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Home My WebLink About94-01984 .~~\ ,.', E ~ '"j ~ ..:,1 .. ' ~...._. ...._.-~,......_~:____ _'_-.<-.<___;..t..:'-_)III(_O.()QlIl().()IIIC)III(~ - . ~ ~ ~ ~ $ ~ ~ ~ 8 I SCOTT C. ROMBERGER .. ....... .......... '...........,...... ..........................,................... I ~ ...,......,...,..............,.... .............,.......,......... I 8 DEBORAH L. ROMBERGER ~ ..,....... .,....-.".. ...,."..,.. , ~ ~ ~ l ~ ~ -- ~ ~ ~ ~ ~ ,,' ~ 8 ~ ~ ~ 8 ~ ~ . tl.-__ 411:' ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF '* PENNSYLVANIA N o. ..,?,~,~J.?,~,~.. C!.Y,!,~....... 19 Versus DECREE IN DIVORCE AND NOW, ,., " ", " " ~';lf-:~, ,;" ",? '. 19, ~>:'. '. it is ordered and decreed that ,'.' .s,c;qr:r..c;:, ~,Qt-)~~~.q~~. ., , ," . , " " , " , ,'" '" plaintiff, and,."""."" ,~~~~~~~, .~'" ~~~~~~~~~""",..,",.,"'" defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; ...AI "'-'- ............ ........ .................................. ...................., .. ........ ........ ............ ......................... Dy T e court:L ,..,~. .. ...,~....(Jl.............................. ..,..... ~ Alle.1: J. ~ ~~i. ..j~:b;,'~~f~\;~~th~~~i.'~y... : ~ ~ ...----......--...-_____~__..._J . @ - . ~ ~ @ . ~ ~ . ~ . ~ -- I . . !i l'< . ~ ~ ~ ~ ;,: ~ 8 M > ~ ~ X > " ~ -, " ..r'!,.. c. /101ia ~~?/<//9~' r-"-'~"_.- ':}.,f;i~\H, ~""",-,,,,,,,,,,,",,,,,.,,,,,....."it >.~..j;:-,..;- . ,. ,'r, '* .. , . 8, For Thanksgiving Day, the parties will alternate from year to year, with Husband assuming care and control of the children for Thanksgiving 1994. For Christmas, the parties will alternate from year to year, in each case with one party assuming care and control on Christmas Eve through Christmas day at noon, and the other party exercising care and control from noon Christmas day through Deeember 26 at 6:00 p.m, Wife shall exercise care and eontrol on Christmas Eve through Christmas day at noon for 1994, With respect to the other Illl\ior holidays, the schedule shall similarly alternate, with the fll"st days as agreed upon by the parties, For Halloween, the parties will alternate from year to year the designated Trick.or-Treat night scheduled in the Carlisle Borough, with Wife exercising the Halloween, 1994 schedule. 4. On Mother's Day and Father's day, regardless of which parent would normally exereise care and control of the children, the parent whose celebration is designated by the day in question shall assume care and control of the children for the entire day. 5, Wife shall have no eontact with Randy Gutshall while she has the children and Randy Gutshall will not be in the presence of the children, and no activities will be planned when they would be together. 6, The above provisions may be modified by mutual consent of the parties, By the Court, ,AiL J. SCO'IT C. ROMBERGER, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL NO. 94-1984 DEBORAH L. ROMBERGER, Defendant : IN DIVORCE MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT is made this Z 5 ~ay of :Ady ( between SCOTT C. ROMBERGER (hereinafter referred to as "Husband") and , 1994, by and DEBORAH L. ROMBERGER (hereinafter referred to as "Wife"), WHEREAS, there were two ehildren born of this marriage, CORYNNE ROMBERGER, currently age 6, and SCOTT CODY ROMBERGER, eurrently age 4; and WHEREAS, eertain differcnees have arisen between the parties and, as a consequence, thcy have agrced to Iivc separatc and apart from each other; and WHEREAS, un aetion for divoree is pending betwecn the parties in the Court of Common Pleas of Cumberlund County, Pcnnsylvania; and . . WHEREAS, the parties wish to set forth certain eovenants and underatandings regarding their separation, the settling of their property righls and other rights and obligations growing out of Iheir marriage, and the divoree aelion pending between them; NOW THEREFORE, in eonsideration of the mutual promises and undertakings eontained herein, the parties hereto, intending to be legally bound, eovenant and agree as follows: 1. VOLUNTARY AGREEMENT: It is aeknowledged by the parties that this Agreement is entered into voluntarily and after due deliberation by eaeh of them. 2, SEPARATION AND NON-INTERFERENCE: It shall be lawful for Husband and Wife at all times hereinafter to live separate and apart from eaeh other and 10 reside from time to time at such plaee or plaees as thcy shall respectively deem fit, free from any control, restraint, or interferenee, indireet or direet, from eaeh other. Neither party shall harass the other nor eompelthe other to eohabit or dwell with him or her by any legal or other proceedings, The foregoing provisions shall not be taken to be an admission on the part of either Husband or Wife of the lawfulness or unlawfulness of ilie eauses leading them 10 live apart, 3. DIVORCE ACTION: The parties acknowledge iliat an action for divoree between them is pending in the Court of Common Pleas of Cumberland County, Pennsylvania, to the caption, Romberger v. Romberger, Civil Tenn No, 94-1984, The parties hereby agree that the tenns of this MARITAL SETILEMENT AGREEMENT shall constitute a full and final settlemenl of all their respeetive claims in sueh aetion and that all sueh elaims raised in sueh aelion shall be marked "Settled" in aecordanee with the ~ , -, . tenus of this MARITAL SETILEMENT AGREEMENT, and the parties further agree to exeeute any affidavits of eonsent, necessury to effeet a consensual divorce, after the expiration of ninety days after the filing of the divoree complaint, 4, REAL PROPERTY: a. The parties aeknowledge that they own and hold in their joint names as tenants by the entirety, real property regarded as the marital residenee, loeated and known as 163 Oak Hill Rood, Carlisle, Cumberland County, Pennsylvania, b, The parties agree that Husband sholl pay to Wife the amount of S4,OOO within three years of exeeution of this Agreement, os full and eomplete settlement of any claims Wife may hove with regard to the martial residenee. Effeetive the dote of this Agreement, Husband sholl hove the exclusive right to oceupy and enjoy the premises located at 163 Oak Hill Rood, Effeetive the dote of