HomeMy WebLinkAbout06-5506MEGGAN J. ARMSTRONG, : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.
STEPHEN ARMSTRONG, CIVIL ACTION -LAW
Defendant CHILD CUSTODY
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take action within twenty (20) days after
this Complaint and Notice are served, by entering a written appearance personally or by
attorney and filing in writing with the Court your defenses or objections to the claims set
forth against you. You are warned that if you fail to do so the case may proceed without
you and a judgment may be entered against you by the Court without further notice for
any money claimed in the Complaint or for any other claim or relief requested by the
Plaintiff. You may lose money or property, or other rights important to you, including
child custody, or child visitation.
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 OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED
FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea
defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe
tomar acci6n dentro de los pr6ximos veinte (20) dias despu6s de la notificaci6n de esta
Demanda y Aviso radicando personalmente o por medio de un abogado una
comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objeccionnes
a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de
tomar acci6n como de describe anteriormente, el caso puede proceder sin usted y un fallo
por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamaci6n o
remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin
mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes
para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A
LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION
A CERCA DE COMO CONSEGUIER UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN
ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER
INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN
CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
MEGGAN J. ARMSTRONG, : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO. 0 to - s56(o
STEPHEN ARMSTRONG, CIVIL ACTION -LAW
Defendant CHILD CUSTODY
COMPLAINT FOR CHILD CUSTODY
AND NOW comes the Plaintiff, Meggan J. Armstrong, by and through her
attorney, Kristin R. Reinhold, Esquire, and respectfully requests this Honorable Court
award her custody of the subject minor child, and in support thereto, avers the following:
1. Plaintiff is Meggan J. Armstrong, an adult individual residing at 1059
York Road, Dillsburg, Cumberland County, Pennsylvania. 17019.
2. Defendant is Stephen Armstrong, an adult individual residing at 211
Castle Shannon Boulevard, Mount Lebanon, Allegheny County, Pennsylvania. 15228.
3. The subject child is Landrie Adore Armstrong, born May 12, 2002.
4. The relationship of the Plaintiff to the subject minor child is that of
natural mother.
5. The relationship of the Defendant to the subject minor child is that of
natural father.
6. The minor child has resided at the following addresses, in the custody
of the following individuals:
a. From birth, May 12, 2002 until October 31, 2004 - the subject
minor child resided with Plaintiff and Defendant at 1446 Timber Brook
Drive, Mechanicsburg, Cumberland County, Pennsylvania.
b. From October 31, 2004 to December 12, 2004 - the subject
minor child resided with Plaintiff and maternal grandparents at 4114
Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania.
c. From December 12, 2004 to March 8, 2005 - the subject minor
child resided with Plaintiff and Defendant at 1446 Timber Brook Drive,
Mechanicsburg, Cumberland County, Pennsylvania.
d. From March 8, 2005 to June, 2005 - the subject minor child
resided with Plaintiff and Defendant at 35 Highland Drive, Pittsburgh,
Pennsylvania.
e. From June, 2005 to June 16, 2006 - the subject minor child
resided with Plaintiff and Defendant at 850 Baldwin Street, Apt. 136,
Pittsburgh, Pennsylvania.
f. From June 16, 2006 to present - the subject minor child resides
with Plaintiff and the child's maternal aunt and uncle, Becky and Michael
Horn, as well as their two children, at 1059 York Road, Dillsburg,
Cumberland County, Pennsylvania.
7. There have been no prior actions for custody of the subject minor child
in this or any other jurisdiction.
8. The Plaintiff is not aware of the existence of any other individuals who
have any type of claim whatsoever regarding the custody of the subject minor child.
9. The Plaintiff believes and therefore avers that she is much better able to
meet the needs of the subject minor child than the Defendant.
10. The Plaintiff believes and therefore avers that it is in the best interest
of the subject minor child that she be placed in her legal and physical custody.
WHEREFORE, Plaintiff requests this Honorable Court award her custody
of the subject minor child.
Respectfully submitted,
mglestownRoad
Harrisburg, PA 17112
(717) 671-1500
I.D. No. 57911
Attorney for Meggan J. Armstrong
AFFIDAVIT
I, ?Y)Qmtot n ArcnOyan4 , hereby certify that the aforegoing is true
and correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to
unsworn falsifications to authorities.
Dated: 9 h- s-1/200 (o
c
F
MEGGAN J. ARMSTRONG IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
06-5506 CIVIL ACTION LAW
STEPHEN ARMSTRONG
IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Monday, September 25, 2006 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, October 24, 2006 at 9:00 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/ Dawn S. Sunda Es q.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
22
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MEGGAN J. ARMSTRONG IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 06-5506 CIVIL ACTION LAW
STEPHEN ARMSTRONG
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this 3c d day of N 6,4 cVh \6 Gr , 2006, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The Father, Stephen Armstrong, and the Mother, Meggan J. Armstrong, shall have shared
legal custody of Landrie Adore Armstrong, born May 12, 2002. Each parent shall have an equal right,
to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions regarding her health, education
and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and
information pertaining to the Child including, but not limited to, school and medical records and
information.
2. The Mother shall have primary physical custody of the Child.
3. The Father shall have partial physical custody of the Child on alternating weekends,
beginning November 10, 2006, from Friday after work between 4:30 and 5:30 p.m. through Sunday at
7:30 p.m. In addition, the Father shall have custody every week from Wednesday after work between
4:30 and 5:30 p.m. through Thursday morning when the Father shall return the Child to preschool.
The Father may have additional periods of custody with the Child as arranged by agreement between
the parties. The Father's first two weekday overnight periods shall take place on Thursdays,
November 1 and 8 due to prior plans and thereafter shall be on Wednesdays with the understanding
that the parties shall cooperate in moving the overnight to another weekday to accommodate special
activities or events. In the event that the Father is not taking the Child to church during his weekend
period of custody, the Father shall notify the Mother by the preceding Saturday and the Mother shall be
entitled to obtain custody of the Child on Sunday at 10:30 a.m. for church and shall return the Child to
the Father's residence immediately following the church service.
