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HomeMy WebLinkAbout06-4699 Date: 8/8/2006 Time: 09:34 AM Page 1 of 2 Co~ia County Court of Common Pleas .., ROA Report Case: 2002-CV-0000050-CU Current Judge: No Judge . User: CHOWER 01-- J./I..'lf. e~I:L/~ Tarin A Steele vs, Jonathan A Steele Date 1 114/2002 1 11 5/2002 1/23/2002 3/712002 9/2/2005 9/6/2005 9/30/2005 10/19/2005 12/23/2005 12/28/2005 Custody Complaint Judge IFP petition and custody complaint filed pro se. Order: IFP petition granted, By the Court:/s/Scott W, Naus. Special master in custody appointed, Order of Court filed approving Special Master Report/Recommendation. Thomas A James Jr Total amt of $75,24 for services rendered as S,M, Piff and Deft to each pay $37,62 within 90 days. By the Court:/s/Thomas A. James Jr. Bills to both parties, Filing: Custody Contempt Petition Paid by: Steele, Jonathan A (defendant) Receipt number: 0008512 Dated: 9/2/2005 Amount: $20,00 (Cash) Custody Contempt Petition filed by Jonathan Steele, pro se, Original to Court Administrator. Hearing Scheduled (Custody Contempt Hearing 10/03/200511 :00 AM) on Thomas A James Jr Petition for contempt F/B Deft in chambers of Judge James. By the Court:/s/Thomas A. James Jr, (2 copies, Cert 1 to Deft on 9-7-2005) Entry of Appearance with Certificate of Service attached fib Atty, Kara Haggerty on behaif of the Respondent, Tarin A. Steele. (1) copy returned to Atty. Motion for Continuance with certificate of service fib Atly, Kara Haggerty. Original to Court Administrator, (2 copies returned to Atly Haggerty with copy of Order by Judge James enclosed by mail on 10-20-2005) Answer to Petition for Contempt for Failure to Comply with Custody Order and Petition to Transfer Venue and Answer to Petition for Contempt for Failure to Comply with Custody Order, and Petition to Transfer Venue fib Atty. Kara Haggerty, Original to Court Administrator, Order: And now, October 13, 2005, after consideration of Deft's Petition for Thomas A James Jr Contempt and Plffs Petition to Change Venue, the Court issues the C-.....ed fro following Order: .. "" m the recordI thII (1) Deft's Petition for Contempt is denied, r.LtLDa Of~A 0 fllVv' (2) Based upon the changed circumstances and upon this Court' own Y , . A"'-"" motion, this matter is referred to the Special Master to issue an appropriate TAMI B,KlINE. P :rHONOTARY recommendation for a modified Order based upon the changed C 11 oJ) 11 _ circumstances, The Master shall schedule a conference expeditiously. ft.,. I ~ rV ~ TJ7J /{Jr'fl (3) Ruling is reserved upon Plffs petition to transfer venue, This Court will . issue a ruling on venue after the modification process is completed and Pmtb. & Ok: !Sev. COUrts upon motion to file to revisit the venue issue, By the Court:/s/Thomas A. "'- "'-m E" t"t "'Al'~~ Jan. It* James Jr. ....3 "". . a..... ~ .I:'6',,~... kl.0ll . (Copy of order mailed to Plffs counsel Kara Haggerty ESQ and Deft Pro se on 10-20-2005. Copy of Order and supporting documents filed by both parties to Special Master in Custody by mail box 10-20-2005) Order of Court filed approving Special Master Report/Recommendation, Scott W Naus Total amt of $105,00 for services rendered as Special Master, Plff and Deft shall each pay the sum of $52,50 w/I 90 days of this Order. By the Court: /sl Scott W. Naus {Order dated Dec 22, 2005) Bills sent to both parties via regular mail. Plaintiff, paid Special Master fee in the amount of $52.50 by check No, 791. Date: 8/8/2006 Time: 09:34 AM Page 2 of 2 Co~ia County Court of Common Pleas . .. ROA Report Case: 2002-CV-0000050-CU Current Judge: No Judge User: CHOWER Tarin A Steele vs. Jonathan A Steele Date 3/1/2006 3/13/2006 7/19/2006 7/20/2006 7/24/2006 8/412006 8/8/2006 Custody Complaint Judge Scott W Naus Order of Court filed approving Special Master Report/Recommendation. Hearing for review only. Total amt of $60.00 for services rendered as Special Master. PIli and Deft shall each pay $30.00 wli 90 days of this Order. By the Court: Isl Scott W. Naus {Order dated Feb 28, 2006} Bills sent to both parties via regular mail. Rec'd payment in the amount of $30.00 from PIli.. {Check #872/mail} Order of Court issued by Judge Thomas A. James, Jr. AND NOW, this 18th day of July, 2006, it is hereby Ordered a hearing has been set at 11 :00 A.M. August 3, 2006 on Petition to Transfer Venue in the Chambers of the Honorable Thomas A. James, Jr. at the Columbia County Courthouse, Bloomsburg, PA. BY THE COURT: ISI Thomas A. James, Jr. Copies mailed to Defendant and Atty. Haggerty by Judge's Secty. Petition to Transfer Venue FIB Atty Kara Haggerty on behalf of PIli. Cert. of service filed for service of copy of Petition upon Deft Jonathan Steele by mail on July 11, 2006. Original to court administrator. Order of Court: And now, July 18, 2006, it is ordered that a hearing has been set at 11 :00 a.m. on August 3, 2006, on Petition to Transfer Venue in the chambers Judge James, Columbia County Courthouse. By the Court:/s/Thomas A. James Jr. (Copy of order to Atty Kara-Haggerty and Deft pro se by mail 7-27-2006. Returned copy of Petition to Atty Haggerty by mail 7-26-2006) Order of Court: And now, August 3, 2006, at the time set for the petition to Scott W Naus transfer venue and after review of the file and agreement of the parties, it is Ordered and Decreed that venue in this matter is transferred to Cumberland County for all future purposes in regard to this custody action. By the Court:/s/Scott W. Naus. (Copy of order to Atty Kara Haggerty and Atty Jonathan A. Steele by mail 8-8-2006) Complete file mailed to Court of Common Pleas of Cumberland County on August 8, 2006. Thomas A James Jr Thomas A James Jr 1"'\ ('. . . ~ n -k g ~ ~ \. "' - ;J:: ~ ~:D ).> -OCP rnf1'"< (> Z.';;., Gl -c,~ - '&,,(, - ~.tJ "l;) ~ 0 =<~,: (JI \J(_l ~c: ~4: - - .." _' -d ~ ~ "'"C O~ 6"" Z- ::J: 6 ~ 'j>C) 'i! c: -=-I ...,.. ~ J ~ - 00 ~ ....~...~~,_. '-'-"--"-'~:- '~:_'~~:?,_,_:~7::-:',--"-_.,c;" ~ . . Plaintiff IN THE COURT OF COMMON PLEAS OF THE 26TH JUDICIAL DISTRICT OF PENNSYLVANIA COLUMBIA COUNTY BRANCH CIVIL ACTION-LAW JONATHAN A. STEELE, VS TARIN A. STEELE, Defendant NO. 50 OF 2002 e'Jn or. s9 ~~:.:.o-: ~ = = =- -0 :/'J o .~ \~ ' ,.:,-'-' 2: c"' I .c -".~ - ~~r O' "70" -0 APPEARANCES: eDe, _-t"! '-:Y KARA HAGGERTY, ESQUIRE, Attorney for Plaintift. JONATHAN A. STEELE, ESQUIRE, Attorney for DeJ~ndaOi. T~ -~'1 ~v --< ORDER OF COURT AND NOW, to wit, this 3rd day of August, 2006, at the time set for the petition to transfer venue and after review of the file and agreement of the parties, it is hereby ORDERED and DECREED that venue in this matter is hereby transferred to Cumberland County for all future purposes in regard to this custody action. BY THE COURT, . IN THE COURT OF COMMON PLEAS FOR THE 26TH JUDICIAL DISTRICT COLUMBIA COUNTY BRANCH, PENNSYLVANIA CIVIL ACTION - CUSTODY - JONATHAN A. STEELE Plaintiff VS TARIN A. STEELE . CASE NO: 50 OF 2002 Defendant ONATHAN A. STEELE, Defendant ORDER OF COURT AND NOW, this 18th day of July, 2006, it is hereby Ordered a hearing has been set at 11:00 AM August 3, 2006 on Petition to Transfer Venue in the Chambers of the Honorable Thomas A. James, Jr., at the Columbia County Courthouse, Bloomsburg, Pennsylvania. BY THE COURT HONORABLE THOMAS A. JAMES, JR., J. THIS COURT WOULD APPRECIATE IF ATTORNEYS WOULD SEND BRIEFS AND LEGAL MEMORANDA (in word) TO THIS COURT VIA E-MAIL AS WELL AS BY HARD COPY. THE E-MAIL ADDRESS IS tiames@columbiapa.oro ALTHOUGH ENCOURAGED, THIS PROCEDURE IS NOT MANDATORY. 't")C"'> or;- 1'0,,) <::!'T1 g z'" Q- --<=" -<0 ~ 0-" r- -"n nO 0C: ClO .-'" c::--< :r'" .,., CZlO U -.." ~.-rJ '*' ~~ U1 en " :lJ o -1 ::I:1I Or' 25r'l :-iO }> :lJ -< . .ABOM & KtfTULAKIS . .~ AlTORNEYSATlAW J6 Sou'" H""..... Slrcct Cllrlillle, Pe:nrurylftrml'7Q1j )OHN A. A80M )AlION P. KUI1.f1o\KIS KIIJtA .... HAGGIlRTY KAnrLE8N ENGLE MlCHllLUl L SOMMER TELEPHONE: ('717) 249-4900 FAX; ('717) 249-3344 ,""",,~bomku.tu1alrit.enm FAX Judy Harmon (570) 389-5621 6 Jonathan Steele v. Tarin Steele: No. 50 of 2002 Kaxa W Haggerty, Esquire Comments: IF YOU DO NOT RECEIVE ALL OF THESE PAGES, PLEASE CONTACT THE FAX OPERATOR AS SOON AS POSSIBLE AT (717) 249-0900. THANK YOUI PRIVILEGE AND CONFIDENTIALITY NonCE Th. doc:u...nts occoropanying this t.I....py frono.boion eont.in info.....tion from the law finn of Abo.. " Kutul.kio, which is contidentt.1 and/or '.gally privilOJ!:ed. The inFonnotJon d intended only For the us. of the individual or entity n.med on thit tr.nomission sheet. If you ar. not the in!ended r..iplent. you sr. h.reby notir",d th.t .ny disci....... eopying, dittribation or the !eking of .ny .ction in r.li.... on the eontrnlll of this telecopied information i. otrkdy prohibited.. The do~uments should M ~rurned to thillll firm immediattly; 'Wit can .rrnnge rOo" the return of the otiJlna. documents to us at no cost to you. . JONATHAN A. STEELE, Petitioner v. TARIN A. STEELE, Respondent . IN THE COURT OF COMMON PLEAS 26'111 JUDICIAJ. BRANCI-I COLUMBIA COUNIT, PENNSYLVANIA NO. 50 of 2002 CIVIL ACTION - CUSTODY ORD.ER OF COQRT AND NOW; this _ day of June, 2006, it is hereby ORDERED AND DECREED that TIlls Honorable Court transfers jurisdiction over the above- docketed custody action to Cumberland County, Pennsylvania. Distribution: KaLa W. Haggerty, Esquire ABOM & KUTULAKIS, L.L.P. 36 South Hanover Street Carlisle, P A 17013 JonathanA. Stecle,pro.re State Route 254, Box 1953B Orangevillc, P A 17859 BY THE COURT: Thomas A. James, Jr.,]. . . JONATHAN A. STEELE, Peri.tioner : IN THE COURT OF COMMON PLEAS 26'111 JUDICIAL BRANCH COLUMBIA COUNlY, PENNSYLVANIA v. : NO. 50 of 2002 TARIN A. STEELE, Respondent CIVIL ACTION - CUSTODY ~TITlQN TO TRANSEER VENUE. AND NOW, comes Petitioner, Tarin A. Houpt, by and thtough her attomey, Kara W. Haggerty, Esquire, of ABOM & KUTULAK1S, L.L.P., and hereby files this Petition to Transfer Venue, and in support thereof avers as follows: 1. On or about March 7, 2002, This Honorable Court entered an Order granting Petitioner primary physical custody and Respondent patti.al physical custody of the subject minor children. 