this Agreement, Husband shall assume sole responsibility for any expenses rclating to the 163 Oak Hill Rood premises and his oceupaney thereof, and sholl hold Wife hamlless and indemnify Wife for any losses or expenses relating to the marital residenee. e. Within thirty (30) days of exeeution of this Agreement, the parties sholl execute the following doeuments: A deed, transferring the real property loeated at 163 Oak Hill Road from Husband and Wife to Seott C, Romberger only, subject to the existing mortgage, and subjeet to 0 second mortgage and lien, to be executed at the same time, seeuring the S4,OOO claim of Deborah L. Romberger, at no interest, payable within three years of the dote of this Agreement, for full settlement of her interests in the marital home. ". -, . d, The parties aeknowledge and eertify that they own no other real property either jointly or individually, 5. MOTOR VEHICLES: Eaeh p~rty eurrently has in his or her possession a motor vehiele, Wife having a 1984 Pontiae and Husband having a 1989 Chevrolet Blazer. Eaeh party sholl be entitled to retain said vehicle for his or her own exclusive use and the parties agree in eonncetion with this Agreemcnt to exeeute any doeuments neeessary for transferring of title in order to convey sole owncrship of the respeetive vehieles to Wife and Husband. 6, PERSONALl It is agreed that all personal property now in the possession of eaeh party is eonsidcred his or her respeetive personal property and eaeh party hereby relinquishes any claim to personal property eurrcntly in the possession of the othcr party with the following exeeption. Immcdiately after exceution of this Agreement, Husband sholl transfer to Wife one-half (1/2) of the Christmas deeorations, 7. CUSTODY OF MINOR CHILDRENl 0, It is agreed by the parties that the children shall reside with and be in the eare and eontrol of Husband one week and Wife the next week, and continuing thereafter on alternating \\,eeks, with the two ehildren to remain together and with transfer of the ehildren to take plaee on Friday evenings at approximately 5:00 p,m. b. With regard to the following major holidays, the parties agree that the sehedule for eare of the ehildren will not be guided entirely by the eoincidenee of whieh parent may be exereising their nonnal week of eare and eontrol of the ehildren, ~ '. . These holidays arc as follows: New Year's Day, Easter Sunday, Memorial Day, Fourth of July, Labor Day, Thanksgiving, and Christmas. c, For Thanksgiving Day, the parties will ahemate from year to year, with Husband assuming eare and eontrol of the children for Thanksgiving 1994. For Christmas, the purties will uhemutc from year to year, in eaeh ease with one party assuming eare und eontrol on Christmas Eve through Christmas day at noon, and the othcr party cxereising eare and eontrol from noon Christmas day through Deeember 26 at 6:00 p,m, Wife shall exereise eare and eontrol on Christmas Eve through Christmas day at noon for 1994, With rcspeet to the other major holidays, the sehedule shall similarly ahemate, with the first days as agreed upon by the parties, For Halloween, the parties will alternate from year to year the designllted Triek-or-Treat night seheduled in the Carlisle Borough, with Wife exereising the Halloween, 1994 sehedule. d. On Mother's OilY and Father's day, regardless of whieh parent would nomlally exereise eare and eontrol of the ehildren, the parent whose eclebration is designated by the day in question shall assume eare and eontrol of the ehildren for the entire day. e. Wife shall have no eontaet with Randy Gutshall while she has the ehildren and Randy Gutshall will not be in the presenee of the ehildren, and no aetivities will be planned when thcy would be together. f. The above provisions may be modified by mutual eonsent of the parties. ~ , , 8, SUPPORT OF MINOR CHILDREN: a. The parties stipulate and agree that Husband's support obligation toward the minor ehildren, in the eon text of this overall Agreement, shall additionally involve payment of reasonable child eare expenses ineurred by Wife, currently in the amount of eighty doll ai'll (580,00) every other week, reOeeting the every other week physieal eare of the ehildren divided between Husband and Wife, b, The parties agrce that Wife shall maintain medieal insuranee for the ehildren as provided through her employment with Cumberland County. Should the county begin to eharge employee co-payments for the ehildren's eoverage, the parties then agree that they would eontinue eoverage through whiehever parent's poliey has the most eeonomie eoveragc available, and that thcy would share equally in the payment of any sueh eoverage for the ehildren, In sueh ease, either Husband or Wife shall maintain medical insuranee as provided through his or her employment, Out-of-pocket medical eosts shall be divided between the parties in proportion of seventy pereent (70%) payable by Husband and thirty percent (30%) payable by Wife. c, The parties agree that they arc eaeh able to provide for their own maintenance and support, They eaeh hereby waive, release and give up any claim or rights they may have agaiust each other for alimony, alimony pendente lite, spousal support, or maintenance, 9, TAXATION: Eaeh parent shall be entitled to claim a tax exemption for one of the minor ehildren, so long as the eustody arrangement remains as stated above, Barring further agreement of the parties, at the time that either ehild shall beeome . ". ineligible to be claimed as a tax exemption, and if the other child continues to be claimable lIS a tax exemption, the parties shall ahem ate years in whieh they may claim the exemption, 10. DEBTS OF THE PARTIES: a. It is agreed and understood that various marital debts of the parties exist, primarily involving a VISA and personal serviee eonsolidated loan. Husband shall lISsume full responsibility for payment of these two debts until their full satisfaetion. Any other debts of the parties, whether eons ide red marital or otherwise, and whether incurred before or after the date of separation, shall be eonsidered the sole debt of the party in whose name the debt WllS ineurred, b, The parties