4. The parties shall share or alternate having custody of the Child on holidays as follows:
A. Christmas: In every year, the Father shall have custody of the Child from
Christmas Eve at 4:00 p.m. through Christmas Day at 11:00 a.m. and the Mother shall have custody
from Christmas Day at 11:00 a.m. through December 26th at 4:00 p.m. The parties shall share having
custody over the remainder of the Child's holiday break from preschool/school as agreed.
B. Thanksgiving: In every year, the Father shall have custody of the Child from
between 4:30 and 5:30 p.m. on the Wednesday before Thanksgiving through the weekend following
Thanksgiving and the Mother shall have custody over the entire weekend preceding Thanksgiving.
C. Alternating Holidays: In even numbered years, the Mother shall have custody of
the Child on Easter Sunday and Independence Day and the Father shall have custody on Memorial Day
and Labor Day. In odd numbered years, the Father shall have custody on Easter Sunday and
Independence Day and the Mother shall have custody on Memorial Day and Labor Day. The holiday
periods o f custody shall run from 10:00 a.m. until 7:30 p.m. on the holiday, with the exception o f
Independence Day which shall run until after the fireworks.
D. Mother's Dayjather's Day: The Mother shall have custody on Mother's Day
and the Father shall have custody on Father's Day from 10:00 a.m. until 7:30 p.m.
E. The holiday custody schedule shall supersede and take precedence over the
regular custody schedule.
5. Each parent shall be entitled to have custody of the Child for two weeks for vacation each
year upon providing at least 30 days advance notice to the other parent. The party providing notice
first under this provision shall be given priority on the selection of vacation dates.
6. I n the e vent either p arent intends to remove the Child from his or h er residence for an
overnight period or longer, that parent shall provide advance notice to the other parent of the address
and telephone number where the Child can be contacted.
7. This O rder i s e ntered p ursuant t o a n a greement o f t he p arties a t a c ustody c onciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT:
?K -? ?AA I J. ?
cc: tephen Armstrong- Father
Aistin R. Reinhold, Esquire - Counsel fo
A
mol
MEGGAN J. ARMSTRONG
Plaintiff
VS.
STEPHEN ARMSTRONG
Defendant
Prior Judge: None
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
06-5506 CIVIL ACTION LAW
IN CUSTODY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Landrie Adore Armstrong May 12, 2002
Mother
2. A custody conciliation conference was held on October 30, 2006, with the following
individuals in attendance: The Mother, Meggan J. Armstrong, with her counsel, Kristin R. Reinhold,
and the Father, Stephen Armstrong, who is not represented by counsel in this matter.
3. The parties agreed to entry of an Order in the form as attached.
Date Dawn S. Sunday, Esquire
Custody Conciliator
LAW OFFICES OF DILS & DILS
DIANE M. DILS, ESQUIRE
Attorney I.D. No. 71873
1400 North Second Street, First Floor, Front
Harrisburg, PA 17102
Telephone No. (717) 233-8743
Attorney for Defendant, Stephen Armstrong
MEGGAN J. ARMSTRONG, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs.
STEPHEN ARMSTRONG,
Defendant
NO. 06-5506 Civil Term
: CIVIL ACTION -LAW
: IN CUSTODY
COMPLAINT TO M015IFY CUSTODY ORDER
AND NOW, this of March, 2008, comes the Defendant, Stephen
Armstrong, by his attorney, Diane M. Dils, Esquire, and respectfully avers the
following:
1. The Defendant is Stephen Armstrong, an adult individual currently
residing at 6331 Linglestown Road, Harrisburg, Dauphin County,
Pennsylvania 17112.
1.
2. The Plaintiff above named is Meggan J. Armstrong, an adult individual
who is represented by Attorney Kristin R. Reinhold, Esquire, whose
office is located at 5922 Linglestown Road, Harrisburg, Dauphin
County, Pennsylvania 17112.
3. Plaintiff and Defendant are the parents of one child; namely, Landrie
Adore Armstrong, born May 12, 2002.
4. Attached hereto and marked Exhibit "A" is a copy of n Order of Court
dated November 3, 2006 setting forth the current custodial arrangement
between the parties and the minor child.
5. The Defendant, Stephen Armstrong, believes that the best interest of his
daughter will be served by granting him primary physical custody.
6. The Defendant, Stephen Armstrong, believes that it may be best for a
custody evaluation to be conducted.
7. Defendant believes that he is better able to provide a stable environment
for his daughter.
2.
WHEREFORE, Defendant, Stephen Armstrong, respectfully prays Your
Honorable Court to modify the Order of Court entered November 3, 2006 granting
him primary physical custody of his daughter.
Respectfully submitted,
i
BY:
iane M. Dils, Esquire
1400 North Second Street
Date: '51 '0 /0 a
Harrisburg, PA 17102
(717) 232-9724
I.D. No. 71873
EXHIBIT "A"
1y1,?u. ? 6 cuUb ?4
MEGGAN J. ARMSTRONG IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 06-5506 CIVIL ACTION LAW
STEPHEN ARMSTRONG
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this 3rd day of 60%Je_MbP_1Z 2006, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The Father, Stephen Armstrong, and the Mother, Meggan J. Armstrong, shall have shared
legal custody of Landrie Adore Armstrong, bom May 12, 2002. Each parent shall have an equal right,
to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions regarding her health, education
and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and
information pertaining to the Child including, but not limited to, school and medical records and
information.
2. The Mother shall have primary physical custody of the Child.
3. The Father shall have partial physical custody of the Child on alternating weekends,
beginning November 10, 2006, from Friday after work between 4:30 and 5:30 p.m. through Sunday at
7:30 p.m. In addition, the Father shall have custody every week from Wednesday after work between
4:30 and 5:30 p.m. through Thursday morning when the Father shall return the Child to preschool.
The Father may have additional periods of custody with the Child as arranged by agreement between
the parties. The Father's first two weekday overnight periods shall take place on Thursdays,
November 1 and 8 due to prior plans and thereafter shall be on Wednesdays with the understanding
that the parties shall cooperate in moving the overnight to another weekday to accommodate special
activities or events. In. the event that the Father is not taking the Child to church during his weekend
period of custody, the Father shall notify the Mother by the preceding Saturday and the Mother shall be
entitled to obtain custody of the Child on Sunday at 10:30 a.m. for church and shall return the Child to
the Father's residence immediately following the church service.