2. On or about June 2002, Mother relocated with the children to Cumberland County, Pennsylvania, with Father's concurrence. 3. Mother and the children have resided in Cumberland County, Pennsylvania since June 2002. 4. Father had been exercising custody with the children in accor.dance with This Court's Order. dated February 28, 2006, which take" into consideration Mother and childr.en. Jiving in Cumberland County by establishing the custody exchanges in Cumberland County. . . 5. Father has not been consistendy exetcising custody pursuant to This Court's Order dated Febmaty 28, 2006. 6. Mothe avers that Cumberland County, not Columbia County, is the proper venue for this custody action, pursuant to the Uniform Child Custody Jurisdiction and Enforcement Act, 23 Pa.C.S.A. Section 5401 et. seq., and that the custody action filed in Columbia County should be transferred to Cumberland County. 7. The provisions of the Uniform Child Custody Jurisdiction and Enforcement Act allocating jurisdiction and functions between and among courts of different states shall also allocate jurisdiction and functions between and among courts of common pleas of this Commonwealth. 23 Pa.C.S.A. ~ 5471. 8. Th.e Court of Common Pleas of Columbia County does not have exclusive, continuing jurisdiction over this custody matter because neither the children. nor their Mother reside in or have a significant connection with Columbia County, and substantial evidence is no longer available in Columbia County concerning the children's care, protection, training and persorull relationships. 23 Pa.C.S.A. ~5422. . . . WHEREFORE, Petitioner respectfully requests This Honorable Court to transfer jurisdiction over the above-docketed custody action to Cumberland County, Pennsylvania. RespecdUUysubnritted, ABOM & KUTUL1K1.f, LLP. DATE 011ill DLt ~. Kara W. Haggerty ID No. 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attornryfor Plaintiff . . . . . CERJ'IFICATE OF SE..BVICE ,.flL .;1u./y' AND NOW, this , day ofJlmt! 2006, I, Kara W. Haggerty, Esquire, of Ahom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregQing Petition to Transfer Venue, upon the Respondent by depositing, or causing to be deposited, same in the United States Mail, First-dass mail, postage prepaid addressed to the followin.g: jonathsn A. Steele State Route 254, Box 1953B OrsngeviUe, PA 17859 Respectfully submitted, MOM &- KUTULAKlS, L.LP. fJMJAJ Kara W. Haggerty ID No. 86914 36 South Hanover Street Carlisle, P A 1.7013 (717) 249-0900 AJtorn~y for Plaintiff . . . JONATHAN A. STEELE Plaintiff : IN THE COURT OF COMMON PLEAS : 26TH JUDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYLVANIA vs. CIVIL ACTION - CUSTODY TARIN A. STEELE Defendant NO. 50 OF 2002 ORDER OF PAYMENT AND NOW, to wit, thi~a.yof ~.. , 20~e within Statement from John L. McLaughlin, Esquire, in the total amount of $60.00 for services rendered as Special Master in the above-captioned matter is hereby approved and the County of Columbia is hereby directed to pay the same. It is further directed that a copy of this Order of Court with copies of the aforesaid attachment hereto, shall be delivered to the Columbia County Commissioner's Office. BY THE COURT: . C}\ - 'td''tl9\olf1103.:i0 ^tm~~ J:JLHO Sl\lf103 30 n." .. J. bE :b "i/ 1- lIVW qDDl ^tJ"V10N0\110H 03ll.:l . . , , . JONATHAN A. STEELE Plaintiff vs. : IN THE COURT OF COMMON PLEAS : 26TH JUDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY TARIN A. STEELE Defendant NO. 50 OF 2002 STATEMENT February 20, 2006 For Professional Services: John L. McLaughlin, Esquire DATE December 21,2005 Review file; Notices of Conference .25 sent to Plaintiff and Defendant .. .)C~ Ii br;- ..J .-rr. -", ;;0 Neither party attended the conference. A :;:>: .... 0 February IS, 2006 -<0 l!I'i -I..., 0'"" 0:> Stipulation was forwarded to the Master on '""n :c_ "" or February 10,2006. nO IN oC ZITI .::0 00 c-< -g ::J::I.I> j;! "'0 ~ ;;0 February 20, 2006 Drafting, preparation, filing and .t~ -< ~ service of Report to the Court upon ~,-.. CJ1 Plaintiff, Jonathan Steele and Defendant, Tarin A. Steele c/o Kara Haggerty, Esquire 1.0 hours at $60.00 per hour TOTAL BALANCE DUE $60.00 Yn (1).. I W I ~~~ I~ Uf) o .-... r . . . vs. : IN THE COURT OF COMMON PLEAS : 26TH JUDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYLVANIA CNIL ACTION - CUSTODY JONATHAN A. STEELE Plaintiff TARIN A. STEELE Defendant NO. 50 OF 2002 ORDER AND NOW, to wit, thist-- )rday of /-e{r- , 20QGupon presentation of the attached Report To The Court, it is hereby ORDERED and DECREED that the recommendations of the Master are incorporated by reference herein as an Interim Order. If no Exceptions are filed within ten (10) days of service of these Recommendations, this Order shall become a Final Order and shall remain in effect until further Order of Court. If Exceptions are filed this Order shall remain an Interim Order until disposition of the Exceptions. Plaintiff and Defendant shall each pay the sum of $30.00 to the Columbia County Prothonotary within ninety (90) days of this Order as costs ofthe Master's proceedings. BY THE COURT: c' ';Id '';I19WnlO:) 30 AHinOJ :jJUjO SllJnOJ 30 ~HYIJ ~ S(:b 'r;f 1- lIVM. J. )JJ \;liON OHl Ci;Ji 03ll..:l . . JONATHAN A. STEELE Plaintiff : IN THE COURT OF COMMON PLEAS : 26TI1 JUDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYLVANIA vs. CIVIL ACTION - CUSTODY TARIN A. STEELE Defendant NO. 50 OF 2002 . REPORT TO THE COURT --"'!rl :.i.r'::-, '-:i:.7J ...P: '<0 0"" ""n nO oC: ,...:;0 c..... ::J:Ul 0:>0 -"T\ ~~ :;:g JOHN L. McLAUGHLIN, ESQUIRE Specially-Appointed Master MARKS, MCLAUGHLIN, & DENNEHY 12 West Market Street P. O. Box 179 DanviIle, P A 17821 ~ ,.,.. ...,., ...... <:XI N W \J -u ::0 o -4'"T\ :I:._ or %("'11 00 ~ ;::0 -< ~ to.) ell . . JONATHAN A. STEELE Plaintiff : IN THE COURT OF COMMON PLEAS : 26TH JUDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYLVANIA vs. "Ii,., CIVIL ACTION - CUSTO~ ~ " ~::o - ;0 -lA .,., 0 NO. 50 OF 2002 ~~:;: ~.." ~g N or oC::: w ZfT1 ~:'\ 30 3:'" "D l>' ~~ N.. :;0 ~-4 -< The present action for custody was initiated on Septen1b~ 2, ~05 by PROCEDURAL HISTORY T ARlN A. STEELE Defendant 1. Plaintiff's Petition for Contempt filed to Number 50 of 2002 with the Columbia County Prothonotary. 2. Plaintiffs Petition for Contempt was heard by Judge James on October 3, 2005. 3. The controlling Order of Court was entered in 2002 and awards primary physical custody ofthe minor children to Mother subject to periods of partial physical custody with Father. 4. The matter was referred to the Special Master by Order of Court dated October 19, 2005. 5. A conference was held on November 11,2005 and recommendations were submitted to the Court for approval. 6. The Court confirmed the recommendations by Order of Court dated December 22,2005. . . 7. The recommendations contained a scheduled review for February 15, 2006. 8. By letter dated February 10,2006, counsel for Mother submitted a signed Stipulation to the Court. 9. The Master reviewed the terms ofthe Stipulation and finds them to be comprehensive and satisfactory in settlement of all outstanding claims. 10. Mother is represented by Kara Haggerty, Esquire and Father is not represented. . . vs. : IN THE COURT OF COMMON PLEAS : 26TIl JUDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY JONATHAN A. STEELE Plaintiff TARIN A. STEELE Defendant NO. 50 OF 2002 INFORMATION and IMPRESSIONS 1. The Master adopts the information and impressions recited in the Order of December 22, 2005 and republishes same. . . vs. : IN THE COURT OF COMMON PLEAS : 26TH JUDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY JONATHAN A. STEELE Plaintiff T ARlN A. STEELE Defendant NO. 50 OF 2002 RECOMMENDATIONS TO THE COURT It is the Recommendation of this Master as follows: I. Plaintiff and Defendant shall each pay the sum of $30.00 to the Columbia County Prothonotary within ninety (90) days of this Order as costs of the Master's proceedings. 2. Plaintiff and Defendant shall abide by the terms of the attached Stipulation which is incorporated herein by reference. Respectfully submitted, ..ly/~~J J1';C...{,,/Jt~/Aj:<__ L. McLAUGHLIN, ES~ Specially Appointed Master/" . . jONAlHAN A. S1'FE:l:S, PlIin!iff : IN THE COURT OF COMMON PLEAS 26'114 JUDICIAL BRANCH COLUMBIA COUNTY, PENNSYLVANIA NO, 50 oE 2002 CML ACl'ION - CUSTOPY v. TARIN A. STEELE, Defendant AND NOW, this Ji- dty of hnJJ {B.th ~. 2006, the: plnies hereby ~tipulate and agree llS follows: ~ L..LBG1\1,. O)STODY 1. The parties bereby agree to share le~l custody of their minor c::hiJdrcn. Hannah It Stecle. bomJl1Iy 2, 1996, and Gage M. S~ele, bOtn August 8, 2000. 2. F.-ell party Agrees to keep the: other. informed of the progress of the children's education IInd social adjustments. Bleh party I1gtcCS oot to impair the: othe.t party's right to shared legal. or phy$al custody of the children. Each party agrees to give Auppon to tb.e other in the .tOle as parent and to take into account.the consensus of the other fOt the pbysicaJa.od emotional, well.bcing oE tbe childri:n. 3. While in the p~ence of the childttn, neither patent shall mRke or permit any other person to make, llt1y remarks or do anything which could in any way be CQnR'lrUed lUl derogato.ry or uncomplimentary to the other pa.tcnt It shall be the express duty of each parent to upho!d the other .parent as one whom the children should respect and love, 4. It shall be the obligation of each pareot to make the children awilablc to the other in accorollDce with the phi"llica.l cu~tody schedule and to encoUf.'llge him to p.lI1ticiPAte in the plan hereby agreed And ordered. .f 5, Each patent shan hive the duty to .tlotify the other of any event ()t activity that could xellSonably be Cltpected to be of ~igoifi.c:ant c::o.ncern to the other parent. . . 