agree that they will not in the future eontraet or ineur any debt or liability for whieh the other party, his or her property or estate, might be responsible and eaeh further agrees to indemnify and save harmless the other party against any claims that may be asserted by anyone against the other party by rellSon thereof, 11. NON-MERGER IN DIVORCE DECREE: The parties agree that in the event of absolute divorce between them, they shall nonetheless eontinue to be bound by all the terms of this Agreement, and neither this Agreement, nor the terms hereof, shall be deemed to have been merged in any deeree or judgment granted in the divoree aetion, but shall survive and be forever binding upon the parties, 12. EXECUTION OF DOCUMENTS: Each of the parties shall, from time to time at the request of each other, exeeute, acknowledge and deliver to the other party any . ~ and all further instruments that may reasonably be required in order to give full force and effect to the provisions of this Agreement. 13. COUNSEL FEES: Eaeh party agrees to be individually responsible for all eourt costs, filing fees, allomeys fees and other eosts and expenses he or she may have ineurred in eonneetion with the divoree aetion between the parties, the support action between the parties and the preparation of this Agreement. 14. MUTUAL RELEASE: Exeept liS provided for in this Agreement, the parties hereby remise, release, quit-claim and forever diseharge eaeh other and the estate of each other, for all time to eome, and for all purposes whatsoever, from any and every elaim, including alimony, alimony pendente lite, equitable distribution of marital property, eounsel fees or eosts under the Divoree Refooo Aet or spousal support, or otherwise, that they make or hereafter make in and to or against eaeh other's estates or any parts thereof, whether by way or dower or eurtesy, or under the intestate laws, or the right to take or cleet against the other's wiIl, except only sueh rights as aeerue pursuant to this Agreement. 15. NON-WAIVERI The failure of either party to insist in anyone or more inlllanees upon the striet perfomlanee of any of the teoos hereof in this MARITAL SETTLEMENT AGREEMENT shall not be construed as a waiver or relinquishment of sueh teoo or temlS in the future. 16. BREACH: III the event that either party breaehes any provision of this MARITAL SETTLEMENT AGREEMENT he or she shall be responsible for any and all eosts incurred to enforee the MARITAL SETTLEMENT AGREEMENT, including, r.~'-''''''' -~o>"'''''''_''' . ~ but not limited to, court costs and eounscl fees of the other pllrty. In the event of breach, the other party shall have the right, at his or her election, to sue for damages for sueh breaeh or to seek sueh other and additional remedies as may be available to him or her. 17. ENFORCEMENT: The parties agree that the tenns of this MARITAL SETILEMENT AGREEMENT, particularly including the custody agrecmcnt, may be entered as separate Orders of Court, and that any part or parts hereof may be enforeed in any eourt of eompetent jurisdietion, 18, APPUCABLE LAW AND EXECUTION: The parties hereto agree that this Agreemcnt shall be eonstrucd under the laws of the Commonwealth of Pennsylvania, and shall bind the parties hereto, and their respective heirs, exeeutors and assigns. This Agrcemcnt shall be exccutcd as original in triplieatc. 19. ENTIRE AGREEMENT: The parties aeknowledge and agree that this MARITAL SETILEMENT AGREEMENT contains the entire understanding of the parties and supersedes any prior agreement bctwecn them. There are no other rcprcscntations, warranties, promises, covenants or understandings between the parties other than thosc expressly set forth herein. 20. INCORPORATION IN JUDGMENT FOR DIVORCE: In thc event that either Husband or Wife at any time hercafter obtain a divoree in the aetion for divorcc prcscntly pending bctwccn them, or otherwise, this MARITAL SETILEMENT AGREEMENT and all of its provisions shall be ineorporated into any such judgment for divoree, either dircctly or by refcrcnce. Thc Court, on entry of judgment for divorce shall . .. retain the right to enforce the provisions and the tenns of this MARITAL SETl'LEMENT AGREEMENT, 21. LEGAL ADVICE: Eaeh party aeknowledges that he and she have reeeived or have had the opportunity to receive independent legal advice from eounsel of his or her seleetion, and that eaeh have detennined to eomplete this MARITAL SETl'LEMENT AGREEMENT and that eaeh fully understands the faets, and eaeh has had the opportunity to be fully infonned as to his or her legal rights and obligations. Eaeh party aeknowledges and aeeepts that this MARITAL SETl'LEMENT AGREEMENT is in the eireumstanees, fair and equitable, and that it is being entered into freely and voluntarily after Wife hilS consulted with her attorney, Taylor Andrews, and Husband has eonsulted with his attorney, Samuel W. Milkes. The exeeution of the MARITAL SETl'LEMENT AGREEMENT is not the result of any duress or undue infiuenee, and it is not the result of any eollusion or improper illegal agreement or agreements, The parties aeknowledge that eaeh has been fully infonned with the wealth, property state, and income of the other, and eaeh party is hereby satisfied that such infonnation is true and eorrect. \ . IN WITNESS WHEREOF, the parties hereto have set their hands and seals as of the day and year first above written. ~~~~~~ scon C. R MBERGE SAMUEL W. MILKES Attorney for Plaintiff .QIJ1f}\Q h d. ~tmll1/~ DEBORAH L. ROMBERGE ~ T LOR ANDREWS A~mey for Defendant " COMMONWEALTH OF PENNSYLVANIA I I I SSI I COUNTY OF CUMBERLAND I On this, th~iC day of ,1994, before me, a Notary Public in and for the aforesaid Common County, personally appeared SCOTT C. ROMBERGER, known to me, or satisfaetorily proven, to be the person whose name is subseribed to the within instrument and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and offieial seal. NOTARY PUBLIC t~~71\1j!",1 S~!,1. v:r.!:~~\fI,''; :!":.':~:.'::( :,CT.\iW PUBLIC CNJ:'15t': ~:.:,l,). f;till~~~'1t.N,D ro PA MV C01JI.IISSIOH ,,"p,r,t; ~"'iWDEA. I, 1997 My Commission Expires: -- ,.'-/l.' !!,;; ~'X~f .