4. The parties shall share or alternate having custody of the Child on holidays as follows:
A. Christmas: In every year, the Father shall have custody of the Child from
Christmas Eve at 4:00 p.m. through Christmas Day at 11:00 a.m. and the Mother shall have custody
from Christmas Day at 11:00 a.m. through December 26`h at 4:00 p.m. The parties shall share having
custody ovel the remainder of the Child's holiday break from preschool/school as agreed.
B. Thanks ig vinw In every year, the Father shall. have custody of the Child from
between 4:30 and 5:30 p.m. on the Wednesday before Thanksgiving through the weekend f6llowing
Thanksgiving and the Mother shall have custody over the entire weekend preceding Thanksgiving.
C.' Alternating Holidays: In even numbered years, the Mother shall have custody of
the Child on Easter Sunday and Independence Day and the Father shall have custody on Memorial Day
and Labor Day. 'i In odd numbered years, the Father shall have custody -on Easter Sunday and
Independence Day', and the Mother shall have custody on Memorial Day and Labor Day. The holiday
periods o f c ustody s hall run from 10:00 a.m. until 7:30 p.m. o n t he h oliday, w ith t he e xception o f
Independence Day which shall run until after the fireworks.
D. Mother's Day/Father's Day: The Mother shall have custody on Mother's Day
and the Father shall have custody on Father's Day from 10:00 a.m. until 7:30 p.m.
E. The holiday custody schedule shall supersede and take precedence over the
regular custody schedule.
5. Each parent shall be entitled to have custody of the Child for two weeks for vacation each
year upon providing at least 30 days advance notice to the other parent. The party providing notice
first under this provision shall be given priority on the selection of vacation dates.
6.. 1 n the a vent either p arent intends to remove the Child from his or h er residence for a n
overnight period or longer, that parent shall provide advance notice to the other parent of the address
and telephone number where the Child can be contacted.
7. This O rder i s e ntered p ursuant t o an a greement o f the p arties a t a c ustody c onciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the 'terms of this Order shall control.
BY THE COURT:
cc: Stephen Armstrong- Father
Kristin R. Reinhold, Esquire - Counsel for Mother
a
191 ,
TRUE COPY
In Testimony,
and t e seal of
T ........ da I
FRnA,4 RECORD
sst my hand
??, ?:,,,?fisle, Pa.
i,,.LG GA1 J. AR14iSTRONG
Plaintiff
vs.
STEPHEN ARMSTRONG
Defendant
Prior Judge: None
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
iN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
,Y
06-5506 CIVIL ACTION LAW
IN CUSTODY
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Landrie Adore Armstrong May 12, 2002
Mother
2. A custody conciliation conference was held on October 30, 2006, with the following
individuals in attendance: The Mother, Meggan J. Armstrong, with her counsel, Kristin R. Reinhold,
and the Father, Stephen Armstrong, who is not represented by counsel in this matter.
3. The parties agreed to entry of an Order in the form as attached.
??c.? ???aooLl
Date Dawn S. Sunday, Esquire
Custody Conciliator
a
VERIFICATION
COMPLAINT TO MODIFY
I verify that the statements made in this CUSTODY ORDER
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.
STEPHEN ARMSTRONG
Date: Z/-Z ?? / 0 F'
CERTIFICATE OF SERVICE
I, Diane M. Dils, Esquire, hereby certify that a true and correct copy of the
within Complaint to Modify Custody Order has been served upon the following
individual, by first class, United States mail, postage prepaid, by placing a copy of
the same at the post office in Harrisburg, Pennsylvania, on this 10 _ day of
Gr , 2008, addressed as follows:
Kristin R. Reinhold, Esquire
Silliker & Reinhold
5922 Linglestown Road
Harrisburg, PA 17112
Respectfully submitted,
BY:
iane M. Dils, Esquire
1400 North Second Street
First Floor, Front
Harrisburg, PA 17102
(717) 233-8743
I.D. No. 71873
Date: 5110/off
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MEGGAN J. ARMSTRONG IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
STEPHEN ARMSTRONG
DEFENDANT
2006-5506 CIVIL ACTION LAW
. IN CUSTODY
ORDER OF COURT
AND NOW, , Monday, March 17, 2008 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, April 16, 2008 at 9:00 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. Failure to appear at the conference may provide grounds for entrv 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/ Dawn S. Sunday, Es q, Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
)7k
t^i'? r
t .J.
MEGGAN J. ARMSTRONG,
Plaintiff
V.
STEPHEN ARMSTRONG,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-5506
CIVIL ACTION -LAW
IN CUSTODY
PETITION FOR FINDING OF CONTEMPT
AND MODIFICATION OF CUSTODY
AND NOW comes the Plaintiff, Meggan J. Armstrong, by and through her
attorneys, the Law Offices of Silliker and Reinhold, by Kristin R. Reinhold, Esquire, and
respectfully petitions this Court to find the Defendant, Stephen Armstrong, in contempt
of its Court Order dated November 3, 2006, and in support thereof, avers the following:
1. Plaintiff is Meggan J. Armstrong, hereinafter referred to as "Mother",
an adult individual residing at 4114 Nantucket Drive, Mechanicsburg, Cumberland
County, Pennsylvania.
2. Defendant is Stephen Armstrong, hereinafter referred to as "Father", an
adult individual residing at 6331 Linglestown Road, Harrisburg, Dauphin County,
Pennsylvania.
3. The subject minor child is Landrie Adore Armstrong, born May 12,
2002.
4. A Custody Order was entered by the Honorable M. L. Ebert, Jr. on
November 3, 2006, after the parties reached an agreement at the time of a Custody
Conciliation. A copy of the Court Order dated November 3, 2006, marked Exhibit "A" is
attached hereto and incorporated herein.
5. Since the entry of the Court Order dated November 3, 2006, Father has
repeatedly violated numerous provisions of the Custody Order.