6. The parents shall communicate dirccdy with one another concerning any parenting issue requiting C()nsultation alld agteement and reganling any proposed modi6cations t() the physical custody schedule, which may from time to time become necessary, and shall specificaDy not use the children as a mCS9enger. Furthermore, neither parent shan discuss with the children any proposed changes to the physical cu~tody schedule, or any other issue tequiring consultation ILnd agteement, prior to disc:u$sing the matter a.nd reaching lU1 agreement with the other pmnt. 7. With rega.td to any emergency decisions that must be made, theparcnt with whom tbe clilldren is pbysically residing at the time shall be permitted to make the decision necessitated by the emergency without consub:u1g the other parent in advance. However, that puent shaU iofonn the other of the emergency and consult with him/her as soon 2S pnssible. Day-to-clay decisions of a routine nature shall be the re.~ponsibility of the pm:nt having physical custody at the time. 8. Each parent sha.\l be entidcd to complete and full infoanation from a.ny doctor, dentist, tcach~ or authority and have copies of any reports given to them as a parent Such documents include, but an: not limited to, medical repotts, academil; and ~chool repo" cuds. 9. Neither puent sball schedule activities or appointmel1ts tor the cb.iJdrcn which would requitc their Attendance or plI.rticipe.tion a.t said activity or appointment during II. tUn.!: when they an: scheduled to be in the physical custody of the other parent without that patent', expr:es' prior approwl, 10, The PlI.rties hereby acknowledge that they have discussed and jointly made the following decisions: a) Father's wife, Ched Steele, shall not be present during the custody exchanges. Mother will h.1lVe primary physical custody with Father having partial physi.cal custody, Cailingmutualags:eem.ent to the conuuy, as fono'Wl\: 1. Alternating weekends with Father from Friday at 6:00 p.m. until Sunday at 6:00 p.rn. The general pattern shall be: one weekend with Father and Me weekend wit.h Moma. , . , , . . 2. Due to the amount of living space the Father has in his apartment, visitation with the Father's children and visitation with Mrs. Cherri Steele's children will occur on opposite weekends. 3.' All holidays will be shared by 88IC\;ment of the parties. 4. Transportation shall be the responsibility of the Father, with the exchanges taking place at Rita's Italian Ice in Carlisle, Pennsylvania m. TELEPHONE PRMLEO:e.8 The parties agree that there shall be reasonable telephone access between the children and both parents. As indicated by their signatures below, the parties agree that this Stipulation shall be entered as an Order of the Court ,t ~b& jl.;:;~'-: ,'I .S!:7;::t-" 1_.lt.,I.-o~ / Jonathan Steele, Defendan.t Kara W. Haggerty, Esquire w. Kim Hill, Esquire . . JONATHANA. STEELE Plaintiff : IN THE COURT OF COMMON PLEAS : 26TH JUDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYLVANIA vs. CIVIL ACTION - CUSTODY TARIN A. STEELE Defendant NO. 50 OF 2002 CERTIFICATE OF SERVICE I, JOHN L. McLAUGHLIN, ESQUIRE, Special Master, do hereby certify that on this ~ day of February, 2006 I served copies of the attached Report to the Court by depositing copies of same with the United States Postal Services, first class mail, postage pre- paid, at DanviIle, Pennsylvania, and addressed as follows: Jonathan A. Steele SR254, Box 1953B Orangeville, P A 17859 Tarin A. Houpt c/o Kara Haggerty, Esquire 36 South Hanover Street Carlisle, PA 17013 I ~ II/} l,/)t~);/.:~~ - / BY: L. McLAUGHLIN, ES pecially Appointed Master , Yr;(l(. I l/u- I ~L/na, ~cI I'"' . i"\ 04r . . JONATHAN A. STEELE Plaintiff : IN THE COURT OF COMMON PLEAS : 26TH JUDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYLVANIA vs. TARIN A. STEELE Defendant CIVIL ACTION - CUSy.qpY ~ NO. 50 OF 2002 C) _:_,-11 <:::> rn ("") N UJ ", C~i ~C) :'.~. :~; ,.,."----1 r(,i) U)0 :"---'1 :;;,.....,') )> o -<-'1 I___ CJr- Zrrl C) _ --_jO p. Of) --< 9 ~ ) '" ORDER OF PAYMENT AND NOW, to wit, this ~ of [j q~ , 2005, the within Statement from John L. McLaughlin, Esquire, in the total amount of $105.00 for services rendered as Special Master in the above-captioned matter is hereby approved and the County of Columbia is hereby directed to pay the same. It is further directed that a copy of this Order of Court with copies of the aforesaid attachment hereto, shall be delivered to the Columbia County Commissioner's Office. BY THE COURT: ~a; J. --....... - . ,. . JONATHAN A. STEELE Plaintiff vs. : IN THE COURT OF COMMON PLEAS : 26TH JUDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY T AR1N A. STEELE Defendant NO. 50 OF 2002 STATEMENT December 21,2005 For Professional Services: John L. McLaughlin, Esquire DATE November 11,2005 Review file; Notices of Conference sent to Plaintiff and Defendant .25 December 14, 2005 Conference with Plaintiff, Jonathan Steele, W. Kim Hill, Esquire, Defendant, Tarin A. Steele, and Kara Haggerty 1.0 December 21, 2005 L~'l.;' ::;: ::;50 R'\ (:)-r'l n service of Report to the Court upon -T1n N Plaintiff, Jonathan Steele clo W. Kim Hill, ~~ N Esquire amd Defendant, Tarin A. Steele ~;:;i c/o Kara Haggerty ~ '?, ..... = = ..." Drafting, preparation, filing and CJ -4'1 ::r:__ 0, zl'l 00 ~ :::v )> ll-P 9 CJ1 .D 1. 7 5 hours at $60.00 per hour TOTAL BALANCE DUE $105.00 '~_.;2.1 r....e-I 'ft~iP (\ () . - . . JONATHAN A. STEELE Plaintiff : IN THE COURT OF COMMON PLEAS : 26TH JUDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYLVANIA vs. ...... = CIVIL ACTION - CUST.ooy ~ i::r: "-, = rT1 " 1'-' w -lJ --::J L) :;~ :" C)r-- :Tr'l1 (:j' 'f ~~[J -~ ;.. TARIN A. STEELE Defendant U't-:) NO. 50 OF 2002 c:. J> 9 =tJ .~, N ORDER AND NOW, to wit, this lL day of [Jr>~ , 2005, upon presentation of the attached Report To The Court, it is hereby ORDERED and DECREED that the recommendations of the Master are incorporated by reference herein as an Interim Order. Ifno Exceptions are filed within ten (10) days of service of these Recommendations, this Order shall become a Final Order and shall remain in effect until further Order of Court. If Exceptions are filed this Order shall remain an Interim Order until disposition of the Exceptions. Plaintiff and Defendant shall each pay the sum of $52.50 to the Columbia County Prothonotary within ninety (90) days of this Order as costs of the Master's proceedings. BY THE COURT: ~~ J. - ~ .. . JONATHAN A. STEELE Plaintiff vs. TARIN A. STEELE Defendant . : IN THE COURT OF COMMON PLEAS : 26TH JUDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY NO. 50 OF 2002 REPORT TO THE COURT ..... .. n = = ~ .c ....... .. " )'~ = CJ "".CJ rn --., CJ -'1 ("""") ::r: '1 " C) l'V 0 (}~2 l'V r- e) ~) ~- fT1 CJ c.: .-; J> :;! 0 :r rr. l.;; 0 ~ 9 ::u ," .'.1 , ~, ,- U1 7'. .. CO JOHN L. McLAUGHLIN, ESQUIRE Specially-Appointed Master MARKS, MCLAUGHLIN, & DENNEHY 12 West Market Street P. O. Box 179 Danville, P A 17821 . . vs. : IN THE COURT OF COMMON PLEAS : 26TH mDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYL VANIA CIVIL ACTION - CUSTODY JONATHAN A. STEELE Plaintiff TARIN A. STEELE Defendant NO. 50 OF 2002 PROCEDURAL HISTORY 1. The present action for custody was initiated on September 2, 2005 by Plaintiff's Petition for Contempt filed to Number 50 of2002 with the Columbia County Prothonotary. 2. Plaintiff's Petition for Contempt was heard by Judge James on October 3, 2005. 3. The controlling Order of Court was entered in 2002 and awards Mother primary physical custody ofthe minor children subject to periods of partial physical custody with Father. 4. The matter was referred to the Special Master by Order of Court dated October 19, 2005. 5. Notices listing the case for conference on were directed to Plaintiff and Defendant on November 11, 2005. 6. Plaintiff and Defendant were advised of the conference by first class mail. . . 7. Both parties attended the conference of December 14, 2005. Plaintiff was counseled by W. Kim Hill, Esquire, and Defendant was counseled by Kara Haggerty, Esquire. 8. Jurisdiction and venue is properly within the 26th Judicial District, Columbia County Branch. . . vs. : IN THE COURT OF COMMON PLEAS : 26TH JUDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY JONATHAN A. STEELE Plaintiff TARIN A. STEELE Defendant NO. 50 OF 2002 INFORMATION and IMPRESSIONS I. Plaintiff, Father, JONATHAN A. STEELE, is an adult individual residing at SR254, Box 1953B, Orangeville, Columbia County, Pennsylvania. 2. Defendant, Mother, TARIN A. HOUPT, is an adult individual residing at 412 Shed Road, Newville, Cumberland County, Pennsylvania. 3. The parties were married on August 1, 1998, separated on October 17,2001, and divorced in 2003. The parties lived together from approximately 1995 until they were married in 1998. 4. Two (2) minor children were born of the parties' union, namely, Hannah R. Steele, date of birth, July 2, 1996, and Gage M. Steele, date of birth, August 8, 2000. 5. The children currently resides with Mother. 6. Mother resides with her husband, Kevin Houpt, their child, Ryan Houpt, age 14, and the two minor children at the afore stated address. 7. Father resides with his wife, Cheri Steele, at the aforestated address. . . 8. Mother is employed as an insurance agent with Shumaker Insurance in Newville, Pennsylvania. 9. Father is employed by Kramers Service Center in Orangeville. 10. Father has no visited with the children in many years. II. Both parties are sincerely interested in the welfare of the minor children. PLEASE NOTE: Tbe foregoing information was provided to tbe Special Master, and includes tbe Special Master's observations and impressions. Tbey are not to be considered conclusive factual findings since a formal bearing was not conducted. However, tbe information and impressions bave assisted the Special Master in forming the basis for the Recommendations to the Court. . . JONATHAN A. STEELE Plaintiff vs. : IN THE COURT OF COMMON PLEAS : 26TH JUDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY TARIN A. STEELE Defendant NO. 50 OF 2002 RECOMMENDATIONS TO THE COURT It is the Recommendation of this Master as follows: I. Primary physical and legal custody of the minor children, namely, HANNAH R. STEELE and GAGE M. STEELE, shall be with Mother. 