christmas holiday in 2006, Father shall have physical custody of the children from 2:00 p.m. to 8:00 p.m. 5. Mother and Father shall participate in family therapeutic counseling as arranged by Mother with a counselor determined by the parties' attorneys. The parties shall follow any recommendations of the counselor. 6. Father shall participate in psychotherapy with a counselor of his choice and follow any recommendations of the therapist. 1 7. The parents shall cooperate with counseling for the children as arranged by Mother with counselors determined by the parties' attorneys. The parents shall follow any recommendations of the counselors CD L _ d co C5 t 3 8. Neither party shall do or say anything, nor permit third parties to do or say anything which may estrange the children from the other parent, injure the opinion of the children as to the other parent, or hamper the free and natural development of the children's love and respect for the other parent. 9. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. cc: Ann Levin, Esquire, counsel for Father Pamela Purdy, Esquire, counsel for Mother% 0, BY THE COURT, JEFFREY KROUSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-2528 CIVIL ACTION - LAW STEPHANIE LYNN KROUSE, : IN CUSTODY Defendant 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 CURRENTLY IN CUSTODY OF Sarah Jane Krouse December 29, 1993 shared Hannah Katherine Krouse January 24, 1998 shared 2. A Conciliation Conference was held on December 12, 2006 with the following individuals in attendance: The Father, Jeffrey Krouse, with his counsel, Ann Levin, Esquire, and the Mother, Stephanie Lynn Krouse, with her counsel, Pamela Purdy, Esquire. 3. The Honorable J. Wesley Oler, Jr. previously entered an Order of Court on June 16, 2006 providing for shared legal custody and shared physical custody on a week on/week off schedule. In the Order, the parties were to cooperate with a custody evaluation. Kasey Shienvold, Psy.D., performed the evaluation and recommended, inter alia, that Mother have primary physical custody, that, if possible, the children remain in their current school district and counseling for all of the parties. Pending a hearing, the parties agree to undertake the recommended counseling and report back to Dr. Shienvold with their progress. 4. Father's position on custody is as follows: Father seeks shared legal and primary physical custody of the children. He asserts that Mother has attempted to thwart his relationship with the children. He is willing to participate in family therapeutic counseling (co-parenting counseling), psychotherapy for himself and agrees that the children attend counseling. He disagrees with Dr. Shienvold's recommendation of primary physical with Mother because the children would have to change schools. 10 5. Mother's position on custody is as follows: Mother seeks shared legal custody and primary physical custody of the children. She previously was willing to accept a shared physical custody arrangement, but because of Father's recent actions of encouraging the older child to be deceptive, she is now seeking primary physical custody and agrees with Dr. Shienvold's recommendation. She indicates that she will relocate in order for the children to continue in their current school district. She is willing to participate in family therapeutic counseling and assure that the children attend counseling. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing, continuing the week on/week off physical custody arrangement with modifications. It is expected that the Hearing will require one day. Date acqu ne M. Verney, Esquire Custody Conciliator JEFFREY KROUSE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW STEPHANIE LYNN : KROUSE, Defendant NO. 06-2528 CIVIL TERM IN RE: CUSTODY ORDER OF COURT AND NOW, this 21St day of March, 2007, upon agreement of counsel, the hearing previously scheduled in the above matter for March 29, 2007, is continued to Thursday, July 12, 2007, at 9:30 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. Xnn Levin, Esq. 4431 North Front Street Harrisburg, PA 17110 Attorney for Plaintiff 308 xela L. Purdy, Esq. North Second Street Suite 200 Harrisburg, PA 17101 Attorney for Defendant :rc A BY THE COURT, 1`4 ;!VA1 4'31 '-A a .v .wf b?Y ?YY 4f? V YI\ ?V?V T'I/U? 0-031lj Pamela L. Purdy PA ID No. 85783 115 Pine Street, Suite 100 Harrisburg, PA 17101 (717) 221-8303 tel (717) 221-8403 fax plpurdy@verizon.net Attorney for Defendant JEFFREY E. KROUSE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. STEPHANIE L. KROUSE, Defendant NO. 06-2528 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY PLAINTIFF'S PRE-TRIAL STATEMENT AND NOW comes Defendant, Stephanie L. Krouse, by and through her attorney, Pamela L. Purdy, and files this Pre-trial Statement, and in support thereof, avers as follows: 1. HISTORY OF CUSTODY Plaintiff Jeffrey E. Krouse ("Father") and Defendant Stephanie L. Krouse ("Mother") are the parents of Sarah Jane Krouse, born December 29, 1993 ("Sarah") and Hannah Katherine Krouse, born January 24, 1998 ("Hannah"). Mother and Father separated on or about April 21, 2006, at which time Mother moved from the marital home with the parties' children. Since that time, Mother and the children have lived at Mother's parents' home. On May 4, 2006, Father filed a Complaint in Custody. The parties attended custody conciliation on June 16, 2006, after which the Court entered an agreed Order granting the parties shared legal custody and shared physical custody on a week on/week off basis. In addition, the parties agreed to participate in a custody evaluation. Said evaluation was performed by Kasey Shienvold, Psy. D., M.B.A., the report from which is attached hereto as Exhibit "A" and incorporated herein as if fully set forth. The parties attended a second conciliation on December 12, 2006, after which a modified Order was entered allowing the non-custodial parent to have Tuesday overnights, instructing Mother and Father to participate in family therapeutic counseling, and instructing Father to participate in psychotherapy with a counselor of his choice. In addition, the Order scheduled a hearing for March 29, 2007 before this Court. The parties agreed to continue said hearing until July 12, 2007 at 9:30 AM. Mother has been the primary caretaker of the children since birth. Mother has a close relationship with the children and attempts to facilitate the relationship between the children and Father. In contrast, Father refuses to discuss issues with regard to the children with Mother. Father's behavior evidences a clear intent to alienate the children from Mother, and to win the favor of the children by buying them things and allowing them to behave in -2- such a manner that was unacceptable during the parties' marriage. The custody evaluation