~'~. .....l. J COMMONWEALTH OF PENNSYLVANIA I I I SSI I COUNTY OF CUMBERLAND I On this, the ';Xi ~ day of (J.",J.../ , 1994, before me, a Notary Public in F~ and for the aforesaid Commonwealth and County, personally appeared DEBORAH L. ROMBERGER, known to me, or satisfaetorily proven, to be the person whose name is subseribed to the within instrument and acknowledged that she exeeuted the same for the purpose therein eontained. IN WITNESS WHEREOF, I hereunto set my hand and offieial seal. ~n<<A- Y4~/." NOTARY PUBUC My Commission Expires: NOTARIAL SEAL IlAENIlA L BIlEHll. NOTARY PUBUC CARUSl.E 1lllAO, CUllllSllAND CllUNTV MY COMMISSION EXPIRES JAlIUAAY 8, lllllll . --"'.,~...;,.. ":r en - >->- ::Z... 0-'" &.LIa~~ 2:z;C.'>z ....0(,,)-1 h..XO> ,?~:r.~ Ol;:'c.tcn Il}r;..~:e ;"~.uIW% \14 ;r:~.l~ 1--:1: .....::::. \:.~ c..~ :z:: "'- en ~ N r- ~ ~ -=: . I .1 SCO'IT C. ROMBERGER, Plaintiff, IN THE COURT OF COMMON PLE CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL NO, 94-1984 DEBORAH L. ROMBERGER, Defendant IN DIVORCE To the Prothonotary: Transmit the reeord, together with the following infonnation, to the Court for entry of a divoree deeree: 1. Ground for the divoree is irretrievable breakdown under Seetion of 3301(c) 3301(d) of the Divoree Code. 2. The Complaint was served by U.S, Mail, to the Defendant and Aeeeptance of Serviee exeeuted by Defendant, April 19, 1994. 3. Plaintirrs Mfidavit required by Seetion 3301(c) or 3301(d) of the Divorce Code was executed by the Plaintiff on July 21, 1994, and by Defendant on July 25, 1994. 4, There are no related claims pending. The parties agree to the entry of the Marital Settlement Agreement dated July 25, 1994, to be ineorporated into the final >. Deeree of Divoree between them, and to the entry of the attaehed Custody Order. Respeetfully submitted, AMUEL W. MILKES JACOBSEN & MILKES 52 East High Street Carlisle, PA 17013 (717) 249-6427 Attorney for Plaintiff a; - s: Q.- en :I" N N -' :::> ...., ~:: ~~.t wn-g~ ~~(..)~ ~%?...J r.)~;~~ :~~: 1~~ 'L;"J~W .. C>. ~'X "::> ~<> <=> SCOTT C, ROMBERGER, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Cf4- /98L/ C,'I,' -r,(fYl NO. CIVIL 1994 IN DIVORCE v, DEBORAH L, ROMBERGER, Defendant 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 objeetions 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 eourt without further notice for any money elaimed in the complaint or for any other claim or reliefrequested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ON, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR, THIRD FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 TELEPHONE: 717-240-6200 SCOTT C. ROMBERGER, Plaintiff, v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA qL/ - (9'6L{ C IV") T~ ((n NO. CML 1994 IN DIVORCE DEBORAH L, ROMBERGER, Defendant COMPLAINT UNDER SECTION 8801(c) COUNT I 1. Plaintiff is Scott C. Romberger, who currently resides at 168 Oak Hill Road, Carlisle, Cumberland County, Pennsylvania 17018, since May, 1992, 2. Defendant is Deborah L. Romberger, who currently resides at Front Street, Plainfield, Cumberland County, Pennsylvania 17081, since January, 1994. 8. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the tiling of this Complaint. 4, The Plaintiff and Defendant were married on September 29, 1984, Mt, Holly Springs, Pennsylvania, 17065. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers & Sailors Civil Relief Act of the Congress of 1940 and it amendments. 6, There have been no prior actions of divorce or for annulment between the parties. 1 ( ~ . '0 "-';;~"~ "\.-:~;:~" 7. The marriage is irretrievably broken. 8. Plaintitl' has been adviBed that counseling is available and that Plaintitl' may have the right to request that the Court require the parties to participate in counseling, WHEREFORE, Plaintitl' requests the Court to enter a decree of divorce. COUNT n - EQUITABLE DISTRmUTION 9, Paragraphs 1 - 9 are incorporated herein, 10. The parties are the owners of real and personal property subject to equitable distribution between them as marital property and are jointly obligated on marital debts and liabilities, WHEREFORE, The Plaintitl' requests the Court to equitably divide such items of marital property and marital liabilities between them, COUNT ill - CUSTODY 11. Paragraphs 1 - 12 are incorporated herein. 12, The Plaintitl' seeks custody of Corynne Romberger, age 6, and Scott Cody Romberger, age 4, The children were not born out of wedlock. The children are preBently in the custody of the Defendant. During the past five years, the children have resided with the following persons and at the following addresses: From January, 1994, to present, With Pliuntiff at 163 Oak Hill Road, Carlisle, Cumberland County, Pennsylvania 17081; From May, 1992, to January, 1994, with Plaintiff and DeCendant at 163 Oak Hill Road, Carlisle, Cumberland County, Pennsylvania 17013, 13. The mother oC the children is the DeCendant, Deborah L, Romberger, She is married, 14. The Cather oC the children is the Plaintiff, Scott C, Romberger, He is married, 15. The relationship oC Plaintiff to the children is that oC biological Cather. The Plaintiff eurrently resides with his minor ehildren, Corynne Romberger and Scott Cody Romberger. 16. The relationship oC the DeCendant to the children is that oC biological mother, The DeCendant currently resides alone. 17. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody oC the children in this or another court, Plaintiff has no information oC a custody proceeding concerning the child pending in a court oC this Commonwealth. 18. Plaintiff does not know oC a person not a party to the proceedings who has physical custody oC the children or claims to have custody or visitation rights with respect to the children. 19. The best interest and permanent welfare oC the children will be served by granting the relieC requested because the Plaintiff is a loving Cather, able to provide a good home Cor his children, ~f~ ~o,~ 20, Each parent whose parentai rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. No other persons are known to have or claim a right to custody or visitation of the children. WHEREFORE, the Plaintiff requests of this Court that he be granted primary legal and physical custody of the minor children. Respectfully submitted, SamuelVV. es,Esqurre JACOBSEN & MILKES 36 South Pitt Street Carlisle, PA 17013-3216 Attorney ID No, 30130 (717) 249-6427 r~ ~ " < .. "'.....,~.".J ..._~ 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: 1+/ IS /Cf't ~~~c.t~7--e-- Scott C. Romb rger 1 t~ ~~ -::z- C7') - CJ:) ~>- 001:~ lllr~:-:: ..f O:;r.C';Z: ;: (.:i t...1_i tl.