2. Father shall have partial physical custody as follows: a) Weekends. Every Saturday, effective December 31, 2005, from 3:00 p.m. until 5:00 p.m. at the Carlisle Y.M.C.A. subject to the supervision of Mr. Kevin Houpt. 3. Father shall provide all transportation necessary to maintain the schedule of contacts recommended herein. 4. Each party shall have reasonable telephone access to the minor children when is in the custody or partial custody of the other. 5. The parties shall exchange all information pertaining to the health, education, and welfare ofthe minor children; including without limitation, report cards; progress . . reports from school; approval of extraordinary medical and dental treatment; summer school; summer camp; and approval of schools in general provided that such approval shall not be unreasonably withheld. 6. Each party shall have access to all school and medical records of the minor children and each shall have the ability to consent to emergency medical treatment when the children is in the custody of such party. 7. If circumstances from time to time prevent the exercise of partial physical custody or visitation, the parties shall provide one another with timely and reasonable notice as to the existence of such circumstances and an equal amount of make-up partial physical custody or visitation shall be provided at the earliest mutually agreeable date and time. 8. The parties shall notify one another by telephone of any serious illness of a children. 9. If any period of partial custody has to be missed due to an illness of the children, Mother will provide Father with at least twenty-four (24) hours notice of said illness, if possible, and Mother will provide to Father make-up time for said visit. A copy of a doctor's excuse outlining the reason for the missed period of partial custody shall be provided to Father at the time of the next visit. Additionally, each party shall notify the other at the time of transfer of the children of any medication, either over the counter or prescription, that has been administered to the children in the preceding twenty-four (24) hours and shall also provide to the other party said medication if it is necessary that the children remain on said medication. . . 10. Each party shall exert reasonable efforts to maintain free access and unhampered contact between the children and the other party and to promote a feeling of love and affection between the children and the other party. 11. Neither party shall harass, molest, or malign the other, or their respective families in the presence of their children. 12. Neither party shall engage in a pattern or course of conduct designed to interfere with the free and natural development of the children's love and respect for the other. 13. If either party intends to relocate from their present residence, he or she shall provide the other with a minimum of thirty (30) days advance written notice of relocation to permit modification of the terms and conditions recommended herein, if necessary. 14. Each party shall at all times keep the other informed of his or her respective address and telephone number. 15. Neither party will abuse alcohol while caring for the minor children and each shall maintain a safe environment for the children. 16. Both parties shall attend and satisfactorily complete the "KIDS FIRST" educational program, unless they have already done so. The "KIDS FIRST" Administrator, shall notifY each party of the date, time and location of the program. 17. The case is scheduled for review on Wednesday. February 15.2006 at 2:30 p.m. The parties and their counsel are directed to personally appear at the conference. . . 18. Either party may seek reconsideration of the Recommendations herein by submitting a written request for review to this Master. The request must contain a listing of where each party can be served (i.e. mailing address) and a telephone munber for each party. 19. Plaintiff and Defendant shall each pay the sum of $52.50 to the Columbia County Prothonotary within ninety (90) days of this Order as costs of the Master's proceedings. submitted, [/Jl r: HN L. McLAUGHLIN, E Specially Appointed Maste . . . vs. : IN THE COURT OF COMMON PLEAS : 26TH JUDICIAL DISTRICT : COLUMBIA COUNTY, PENNSYLVANIA CIVIL ACTION - CUSTODY JONATHAN A. STEELE Plaintiff TARIN A. STEELE Defendant NO. 50 OF 2002 CERTIFICATE OF SERVICE I, JOHN L. McLAUGHLIN, ESQUIRE, Special Master, do hereby certify that on this d- \ st" day of December, 2005, I served copies of the attached Report to the Court by depositing copies of same with the United States Postal Services, first class mail, postage pre-paid, at Danville, Pennsylvania, and addressed as follows: Jonathan A. Steele c/o W. Kim Hill, Esquire Harding & Hill 16 West Main Street Bloomsburg, PA 17815-1703 Tarin A. Steele c/o Kara Haggerty, Esquire 36 South Hanover Street Carlisle, PA 17013 BY: L. McLAUGHLIN, ES .. pecially Appointed Master }-d1 ~I ~JI1~cI ,'-" , r- , - '''' . ' ~ ~ -. /_. 'lI - JONATHAN A. STEELE, Petitioner VS TARIN ~. STEELE, Respondent IN THE COURT OF COMMON PLEAS OF THE 26TH JUDICIAL DISTRICT OF PENNSYLVANIA COLUMBIA COUNTY BRANCH CIVIL ACTION-CUSTODY NO. 50 OF 2002 ...., = = '-" c=; n --< .0 ~1,-- o,.~,.:, )> -~ y (-': -P. w APPEARANCES: The Petitioner appeared pro se. KARA W. HAGGERTY, ESQUIRE, Attorney ~..... I ;:~ for Respondent. ORDER OF COURT AND NOW, to wit, this 13th day of October, 2005, after consideration of Petitioner's petition for contempt and Respondent's petition to change venue, the Court issues the following Order: 1. Petitioner's petition for contempt is denied. 2. Based upon the changed circumstances and upon this Court's own motion, this matter is hereby referred to the Special Master to issue an appropriate recommendation for a modified Order based upon the changed circumstances. The Master shall schedule a conference expeditiously. 3. Ruling is reserved upon Respondent's petition to ~ ~ transfer venue. The Court will issue a ruling on venue after the aforesaid modification process is complete and upon motion filed to revisit the venue issue. BY THE COURT, ~~~~. n ~ -..... ; ) ~uia,(s~ I (}1"3'~ vir ~I:D ~~~ ,Il'f'~ ~ 1;b S rx- ;t3tI Ctw1i"At ~ J 0- /)lJ-U:::> . . JONATHAN A. STEELE, Plaintiff : IN THE COURT OF COMMON PLEAS 26TH JUDICIAL BRANCH COLUMBIA COUNlY, PENNSYLVANIA v. NO. 50 of 2002 TARIN A. STEELE, Defendant CIVIL ACTION - CUSTODY Q..RDER OF COURT AND NOW, this day of , 2005, upon consideration of the Petition to Transfer Venue, the request is hereby GRANTED. Jurisdiction over the Petition for Contempt for Failure to Comply with Custody Order is hereby transferred to the Cumberland County Court of Common Pleas for disposition. BY THE COURT: Thomas A. Jarnes,Jr., J. Distribution: Kara W. Haggerty, Esquire 36 South Hanover Street Carlisle, P A 17013 Jonathan A. Steele, ProSe State Route 254, Box 1953B Orangeville, PA 17859 . . v. IN THE COURT OF COMMON PLEAS 26TII JUDICIAL BRANCH COLUMBIA COUNTY, PENNSYL ~li\,. = . U"O JONATHAN A. STEELE, Petitioner . . NO. 50 of 2002 ,-: v:> ,.,., -0 W C> c.::) ::ill Or :z: orrJ ~o :Po ::0 TARIN A. STEELE, Respondent c; !- CIVIL ACTION - CUSTOD~,7 l> G,. ~-=-' ?~; 9 -< 1:?n - ANSWER TO PETII.IO..N FOR CONTEMPT FOR FAILURE To COMPLY wrra CUSTODY ORDER AND PETITION TO TRWSFE.R VENUE AND NOW, comes Respondent, Tarin A. Steele, by and through her attorney, Kara Woodruff Haggerty, Esquire, of ABOM & KUTULAKIS, L.L.P., and hereby files this Answer to Petition for Contempt for Failure to Comply with Custody Order and a Petition to Transfer Venue, and in support thereof avers as follows: ANSWER TO PETI':(ION FOR CQNIEMPT FQR FAILURE TO COMPLY WITH CUSTODY OlID-E:R 1. It is admitted that the Petitioner is Jonathan A. Steele who currently resides at State Route 254, Box 1953B, Orangeville, Columbia County, Pennsylvania. 2. It is admitted that the Respondent is Tarin A. Steele who resides at 412 Shed Road, Newville, Cumberland County, Pennsylvania. By way of further answer, Respondent's name is Tarin A. Houpt, by reason of marriage. 3. No responsive pleading is required of this averment due to the Petitioner's failure to complete this averment. By way of further answer, it is admitted that a prior order of custody had been entered by This Honorable Court on March 7, 2002. . . 4. Denied. It is specifically denied that the Respondent has violated said Order of Court in that Respondent has not followed the Court Order by not allowing Petitioner to have any contact with Hannah and Gage, the subject minor children. It is specifically denied that Respondent stopped all visitation and contact when Petitioner got remarried on January 30, 2004. WHEREFORE, Respondent respectfully requests This Honorable Court to deny Petitioner's Petition for Contempt. PETITIQN TO TRANSFER VENUE 5. Paragraphs one (1) through four (4) of this Petition are incorporated as though set forth in full. 6. On or about March 7, 2002, This Honorable Court entered an Order granting Respondent primary physical custody and Petitioner partial physical custody of the subject minor children. 7. On or about June 2002, Mother relocated with the children to Cumberland County, Pennsylvania, with Father's concurrence. 8. Mother and the children have resided in Cumberland County, Pennsylvania since June 2002. 9. Between March 2002 and June 2002, Father exercised custody with the children approximately two (2) to three (3) times, but not at the times specified in This Court's Order. . . 10. Between June 2002 and November 2002, Mother was unaware of Father's whereabouts as he moved often and was living in other states or other areas of Pennsylvania. 11. Father did exercise custody with the children over Thanksgiving of 2002. 12. In the early months of 2003, Father exercised custody with the children on three (3) weekends with Mother primarily providing the transportation. 13. In June 2003, Father telephoned Mother but did not ask about the children and did not request custody. 