6. Pursuant to paragraph six of the parties' Custody Order, the parent
shall provide advance notice to the other parent of the address and telephone number
where the child can be contacted if the parent intends to remove the child from his or her
residence for an overnight period or longer.
7. In February, 2007, Father began exercising his custodial periods at his
girlfriend's mother's house. Father failed to ever put Mother on notice that he was
exercising his overnight custodial periods at his girlfriend's mother's residence as
opposed to his residence. When Mother became aware that the subject child was not
spending her overnights at Father's residence, she requested the address, telephone
number, and the names of the individuals residing in the home where he was spending his
custodial time with the child. Despite numerous verbal requests from Mother to Father
and from Mother's counsel to Father's counsel, Father never provided the name, address,
and telephone number of the residence wherein he was exercising overnight custody.
Father told Mother that he did not need to provide the names of the people in the home or
the home telephone number as she had his cell phone number and that was all she
needed. Only when Father moved into a new residence in or around December, 2007, did
Father provide Mother with his address and telephone number.
8. In January, 2007, Father took the subject child on an overnight trip to
Pittsburgh and failed to inform Mother or provide her with the address and telephone
number where the child could be contacted.
9. In 2007, Father took the subject child on an overnight camping trip
with his girlfriend and failed to inform Mother or provide her with the address and
telephone number where the child could be contacted.
10. Father is in contempt of this Court's Order dated November 3, 2006,
by failing to provide advance notice to Mother of the address and telephone number
where the subject child could be contacted as set forth in paragraphs seven, eight, and
nine of this Petition.
11. Pursuant to paragraph three of the Custody Order, Father's custodial
time is to begin on alternating Fridays after work between 4:30 and 5:30 p.m. and on
Wednesdays after work between 4:30 and 5:30 p.m.
12. On approximately twelve occasions since the entry of the Court Order
dated November 3, 2006, the subject child was picked up prior to 4:30 at her daycare
with no notice given to Mother. On the majority of these occasions when the child was
picked up early, she was picked up by Father's paramour because Father was not off
work.
13. Father is in contempt of the Custody Order dated November 3, 2006,
by repeatedly picking up the child prior to his custodial time or having a third party pick
up the child before his custodial time without notice to or agreement of Mother.
14. Pursuant to paragraph one of the parties' Custody Order, the parties
share legal custody of the subject minor child.
15. Father has repeatedly violated the shared legal custody provision of
the parties' Custody Order by unilaterally scheduling and attending medical and mental
health care appointments with the subject child without providing any notice to Mother.
16. Specifically, Father violated the legal custody provision including but
not limited to the following instances: In March, 2007, Father unilaterally chose a
counselor for the child and made an appointment for her attendance. When Mother
discovered the appointment, her counsel cancelled it due to the fact there had been no
discussion between the parties as to the choice of a counselor. Despite notification to
Father's attorney at the time that a counselor would need to be jointly chosen, Father
again scheduled the child with the same counselor without any input from Mother. In
October, 2007, Father unilaterally chose a dentist for the subject child, scheduled an
appointment, and picked the child up from daycare without giving Mother any prior
notice. Father took the subject child to her pediatrician in January, 2008, for a non-
emergency visit and did not inform Mother until after the appointment had taken place.
Father called Mother following the appointment and told her, "You are a f***ing bitch"
and "Listen up, she has pneumonia". Despite the subject child having pneumonia, Father
took the child to the Farm Show the following day.
17. Father is in contempt of the Custody Order dated November 3, 2006,
by repeatedly violating the shared legal custody provision as set forth in paragraph 16 of
this Petition.
18. Pursuant to paragraph three of the parties' Custody Order, Father is to
notify Mother by the preceding Saturday during his custodial weekend if he is not taking
the child to church and Mother is entitled to obtain custody of the child on Sunday at
10:30 a.m. for church, and to return her to Father immediately following the service.
19. Mother believes and therefore avers that aside from approximately
one or two times, Father has not taken the child to church during his custodial weekend
since the entry of the Court Order, and has never contacted Mother to inform her that she
may take the child to church since he would not be taking the child to church.
20. Father is in contempt of the Court Order dated November 3, 2006, by
failing to contact Mother and giving her the opportunity to take the child to church on his
custodial Sundays when he was not going to take the child.
21. Pursuant to paragraph three of the parties' Court Order dated
November 3, 2006, Father is to return the subject child to Mother's custody at the end of
his custodial weekends on Sunday at 7:30 p.m.
22. Father has violated the spirit of the Court Order dated November 3,
2006, by repeatedly threatening to not return the child on Sunday to Mother if she would
not meet him at whatever location he decided would be an appropriate exchange point.
After approximately six months of Father returning the child to Mother at Mother's
residence on Sundays following his custodial weekend, Father began threatening Mother
that he would keep the child until Monday morning and return her to the preschool if she
would not meet him at various locations. Mother would go to those locations as she did
not want Father to retain the child beyond his custodial period.
23. Father has violated the spirit of the Court Order dated November 3,
2006 by treating Mother with the utmost disrespect and vulgarity during his
communications with Mother. Father frequently calls Mother names and swears at her in
his verbal interactions with Mother. When counsel for both parties discussed that e-mail
should be used exclusively so that there would be a record of their conversations, Father
shut down his current e-mail account and obtained a new e-mail address of
"Iamabadmother@yahoo.com", thereby forcing Mother to type in the words "I am a bad
mother" every time she a-mails Father.
24. Father's flagrant disregard for the terms of this Court's Order dated
November 3, 2006, constitutes a finding of contempt.
25. Mother has incurred and shall continue to incur legal fees and costs
relative to the filing of this Petition for Finding of Contempt and Modification of
Custody.
WHEREFORE, Plaintiff, Meggan J. Armstrong, respectfully requests this
Honorable Court:
a. Find the Defendant, Stephen Armstrong in contempt of this
Court's Order dated November 3, 2006;
b. Order the Defendant to pay reasonable attorney's fees incurred
related to the filing of this Petition for Finding of Contempt and
Modification of Custody;
c. Order the Defendant to immediately begin complying with all
of the terms of the Custody Order dated November 3, 2006;
d. Order the Defendant to engage in anger management
counseling and co-parenting counseling in order to more effectively deal
with the Plaintiff as it relates to custody;
e. Modify the current Custody Order to change Father's
Wednesday overnight to alternating Wednesdays from 4:30 p.m. to
7:30 p.m.;
f. Any other relief this Court deems reasonable and just.