~n:~" ;::" '.' .J :'.~ ~:~ ;~ ~: . ~.; I,! _. .......... ....." '.ll.d~ ;::':40... 'n- O;> ~U ~ ~ <;;) ~~ :c 0- m N C") @)~ r- r-- r'G ~ ~ -~ i . ~ '& '-.l ~ ~ >: \ (0 .0 ") \.1) <;:\ 0 0... ") C ........ ".... \ j ~ , v. NO. 94-1984 CML TERM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA SCOTT C. ROMBERGER, Plaintiff DEBORAH L, ROMBERGER, Defendant AFFIDAVI_T OF SERVICE I, Roberta A. Hockenberry, hereby certify that a true and correct copy of the Complaint and Waiver of Counseling in the above-captioned matter was duly served upon the Defendant, Deborah L, Romberger, by depositing it in the U.S. Mail, certified, restricted, return receipt requested, on April 18, 1994, addressed as follows: Deborah L. Romberger Front Street Plainfield, PA 17081 The return receipt card was signed on the 19th day of April, 1994. The return reeeipt card is attached as Exhibit "A," I hereby verify that the statements made in the foregoing 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, Dated: May 5, 1994 ~//J' (}@crUJ.Jt/f.!/ P berta A. Hockenberry I ,~'. '8lIl1U1S ~llall. WIQIII aUl.n'~~B ~i. '15'''.'" !I$J.... Ii; 1:"1 g'~.--i 'ii:r~ :~i' ;. :i 1 i. ~ J ~J '" ~ . ! ~~ <( II: IIl1 DOls.l;' - CJ t t 0 '!s..., ~ ~ ~ " .1 ti _.!! "''': N ~ z 1-11 J ~ J "j.!! W ~J Ui~d,iti;~ J 8 S D P ~~~.fu.llc <1. I t oS 11; ~D'5l..D r: .; i '" '~ a 1 1l) , ~ ~ I. .1 · .~ Ii I' t u 1 1 . i '6 - 'i &~ !il ~ Ii s ...i .~ tf 1~1;is ,t' I ~ ~ \J ~.. ;g ~I ~ ~VJ 1) alUftilUJ ~ ~,~ll ~JUl~1i~II'~ 2!~o.:. w uif cl::C= M 11). .. . -8 . . ,f.... . P 214 465 ?67 ~ Receipt for Certified Mail '" No Insurance Coveloge Providod ~ 00 not use for hllmnational Mail .."'. ....., 15co Roversat , 1'10 I $ sa 100 - h'~l,q. C..tH,"ll.." S",.,.,.,ll,.....".I.., ~ r f H,'~I",h'\1 [I.,. "",1.". .,:J5D rOO \)0 ~ - ~ " ,Bpt. BIIIABI 141 uo PllljdWOD '" ,-' i g ~. - en 'en - j E .. II c . , ... ... E o ... .. Ie lnoA Bt ' ...~~ -."'::" ~~ ':P' ~ e; - ::c= 0- r- IJ"I N :(.~ ..1'.- r" . ~~..I aJ f~ ~~, ;; ~:."o..~ 1.....1:,:-.... , ~,.:.I~ '. LM .. \ ,~ ... ~, ::.= 'HZ:- CJ SCOTI' C. ROMBERGER, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL NO. 94-1984 DEBORAH L, ROMBERGER, Defendant : IN DIVORCE AFFIDA VIT OF CONSENT 1. A Complaint in Divoree under the Divoree eode was filed on April 18, 1994, on the grounds that the marriage of the parties is irretrievably broken. 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint, 3. I eonsent to the entry of a final deeree of divoree. 4. I understand that I may lose rights eoneerning alimony, division of property, lawyer's fees or expenses if I do not elaim them before a divorce is granted. I verify that the statements made in the Affidavit are true and eorreet, I understand that false statements herein are made subjeet to the penalties of 18 Pa,C,S, ~ 4904 relating to unsworn falsifieation to authorities, Date: i - z.';- - '7 'i \Dc Jy,."n 1'\."'1. :Jib-r.....LllA~l , DEBORAH L, ROMBERGER' '- ~ en - :.-... "'... "'". 4J t:;.:-~:! <,").--f;"-;,r'; ~O(,):-t ;... ";t:C\ ;.I> r.~.... :r:: ~.! 'i ;~'t '-t,:~ , ,.~.:; :c: C~ o II'> N r-- c-..J '. ~.~ .... => -, '" h. ~.\ ~) '- SCOTI C. ROMBERGER, Plainliff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL NO. 94-1984 DEBORAH L. ROMBERGER, Defendanl : IN DIVORCE AFFIDA VIT OF CONSENT 1. A Complainl in Divorce under Ihe Divoree eode was filed on April 18, 1994, on Ihe grounds Ihal Ihe marriage of Ihe parties is irrelrievably broken, 2, The marriage of Plainliff and Dcfendanl is irrelrievably broken and ninely days have elapsed from Ihe dale of filing Ihe Complainl. 3. I eonsenl 10 Ihe enlry of a final deeree of divoree. 4, I understand Ihal I may lose righ18 concerning alimony, division of property, lawyer's fees or expenses if I do not claim Ihem before a divoree is granled, I verify Ihal Ihe stalemenls made in the Affidavit are true and eorreel. I undersland Ihal false stalemenls herein are made subjeel 10 the penalties of 18 Pa.C,S. ~ 4904 relaling 10 unsworn falsifieation 10 aUlhorilies, Dale: ~'l'91 J,-e;.1P- V~ ?c:")Ic.L~ SCOTI, C, RO BERGER ..... ~ >-... "'... j':..:.e tun:::':! uzc"'z ~ou-i ..xc~c. ot:"z:::' , ,.......- ., ":-Itn ; J, ,~.:r.: , ....i.j.z \ ':.l&.IJ t":xQ. ....=> 0'" "::r en - :z: c- O In N ...... ::> --. v, IN THE COURT OF COMMON PLEAS CUMBERLANP COUNTY PENNSYLVANIA 9L/ - 1'15'1/ NO, CIVIL 1994 IN DIVORCE SCOTTC.ROMBERGE~ Plaintiff, DEBORAH L, ROMBERGER, Defendant ORDER OF COURT , AND NOW, this ~4day of I)pl"" / ,1994, upon consideration of the attached Complaint, it is hereby direeted that the parties and their respective . t;>o I counsel appear before ~..(r 'f. (,.,1('1'. the Conciliator, at (oor L.v.n--b, LO. Ca.~i\I-v'Y- ,on the Cf1h day of Tunt~ ,1994, at g:.Jo!l. o'clock _,m,. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: 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, OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 (717) 240.6200 '., '.ll'i ..:'t , 'l'J "PR ./. 111U ~K '9'1 SCOTT C. ROMBERGER, Plaintiff, v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 9'1 - /9Ft.j C/v.1 7t r m NO. CML 1994 IN DIVORCE DEBORAH L. ROMBERGER, Defendant WAIVER OF COUNSELING Scott C, Romberger, Plaintiff herein, hereby states and certifies as follows: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling, 2, I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request, S, Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce deeree being handed down by the Court, I understand that false statements herein are made subject to the penalties of 18 Pa.C,S, ~ 4904, relating to unsworn falsifieation to authorities, Dated: i / ~ /9 I.j- ..l.,q -CcttJc~;;#,,~~~ P'______. Scott C, RomlS'erger /'- -=-- !:'>> ~ C'_ ... ... C"') >- ",,>>- ...... ,.~. ~ ~t.)::"l.' _.:a;:'L.. ......0("..1:.. .:~ ,:: '] .