14. The children spent the Summer of 2003 with their maternal great- grandmother in Benton, Columbia County, Pennsylvania; however, Father never attempted to contact them or exercise custody with them. 15. In September 2003, Father exercised custody of the children for one weekend. 16. Father never appeared for the custody exchanges following his weekend in September 2003. 17. Between September 2003 and July 2005, Father made no contact with Mother or the children at all. 18. InJuly 2005, Father left a message on Mother's answering machine. 19. In August 2005, Father telephone Mother but did not request custody of the children. 20. Mother has not heard from Father since the telephone call in August 2005. . . 21. Mother avers that Cumberland County, not Columbia County, is the proper venue for this custody action, pursuant to the Uniform Child Custody Jurisdiction and Enforcement Act, 23 Pa.C.S.A. Section 5401 et. seq., and that the custody action filed in Columbia County should be dismissed. 22. The provisions of the Uniform Child Custody Jurisdiction and Enforcement Act allocating jurisdiction and functions between and among courts of different states shall also allocate jurisdiction and functions between and among courts of common pleas of this Commonwealth. 23 Pa.C.S.A. ~ 5471. 23. The Court of Common Pleas of Columbia County does not have exclusive, continuing jurisdiction over this custody matter because neither the children nor their Mother reside in or have a significant connection with Columbia County, and substantial evidence is no longer available in Columbia County concerning the children's care, protection, training and personal relationships. 23 Pa.C.S.A. ~5422. WHEREFORE, Respondent respectfully requests This Honorable Court to transfer jurisdiction over the above-docketed custody action to Cumberland County, Pennsylvania. Respectfully submitted, Kara WoodruffHa Attorney ID No. 86914 36 South Hanover Street Carlisle, P A 17013 (717) 249-0900 . . :vERlFICATIO~ Kara W. Haggerty, Esquire, states that she is the attorney for the party filing the foregoing document; that she makes this affidavit as an attorney for the Petitioner, because the party she represents for whom she makes this affidavit is outside the jurisdiction of the court, and verification of the Petitioner can not be obtained within the time allowed for the filing of the document; and that she has sufficient knowledge or infonnation and belief, based upon her investigation of the matters averred in the foregoing document; and that this statement is made subject to the penalties of 18 Pa.C.S.A. ~4904, relating to unsworn falsification of authorities. Respectfully submitted, ABOM & KUTULAKIS, LLP DATE~2q/~S Kara W. Haggerty, Es 36 South Hanover Sa:: Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Petitioner ID #86914 . . . . CERTIFICATE OF SERVICE AND NOW, this 2.q~ay of S1fkm~2005, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Answer to Petition for Contempt and Petition to Transfer Venue, upon the Plaintiff by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Jonathan A. Steele State Route 254, Box 1953B OrangeviUe, PA 17859 Respectfully submitted, ABOM & KUTULAKlS, L.L.P. Kara Woodruff Hagge ill No. 86914 36 South Hanover Street Carlisle, P A 17013 (71 TJ 249-0900 Attorney for Difendant -<~C) c")..r: -r;r: ..... = = '"" en ...... -c I.JJ o --.,...; .~ ~:JC: i'.- ,~ )> 9 o -<--rj ::r:__ or :Z:fTl ~o J>" :::0 -< c::-~ ~::U) ::r:::o "-~ ?,-., ~~ o ~ Ib~/t{) ~ ttJ~ ~--~ '" ! . . JONATHAN A. STEELE, Plaintiff IN THE COURT OF COMMON PLEAS 26TH JUDICIAL BRANCH COLUMBIA COUNTY, PENNSYLVANIA v. NO. 50 of 2002 TARIN A. STEELE, Defendant CML ACTION - CUSTODY AND NOW, this ORD..ER OF COURT day of ~~ ,2005, upon consideration of the Motion for Continuance, the request is hereby GRANTED. A hearing is rescheduled follL '"1} '-'/____' the 1-2 ~y of M;z;Jr€-r ,2005, at q ~i1:. in the Judge's Chambers, Columbia County Courthouse, Bloomsburg, P A. BY THE COURT: Distribution: Kara W. Haggerty, Esquire 36 South Hanover Street Carlisle, P A 17013 Jonathan A. Steele, ProSe State Route 254, Box 1953B Orangeville, P A 17859 . . JONATHAN A. STEELE, Plaintiff IN THE COURT OF COMMON PLEAS 26TI1 JUDICIAL BRANCH COLUMBIA COUNTY, PENNSYLVANIA v. NO. 50 of2002 TARIN A. STEELE, Defendant ....., ~ "u r.J"1 ::::J o -i-" I_ Or zrrl ,Z~ ~o _c."., J> 1> ~";'"J D :::0 :,.., 2] .. .-<: ~~ - AND NOW, this 29th day of September, 2005, comes the defend'ant, 'Fitin A. C" . CIVIL ACTION - CUSTODY;;y. ,-,,) "'" ,.,., "'C W C) MOTION FOR CONTINUANCE Steele, by and through her attorney, Kara Woodruff Haggerty, Esquire, of Abom & Kutulakis, LLP, and respectfully moves This Honorable Court to continue the above- referenced matter, and in support thereof avers the following: 1. A hearing on Plaintiff's Petition for Contempt for Failure to Comply with a Custody Order is presently scheduled for Monday, October 3, 2005, at 11 :OOAM. 2. This is the first requested continuance in this case. 3. A Petition to Transfer Venue is being filed by undersigned counsel requesting this matter be transferred to Cumberland County, Pennsylvania. 4. The Defendant is unable to rearrange her work schedule as she is employed by a small insurance company and is the only employee scheduled to work on the date of the hearing. 5. Undersigned counsel attempted to contact the Plaintiff, Jonathan A. Steele, by telephone to inquire as to his position on this request; however, there was no answer and no answering machine available to leave a message. . . WHEREFORE, it is respectfully prayed that This Honorable Court will grant the above Motion to Continue. Respectfully submitted, ADOM & KUTULAKI8, LLP Kara Woodruff Ha Attorney ID No.8 36 South Hanover Street Carlisle, P A 17013 (717) 249-0900 . ~ CERTIFICATE OF SERVICE AND NOW, this 20 Ul day oLvpbbu- 2005, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Motion for Continuance, upon the Plaintiff by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Jonathan A. Steele State Route 254, Box 1953B OrangeviUe, PA 17859 Respectfully submitted, MOM & KUTULAKlS, L.L.P. K.~~J~ctf ID No. 86914 36 South Hanover Street Carlisle, P A 17013 (717) 249-0900 AttornV' for Defendant ''':-;:(' ..~~ ~').- ~r ~ ,-.-....,., -,- ~ ; ,"- ,---.C ~c:; ::;::q ?"~ :iZ~ - ...... = = '"'" j ::::; V> 0 .-n -<., -0 :I_ W or a Zf11 )> 00 J;l 9 :xl -< C> r' ... . . JONATHAN A. STEELE, Petitioner IN THE COURT OF COMMON PLEAS 26TI1 JUDICIAL BRANCH COLUMBIA COUNTY, PENNSYLVANIA v. NO. 50 of 2002 TARIN A. STEELE, Respondent CIVIL ACTION - CUSTODY ENTRY OF APPEARANCE Please enter the appearance of the undersigned as counsel for the Respondent, Tarin A. Steele, in the above-captioned matter. Respectfully submitted, ABOM & KuruLAKls, LLP DATE~ Kara Woodruff Ha , E 36 South Hanover Stteet Carlisle, P A 17013 (717) 249-0900 ID No. 86914 ~ .. = ,- = <on ~.i. c:n -< c:~, ,.." ..-i -0 r: '1 .- - w ":1 I ,m") c::> ".'.- rrl ::~) -0 )> -< 0 -, (./j ;> 0 <;:;> '-' > -c "" "D (") > ", 0 r .. . . CERTIFICATE OF SERVICE AND NOW, this 2..gtLL day of~2005, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Entry of Appearance, upon the Plaintiff by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Jonathan A. Steele State Route 254, Box 1953B Orangeville, PA 17859 Respectfully submitted, ABOM & KUTULAKlS, LL.P. ,~.(- Kara Woodruff Ha ID No. 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attornry for Defendant ,..., => c.:-: = '-'"' :;J:) :::-j:::i- (/} 0 ,.., -<.., -0 ::t:_ W 0, 0 Zl'1 )> 00 };! Q :;0 ;;g -< 0 IN THE COURT OF COMMON PLEAS . 26TH JUDICIAL DISTRICT tA;r11l ,..,J" 'If( COUNTY BRANCH, PENNA. (county} . - . 1', VI If r~ 17~ Cl, 5"'-~ tt:- Ie.. PETITIONER * * * * * * * CIVIL ACTION NO'Si> of - CUSTODY 200.sJ. , : vs. -r; r /" .7~ ~ / L. RESPONDENT ,4, o R D E R Legal proceedings have been brought against you alleging you have willfully disobeyed an Order for visitation. If you wish to defend against the claims set forth in the following pages, you may, but are not required, to file in writing to the Court your defenses or objections. Whether or not you file in writing with the Court your def~sj!s or objections~ you must appear in person in Court on_ .~~_ theiL~ay of ~ ' ~~ at / .' erD . in the Judge I s Chambers , Columb a/ll!ll' I _r county Courthouse, Bloomsburg/Da "'e, PA, for a HEARING. IF YOU DO NOT APPEAR IN PERSON, THE COURT MAY ISSUE A WARRANT FOR YOUR ARREST. If the Court finds that you have willfully failed to comply with its Order for visitation, you may be found to be in contempt of court and committed to jail, fined, or both. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFICER LEGAL SERVICES TO ELIGIBLE PERSONS: COURT ADMINISTRATOR COLUMBIA COUNTY COURTHOUSE BLOOMSBURG PA 17815 570-389-5667 DATE: f~~1 'i'") or,- c:r" ::ZO::O ~;>C -<0 Bm~ . ." ~g j -0 ::0 o -l"TJ ::c_ or zfT! 00 ~ ::0 -< en ,.., -0 I cr "D ~ c.n N . 'J;h,rJ,.,_ L/. .P'~ ~/e.. PETITIONER I' vs. /;r/h A. 5J;</.e RESPONDENT . * * * * * * * IN THE COURT OF COMMON PLEAS 26TH JUDICIAL DISTRICT Ccr/u,..j" If' COUNTY BRANCH, PENNA. (county) CIVIL ACTION - CUSTODY NO':50 of 28 Il:).. PETITION FOR CONTEMPT FOR FAILURE TO COMPLY WITH CUSTODY/VISITATION ORDER TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. The Petitioner is :]"tp"'a-1J........ i. me/e. who resides at Y1;'&: ~_r2.5LJ ?e:>Y /'1H~ / tP/'4'~~~v,'/I~ "If 17ft51 . , 2. The Respondent is '[;,."., /I- ~~-e 1< who resides at t{ 12.. -;/.,,ePi /rd, N~lPlI,'II<- fA. /77..'{ ( 3. On entered by this court, a true and correct copy of which is attached an Order of Custody/Visitation was hereto, marked Exhibit "A" and made part hereof. 4. The Respondent has violated said Order in that: -';',-,'~ .f'T.eeJ-L IIv~ hIT hll41w~"/ Ttu C,t. f"r~,.,1",.- P,"Y Ne:>r t.~7'T,o.., :T.,.......Th...... (?~r,7,'",,,,,,,-) hu~~ 1f(rlY C-(?#trQc.7 t#,'Tt, , , 1;/lh {!( e ,p-.."I <-., 7) -;7p.'fr/ :7".. (I...." t' ~7,7;__~/.J ,...r 1I"'"h"~ ~t'.'..'/ c.....