Date: Respectfully submitted, - 10 THE LAW OFCES OF
SILLIKER & IIEINHOLI
Kristi R. Reinhold, Esc
5922 inglestown Road
Harrisburg, PA 17112
(717) 671-1500
I.D. No. 57911
Attorney for Meggan J. Armstrong
MEGGAN J. ARMSTRONG, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 06-5506
STEPHEN ARMSTRONG, CIVIL ACTION -LAW
Defendant IN CUSTODY
CERTIFICATE OF SERVICE
The undersigned, Renee Dreisbach, hereby certifies that a copy of a
Petition for Finding of Contempt and Modification of Custody was mailed to Diane Dils,
Esquire, attorney for Defendant, Stephen Armstrong, on April 9, 2008, by first-class mail,
addressed as follows:
Diane Dils, Esquire
1400 North Second Street, first floor front
Harrisburg, PA 17102
I hereby certify that the aforegoing is true and correct to the best of my
knowledge, information and belief. 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: k8 '(?
Renee Dreisbach
NOV 0 2 2006r?
MEGGAN J. ARMSTRONG
Plaintiff
vs.
STEPHEN ARMSTRONG
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
06-5506
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this a day of 2006, upon
?_
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The Father, Stephen Armstrong, and the Mother, Meggan J. Armstrong, shall have shared
legal custody of Landrie Adore Armstrong, born May 12, 2002. Each parent shall have an equal right,
to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the
Child's general well-being including, but not limited to, all decisions regarding her health, education
and religion. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and
information pertaining to the Child including, but not limited to, school and medical records and
information.
2. The Mother shall have primary physical custody of the Child.
3. The Father shall have partial physical custody of the Child on alternating weekends,
beginning November 10, 2006, from Friday after work between 4:30 and 5:30 p.m. through Sunday at
7:30 p.m. In addition, the Father shall have custody every week from Wednesday after work between
4:30 and 5:30 p.m. through Thursday morning when the Father shall return the Child to preschool.
The Father may have additional periods of custody with the Child as arranged by agreement between
the parties. The Father's first two weekday overnight periods shall take place on Thursday,
November 1 and 8 due to prior plans and thereafter shall be on Wednesdays with the understanding
that the parties shall cooperate in moving the overnight to another weekday to accommodate special
activities or events. In the event that the Father is not taking the Child to church during his weekend
period of custody, the Father shall notify the Mother by the preceding Saturday and the Mother shall be
entitled to obtain custody of the Child on Sunday at 10:30 a.m. for church and shall return the Child to
the Father's residence immediately following the church service.
4. The parties shall share or alternate having custody of the Child on holidays as follows:
A. Christmas: In every year, the Father shall have custody of the Child from
Christmas Eve at 4:00 p.m. through Christmas Day at 11:00 a.m. and the Mother shall have custody
from Christmas Day at 11:00 a.m. through December 26th at 4:00 p.m. The parties shall share having
custody over the remainder of the Child's holiday break from preschool/school as agreed.
EXHIBIT
B. Thanksgiving: In every year, the Father shall have custody of the Child from
between 4:30 and 5:30 p.m. on the Wednesday before Thanksgiving through the weekend following
Thanksgiving and the Mother shall have custody over the entire weekend preceding Thanksgiving.
C. Alternating Holidays: In even numbered years, the Mother shall have custody of
the Child on Easter Sunday and Independence Day and the Father shall have custody on Memorial Day
and Labor Day. In odd numbered years, the Father shall have custody on Easter Sunday and
Independence Day and the Mother shall have custody on Memorial Day and Labor Day. The holiday
periods o f c ustody shall run from 10:00 a.m. until 7:30 p.m. on the holiday, with the exception o f
Independence Day which shall run until after the fireworks.
D. Mother's Day/Father's Day: The Mother shall have custody on Mother's Day
and the Father shall have custody on Father's Day from 10:00 a.m. until 7:30 p.m.
E. The holiday custody schedule shall supersede and take precedence over the
regular custody schedule.
5. Each parent shall be entitled to have custody of the Child for two weeks for vacation each
year upon providing at least 30 days advance notice to the other parent. The party providing notice
first under this provision shall be given priority on the selection of vacation dates.
6. In the event either p arent intends to remove the Child from his or h er residence for an
overnight period or longer, that parent shall provide advance notice to the other parent of the address
and telephone number where the Child can be contacted.
7. This O rder i s e ntered p ursuant t o a n a greement o f t he p arties a t a c ustody c onciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT:
js)-M.?-nrlom-? J-1--
cc: Stephen Armstrong- Father
Kristin R. Reinhold, Esquire - Counsel for Mother
TRUE COPY ' RMA RECORD
Is Testimo^y ,„t my nand
e seal of Pa.
J
rothorata .
AFFIDAVIT
I, Meggan J. Armstrong, hereby certify that the aforegoing is true and
correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to
unsworn falsifications to authorities.
Dated:
?11?
Meg J trong
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APR IS 2008
MEGGAN J. ARMSTRONG IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 2006-5506 CIVIL ACTION LAW
STEPHEN ARMSTRONG
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this vS day of 11`A 2008, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The parties shall submit themselves, their minor Child, and any other individuals deemed
necessary by the evaluator to a custody evaluation to be performed by Arnold Shienvold, Ph.D. The
purpose of the evaluation shall be to obtain independent professional recommendations concerning
ongoing custody arrangements which will best meet the needs of the Child and to address the issues
raised by the Father in his Petition for Modification and by the Mother in her Petition for Contempt
and Modification. The Father shall be responsible to pay all costs of the evaluation.
2. All exchanges of custody which do not take place at the Child's school/daycare shall occur
at the McDonalds on Front Street in Harrisburg, unless otherwise agreed between the parties.