~~ " . ~ i' i co - .- }" g: ~ :::.. ^. '..:"-..) ~.. ....' SCOTT C, ROMBERGER, PlAintlfT. IN THE COURT OF COMMON PLEAS CUMBERLAND CSUNT'i PENNSYLVANIA if'!. 19fT NO, CIVIL 1994 v. DEBORAH L, ROMBERGER, Defend'1nt IN DIVORCE ORDER OF COURT You, DEBORAH L, ROMBERGER, Defendant, have been sued in court to obtain custody, partial custody or visitation of the children: CORYNNE ROMBERGER and SCOTT CODY ROMBERGER. You are ordered to appear in person at The Cumberland County Courthouse, Court Room No, -' on , 1994, at _, o'clock, _,M" for a hearing, If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the Court may issue a warrant for your arrest. The Plaintiff is awarded physical custody of the child, SCOTT C. ROMBERGER, pending further Order of Court, 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. COURT ADMINISTRATOR, THIRD FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 TELEPHONE: 717-240-6200 BY THE COURT: Dated: (J,) SCOTT C. ROMBERGER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL ACTION - LAW DEBORAH L. ROMBERGER, Defendant NO. 94-1984 CIVIL TERM IN DIVORCE NOTICE OF ELECTION TO RETAKE MAIDEN NAME Notice is hereby given that the Defendant in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on the 2nd day of August, 1994, hereby elects to retake and hereafter use her previous name of DEBORAH L. CRAIG. \Jlt.b~ld.~~ De orah L. Romberg -- TO BE KNOWN AS: \D, h{~oI. +>10 ~ De orah L, Cra COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND SS. On the ,,~~ day of ~At.k" 1994, before me, a Notary Public, personally appeared DEBORAH L. ROMBERGER, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ~.~r~,,- Y~A'_ Notary Public NOTARIAl. SEAL IIR9lllA L BREHM, NOTARY PU8UC CAAuSLE llllAO, CUMWlLAHD COUNTY MY COMIIISSIDN EXPIRES JAllUARY &, 1991l '-; r ..;., ....., - " ..':". '.j..o:: ... 'I.J r'i".:.. .....~ ..;,l.... 1 t \ ~ '" ~ ~ ",'" ~ ":0- cr, - if: ,... ... ~ ->>0 :~~- ""'" 1-';... '~1.~~ ~ ""-.1".""' . . ~,::..; .... ~ JUL 27 1994 cVv SCOTT C. ROMBBRGBR, Plaintiff : IN THB COURT OF COMMON PLEAS OF :CUMBBRLAND COUNTY, PBNNSYLVANIA v . . :NO. 1984 - CIVIL - 1994 . . DBBORAH L. ROMBBRGBR, Defendant : :CIVIL ACTION - CUS'l'ODY l( COUR'l' ORDBR AND NOW, this IF/' day of ~~ ' 1994, the Conciliator being advised that the parti she reached an agreement in this matter, the Conciliator relinqui hes jurisdiction. ." u ~.j fU'1 , :".... ~~!. -,- t ,. t l ~, Ii- n', if' JUl 11 Z S2 r~ 'M , .'~ offiCE 01 1;,[ c,$\IHOMOUkY CUMi''::H.AMO CO$llTl P(hllS1~V.HIA ., f " on the issue stated in the Petition on the _ day of , 1998, at (1 JUN 29 1998 SCO'IT C. ROMBERGER, PbdntifYRe~ndent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNI'Y, PENNSYLVANIA v. : CIVIL ACI'lON - LAW : CUSTODY DEBORAH L. GORDON, Defendant/Petitioner : NO. 94-1984 CIVIL TERM ORDER AND NOW, this _ day of June, 1998, upon presentation and consideration of the attached, verified Petition for Special Relief, it is ordered that the parties appear for a hearing _o'clock _.M. in Courtroom No. of the Cumberland County Courthouse, Carlisle, Pa. BY THE COURT F:1.ED-O::F::E CI"" ....-! .r.' ,,.....TI :~"( .. !' ' ::,'.-.1 Sil JUl. - -" .... r ,; '), ", 73 CJ;:'..l>: h::<:'~~;\ t: .' .J.':i I' ~", SCO'IT C. ROMBERGER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : CUSTODY DEBORAH L. GORDON, Defendant/Petitioner : NO. 94-1984 CIVIL TERM PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 1915.13 Petitioner, Deborah L. Gordon, by and through her attorneys, The Family Law Clinic, petitions this court for special relief pursuant to Pa.R.C.P. 1915.13, and alleges the following: 1. The parties are the natural parents of Scott Cody Romberger, born 11/0/89 and Corynne Victoria Romberger, born 2/19/88. 2. Pursuant to an Order of this court, dated August 2, 1994, case number 94-1984, the parties have custody on alternating weeks, that is, the children reside one week with Respondent and the next week with the Petitioner. 3. As of June, 1998, Petitioner has been at home through the day and can care for the children during that time. 4. During the weeks that Respondent has custody, the minor children are in the care of a baby sitter from 6:00 am until approximately 3:30 pm, Monday through Friday. 5. Respondent does not concur in this Petition. 6. It would be in the best interest of the children if Petitioner were to have partial custody of the children during the hours that Respondent is working. WHEREFORE, Petitioner respectfully requests the Court to grant this Petition and direct , . . that Petitioner have partial custody of the children during the hours that Respondent is working during the weeks that he has custody of the children. ?lrJIdtI. 7/1. lIJu.tt:uuJJ Ichole M. Walters ~iM~ THOMAS M. pLACB ROBERT B. RAINS KATHBRINB C. PEARSON Supervising Attorney DONALD MARRlTZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 240-5204 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa.C,S. 14904, relating to unsworn falsification to authorities, I verify that the statements made in the foregoing Petition are true and correct, to the best of my knowledge, information and belief. -::nv'\Ma..hOl. 'fl(l-'lr/ O)L.I Deborah L. Gordon Dated: lune ~lLJ ,1998 [2;: . ...--:- .' '. C') ~ ;.- ~ ,-. a, ;':'. urr.J ~.< c..J~.' ".: [i: '. r.: . ._~ :pt ~)~,~ ...J 6; rJ' "(r-, t.:..s'u c...,: .J _J tl.;: ..... ,', ..'- f.:":' ::';:1 .11) -, ... I.:.. (~ ::3 0 u\ U scarr c. ROMBEROER, PlalndWRcspondent @JUN 29 1998 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : CUSTODY DBBORAH L, OORDON, Defendant/Petitioner . . : NO. 94-1984 CIVIL TERM ORDER AND NOW, this _ day of June, 1998, upon presentation and consideration of the attached, verified Petition for Special Relief, it is ordered that the parties appear for a hearing on the issue stated in the Petition on the _ day of , 1998, at _o'clock Carlisle, Pa. .M. in Courtroom No. of the Cumberland County Courthouse, BY THE COURT ,- -..- - -"..~ .. . SCO'IT C. ROMBERGER, Plaintiff/Respondent : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL AcnON - LAW : CUSTODY 0 ..0 0 :;J ., l ! . -: ......, ~~ !' \; --~ '1':!1 '. ;->-.) d..;J ,. \~ .~ l ":' " -, .\ ,. :!.