~ c:. (11..1,'" k, ',/;7), QI/ /I'/!;-;7"";,1;..,."1 t:/-/'::cP,.,r.f.c/ WA..e.11 r~ 117"'/"'~'/ .7;;,., U/,y :3 6/,2.. &t? If, o WHEREFORE, petitioner respectfully prays this Court grant a Rule upon the Respondent to show cause why (he) (she) should not be held in contempt for violation i"d'VI8~nlOJ 10 AlNnO' .:IJI110 SUInO:) 10 >lll"'; ~1l :Z d l- d3S ~1lB11 .. " .1JjV'.wNOHIO~d 03lld of the Order of this Court. (j., :J4-, It. ~~ , pro se . . . . , TARIN A. STEELE, PLAINTIFF IN THE COURT OF COMMON PLEAS 26TH JUDICIAL DISTRICT COLUMBIA COUNTY BRANCH, PENNA. vs. JONATHAN A. STEELE, DEFENDANT CIVIL ACTION - CUSTODY NO. 50 OF 2002 ORDER AND NOW, to wit, this _ day of , 2002 upo presentation of the attached Report To The Court, it is hereby ORDERED and DECREED tha the recommendations of the Master are incorporated by reference herein as an Interim Order. If no Exceptions are filed within ten (10) days of service of these Recommendations, thi Order shall become a Final Order and shall remain in effect until further Order of Court. I Exceptions are filed this Order shall remain an Interim Order until disposition of the Exceptions Plaintiff and Defendant shall each pay the sum of $37.62 to the Columbia Count Prothonotary within ninety (90) days of this Order as costs of the Master's proceedings. BY THE COURT: J. . . . , TARIN A. STEELE, PLAINTIFF : IN THE COURT OF COMMON PLEAS : 26TH JUDICIAL DISTRICT COLUMBIA COUNTY BRANCH, PENNA. vs. JONATHAN A. STEELE, DEFENDAN;r CIVIL ACTION - CUSTODY : NO. 50 OF 2002 REPORT TO THE COURT JOHN 1. McLAUGHLIN, ESQUIRE Specially-Appointed Master MARKS, MCLAUGHLIN, & DENNEHY 12 West Market Street P. O. Box 179 Danville, PA 17821 . . TARIN A. STEELE, PLAINTIFF IN THE COURT OF COMMON PLEAS 26TH JUDICIAL DISTRICT COLUMBIA COUNTY BRANCH, PENNA. vs. JONATHAN A. STEELE, DEFENDANT PROCEDURAL mSTORY CIVIL ACTION - CUSTODY NO. 50 OF 2002 1. The present action for Custody was initiated on January 23, 2002 by Plaintiff Complaint for Custody filed to Number 50 of 2002 with the Columbia County Prothonotary. 2. Plaintiffs Custody Complaint seeks primary physical custody of the parties' tw (2) minor children; namely, Hannah R. Steele, date of birth, July 2, 1996, and Gage M. Steele date of birth, August 8, 2000. 3. The matter was referred to the Special Master by Order of Court dated Janu 23, 2002. 4. Notices listing the case for conference on February 27, 2002 were directed t Plaintiff and Defendant on January 30, 2002. 5. Plaintiff was advised of the conference by first class mail. 6. Defendant was advised of the conference by certified mail, return receip requested, and also by first class mail. The certified mailing was returned to the Special Maste marked "Unknown". The first class mailing was not returned. 7. Defendant attended the conference of February 27, 2002 without counsel. 8. Jurisdiction and venue is properly within the 26th Judicial District, Columbi County Branch. . . TARIN A. STEELE, PLAINTIFF IN THE COURT OF COMMON PLEAS 26TH JUDICIAL DISTRICT COLUMBIA COUNTY BRANCH, PENNA. vs. JONATHAN A. STEELE, DEFENDANT CIVIL ACTION - CUSTODY NO. 50 OF 2002 FINDINGS 1. Plaintiff, "Mother" is TARIN A. STEELE, an adult individual residing at 7 Grouse Road, MiIIviIIe, Columbia County, Pennsylvania. 2. Defendant, "Father" is JONATHAN A. STEELE, an adult individual residing a 550 Scenic Avenue, Apartment #5, Bloomsburg, Columbia County, Pennsylvania. 3. The parties were married on August I, 1999, and separated on October 17, 2001. The parties lived together from approximately 1995 until they were married. 4. Two (2) minor children were born of the parties' union, namely, Hannah R. Steele, date of birth, July 2, 1998, and Gage M. Steele, date of birth, August 8, 2000. 5. The children currently resides with Mother. 6. Mother resides with the two minor children and her friend, Amy Kisinski, ag 24, at the aforestated address. 7. Fatherresides with his brother, Shane Leiby, age 19, and a friend, Dan Albertson, age 19, at the aforestated address. 8. Mother is not employed. 9. Father is employed by Heller's Gas in Bloomsburg, PA. 10. Both parties are sincerely interested in the welfare of the minor children. . . T ARlN A. STEELE, PLAINTIFF IN THE COURT OF COMMON PLEAS 26TH JUDICIAL DISTRICT COLUMBIA COUNTY BRANCH, PENNA. vs. JONATHAN A. STEELE, DEFENDANT RECOMMENDATIONS TO THE COURT CIVIL ACTION - CUSTODY NO. 50 OF 2002 It is the Recommendation of this Master as follows: 1. Primary physical custody of the minor children, namely, Hannah R Steele, dat of birth, July 2, 1996, and Gage M. Steele, date of birth, August 8,2000, shall be with Mother 2. The parties shall share legal custody of the minor children. 3. Father shall have partial physical custody as follows: ~a. Weekends - Alternating weekends effective March 2, 2002 from Saturda at 1 :00 p.m. until the following Sunday at 7:00 p.m. b. Weekdays - Every Tuesday and Thursday effective February 28, 200 c. Holidays - The parties shall equally share physical custody of the mino from 6:30 p.m. until 9:00 p.m. children on the holidays of January 1st, Easter, Memorial Day, July 4th, Labor Day, Thanksgiving and Christmas as they may agree. d. Summer - Each party shall have one (1) week of physical custody wi the minor children during each summer at their convenience and subject to thirty (30) day advance written notice to the other. e. Mother shall have physical custody of the minor children for Mother' Day, and Father shall have partial custody of the minor children on Father's Day at times to b agreed by the parties. . . f. Each party shall have access to the children on or near each child' birthday and on the individual parent's birthday. }ltg. Holidays shall take precedence over other periods of partial physica custody or visitation. )t h. Father shall have additional periods of partial physical custody with th minor children at such other times and places and under such circumstances as the parties ma mutually agree upon from time to time. 4. The parties shall equally share all transportation necessary to schedule of contacts recommended herein. ~5. Each party shall have reasonable telephone access to the minor children whe they are in the custody or partial custody of the other. )t. 6. The parties shall exchange all information pertaining to the health, education, an welfare of the minor children; including without limitation, report cards; progress reports fro school; approval of extraordinary medical and dental treatment; summer school; summer camp' and approval of schools in general provided that such approval shall not be unreasonabl withheld. *7. Each party shall have access to all school and medical records of the mino children and each shall have the ability to consent to emergency medical treatment when th children are in the custody of such party. 8. If circumstances from time to time prevent the exercise of partial physic custody or visitation, the parties shall provide one another with timely and reasonable notice a to the existence of such circumstances and an equal amount of make-up partial physical custod or visitation shall be provided at the earliest mutually agreeable date and time. . . 9. The parties shall notifY one another by telephone of any serious illness of th children. 10. In the event of any serious illness of a child, each party shall have the right t visit the child as frequently as he or she desires, consistent with his proper medical care. 11. The term "illness", as used herein, shall mean any disability which confmes child to bed under the direction of a licensed physician for a period in excess of forty-eight (48 hours. 12. If any period of partial custody has to be missed due to an illness of the child Mother will provide Father with at least twenty-four (24) hours notice of said illness, i possible, and Mother will provide to Father make-up time for said visit. A copy of a doctor' excuse outlining the reason for the missed period of partial custody sha1l be provided t MotherlFather at the time of the next visit. Additionally, each party shall notifY the other a the time of transfer of the child of any medication, either over the counter or prescription, tha has been administered to the child in the preceding twenty-four (24) hours and shall als provide to the other party said medication if it is necessary that the child remain on sai ~13. Each party shall exert reasonable efforts to maintain free access and unhampere medication. contact between the children and the other party and to promote a feeling of love and affectio between the children and the other party. . ~4. Neither party shall harass, molest, or malign the other, or their respective familie in the presence of their children. ~5. Neither party shall engage in a pattern or course of conduct designed to interfer with the free and natural development of the children's love and respect for the other. . . 16. If either party intends to relocate from their present residence, he or she shal provide the other with a minimum of thirty (30) days advance written notice of relocation t )!17. Each party shall at all times keep the other informed of his or her respectiv permit modification of the terms and conditions recommended herein, if necessary. address and telephone number. 18. Neither party will abuse alcohol while caring for the minor children and eac shall maintain a safe environment for the children. 19. Both parties shall enroll in and satisfactorily complete the "KIDS FIRST' educational program, unless they have already done so. The Court Administrator, or the "KID FIRST" Administrator, shall notify each party of the date, time and location of the program tha each is required to attend. 20. Each party shall maintain a journal containing a listing of dates and times whe the child is in the physical custody of Father. 21. Either party may seek reconsideration of the Recommendations herein b submitting a written request for review to this Master. 