performed by Dr. Shienvold supports these conclusions. Dr. Shienvold based his decision upon his observations that, among other things, Father appears to be having a more difficult time with the co-parent relationship, Father intentionally engages in behavior that continually puts a strain on Mother and the children, Father attempts to "buy the children" and Father reported that he feels not competent as a parent. As a result, Dr. Shienvold concluded that it would be in the children's best interest to reside primarily with Mother. Although a change to Mother having primary custody of the children would result in a change of school districts for the children, the children currently live half of the time in Mother's school district and have begun to made friends with the children in that area. The importance of the children living in a consistent, supportive home outweighs any discomfort they may feel in changing school districts. II. MOTHER'S POSITION ON CUSTODY Mother agrees with Dr. Shienvold's recommended custody schedule. This schedule provides for Mother to have primary physical custody of the children during the school year, with Father enjoying periods of partial physical custody every other weekend, Wednesday evenings and every other Monday evening. In addition, Mother agrees that if the parties' current co-parenting counselor Anthea Stebbins, LCSW, determines that a shared custodial schedule is -3- appropriate, the parties will share custody on a week on/week off basis during the summer. If the parties' relationship has not progressed to the point where they can effectively communicate, Mother requests that she continue to have primary physical custody of the children in the summer. III. LIST OF WITNESSES AND ANTICIPATED TESTIMONY Attached hereto as Exhibit "B" is a list of Mother's professional witnesses and their anticipated testimony. Also attached hereto as Exhibit "C" is a list of Mother's lay witnesses and their anticipated testimony. Mother reserves the right to supplement this list of witnesses prior to the scheduled hearing date. Respectfully submitted, Pamela L. Purdy I.D. No. 85783 308 N. 2"d St., Ste. 200 PO Box 11544 Harrisburg, PA 17108 (717) 221-8303 (717) 221-8403 plpurdy@verizon.net Date: / )tow Attorney for Defendant -4- 6 0 "1 Riegler - Shienvold & Associates CUSTODY EVALUATION JEFFREY KROUSE V. STEPHANIE KROUSE NO. 2006-2528 Referred By: Court Order No. 2006-2528 Civil Action - Law Elliot Riegler, Ph.D. (1948-1999) Arnold T. Shienvold, Ph.D. Melinda Eash, MS James Eash, LSW Bonnie Howard, Ph.D. Amy K. Keisling, ACSW, LCSW Tracy Richards, QCSW, LCSW Dyanne Sage, QCSW, LCSW Jeffrey Pincus, Ph.D. Ann Vergales, ACSW, LCSW Kasey Shienvold, Psy.D. Shanen Turk-Geller, LCS W Harvey H. Shapiro, MD Sandra Wiley, LCSW Referral Reason: To conduct a comprehensive custody evaluation and to make recommendations regarding the most appropriate custodial placement for Sarah Jane Krouse, DOB December 29, 1993, and Hannah Katherine Krouse, DOB January 24, 1998. Individual Interviews: Jeffrey Krouse 7/10/06, 7/24/06, 8/07/06, 8/24/06,9/22/06 Stephanie Krouse 7/11/06, 7/26/06, 8109/06, 9/12/06 Sarah Krouse 8/14/06, 8/21/06 Hannah Krouse 8/14/06, 8/21/06 Psychological Testing: Minnesota Multiphasic Personality Inventory-2 (MMPI-2) Jeffrey Krouse Stephanie Krouse Custody Instruments: Parenting Stress Index (PSI) Jeffrey Krouse Stephanie Krouse 2151 Linglestown Road, Suite 200 - Harrisburg, Pennsylvania 17110 - (717) 540-1313 - Fax: (717) 540-1416 Krouse v. Krouse Page 2 of 15 Sentence Completion Test Sarah Krouse Hannah Krouse Parent Report Card Sarah Krouse Hannah Krouse Home Visits: Each parent's residence was evaluated for safety concerns and each parent was observed interacting with Sarah and Hannah in the home setting. Additional Information: 1. Photographs of Stephanie Krouse's residence provided by Stephanie 2. Copy of instant message chat provided by Stephanie Krouse 3. Sarah and Hannah's report cards from the school year 2005/2006 The recommendations at the conclusion of this report are offered within a reasonable degree of psychological certainty and are the result of all of these sources of information as well as the integration of the psychological literature and the experience of the evaluator. Background: Jeffrey and Stephanie Krouse currently share legal and physical custody of their two children, Sarah and Hannah. The Krouses currently utilize a week-on/week-off custody schedule with exchanges occurring Fridays at 6:00 PM. This custody schedule was put into place three weeks prior to the start of the evaluation. Prior to that time Stephanie had primary physical custody of the children and Jeffrey had periods of partial custody every other weekend with Wednesday overnights. The parties initially separated on April 21, 2006. Jeffrey is pursuing the change in physical custody. He indicated a desire to be named primary custodian of the children. He reported that he wants the children to live with him on school nights and every other weekend. Krouse v. Krouse Page 3 of 15 Jeffrey expressed several concerns about Stephanie and her behavior with the children. He indicated that Stephanie is trying to prevent him from going to the family church. He noted several other incidences in which Stephanie attempt to prevent him from having contact with the children during her custody time. He reported that it is difficult to call the children during Stephanie's custody times and that the children feel pressure not to talk to him. Jeffrey noted that Stephanie became very upset with Sarah when she found out Sarah was e-mailing Jeffrey during her weeks with Stephanie. He alleged that Stephanie yells and becomes condescending when she is angry. He expressed concern that Sarah has become a target of her anger. Stephanie denied trying to hurt the children's relationship with Jeffrey. She indicated that she asked him not to go to church because he makes her, the children, and her parents uncomfortable. She claimed that Jeffrey only began going to church two years ago to try and save their marriage. She alleged that Jeffrey is only attending to be spiteful and make the children feel distressed about where they are supposed to sit. Stephanie also stated that Jeffrey does not go to church on the weeks he has the children. She reported that he only goes on Stephanie's custody weeks. Stephanie denied becoming inappropriately angry when she discovered that Jeffrey and Sarah were e-mailing each other. She indicated that she was angered by the fact that Sarah had been lying to her about her behavior. Stephanie noted that she checked the computer history and discovered that Jeffrey had been encouraging Sarah to lie to her. Stephanie presented a transcript from a chat room in which Jeffrey was telling Sarah how to clear the memory