~~ -\ :\".1 -' ~C) ..p, ..;:! , ) . . -=-< . -;-.. :-J (.) ~ll - -. DEBORAH L. GORDON, Defendant/Petitioner : NO. 94-1984 CIVIL TERM PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 1915.13 Petitioner, Deborah L. Gordon, by and through her attorneys, The Family Law Clinic, petitions this court for special relief pursuant to Pa.R.C.P. 1915.13, and alleges the following: 1. The parties are the natural parents of Scott Cody Romberger, born 1110/89 and Corynne Victoria Romberger, born 2/19/88. 2. Pursuant to an Order of this court, dated August 2, 1994, case number 94-1984, the parties have custody on alternating weeks, that is, the children reside one week with Respondent and the next week with the Petitioner. 3. As of June, 1998, Petitioner has been at home through the day and can care for the children during that time. 4. During the weeks that Respondent has custody, the minor children are in the care of a baby sitter from 6:00 am until approximately 3:30 pm, Monday through Friday. 5. Respondent does not concur in this Petition. 6. It would be in the best interest of the children if Petitioner were to have partial custody of the children during the hours that Respondent is working. WHEREFORE, Petitioner respectfully requests the Court to grant this Petition and direct that Petitioner have partial custody of the children during the hours that Respondent is working during the weeks that he has custody of the children. 'Y!:vr.Iw6. 7JI. !,(}rdi:lA-d) Mchole M. Walters ~1r~ mOMAS M. PLACE ROBERT E. RAINS KATHERINE C. PEARSON Supervising Attorney DONALD MARRITZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 240-5204 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa.C.S. 14904, relating to unsworn falsification to authorities, I verify that the statements made in the foregoing Petition are true and correct, to the best of my knowledge, information and belief. :a r h lH a..h0J 'fIn"! rI O}l...,/ Deborah L. Gordon Dated: June ~la ,1998 -' '. !,'':;0 .;i';'Y'.'C_ _~~,.., '..11' ~. ~JUN 291998 scarr C. ROMBERGER, Plaintiff/Respondent : IN 'mE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : CUSTODY DEBORAH L. GORDON, DefendantlPetitioner : NO. 94-1984 CIVIL TERM ORDER AND NOW, this _ day of June, 1998, upon presentation and consideration of the attached, verified Petition for Special Relief, it is ordered that the parties appear for a hearing on the issue stated in the Petition on the _ day of , 1998, at _o'clock .M. in Courtroom No. of the Cumberland County Courthouse, Carlisle, Pa. BY THE COURT SCOIT C. ROMBERGER, Plaintiff/Respondent : IN TIlE COURT OF COMMON PLEAS OP : CUMBERLAND COUNTY, PBNNSYLV ANIA o " " ,--'.1 :::1 n II .' \:1" G r:;J ',.j .. . , l..' ..( ) ci(tl ..,I ...,. '-OJ =< v. : CIVIL ACTION - LAW : CUSTODY '-'j P'l "-.{ r.~ ,.0 l"~,: \ < ~ t ,. ).. ~,. :.:': .~ "':.' DEBORAH L. GORDON, Defendant/Petitioner ::j c,.) : NO. 94-1984 CIVIL TERM PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 1915.13 Petitioner, Deborah L. Gordon, by and through her attorneys, The Pamily Law Clinic, petitions this court for special relief pursuant to Pa.R.C.P. 1915.13, and alleges the following: 1. The parties are the natural parents of Scott Cody Romberger, born 11/0/89 and Corynne Victoria Romberger, born 2/19/88. 2. Pursuant to an Order of this court, dated August 2, 1994, case number 94-1984, the parties have custody on alternating weeks, that is, the children reside one week with Respondent and the next week with the Petitioner. 3. As of June, 1998, Petitioner has been at home through the day and can care for the children during that time. 4. During the weeks that Respondent has custody, the minor children are in the care of a baby sitter from 6:00 am until approximately 3:30 pm, Monday through Priday. 5. Respondent does not concur in this Petition. 6. It would be in the best interest of the children if Petitioner were to have partial custody of the children during the hours that Respondent is working. WHBRBFORB, Petitioner respectfully requests the Court to grant this Petition and direct that Petitioner have partial custody of the children during the hours that Respondent is working during the weeks that he has custody of the children. 11b,-JIdtl 7/1. !Ik~) Nichole M. Walters Certified Legallntem ~~~ M~ THOMAS M. PLACE ROBERT E. RAINS KATHERINE C. PEARSON Supervising Attorney DONALD MARRlTZ Staff Attorney FAMILY LAW CLINIC 4S North Pitt Street Carlisle, PA 17013 (717) 240-5204 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa.C.S. 14904, relating to unsworn falsification to authorities, I verify that the statements made in the foregoing Petition are true and correct, to the best of my knowledge, information and belief. :J::JJj1lHa.110! .y-JnJtrY "R/ Deborah L. Gordon Dated: June dla ,1998 ,t"" . .~JUN 2' 1998 SCOTI' C. ROMBERGER, PlaintifflRespondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : CUSTODY DEBORAH L. GORDON, DcfendantlPetitioner : NO. 94-1984 CIVIL TERM ORDER AND NOW, this _ day of June, 1998, upon presentation and consideration of the attached, verified Petition for Special Relief, it is ordered that the parties appear for a hearing on the issue stated in the Petition on the _ day of , 1998, at _o'clock _.M. in Courtroom No. of the Cumberland County Courthouse, Carlisle, Pa. BY THE COURT SCOTI' C. ROMBERGER, Plaintiff/Respondent : IN TIm COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL AcrION - LAW : CUSTODY n ,0 n c to -" ':','" , -J -r~ , (~ ". ~q t!;l "1- J ; :....) :t:q l ,'" .~'(1) " \ .J-;, , i:'~ . .' j {.\~1 ..-., , '.::J '..~rn ~' c..' .. :.-1 . . :.i~ ~~~ ~ t,.) --.. DEBORAH L. GORDON, Defendant/Petitioner . . : NO. 94-1984 CIVIL TERM PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 1915.13 Petitioner, Deborah L. Gordon, by and through her attorneys, The Family Law Clinic, petitions this court for special relief pursuant to Pa.R.C.P. 1915.13, and alleges the following: 1. The parties are the natural parents of Scott Cody Romberger, born 11/0/89 and Corynne Victoria Romberger, born 2/19/88. 2. Pursuant to an Order of this court, dated August 2, 1994, case number 94-1984, the parties have custody on alternating weeks, that is, the children reside one week with Respondent and the next week with the Petitioner. 