22. Plaintiff and Defendant shall each pay the sum of $3 7.62 to the Columbia Coun Prothonotary within ninety (90) days of this Order as costs of the Master's proceedings. o;z"""""'" (" /.f0HN L. McLAUGHL , ESQ /Specially Appointed Master i;/ te/ . . , " TARIN A. STEELE, PLAINTIFF IN THE COURT OF COMMON PLEAS 26TH JUDICIAL DISTRICT COLUMBIA COUNTY BRANCH, PENNA. vs. JONATHAN A. STEELE, DEFENDANT CIVIL ACTION - CUSTODY : NO. 50 OF 2002 CERTIFICATE OF SERVICE I, JOHN L. McLAUGHLIN, ESQUIRE, Special Master, do hereby certify that on thi 6th day of March, 2002, I served copies of the attached Report To The Court by depositin copies of same with the United States Postal Services, first class mail, postage pre-paid, a Danville, Pennsylvania, and addressed as follows: Tarin A. Steele 73 Grouse Road Millville, P A 17846 Jonathan A. Steele 550 Scenic Avenue Apartment 5 Bloomsburg, PA 17815 OtI(j)t~ //JOHN L. McLAUGHLn::_~ 1/ Specially Appointed Mas~ q b )DS- ~d.-G)-I ~~ /'"""'. . . 17'""'- , \ . " . L/ '5 'b -q 1)1(1 (;-I ) il5t~111 (VI) It ,. , - . . ,. , TARIN A. STEELE, PLAINTIFF IN THE COURT OF COMMON PLEAS 26TH JUDICIAL DISTRICT COLUMBIA COUNTY BRANCH, PENNA. vs. JONATHAN A. STEELE, DEFENDANT CML ACTION - CUSTODY NO. 50 OF 2002 ORDER OF PAYMENT AND NOW, to wit, this ? :Pdayof ~ Statement from John L. McLaughlin, Esquire, in the total amount of $75.24 for service rendered as Special Master in the above-captioned matter is hereby approved and the Coun of Columbia is hereby directed to pay the same. It is further directed that a copy of this Order of Court with copies of the aforesai attachment hereto, shall be delivered to the Columbia County Commissioner's Office. BY THE COURT: / J. ( . . March 6, 2002 . TARIN A. STEELE vs. JONATHAN A. STEELE NO. 50 OF 2002 STATEMENT '. FOR PROFESSIONAL SERVICES: JOHN L. McLAUGHLIN, ESQUIRE 2002 01/30102 01/27/02 01/28/02 - 03/06/02 Review of file, Notices of Conference sent to Plaintiff and Defendant Conference with Defendant Drafting, Preparation, Filing and Service of Report to the Court upon Plaintiff and Defendant 1.08 Hours at $60.00 Per Hours Postage TOTAL BALANCE DUE $64.80 10.44 $75.24 '"'~ om c::'" ~;:o; -<0 0-" -.,(') nO oC: ,--'" c:.... ;r'" 000 --., ~-., ~~ .25 .33 .50 - !! ~ I ....J <;) .~::> -1-., :I:_ Or z!T1 00 ~ ;u -< )> - - .. I:) J:J .^ . - o . - < .' / ~ !fJ m 1/J 9UU5~ . . , ' TARIN A. STEELE, PLAINTIFF IN THE COURT OF COMMON PLEAS 26TH JUDICIAL DISTRICT COLUMBIA COUNTY BRANCH, PENNA. vs. JONATHAN A. STEELE, DEFENDANT CIVIL ACTION - CUSTODY NO. 50 OF 2002 ORDER AND NOW, to wit, this '? ~day of #I~ , 2002 upo presentation of the attached Report To The Court, it is hereby ORDERED and DECREED tha the recommendations of the Master are incorporated by reference herein as an Interim Order. Ifno Exceptions are filed within ten (10) days of service of these Recommendations, thi Order shall become a Final Order and shall remain in effect until further Order of Court. I Exceptions are filed this Order shall remain an Interim Order until disposition of the Exceptions. Plaintiff and Defendant shall each pay the sum of $37.62 to the Columbia Count Prothonotary within ninety (90) days of this Order as costs of the Master's proceedings. BY THE COURT: /?'~ . TARIN A. STEELE, PLAINTIFF vs. JONATHAN A. STEELE, DEFENDANT . . . IN THE COURT OF COMMON PLEAS 26TH ruDICIAL DISTRICT COLUMBIA COUNTY BRANCH, PENNA. CIVIL ACTION - CUSTODY NO. 50 OF 2002 (")("") i REPORT TO THE COURT or '-""J ..-(T1 ~'" :0 ::i"" :-= 0 -<0 !D ::;:!-rt 0'" .,,("") -- , or ("")0 ...J 0<= ZfTl r'" 00 c:-i )> 3:'" > 0)0 ;.0 -...... ?>." .. -< ~g 0 JOHN 1. McLAUGHLIN, ESQUIRE Specially-Appointed Master MARKS, MCLAUGHLIN, & DENNEHY 12 West Market Street P. O. Box 179 Danville, PA 17821 . . . . TARIN A. STEELE, PLAINTIFF IN THE COURT OF COMMON PLEAS 26TH JUDICIAL DISTRICT COLUMBIA COUNTY BRANCH, PENNA. vs. JONATHAN A. STEELE, DEFENDANT CIVIL ACTION - CUSTODY NO. 50 OF 2002 PROCEDURAL HISTORY 1. The present action for Custody was initiated on January 23, 2002 by Plaintiff Complaint for Custody filed to Number 50 of 2002 with the Columbia County Prothonotary. 2. Plaintiffs Custody Complaint seeks primary physical custody of the parties' tw (2) minor children; namely, Hannah R. Steele, date of birth, July 2, 1996, and Gage M. Steele date of birth, August 8, 2000. 3. The matter was referred to the Special Master by Order of Court dated Jan nO ;a .....:; g~ ;::; ,/,J "",0 :II: 0 -t?Z. ~ -"~ Notices listing the case for conference on February 2~~002 "'ere ~'Fed t -n(""l t -;r.~ ,-,0 -' 0'"' Plaintiff and Defendant on January 30, 2002. ?!~.-.O c'" ):> J:'" z<P ::0 Plaintiff was advised of the conference by first class m~~ :::=. -< ;'F) ~ .,.."" ~ Defendant was advised of the conference by certified mail, return receip 23, 2002. 4. 5. 6. requested, and also by first class mail. The certified mailing was returned to the Special Maste marked "Unknown". The first class mailing was not returned. 7. Defendant attended the conference of February 27, 2002 without counsel. 8. Jurisdiction and venue is properly within the 26th Judicial District, Columbi County Branch. . . TARIN A. STEELE, PLAINTIFF IN THE COURT OF COMMON PLEAS 26TH JUDICIAL DISTRICT COLUMBIA COUNTY BRANCH, PENNA. vs. JONATHAN A. STEELE, DEFENDANT CIVIL ACTION - CUSTODY NO. 50 OF 2002 FINDINGS 1. Plaintiff, "Mother" is TARIN A. STEELE, an adult individual residing at 7 Grouse Road, Millville, Columbia County, Pennsylvania. 2. Defendant, "Father" is JONATHAN A. STEELE, an adult individual residing a 550 Scenic Avenue, Apartment #5, Bloomsburg, Columbia County, Pennsylvania. 3. The parties were married on August I, 1999, and separated on October 17, 2001 The parties lived together from approximately 1995 until they were married. 4. Two (2) minor children were born of the parties' union, namely, Hannah R. Steele, date of birth, July 2, 1998, and Gage M. Steele, date of birth, August 8, 2000. 5. The children currently resides with Mother. 6. Mother resides with the two minor children and her friend, Amy Kisinski, ag 24, at the aforestated address. 7. Father resides with his brother, Shane Leiby, age 19, and a friend, Dan Albertson, age 19, at the aforestated address. 8. Mother is not employed. 9. Father is employed by Heller's Gas in Bloomsburg, PA. 10. Both parties are sincerely interested in the welfare of the minor children. . . TARIN A. STEELE, PLAINTIFF IN THE COURT OF COMMON PLEAS 26TH JUDICIAL DISTRICT COLUMBIA COUNTY BRANCH, PENNA. vs. JONATHAN A. STEELE, DEFENDANT CIVIL ACTION - CUSTODY NO. 50 OF 2002 RECOMMENDATIONS TO THE COURT It is the Recommendation of this Master as follows: 1. Primary physical custody of the minor children, namely, Hannah R. Steele, dat of birth, July 2, 1996, and Gage M. Steele, date of birth, August 8,2000, shall be with Mother. 2. The parties shall share legal custody of the minor children. 3. Father shall have partial physical custody as follows: a. Weekends - Alternating weekends effective March 2, 2002 from Saturda at 1:00 p.m. until the following Sunday at 7:00 p.m. b. Weekdays - Every Tuesday and Thursday effective February 28, 2002 from 6:30 p.m. until 9:00 p.m. c. Holidays - The parties shall equally share physical custody of the mino children on the holidays of January 1st, Easter, Memorial Day, July 4th, Labor Day, Thanksgiving and Christmas as they may agree. d. Summer - Each party shall have one (1) week of physical custody wi the minor children during each summer at their convenience and subject to thirty (30) day advance written notice to the other. e. Mother shall have physical custody of the minor children for Mother' Day, and Father shall have partial custody ofthe minor children on Father's Day at times to b agreed by the parties. . . f. Each party shall have access to the children on or near each child' birthday and on the individual parent's birthday. g. Holidays shall take precedence over other periods of partial physica custody or visitation. h. Father shall have additional periods of partial physical custody with th minor children at such other times and places and under such circumstances as the parties ma mutually agree upon from time to time. 4. The parties shall equally share all transportation necessary to maintain th schedule of contacts recommended herein. 5. Each party shall have reasonable telephone access to the minor children whe they are in the custody or partial custody of the other. 6. The parties shall exchange all information pertaining to the health, education, an welfare of the minor children; including without limitation, report cards; progress reports fro school; approval of extraordinary medical and dental treatment; summer school; summer camp' and approval of schools in general provided that such approval shall not be unreasonabl withheld. 7. Each party shall have access to all school and medical records of the mino children and each shall have the ability to consent to emergency medical treatment when th children are in the custody of such party. 8. If circumstances from time to time prevent the exercise of partial physic custody or visitation, the parties shall provide one another with timely and reasonable notice to the existence of such circumstances and an equal amount of make-up partial physical custod or visitation shall be provided at the earliest mutually agreeable date and time. . . 9. The parties shall notify one another by telephone of any serious illness of th children. 10. In the event of any serious illness of a child, each party shall have the right t visit the child as frequently as he or she desires, consistent with his proper medical care. 11. The term "illness", as used herein, shall mean any disability which confmes child to bed under the direction of a licensed physician for a period in excess of forty-eight (48 hours. 12. If any period of partial custody has to be missed due to an illness of the child Mother will provide Father with at least twenty-four (24) hours notice of said illness, i possible, and Mother will provide to Father make-up time for said visit. A copy of a doctor' excuse outlining the reason for the missed period of partial custody shall be provided t MotherlFather at the time of the next visit. Additionally, each party shall notify the other a the time of transfer of the child of any medication, either over the counter or prescription, tha has been administered to the child in the preceding twenty-four (24) hours and shall als provide to the other party said medication if it is necessary that the child remain on sai medication. 