from her computer in order to conceal their conversations from Stephanie. Furthermore, she provided a history of chats with an online boyfriend with whom Sarah formed a relationship. Stephanie alleged that she was most angry about Sarah's lying to her and the fact that Jeffrey was encouraging her to do so. However, Sarah reported that her mother's anger was also a result of Stephanie's perception that Sarah was showing more affection for her father. According to Sarah, Stephanie told her "if you really wanna [sic] be with him so much why don't you just live with him." Sarah indicated that she did not know how to react to her mother's anger and that she "felt like crap" as a result. Jeffrey admitted to teaching Sarah how to clear the memory from her computer. He stated that he did so because he believed Stephanie would refuse to allow Sarah to chat with him. Jeffrey also indicated that he was aware that Sarah had an online boyfriend. Additionally, he stated that he was aware she was making references to sexual behavior in her chats with her boyfriend. Jeffrey reported that he was not concerned because he felt it was an "innocent pubescent interest in boys." Jeffrey showed no insight or understanding of the potential dangers in allowing and condoning those behaviors. Krouse v. Krouse Page 4 of 15 Stephanie noted other concerns about Jeffrey as well. She claimed that Jeffrey sets very few limits on the children at his home. She alleged that Jeffrey allows them to be disrespectful with one another and that they are disrespectful towards her when she first regains custody. Stephanie noted that she and Jeffrey were strict with the children when they were living together. She alleged that Sarah is now allowed to listen to music with profane lyrics and that Jeffrey tries to buy their affections. Jeffrey denied being too lenient with the children. He indicated that the children show respect when in his care and reported appropriate bedtimes for the children. He reported that he is more willing to allow the children some independence. Jeffrey stated that he enjoys buying the children things within reason and noted that the children are always appreciative of his gifts. Sarah reported in her interview that her father buys her and Hannah anything they want. She indicated that her father has become more involved and more lenient since the marital separation. History of Relationship: Jeffrey and Stephanie met at a bar when Jeffrey was 31 years old and Stephanie was 21 years old. They began dating casually for two years before their relationship became serious. Stephanie reported that they moved in together shortly after. Jeffrey indicated that he was unsure of the relationship at that time but wanted to give it a chance to be successful. Stephanie and Jeffrey reported that the relationship was positive at that point. Stephanie denied arguments but stated that Jeffrey was not emotional or affectionate. Jeffrey and Stephanie lived together for one year before they became engaged. The couple purchased their family home at that time. They were married seven months after moving into the family home. Stephanie became pregnant in 1993. The pregnancy was unplanned. Stephanie reported that she was surprised, but excited. Jeffrey reported that he was very worried. Stephanie reported that her pregnancy was difficult because she was sick for most of the time. She also alleged that Jeffrey was not sympathetic. Sarah was born three weeks premature but otherwise healthy. Stephanie took twelve weeks off from work. Although, Jeffrey reported that he took four weeks off from work, Stephanie alleged that he did not take time off from work. Stephanie indicated that Jeffrey was involved in child care when he was home, but she was primary caretaker. The parties reported that Sarah went to a babysitter once Stephanie returned to work. Stephanie noted that the relationship between her and Jeffrey lacked intimacy. However, they continued to argue frequently. Stephanie became pregnant for a second time in 1997. This pregnancy was also unplanned. Jeffrey reported that he was distressed because of their financial situation. Stephanie was excited, but was sick throughout her pregnancy once again. She reported that Hannah was born healthy following normal labor and delivery. Each party reported Krouse v. Krouse Page 5 of 15 that they took the same amount of time off from work after Hannah was born. Jeffrey felt their marriage was strong but Stephanie indicated that she felt under appreciated. She reported that Jeffrey was inconsiderate and often ignored her when he was home. Shortly after Hannah was born, Stephanie lost her job. As a result, Stephanie began running a daycare out of their home. Jeffrey indicated that he opposed Stephanie working at home. Each party reported that their marriage became more strained at that time. There were no heated arguments, but the couple began living separately in their home. Stephanie reported that they lived separately for a period of four months Jeffrey reported that Stephanie was unhappy because she did not feel cared for or loved by him. He stated that Stephanie began discussing the idea of divorce in 2004. As a result, Jeffrey promised to try and be more intimate and caring. Around that time, Jeffrey lost his job and began to work out of the home. Stephanie was forced to return to work because the family needed medical insurance. Jeffrey reported that Stephanie was unhappy with her job and took it out on him and the children at home. He stated that Stephanie became miserable to be around. Stephanie reported that she was unhappy because Jeffrey became controlling and reverted back to his unemotional behaviors. In 2005, the parties began living separately in the house once again. The relationship stayed that way until April 2006 when Stephanie decided to move out of the home. Sarah Jane Krouse Sarah is a twelve-year-old girl currently living with her parents in the shared custodial arrangement. Sarah is described by her parents as smart, pleasant, and independent. Each parent indicated that Sarah tends to be more introverted and shy. Jeffrey reported that Sarah appears to be "crawling into more of a shell since the separation." He noted that she has begun isolating herself more than usual. Each parent reported that Sarah can be opinionated and head-strong. Jeffrey stated that Sarah has become increasingly short-tempered with Hannah. Stephanie and Jeffrey each reported removal of privileges and lecturing as typical disciplines. Both parents denied the use of corporal discipline. Sarah reportedly does very well in school. The parents stated that she is on the honor roll and both denied the presence of behavioral problems at school. A review of her report cards revealed mostly A's and B's and positive comments from all of