3. The parties shall cooperate with each other in encouraging the non-custodial parent to
maintain telephone contact with the Child. Unless otherwise agreed, the non-custodial parent shall
contact the Child between 6:30 p.m. and 7:00 p.m. prior to the beginning of the bedtime routine.
4. Within sixty (60) days of completion of the custody evaluation and receipt of the evaluator's
written recommendations, counsel for either party may contact the conciliator to schedule an additional
custody conciliation conference, if necessary.
BY THE COURT,
M. L. Ebert, Jr. J.
cc: Kristen R. Reinhold, Esquire - Counsel for Mother
`Diane M. Dils, Esquire - Counsel for Father
ce>F i FS M.-a t LEL
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.3l;qi :10
MEGGAN J. ARMSTRONG
Plaintiff
vs.
STEPHEN ARMSTRONG
Defendant
Prior Judge: M. L. Ebert, Jr.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2006-5506 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Landrie A. Armstrong May 12, 2002 Mother
2. A custody conciliation conference was held on April 16, 2008, with the following
individuals in attendance: the Mother, Meggan J. Armstrong, with her counsel, Kristen R. Reinhold,
Esquire, and the Father, Stephen Armstrong, with his counsel, Diane M. Dils, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
ry
Date Dawn S. Sunday, Esquire
Custody Conciliator
10,
MEGGAN J. ARM STONG IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. 2006-5506 CIVIL ACTION LAW
STEPHEN ARMSTRONG
DFFI?NDANT
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, August 27, 2010 upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Friday, September 24, 2010 at 9:00 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issuc°s in dispute: or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter- into a temporary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinLl.
FOR THE COURT.
By: i/s/ Dawn S. Sund_ V Es0 -
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the schedul ed
conference or hearin(,.
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 OFF ICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association ('>
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Carlisle, Pennsylvania 17013
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Telephone (717) 249-3166
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MEGGAN J. ARMSTRONG,
Respondent
v.
STEPHEN ARMSTRONG,
Petitioner
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION
No. 06-5506
IN RE: CUSTODY
ORDER OF COURT
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AND NOW, upon consideration of Father, Stephen Armstrong's, Ex Parte
Petition for Emergency Relief, and the Court noting that Father agreed to allow Mother to
have primary physical custody of the child pursuant to Order dated November 3, 2006,
and further that even if the Emergency Order was granted the child would still be
required to attend a new school this year,
IT IS HEREBY ORDERED AND DIRECTED that the Emergency Petition for
Relief is DENIED. The matter shall proceed to conciliation before Custody Conciliator
Dawn Sunday on September 24, 2010 at 9:00 a.m. Nothing in this Order shall be
construed to imply that the child should remain in Mother's custody even if he has begun
the third grade in Mother's current school district.
By the Court,
~'t
M. L. Ebert, Jr.,
J.
Diane M. Dils, Esquire
1400 N. Second Street
Harrisburg, PA 17102
Attorney for Petitioner
~eggan J. Raymond
108 W. South Street
P.O. Box 33
Franklintown, PA 17323
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MEGGAN J. ARMSTRONG IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs r ;
06-5506 CIVIL ACTION LAW ~i
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STEPHEN ARMSTRONG ~~~' _
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Defendant IN CUSTODY ' ° ' ~-'
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ORDER OF COURT ° ~~
AND NOW, this Jr'~h day of ~ ~~ 0~ tr 2010, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
1. The prior Orders of this Court dated November 3, 2006 and April 21, 2008 are vacated and
replaced with this Order.
2. The Mother, Meggan J. Raymond, formerly Armstrong, and the Father, Stephen Armstrong,
shall have shared legal custody of Landrie Adore Armstrong, born May 12, 2002. Major decisions
concerning the Child including, but not necessarily limited to, her health, welfare, education, religious
training and upbringing shall be made jointly by the parties after discussion and consultation with a
view toward obtaining and following a harmonious policy in the Child's best interest. Neither party
shall impair the other party's rights to shared legal custody of the Child. Neither party shall attempt to
alienate the affections of the Child from the other party. Each party shall notify the other of any
activity or circumstance concerning the Child that could reasonably be expected to be of concern to the
other. Day to day decisions shall be the responsibility of the parent then having physical custody.
With regard to any emergency decisions which must be made, the parent having physical custody of
the Child at the time of the emergency shall be permitted to make any immediate decisions
necessitated thereby. However, that parent shall inform the other of the emergency and consult with
him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to
complete and full information from any doctor, dentist, teacher, professional or authority and to have
copies of any reports or information given to either party as a parent as authorized by statute.
3. The Father shall have primary physical custody of the Child beginning October 1, 2010.
4. The Mother shall have partial physical custody of the Child beginning October 8, 2010 on
alternating weekends from Friday, when the Mother shall pick up the Child after school, through
Tuesday morning, when the Mother shall take the Child to school. The parties shall cooperate in
scheduling additional midweek periods of custody for the Mother as appropriate.
5. The parties shall share having custody of the Child on holidays as follows:
A. Christmas: The Christmas holiday shall be divided into Segment A, which shall run
from Christmas Eve at 4:00 p.m. through Christmas Day at 2:00 p.m., and Segment B which shall run
from Christmas Day at 2:00 p.m. through December 26 at 4:00 p.m. In even numbered years, the
Mother shall have custody of the Child during Segment A and the Father shall have custody during
Segment B. In odd numbered years, the Father shall have custody of the Child during Segment A and
the Mother shall have custody during Segment B.
B. Thanks ig ving: In every year, the Father shall have custody of the Child from
between 4:30 and 5:30 p.m. on Wednesday before Thanksgiving through the weekend following
Thanksgiving and the Mother shall have custody over the entire weekend preceding Thanksgiving.
C. Alternatin Hg_olidays: In even numbered years, the Mother shall have custody of the
Child on Easter Sunday and Independence Day and the Father shall have custody on Memorial Day
and Labor Day. In odd numbered years, the Father shall have custody on Easter Sunday and
Independence Day and the Mother shall have custody on Memorial Day and Labor Day. The holiday
periods of custody shall run from 10:00 a.m. until 7:30 p.m. on the holiday, with the exception of
Independence Day which shall run until after the fireworks.