13. Each party shall exert reasonable efforts to maintain free access and unhampere contact between the children and the other party and to promote a feeling of love and affectio between the children and the other party. 14. Neither party shall harass, molest, or malign the other, or their respective familie in the presence of their children. 15. Neither party shall engage in a pattern or course of conduct designed to interfer with the free and natural development of the children's love and respect for the other. . . 16. If either party intends to relocate from their present residence, he or she shal provide the other with a minimum of thirty (30) days advance written notice of relocation t permit modification of the terms and conditions recommended herein, if necessary. 17. Each party shall at all times keep the other informed of his or her respectiv address and telephone number. 18. Neither party will abuse alcohol while caring for the minor children and eac shall maintain a safe environment for the children. 19. Both parties shall enroll in and satisfactorily complete the "KIDS FIRST' educational program, unless they have already done so. The Court Administrator, or the "KID FIRST" Administrator, shall notify each party of the date, time and location of the program tha each is required to attend. 20. Each party shall maintain a journal containing a listing of dates and times wh the child is in the physical custody of Father. 21. Either party may seek reconsideration of the Recommendations herein b submitting a written request for review to this Master. 22. Plaintiff and Defendant shall each pay the sum of$37.62 to the Columbia Coun Prothonotary within ninety (90) days of this Order as costs of the Master's proceedings. . . . . . TARIN A. STEELE, PLAINTIFF IN THE COURT OF COMMON PLEAS 26TH JUDICIAL DISTRICT COLUMBIA COUNTY BRANCH, PENNA. vs. JONATHAN A. STEELE, DEFENDANT CIVIL ACTION - CUSTODY NO. 50 OF 2002 CERTIFICATE OF SERVICE I, JOHN L. McLAUGHLIN, ESQUIRE, Special Master, do hereby certify that on thi 6th day of March, 2002, I served copies of the attached Report To The Court by depositin copies of same with the United States Postal Services, first class mail, postage pre-paid, a Danville, Pennsylvania, and addressed as follows: Tarin A. Steele 73 Grouse Road MiIlville, P A 17846 Jonathan A. Steele 550 Scenic Avenue Apartment 5 Bloomsburg, PA 17815 ~ ' . ' ! t) 147 mID 8i1h IJJ ~ ~ "......~ , - ,J. .... . . / ~ &Sf ()'\I'l1l ouiQ ~\ ~ PLAINTIFF vs. ~Mll.thQ n A , CStl D fA - DEFEN ANT * * * * * * * IN THE COURT OF COMMON PLEAS 26TH JUDICIAL DISTRICT ~ COUNTY BRANCH, PENNA. (County) CIVIL ACTION - CUSTODY NO. 50 0 f ~ d(J(J-L. ORDER OF COURT APPOINTING SPECIAL. MASTER AND NOW, to-wit, this ~2vIol- day of ~a." ,~_, the within matter is hereby referred to Special Master, for further ,proceedings in Rules of the Court, Chapter V, dated May 23, 1990, pertaining to special Master's in custody and visitation matters, upon receipt by the Court Administrator of proof of service. PROTHONOTARY: ~~~/~ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. SUSQUEHANNA LEGAL SERVICES 168 WEST FIFTH ST BLOOMSBURG PA 17815 COURT ADMINISTRATOR PRO BONO PROGRA~ (CONSULTATION ONLY) COLUMBIA COUNTY COURTHOUSJ; BLOOMSBURG PA 17h15 PHONE: 784-8760 PHONE: 389-5667 .. . ~}f ,'n A. Stoot PLAINTIFF vs. ~()thn0' l <:)11of1 -0 FENDANT . * * * * * * * IN THE COURT OF COMMON PLEAS 26TH JUDICIAL DISTRICT Co..\l.I.fYl b ,~ COUNTY BRANCH, PENNA. (county) CIVIL ACTION - CUSTOD~ ~^f~ NO. 6l) of """" ervvo-., COMPLAINT FOR CUSTODY 1. Plaintiff is-.JOlI J'n ~/Joi..Q r( 2 QA. r:;) I . tnaljle) , I :) &1)II'ilU) 9.. un ' ll1.iJ.thl {t L2~'L? (Stre~t) (City) (Zip Code) 2. Defendant is ~lmntY1an. ~s.~ BJ (name) 5c(~~~~ett. )pt.S (c'Rr:;AJh1f~ gllJc~de) 550 3. Plaintiff seeks of the following child(ren): NAME }ja~ m r Stull , residing at ~lmb'6l- . (County) , residing at (1= County) ~' /.:)t?Jdu (cu oay) ~tial <..uscocty/vh:ita'ti..on') PRESENT RESIDENCE AGE ~ 5 ~ = .... c~rn --;:;0 :::;:;:s;;. c.... <LJ __ o"Tl :z: "'1n ~O _ oc.: "'- ,-;0 c.... -n .,.v> LJ coo ~~ ~ w~ocJE C) =t"T] ::r:_ Dr .....fT1 DO ~ ;1;) c' 4. The child (ren) I J '('1.0 ~ 5. The child (ren) is presently who resides (County) . fI . 6. During the past five years, the child(ren) have resided with the following persons and at the following addresses: (Dates - Most recent first) (All Addresses where the child lived at) (Parent or other persons the child lived with) Oct .zoo( ~ t:fllo- Oct'.1;;WO( Jnnil1 ,"StuJ 0 'l~J.:hmLo~llt 11'iN~ ~ 7. Mother of the child(ren) currently residing at 1 (Street) ( (Zip) ( County) She is fY"llli\J1.iod. (married) ie.i':orced) ("iR~le). 8. Father of the child (ren) is ]L\Ylathan A, StuL currently residing at 5rmiC AI{{, .B\lllwn(lhlln~ tJ815 (\lwnbLo..-. (Street) . (City) Zip) (County) He is martJ1~orl (married) (-Qi"8l!'e~d) (dR'3"le). . 9. The relationship of Plaintiff to the child (ren) is that of mcrttml. (mother) (f:i.1i1.~J:) The Plaintiff currently resides with the " . . following persons: (Name) JlonY\o tLR.:3.tOI ~Q jj~tfolL (Relationship) . (~C"-' 1 Co h \..OC , ,(\() II , 10. The relationship of Defendant to the child(ren) is that of -\'Cl.th~ 11. The Defendant currently resides with the . ~lRe'ei'll!!)r) (father) following persons: (Name) :ShuY'\1l '(b. D ~bU .. 0 (Relationship) .-hJ'I 0 tht1t 11. Plaintiff hc:vQ.. n.....ot participated as a party or ~) (has not) witness, or in another capacity, in other litigation concerning the custody of the child(ren) in this or another court. The court, term and number, and its relationship to this action is: > . . 12. Plaintiff_hn ~ n (") information of a custody .(In.e) (has no) proceeding concerning the child(ren) pending in a court of this Commonwealth. The court, term and number, and its relationship to this action is: , 13. Plaintiff-..d~ n.ot.-J"')nmv of a person not a party (kR6IiS) (does not know) to these proceedings who has physical custody of the child(ren) or claims to have custody or visitation rights with respect.to the child(ren). The name and address of such person is: 14. The best interest and permanent welfare of the child(ren) will be served by granting the relief requested because (explain why you should be given custody er v~&i~ati9A): n ttll r(\~ 0 0 P ('1. \i)S fu.ti 1m jOLh crt.u Q a - ~ . . 15. Each parent whose parental rights to the child(ren) have not been terminated and the person who has physical custody of the child(ren) have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child(ren) will be given notice of the pendency of this action and the right to intervene: (Name) (Address) (Basis of Claim) WHEREFORE, Plaintiff requests the court to grant (CUS USTODY/VISITATION) of the child(ren). I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. DATE:~~ f"'\ ,." .,;j, ~ k '., ~~.. /-d-:>-O ~ ~~U~ k~tb~ ~ .~ ~~ /bStwt.. I~ m t'tl i;) '. . . / : . ...In 11 i V\ A .~t II tc. , PLAINTIFF * * * * * * * IN THE COURT OF COMMON PLEAS cb~~~~i~ICIAL DISTRICT COUNTY BRANCH, PENNA. (county) CIVIL ACTION - CUSTODY NO. SO of ~d:OO ~ vs. ~(In A.~hDQD . DEFENDANT APPLICATION TO PROCEED IN FORMA PAUPERIS Kindly allow in the above captioned matter to proceed in Forma pauperis based upon the attached affidavit. I believe I am unable to pay the costs involved in this case. ju;,. .A"Skt Proceeding pro se I o R D E R AND NOW, this t r--:'ay of ~ , 2.j!.:~ upon consideration of the attached apPli~ proceed in Forma Pauperis and the income affidavit, the same is G~D/DENIED. BY THE COURT: ~. J. . ... . .. j r": " -;t<., f1(/ #,. () 3~/ Uft ~.t;;u ~ -(1U 1'bP- j3'- 637( , . .. . . -Tn 11 ; n. A. ~t.J D PLAINTIFF * * * * * * * IN THE COURT OF COMMON PLEAS 26TH JUDICIAL DISTRICT ~ COUNTY BRANCH, PENNA. (county) vs. DEFENDANT ~~~IL A~~O~f- CUSTOD~~~ AFFIDAVIT FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the (Plaintiff) (Defendant) in the above matter and because of my financial condition am unable to pay the fees and costs of the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct: b. NAME: \o.~~ ~~O~~ ADDRESS: )j Cl ~~v)~~~ft 1J'1f41" SOCIAL SECURITY NUMBER: , R 4~~1 EMPLOYMENT: If you are presently employed, state n Employer: ~.... Address: ~", Salary or Wages per month: ~; Type of work: ~;, C"JO c>C ....~ c<f) ~~ -.." ~~ ~ =. . a. If you are presently unemployed, state Date of last employment :1f:lIJ~:Jon I - Nov ;2.001 Salary or wages per mont : I 00.- Type of work:'K, f.ljrlor'dia..Q <YIvi~ '"0 ::;:.1 o .-\"'" ::r.- or- "Z-fT' ~O Y" -;xJ -< ,- ~ - ~ f.-i ..: - c. Other income within the past twelve months: n Business or profession: 0 Other self-employment: 0 Interest: 0 Dividends: () Pension and annuities: ~ social security ~enefits: 0 Support payments. ~o. 0 . .. Disability payments: 0 Unemployment compensation and supplemental benefits: 0 Workman 1 s compensation: 0 Publ ic ass istance: (;) Other: 0 d. Other contributions to household support (wife) (Husband) Name: If your (wife) (husband) is employed, state Employer Salary or wages per month: Type of work: Contributions from children: contributions from parents: Other contributions: i e. --, . . . . Property owned Cash: (") Checking Account: () savings Account: () certificate of deposit: () Real estate (including home): (") Motor vehicle: MakeFI~. , Year~, Amou~wed $~ stocks: 0 Bonds: 0 Other: Cost f. Debts and obligations Mortgage: 0 Rent: ?lnO. .. Loans: ~ ~r: ~SSJi1cn~' ~~Lt10tl-~ 'i=t..omlln ').Do n-a/l'h '" h.. . '""- Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: N.ame:~n~.11~l~1 il ~( t'QJI) I/()""Oo g. Age: 5 Age: I Age: Age: Other persons: Name: Relationship: 4. I understand that I have a continuing obligation to inform the court of improvement in my financinl circumstances which would permit me to pay the costs incurrred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities'j' ~ DATE: 1on. lot I ~O~ ~_Q..ll.A..- A- JJtn lu p~~~~ er, pr&/se