her teachers. Sarah's physical health is very good. There were no reports of current illnesses and both parents denied any serious injuries. Sarah takes no medication. Jeffrey and Stephanie indicated that Sarah has a healthy appetite. They reported variable tastes for food and noted that she eats healthy. Her favorite foods include macaroni and cheese, fruits and vegetables, and chicken. Krouse v. Krouse Page 6 of 15 Jeffrey and Stephanie each indicated appropriate bedtimes for Sarah. Each party indicated similar, child appropriate routines that involve her going to sleep around 9:00 PM on school nights. They each noted that Sarah is able to sleep through the night without interruption. Stephanie reported that Sarah is difficult to arouse in the morning and may be in a bad mood. Jeffrey stated that he does not have sleep restrictions on the children during weekends. Each parent reported that Sarah enjoys videogames, music, shopping, and reading. They reported that she has a small group of friends. Sarah reported that she has her friends sleep over when she is at her father's house. Sarah reported to the evaluator that she is in the seventh grade. She stated that she enjoys doing most things by herself. She indicated that her hobbies involve reading, playing videogames, being on the computer, and playing the clarinet. She also noted that she enjoys playing outside with her grandmother's dog. Sarah reported that Hannah tends to follow her around and that she gets annoyed at her easily. Sarah noted that she feels confused by the current custody evaluation. She denied being talked to by either parent about the evaluation. She stated that she does not feel pressured to pick one parent over the other. Sarah reported that her father will buy her anything she wants. She stated that he takes time off from work to spend time with her and Hannah and that he "rough houses" with them. Sarah noted that he has been much more involved since the separation. She indicated that he was not active with the children prior to that time. She alleged that Jeffrey would work, eat, and then sleep on the couch. Sarah reported that her mother was their primary caretaker. Sarah reported that she overhears her father and mother arguing on the phone. She denied Jeffrey speaks negatively about her in front of her. She noted that her father does not believe her or her mother about her completing her homework when she is at her mother's house. Sarah indicated that she is angry that her father accused her and her mother of lying. Sarah reported that she enjoys staying at her mother's house. She stated that her grandmother watches them during the day when her mother is at work. She indicated that her grandmother is fun to be around and that she interacts with them very well. Sarah reported that Stephanie is a "great parent." She reported that her mother was solely responsible for raising she and Hannah and that her father was "only around on weekends." Krouse v. Krouse Page 7 of 15 Sarah told the evaluator that her mother wanted to leave the marriage two years ago. She stated that she knew that her mother was unhappy with her father's lack of involvement with the family and that her father was mean to her mother. She stated "mom put up with him for two more years but he was mean and would yell at her a lot." Sarah denied that her father was inappropriately mean to the children. Sarah stated that she feels her mother is easier to talk to because she understands her better. She also indicated that she can talk to her grandmother. Sarah noted that her father is difficult to talk to because he does not know her as well as her mother knows her. She also stated that he does not make himself as approachable. Sarah was asked to make three wishes. Sarah wished that: (1) She was trusted more by everyone about her decisions; (2) That everyone would be happier and there was no fighting or hate in her family; and (3) "I just wish my father was this involved when the family was together." Sarah completed the Parent Report Card for each of her parents. She graded Jeffrey higher in helping her with her homework, keeping secrets, and in buying her the things she wants. Sarah graded Stephanie higher in showing physical and emotional affection, spending time alone with her, and understanding poor grades. Sarah completed a Sentence Completion Test for this evaluation. Her responses indicate that she experiences a lot of distress about her parent's separation. She expressed a desire to have her family back together again. She reported that she gets sad when her parents fight and that she has thoughts of running away because of the stress. Her responses indicate that she has positive feelings about both of her parents but that her mother is more affectionate and understands her better. During her interview, Sarah stated that she feels she needs someone to talk to about the stress and negative emotions associated with the situation. She reported that she talks to the dog when she is distressed. Hannah Katherine Krouse Hannah is currently eight-years-old. She is described by her mother as funny, happy-go- lucky, outgoing and affectionate. Each parent described her as inquisitive and concerned about other's feelings. Jeffrey indicated that Hannah tends to be more shy and reserved around crowds than her sister. However, Stephanie stated that Hannah is outgoing and outspoken. Each parent denied the presence of behavioral problems for Hannah. Jeffrey indicated that Hannah is a perfectionist and can be very hard on herself. Each parent described similar discipline techniques with Hannah. They denied the use of corporal punishment. Krouse v. Krouse Page 8 of 15 Each parent described bedtime routines similar to those used for Sarah. They each stated that Hannah goes to sleep easily and arouses without a problem. Jeffrey reported that Hannah often sleeps in the bed with him. Jeffrey did not report a plan to eliminate this behavior. Stephanie and Jeffrey reported that Hannah has a healthy appetite and appropriate diet. Jeffrey stated that Hannah has more of a sweet tooth than Sarah. Both parents denied significant medical problems for Hannah. Stephanie reported that Hannah will need braces but denied a history of significant illness or injury. They denied the use of any medications and denied involvement in psychotherapy. Hannah reported that she is currently in the third grade. She denied being talked to by either parent about the custody evaluation. She indicated that she enjoys time spent with each parent. She stated that her father helps her with her homework and greets her at the door after school. She indicated that they have fun together and that he lets her stay up past her bedtime in the summer and on weekends. Hannah noted that her father talks to her about court and what