D. Mother's Day/Father's Day: The Mother shall have custody on Mother's Day and
the Father shall have custody on Father's Day from 10:00 a.m. unti17:30 p.m.
E. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule.
6. During the summer school break each year, the Mother shall have custody of the Child for
the first three weeks beginning on the last day of school, the Father shall have custody for the
following three weeks, the Mother shall have custody for the next three weeks and the Father shall
have custody of the Child for the remainder of the summer break.
7. The parties agree that the Child shall attend school at Linglestown Elementary in the Central
Dauphin School District as the Father assumes primary physical custody.
8. The parties shall share all information pertaining to the Child, including but not limited to
school and activity information, on a timely basis to enable both parties to remain involved in the
Child's development. Neither party shall enroll the Child in activities without advance consultation
and agreement with the other parent.
9. Unless the exchange of custody takes place at the Child's school, the parent receiving
custody of the Child shall be responsible to provide transportation from the other parent's residence
unless agreed otherwise between the parties.
10. Neither parent shall remove the Child from school during his or her period of custody,
without the advance consent of the school and the other parent.
11. The Mother may contact the Child one time each day before bedtime by telephone.
12. The parties shall participate in a minimum of four counseling sessions with a professional
selected by agreement. The purpose of the counseling shall be to assist the parties in establishing an
effective co-parenting relationship with the necessary communication skills. The parties shall follow
the recommendations of the Counselor as to the timing of inclusion of third parties in the counseling
sessions. Each party shall be responsible to pay for his or her individual sessions and the costs of all
joint sessions shall be shared equally between the parties. The parties shall select the counselor and
contact the counselor's office within two weeks of the date of the custody conciliation conference to
schedule the initial sessions.
13. In the event either parent intends to remove the Child from his or her residence for an
overnight period or longer, that parent shall provide advance notice to the other parent of the address
and telephone number where the Child can be contacted.
14. This Order is entered pursuant to an agreement of the parties at a custody conciliation
conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT,
~~
M. L. Ebert, Jr. J.
cc: ~ gan J. Raymond -Mother
e M. Dils, Esquire -Counsel for Father
OCi' 0 4 2010
MEGGAN J. ARMSTRONG
Plaintiff
vs.
STEPHEN ARMSTRONG
Defendant
Prior Judge: M. L. Ebert, Jr.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
06-5506 CIVIL ACTION LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
Landrie Adore Armstrong May 12, 2002
CURRENTLY IN CUSTODY OF
Mother
2. A custody conciliation conference was held on September 24, 2010, with the following
individuals in attendance: the Father, Stephen Armstrong, with his counsel, Diane M. Dils, Esquire,
and the Mother, Meggan J. Raymond, formerly Armstrong, who is not represented by counsel in this
matter.
3. The parties agreed to entry of an Order in the form as attached resolving both the Father's
Petition for Modification and the Father's Petition for Emergency Relief.
o~ 9 aa~o
Date ~- Dawn S. Sunday, Esquire
Custody Conciliator
MEGGAN J. RAYMOND, formerly IN THE COURT OF COMMON PLEAS
known as MEGGAN J. ARMSTRONG, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff /Petitioner ?
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IN CUSTODY C-)
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STEPHEN ARMSTRONG,
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Defendant/Respondent PRIOR JUDGE - EBERT
PLAINTIFF'S PETITION/COMPLAINT TO MODIFY CUSTODY ORDER
?ohn err a?. P(:
5020 Ritter Road
Suite 104
Mechanicsburg, PA 17055
PHONE: 717.766.4008
F.: 717.766.4066
1. Plaintiff/Petitioner is Meggan J. Raymond (hereinafter, "Mother"), formerly known as
Meggan J. Armstrong, an adult individual residing at 1059 York Road, Dillsburg, Cumberland
County, Pennsylvania 17019.
2. Defendant/Respondent is Stephen Armstrong (hereinafter, "Father"), an adult individu
who resides at 5997 Three Rivers Drive, Harrisburg, Dauphin County, Pennsylvania 17112.
3. The parties are the natural parents of the following minor child: Landrie Adore
Armstrong, born May 12, 2002.
4. The child was not born out of wedlock.
5. The child is presently in the custody of Father, pursuant to an Order of Court, entered i
September, 2010, following a custody conciliation held on September 24, 2010 (see,
copy of Order of Court appended to this Petition). This Order of Court vacated all prior Orders
entered in 2006 and 2008. The Father currently resides at 5997 Three Rivers Drive, Harrisburg,
Pennsylvania 17112, while the Mother resides at 1059 York Road, Dillsburg, Pennsylvania
17019.
6. In the last five years, the child has resided with the following persons and at the
following addresses:
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Names
Stephen Armstrong
Danette Armstrong
Brooks Armstrong
Quinn Armstrong
Stephen Armstrong
Danette Armstrong
Brooks Armstrong
Quinn Armstrong
Meggan Raymond
Landrie Armstrong
Jonah Raymond
Savannah Raymond
Meggan Raymond
Landrie Armstrong
Jonah Raymond
Savannah Raymond
Meggan Armstrong
Landrie Armstrong
Wayne Hasnson
Jennie Hanson
Residences
5997 Three Rivers Drive
Harrisburg, PA 17112
6331 Linglestown Road
Harrisburg, PA 17112
108 W. South Street
P.O. Box 33
Franklintown, PA 17323
510 Grant Street
Camp Hill, PA 17011
4114 Nantucket Drive
Mechanicsburg, PA 17055
Dates
06/12/12- present
10/01/10 - 06/12/12
07/10 -10/01/10
12/08-07/10
11/06-12/08
7. The Mother of the child is Meggan J. Raymond , who is residing at 1059 York Road,
?ohnerr?aw. PC
5020 Ritter Road
Suite 104
McChaniCSbur$, PA 17055
P1tor1E: 717.766.4008
FAx: 717.766.4066
Dillsburg, Pennsylvania 17019.
She is married.
8. The Father of the child is Stephen Armstrong, who is residing at 5997 Three Rivers
Harrisburg, Pennsylvania 17112.