happens in court with her mother. She denied hearing her father speak negatively about her mother. Hannah indicated that she has fun when she is at her mother's house. She stated that they play a lot games together after her mother comes home from work. She also reported that her grandmother plays with her when her mother is not home. She denied hearing her mother speak negatively about her father. Hannah reported that each of her parents are able to soothe her when she is upset. She indicated that both parents make themselves available to her if she needs to talk. She noted that she misses each parent when she is with the other. Hannah completed a Parent Report Card for each of her parents. Hannah scored her parents equal on measures of schoolwork, affection, and making her feel comfortable. She scored her mother higher on keeping the house clean and cooking good meals. Hannah also completed the Sentence Completion Test. Her responses indicate that she experiences a great deal of distress because of her parents' separation. She finished sentences in a way that suggests she feels positively about both parents and has positive experiences with each. Jeffrey Krouse Jeffrey is self-employed and works out of his home as a mechanical engineer and draftsman. He also works part-time in a funeral home. As a result, he has a flexible work schedule in which he can be home with the children during his custody times. Jeffrey is the middle of three children born to now divorced parents in Camp Hill, Pennsylvania. Jeffrey indicated that he had a positive relationship with his siblings and his mother. He reported that his father was reclusive and "stand-offish." He stated that Krouse v. Krouse Page 9 of 15 each of his parents were involved in the discipline of the children and denied the use of corporal discipline. Jeffrey noted that his parents separated when he was 16 years old for unknown reasons. He reported that he remains close to his mother and his siblings but that he has a distant relationship with his father. Jeffrey stated that he did very well in school. He reported that he was active in athletics and was part of the stage crew for plays and musicals. He indicated that he had a small group of friends but was more introverted in social settings. Jeffrey denied any significant dating relationships and denied ever being disciplined for his behavior in high school. He denied a history of violent or aggressive behavior. Jeffrey reported that he attended the Harrisburg Area Community College and the Thompson Institute after he graduated high school. He indicated that he began working as a draftsman. He worked with small companies for approximately two years prior to working for GS Electronic. He remained there until he was laid off and began working from home as a mechanical engineer. Jeffrey reported that he was in two long-term relationships prior to meeting Stephanie. He indicated that the first relationship lasted two and one half years before the woman called it off. He denied any plans for marriage and denied any children from that relationship. Jeffrey stated that he lived with another female when he was 27 years old. He reported that the relationship ended amicably after three years. Jeffrey denied the use of alcohol in the past three years. He reported a history of social drinking. He stated that he smokes one-half pack of cigarettes per day but denied the use of cigarettes in front of the children. He denied the use of illegal drugs. Jeffrey denied ever being arrested or charged with a crime as an adult. He indicated that he was caught shoplifting when he was 15 years old but denied being charged with a crime. He stated that he was forced to return the stolen spray paint. Jeffrey indicated that he has high cholesterol for which he takes Vytorin. He denied any other medical problems. He reported that he was involved in psychotherapy in his early 20's following the end of his first significant relationship. He denied any counseling since that time and denied the use of psychotropic medications. At his interviews, Jeffrey presented as concerned about Stephanie's behavior since the separation. His conversation style was thoughtful and analytical. Jeffrey responded thoroughly to questions about Stephanie's concerns. However, he demonstrated little understanding and insight about the impacts of some of his behaviors on Stephanie or the children. His thought processes were logical and coherent. There were no observations of unusual or bizarre cognitions. Jeffrey's MMPI-2 profile appears to be valid but indicated a mildly defensive response pattern. Jeffrey appeared to present himself in a favorable light. Jeffrey's profile is consistent with individuals who have a lower activity level and who are typically Krouse v. Krouse Page 10 of 15 seclusive or withdrawn from others. There is evidence to suggest that Jeffrey has a low drive and may be difficult to motivate. Others often describe people with this profile as timid and hard to get close too. Jeffrey completed the Parenting Street Index (PSI) which evaluates potentially stressful characteristics of a child, i.e. Child Domain, and potentially stressful characteristics of a parent, i.e. Parent Domain. Jeffrey's responses on the Child Domain suggest that he sees both Sarah and Hannah as having difficulty adapting to new situations and difficulty accepting his limits. Also, there is evidence that he does find that either child reinforces him as a parent. He also described them both as having problems related to their mood. On the Parent Domain, Jeffrey responded in a way that suggests he does not feel competent as a parent and he does not experience secure attachments with the children. Furthermore, he fords his role as a parent to be isolating. He appears to experience minor stress related to his relationship with Stephanie. Jeffrey lives in a ranch home located in a residential area of Carlisle. Both the interior and exterior of his home are in good condition. The house has three bedrooms. Each girl has their own bedroom which was well-maintained with appropriate furnishings and decorations. For a family activity, Jeffrey and the girls played Disney Monopoly. Sarah did not appear to enjoy the game and was more quiet and reserved. Hannah was excited and chatty throughout and appeared to enjoy the experience. During the game, Hannah was the banker and Sarah handled the real estate. Jeffrey interacted positively with the girls and helped manage all of the transactions during the game and the children responded appropriately to his limits. The family played seriously with game related conversation. While there was little physical affection between Jeffrey and the children during the observation, there were no signs of apprehension or discomfort exhibited by the children. Overall, they were cooperative as they read cards and took turns together. Stephanie Krouse Stephanie is the younger of two siblings born to now divorced parents in Portsmouth, VA. She stated that she has two step-siblings from her mother's remarriage. Stephanie indicated that her parents divorced when she was eight years old. She reported that she had no relationship with her biological father and that her mother remarried when she was 10 years-old. Stephanie noted that she had a positive relationship with her mother and her siblings. She stated that her family moved around often and that they finally settled in Mechanicsburg, PA when she 19 years-old. Stephanie reported that her mother was the disciplinarian and denied exposure to corporal discipline. Krouse v. Krouse Page 11 of 15 Stephanie indicated that she was a below average student and that she did not enjoy school. She stated that she went to a Baptist high school where she played on the volleyball team. She reported that she had a good group of friends but denied any significant dating relationships during high school. Stephanie denied getting involved in any fights during school. She indicated that she got in trouble for things like talking or for. not doing her homework. Stephanie reported that she got married when she was 17 years-old to a man she had only known for six months. She stated that she was married for only six months. She indicated that the marriage ended because they "realized it was foolish to get married." Stephanie had no children during that relationship. Stephanie indicated one other significant relationship that lasted approximately one year. She stated that she left the relationship because the man was abusive and involved in drugs. There were no children conceived during that relationship. Stephanie noted that she worked in retail stores, restaurants, and as a customer service representative in the past. She currently works for Bobby Rahal Honda as a service advisor. She indicated that she works Monday through Friday from 6:15 AM until 4:00 PM. She denied working weekends. Stephanie reported that she drinks socially but denied drinking when she is with the children. She denied the use of cigarettes or drugs. She denied any legal history. Stephanie indicated that she takes medication for migraine headaches but denied other medical problems. Stephanie denied being involved in psychotherapy. She reported that she has been taking an anti-depressant since the marital separation. Stephanie stated that she was experiencing increased crying spells and sad mood following the separation and that she contacted her primary care physician about possible medications. Stephanie presented for her scheduled appointments on time and was cooperative with the evaluation process. During the initial interviews, Stephanie expressed a desire to have a shared custodial relationship with Jeffrey. However, after she uncovered the interactions between Sarah and Jeffrey, she decided that she should seek primary custody of the children. She appeared thorough in answering the evaluator's questions and demonstrated no bizarre or unusual cognitions. Stephanie's MMPI-2 profile suggests a mildly defensive response pattern. Stephanie was reluctant to admit perceived psychological shortcomings and attempted to present herself in a favorable light. The MMPI-2 profile seems to validate that Stephanie is experiencing a fair amount of situational stress and resentment. Women with this profile may overreact to perceived criticism and times of stress may lead to somatic complaints. It is possible that Stephanie's migraine headaches are related to her stress. Krouse v. Krouse Page 12 of 15 Stephanie's responses on the PSI indicate that she feels the children are not consistently reinforcing her parenting. She also indicated stress related to Sarah's mood difficulties and Sarah's willingness to accept Stephanie's limits. On the Parent Domain, Stephanie reported that she feels competent as a parent and experiences secure attachments with her children. She indicated that she experience a significant level of stress as a function of dealing with Jeffrey. Stephanie lives with the children in her parent's home located on two acres in Carlisle, PA. Both the interior and exterior of the home are in good condition and each girl has their own bedroom in the home. Each girls' room was appropriately furnished and decorated and there were no safety issues associated with house or yard. The family decided to play Uno for their family activity. Their interactions during the set- up and their conversations about previous games indicated a great level of familiarity with his type of activity. The family enjoyed joking and teasing one another throughout the activity and seemed to be close and get along well. Furthermore, Ms. Gribble (maternal grandmother) was present for the home visit. The children appeared emotionally attached to her as well. Recommendations: Jeffrey Krouse has petitioned the court for a change in the current custody arrangement. He is requesting that the schedule be amended to allow the children to spend all school nights with him and only alternating weekends with Stephanie. Stephanie initially indicated that she was content with the shared custodial arrangement but as the evaluation proceeded she noted a preference for an arrangement in which she was primary physical custodian of the children. There is a considerable amount of hostility between these parties and it appears to be negatively impacting the children, particularly Sarah. Jeffrey and Stephanie are unable to communicate with one another in a meaningful way. Additionally, they are extremely uncomfortable being in the same place together. This latter fact is illustrated by Stephanie's request that Jeffrey not attend her church on the Sundays when she has custody of the children. Jeffrey appears to be having a more difficult time with the co-parent relationship. This is evidenced by the e-mail conversations he was having with Sarah. Jeffrey demonstrated a willingness to permit behavior that he knew Stephanie would dislike and with which she was opposed. Yet, instead of addressing the issue with Stephanie, he encouraged the behavior and even taught Sarah how to conceal things from her mother. Jeffrey's behavior demonstrates poor judgment and understanding of the developmental needs of Sarah. Further, it suggests that Jeffrey is intentionally engaging in behavior that puts a strain on Stephanie's relationship with the children. Furthermore, Jeffrey expressed little remorse or understanding about the effects the emails had on the relationship between Sarah and Stephanie. Krouse v. Krouse Page 13 of 15 Jeffrey appears to spend a great deal more money on the children, especially buying them luxury items, than does Stephanie. Sarah