He is married.
9. The relationship of the Mother to the child is that of mother. The child currently lives
with Father.
10. The relationship of the Father to the child is that of Father. The child currently lives with
Father.
11. Plaintiff/Petitioner currently lives with the following persons:
Name Relationship
Savannah Raymond Daughter
Michael Horne Brother-in-Law
Becky Horne Sister
Talan Horne Niece
Keaton Horne Nephew
12. Defendant/Respondent currently lives with the following persons:
Name Relationship
Landrie Armstrong Daughter
Danette Armstrong Spouse
Brooks Armstrong Son
Quinn Armstrong Son
5020 Ritter Road
Suite 104
McChardCSburg, PA 17055
PHONE: 717.766.4008
F.: 717.766.4066
13. Each parent whose parental rights to the child have not been terminated, and the
person who has physical custody of the child, have been named as parties to this action.
14. Plaintiff /Petitioner has not participated as a party or witness, or in another capacity, it
other litigation concerning the custody of the child pending in a court of this Commonwealth o
any other state.
15. Plaintiff/Petitioner does not know of a person not a party to the proceedings who has
physical custody of the child or claims to have custody or visitation rights with respect to the
child.
16. Plaintiff /Petitioner has no information of a custody proceeding concerning the child
pending in a court of this Commonwealth or any other state.
11. Plaintiff/Petitioner seeks to modify the attached Order, as follows: in 2010, Petitioner/
Plaintiff agreed to transfer primary physical custody of the Child to Defendant/Respondent
Father. This was based upon the fact that he was not working at the time and her belief that hel
should be given a chance to raise her. She now requests that primary physical custody be
transferred to her, predicated upon the following:
a) Father has violated the existing custody Order by refusing to cooperate with M
in scheduling additional midweek periods of custody (see 94 of existing Order);
b) Father has violated the shared legal custody provision of the Order by failing to
notify Mother of a suicide threat by the Child until 3:30 p.m. of the next day (see,
of existing Order);
c) Father and his wife have created an onerous environment for the Child at their
home, in that i) the Child is required to make her own breakfast and lunch; ii) the
Child is required to do her own laundry; iii) the Child is required to watch her th
and two year old step-siblings while father and his wife shower together; iv) the
Child is required to help get dinner ready and to help with the dishes; v) the Child
required to to go directly to her room after school and to present her homework
her step-mother or father and to begin her homework immediately; vi) if her cl
are deemed to be not folded properly, she must start over; vii) father and step-
mother have threatened to evict the Child from their home; and viii) she is requi
to walk by herself to and from the school bus stop.
d) At a recent meeting at the Child's counselor, Father screamed at Mother in front
both daughter and her counselor.
?ohn ierrY,_. PC
5020 Ritter Road
Suite 104
Mechanicsburg, PA 17055
Pmr. E: 717.766.4008
FAX: 717.766.4066
WHEREFORE, Mother requests that primary physical custody be returned to her as it
i
is in the best interests of the Child.
Respectfully submitted,
4 (M x AV- W
Jo n M. Kerr, Esquire
I. D. # 26414
At col
John Kerr Law, P.C.
5020 Ritter Road
Suite 104
Mechanicsburg, PA 17055
(717) 766-4008
Dated: July 25, 2012
?ohn ?rrr a??. PC
5020 Ritter Road
Suite 104
MechaniCSburg, PA 17055
PHoNF: 717.766.4008
FAx: 717.766.4066
VERIFICATION
The undersigned, Meggan J. Raymond, hereby states that she is the Petitioner in the foregoin,
custody action and, as such, is authorized to execute this Verification, and that any factual statement,
contained in the Petition To Modify Custody Order are true and correct to the best her information,
knowledge and belief. She understands that false statements are subject to the penalties prescribed
18 Pa. C.S. §4904, relating to falsification to authorities.
M n J. Raymond
CERTIFICATE OF SERVICE
The undersigned hereby certifies that he has served a copy of the foregoing, "Plaintiff!
Petition/Complaint To Modify Custody Order," on the below-named individuals in the manner
indicated:
First Class Mail Postage Prepaid
Certified Mail. Restricted Delivery
Diane M. Dils, Esquire
Law Offices of Dils & Dils
1400 North Second Street
First Floor Front
Harrisburg, PA 17102
Counsel of record for Defendant/Respondent
Stephen Armstrong
5997 Three Rivers Drive
Harrisburg, PA 17112
I?V, )0. &,
Joh . Kerr, Esquire
5020 Ritter Road
Suite 104
Mechanicsburg, PA 17055
(717) 766-4008
?ohn ? rr aw. P(_
5020 Ritter Road
Suite 104
Mechar C ur$, PA 17055
PHONE: 717.766.4008
FAx: 717.766.4066
Dated: July 25, 2012
MEGGAN J. RAYMOND IN THE COURT OF COMMON PLEAS OF .ate
m
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. 2006-5506 CIVIL ACTION LAW
STEPHEN ARMSTRONG
IN CUSTODY -
DEFENDANT
ORDER OF COURT
AND NOW, Wednesday, August 01, 2012 , upon consideration of the attached Comf
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the
-" V
at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, August 29, 2012 at 11:0 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in disp te; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a tem orary
order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,)
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: /s/ Dawn S. Sunday, Esq.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the A=
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 arrangem
must be made at least 72 hours prior to any hearing or business before the court. You must attend the schf
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
? -2) l7? Gs, -
?J-ohA 614.
ondc y?
? Dgw o 5- 5'
Fir -
41 ?0
MEGGAN J. RAYMOND IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 2006-5506 CIVIL ACTION LAW
STEPHEN ARMSTRONG
Defendant IN CUSTODY
ORDER
AND NOW, this 16th day of August, 2012, the conciliator, having been advby;Iairxff's
counsel that the Plaintiff/Mother does not wish to proceed with her Petition to ModiereWy'
relinquishes jurisdiction. The custody conciliation conference scheduled for Augus;* 2(1 2 is
75
canceled.
FOR THE COURT,
Dawn S. Sunday, Esquire
Custody Conciliator