and Hannah each reported that Jeffrey will buy them almost anything they want. They also stated that Jeffrey is much more lenient with restrictions and rules than is Stephanie. Jeffrey's leniency appears to be a new phenomenon since the separation. The children and Stephanie reported that Jeffrey and Stephanie were strict as parents, with rules and expectations, when they were together. Stephanie continues to utilize the same rules and expectations for the children that were in place prior to the separation. This change in Jeffrey's behavior suggests that he is trying to win the affection of the children and make his home more appealing. While some of that behavior might be expected due to the separation, Jeffrey's lack of insight into how that might be unhealthy for the children and the relationships with their mother is of great concern. While Hannah is described as happy and vivacious, Sarah is described by both parents as challenging and isolated. The parents' responses on the PSI further verify that she can be moody and has trouble respecting the limits set by her parents. Sarah reported that she feels conflicted about her parents fighting and that she has no one with whom she can talk about her feelings. Research on adjustment of children after separation shows that the greater the hostility between parents to which children are exposed, the more likely the incidence of behavioral and emotional problems, such as depression and acting-out behavior. It is unclear whether or not Sarah was experiencing depressive symptoms prior to the separation, but it is clear that the conflict between the parents is exacerbating her problems with adjustment. Another area of concern raised by the results of the evaluation is Jeffrey's perceived role as a parent. Jeffrey's responses to testing indicate that he does not feel competent as a parent and that he questions his attachments to the children. Furthermore, his testing suggested feelings of isolation related to his parenting responsibility. His PSI results indicate that he does find parenting reinforcing and suggested that each of the girls' inconsistent moods cause him a significant amount of stress. In spite of Jeffrey's self-report, he is described by Sarah and Hannah as having good qualities as a father. He schedules his work around his custody time in a way that maximizes the time he can spend with his children. While he was not as available to the children during the marriage, he has been consistent with his prioritizing of the children since the separation. The children reported that he interacts with them during their time with him and that he does a good job of meeting their physical needs. However, Sarah reported that she does not find her father as approachable or easy to talk to about emotional concerns. Krouse v. Krouse Page 14 of 15 Jeffrey's personality testing indicates that he typically has low energy and experiences low motivation. His profile suggests that he is emotionally constricted and prefers more introverted or isolated activities. His personality style could help explain why Sarah does not find him as easy to talk to as her mother. The testing also provides insight into why he does not experience secure emotional attachments to the children. His emotional constriction may prevent him from forming deep emotional attachments. Stephanie's testing suggests that she has a tendency to overreact to perceived criticism and that she can be oversensitive. Her handling of the situation with the family attending church as well as her reaction to the a-mails may be an example of some of her reactivity. However, her responses in those situations also show appropriate levels of concern. However, the way in which these concerns are expressed may place pressure on the children. Stephanie's responses include problem solving strategies that place Sarah and Hannah in the middle of conflict between the parents. Based on all of the information provided during the interviews, the results of the home evaluations, psychological testing, and the current peer-reviewed research, the following recommendations are given within reasonable degree of psychological certainty. 1. Stephanie be granted primary physical custody of the children during the school year. Jeffrey should have periods of partial custody on alternating weekends from Friday after school until Monday morning. Jeffrey should also have periods of partial custody on Wednesday evenings from after school until 7:00 PM and on the Monday evening following his non-custodial weekends from after school until 7:00 PM. This schedule will allow Jeffrey to have sufficient time and contacts with Sarah and Hannah in order to maintain the bond between them. During the summer months it is recommended that the parties should use a week-on-week- off shared physical custody schedule with a midweek visit for the non-custodial parent. a. The shared summer schedule is dependent upon the parents' involvement in co-parent counseling. In order for Sarah and Hannah to have the opportunity to thrive in their new family dynamic, the parents need to learn effective ways of communicating. If these parents continue to work together in the maladapted style they have adopted, it is likely to cause more significant adjustment problems for Sarah and Hannah. Admittedly, Hannah is not demonstrating problems at this time, but continued hostility and stress from her parents' relationship will have a detrimental effect. b. It is recommended that if possible Sarah and Hannah remain in their current school district so that they are not exposed to additional change. Krouse v. Krouse Page 15 of 15 2. Sarah is experiencing a fair amount of emotional distress currently. Her parents are noticing behavioral problems and Sarah reported that she experiences confusion and sadness when confronted by the current family situation. It is recommended that Sarah begin counseling with a child therapist who can help her process her emotions through this transition. The therapist can offer her an outlet for her distress and help her with techniques for communicating with her parents. Hannah is not currently exhibiting emotional issues related to the separation and impending divorce. However, Hannah may also benefit from having a relationship with a child therapist for the same reasons. 3. It is also recommended that the parents become active either with a counselor who works with divorced parents or with the children's therapist. The therapist can work with the parents on ways to communicate with Sarah and Hannah about important issues and allow a forum for important discussions to take place. Furthermore, the therapist could help Jeffrey better understand the emotional and behavioral needs of the children to develop better insight into how his actions affect the children. The Therapist could help Stephanie work on her reactivity to the children. 4. Jeffrey could also benefit from working with a psychotherapist who can help him process the resentment and anger that he currently feels toward Stephanie and the dissolution of the marriage. The therapist should further evaluate his symptoms of low energy, low motivation, and sad mood to determine if he is clinically depressed and could benefit from additional interventions. //-C>3 - zoo& Date Kasey Shienvold, Psy.D. Licensed Psychologist ? ?.` b ? ? ? ?x ? ? EXHIBIT "B" DEFENDANT'S LIST OF PROFESSIONAL WITNESSES Kasey Shienvold, Psy. D., M.B.A. 2151 Linglestown Rd., Ste. 200 Harrisburg, PA 17110 Dr. Shienvold will testify as to the custody evaluation we performed in anticipation of this trial. Dr. Shienvold's report is attached hereto as Exhibit "A," and incorporated herein as if fully set forth. -6- ???? t EXHIBIT "C" DEFENDANT'S LIST OF LAY WITNESSES 1. Stephanie Krouse 1151 Easy Road Carlisle, PA 17013 Ms. Krouse will testify with regard to her relationship with the children and why it is in their best interest to be in her primary custody. 2. Jean Gribble 1 151 Easy Road Carlisle, PA 17013 Ms. Gribble is Stephanie's mother, who currently lives with Mother and the children. Ms. Gribble will testify as to Mother's parenting skills and Mother's relationship with the children. 3. Glenn Gribble 1151 Easy Road Carlisle, PA 17013 Mr. Gribble is Stephanie's father, who currently lives with Mother and the children. Mr. Gribble will testify as to Mother's parenting skills and her relationship with the children. 4. Bill Bain Bobby Rahal Honda Carlisle Pike Mechanicsburg, PA 17050 Mr. Bain is Stephanie's Supervisor at Bobby Rahal Honda. Mr. Bain will testify as to Mother's exemplary work record and Mother's ability to have some flexibility with regard to her schedule. -7- 5. Chris Eberly 903-8347 Ms. Eberly and Stephanie have been friends for over ten (10) years. Ms. Eberly's two daughters are playmates with Hannah and Sarah. Ms. Eberly will testify as to Mother's relationship with children and her parenting skills. 6. Tracy White 243-3217 Ms. White and Stephanie have been friends for five (5) years. Ms. White has two daughters that are playmates of Sarah and Hannah. Ms. White will testify as to Mother's parenting skills and her relationship with the daughters. -8- CERTIFICATE OF SERVICE The undersigned certifies that on the 6 *^ day of duly, 2007, a true and correct copy of the foregoing Pre-Trial Statement was served via facsimile and first-class mail, postage prepaid, upon the following: Ann V. Levin, Esquire Smigel, Anderson & Sacks, LLP 4431 North Front Street Harrisburg, PA 171 10 PU'a ro, Pamela L. Purdy, Esquire Of Counsel for Defendant CD CTN rt ) To CIO I A JEFFREY KROUSE, Plaintiff v STEPHANIE LYNN KROUSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 06-2528 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY IN RE: AGREEMENT OF THE PARTIES ORDER OF COURT AND NOW, this 12th day of July, 2007, upon consideration of custody with respect to the parties' children, Sarah Jane Krouse (date of birth, December 29, 1993) and Hannah Katherine Krouse (date of birth, January 24, 1998), and pursuant to an agreement of the parties reached in open court through their counsel, it is ordered and directed as follows: 1. The parties shall continue to share legal custody of the minor children as set forth in paragraph 1 of the June 16th, 2006, Order of Court. 2. Mother shall have primary custody of the children subject to father's rights of partial physical custody as follows: a. Alternating weekends from Friday after school through Monday morning. b. Monday after school through Tuesday morning following mother's custodial weekend. C. Wednesday after school through Thursday morning following father's custodial weekend. d. Wednesday after school until 7:30 p.m. following mother's custodial weekend. 3. Father's alternating weekends of custody shall end at 7:30 p.m. following mother's relocation to the Carlisle area set forth below. >: i 1 4. The parties shall continue to alternate weeks during the summer as they have been. 5. Mother's primary custody schedule, as set forth above, shall commence the first week of school. 6. Mother shall relocate to the Lamberton Middle School area. Mother shall initiate this move in good faith as soon as possible, and no later than 6 months from the date that the parties reach a financial settlement on their pending economic claims in the divorce action. 7. The parties shall continue to share holidays as they have been. 8. The minor child, Hannah, shall continue to be enrolled at Mooreland Elementary. In the event a letter is needed from Doctor Kasey Shienvold to cause that enrollment to continue, the parties shall cooperate in obtaining such a letter. 9. Sarah shall continue to be enrolled in the Lamberton Middle School. 10. Hannah and Sarah shall both participate in counseling with Kristen Gennett of Franco and Associates. The parents shall alternate taking the children to these appointments. 11. The parties shall continue in co-parent counseling with Anthea Stebbins as Ms. Stebbins recommends. 12. Both Father and Mother shall undergo a psychiatric evaluation and follow the recommendations of that evaluation regarding follow-up counseling and medication. 13. The parties shall participate in a re-evaluation with Doctor Kasey Shienvold no later than March of 2008 to determine the progress they have made in terms of their communication and parenting in moving towards a 50/50 schedule with the children. 14. Father shall transport the children to and from school until such time as Mother relocates to the Carlisle area as set forth above. 15. Hannah's participation in "Child Time" shall be determined as so; the parents and the counselor discuss. 16. The costs for Doctor Kasey Shienvold for the original valuation, attendance here this morning, and the re-evaluation shall be prorated by the parties and taken into account in their equitable distribution proceedings. 17. In the event that either party is in need of a baby-sitter for more than 3 hours, they shall contact the non-custodial parent and offer a baby-sitting opportunity to the other parent, except that mother is not bound by this paragraph if the maternal grandmother will provide the baby-sitting; Father will also not be bound by this paragraph if his mother is available to provide the baby-sitting. 18. The parties shall have liberal telephone contact with the children. 19. This order is entered pursuant to an agreement of the parties. 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, Ann Levin, Esquire 4431 North Front Street Harrisburg, PA 17110 For Plaintiff Pamela L. Purdy, Esquire 308 North Second Street Suite 200 Harrisburg, PA 17101 For Defendant mae