3. As of 1une, 1998, Petitioner has been at home through the day and can care for the children during that time. 4. During the weeks that Respondent has custody, the minor children are in the care of a baby sitter from 6:00 am until approximately 3:30 pm, Monday through Friday. 5. Respondent does not concur in this Petition. 6, It would be in the best interest of the children if Petitioner were to have partial custody of the children during the hours that Respondent is working. WHEREFORE, Petitioner respectfully requests the Court to grant this Petition and direct - that Petitioner have partial custody of the children during the hours that Respondent is working during the weeks that he has custody of the children. ~tj~ 71J. !JktJ.bALlJ Ichole M. Walters Certified Legal Intern 1?oM~ M~ mOMAS M. PLACE ROBERT E. RAINS KATHERINE C. PEARSON Supervising Attorney DONALD MARRlTZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 240-5204 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa.C.S. 14904, relating to unsworn falsification to authorities, I verify that the statements made in the foregoing Petition are true and correct, to the best of my knowledge, information and belief. ~1ltJla.h0l,y-JttJtrl n)\...../ Deborah L. Gordon Dated: June dlLJ ,1998 '>;'. ...,. I , - - -. ~r',,, ... ,. - ",' .... -",...- ~i:-_",:_J" f.i.ilJj".; "Mr"'_ ~d' ~ . . . " . .' ";0-"-' -" ',.,7-:". ,. ',':: n'M'~'''''<'::'',,,, Y"""('~"-_"~.-:--W"'~~__:_:"-w::""~"",,.,",~o,.,,_;~..,..,;::!C'~r~"'_~-r~',,,_"'.,,_~,J-,,,,,... FAMILY LAW CLINIC The Dickinson School of Law The PeMSylvania Slate Univel1lity The Dale F, Shughart Community Law Center 45 North Pill Street Carlisle, PA 17013-2899 #,.:'-:-"'''-..." ,...,..','l....I.J." C' '~) "F':', .J' '-~---.-. .___.__'~ C"j.r-O.1,.,-,,~ ':' , . .;) ...1 o":,.;'.'! ,l.- ~'\>)~' ~".-:--,; n I"' ..! I" I-I' /. Y-lj':" I;. .' ~.:. ." ..... .,. I~ J -~;/.:.~ :!; Ul-if.:c;-, :';~,:.~~!l ~~l MR DANIEL DEARMENT IRWIN MCKNIGHT AND HUGHES 60 WEST POMFRET STREET CARLISLE PA 17013 SCO'IT C. ROMBERGER, PlaintiffJRespondent @JUN 291998 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. . . : CIVIL ACTION - LAW : CUSTODY DEBORAH L. GORDON, DefendantIPetitioner . . : NO. 94-1984 CIVIL TERM ORDER AND NOW, this _ day of June, 1998, upon presentation and consideration of the attached, verified Petition for Special Relief, it is ordered that the parties appear for a hearing on the issue stated in the Petition on the _ day of , 1998, at _o'clock _.M. in Courtroom No. of the Cumberland County Courthouse, Carlisle, Pa. BY THE COURT scorr C. ROMBERGER, PlaU1tiffnR~ndent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. . . : CIVIL AcrION - LAW : CUSTODY n l<' n ~ -~ :J.> .n - ~ . ; t.::: ~J f.: , lJj .'.-- 1'-> ...;..., 'y (. q; , . .. ;,.., .' .. :r.. ."1 , -'1 . ( !;:., , "-:: ',?n .' ~ ..; '.. -., :'j (,l ~ -. ..... DEBORAH L. GORDON, Defendant/Petitioner : NO. 94-1984 CIVIL TERM PKrrnON FOR SPECIAL RELIEF PURSUANT TO RULE 1915.13 Petitioner, Deborah L. Gordon, by and through her attorneys, The Family Law Clinic, petitions this court for special relief pursuant to Pa,R,C.P. 1915.13, and alleges the following: I. The parties are the natural parents of Scott Cody Romberger, born 11/0/89 and Corynne Victoria Romberger, born 2/19/88. 2. Pursuant to an Order of this court, dated August 2, 1994, case number 94-1984, the parties have custody on alternating weeks, that is, the children reside one week with Respondent and the next week with the Petitioner. 3. As of June, 1998, Petitioner has been at home through the day and can care for the children during that time. 4. During the weeks that Respondent has custody, the minor children are in the care of a baby sitter from 6:00 am until approximately 3:30 pm, Monday through Friday. 5. Respondent does not concur in this Petition. 6. It would be in the best interest of the children if Petitioner were to have partial custody of the children during the hours that Respondent is working. WHEREFORE, Petitioner respectfully requests the Court to grant this Petition and direct .' f!rj~E~;:h ~?,u,-",.~..,..;I'I " that Petitioner have partial custody of the children during the hours that Respondent is working during the weeks that he has custody of the children. 7/MlwU 7/1. 1,(}all1AlIl N'ichole M. Walters ~u~~ THOMAS M. PLACE ROBERT E. RAINS KATHERINE C. PEARSON Supervising Attorney DONALD MARRlTZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 240-5204 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa.C.S. 04904, relating to unsworn falsification to authorities, I verify that the statements made in the foregoing Petition are true and correct, to the best of my knowledge, information and belief. :i) r h D-'I oj y')J ,\J-/ ()..... rl 0)1...../ Deborah L. Gordon . Dated: June dto ,1998 .,..-____"'.....,.....,...______.:-~.---~~.a_e'~_"\."':".,...........~~$<~~""'...,~~,."""""_~ .1.4".~-,....-,..j,'~~ ,~I JIt-Ut:alll,.uM'~I....-'.... - .' " " FAMILY LAW CUNIC 46 Norlh Pitt Stroo, Corll.lo, PA 17013 "'~,~".~..t<4<~....;/......~--~......,....'--~'~,..-~ . "---- , , " I, .', ~ . ' . I' ~~::~ t I , , C ",;.1 [\ ,;' -- .' . ~-' ~..-~- r' ~' '"\ , . " "') ", " . '.;' ,?coil :~., , ! " , "/ :' " 1: ~ HAIIOLD a. IIIWIN, III, EaQUllIE ATTOIINEY ID NO. ZIIZO 3IUaT HIGH aTIIEET CAIILlaLE PA 17013 (717) zaolDlO ATTOIINEY 'Oil PETITION Ell SCOTT C. ROMBERGER, PlalntlH : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW v. . . DEBORAH L. ROMBERGER, aka DEBORAH L. GORDON, Defendant : NO. 94. 1914 CIVIL TERM . . : CUSTODY ORDER OF COURT NOW, this 5" day of August, 1998, on petition of the plaintiff and on motion of Harold S, Irwin, III, Esquire, a rule is hereby issued upon the defendant, Deborah L. Romberger, to show cause why a continuance in this matter should not be granted in order for a child custody psychological evaluation to be performed prior to any hearing hereon, Rule returnable If) days after service upon defendant's attorney of record, Nichole Walters, Family Law Clinic, 46 North Pitt Street, Carlisle, PA 17013. Pending the hearing in this matter and further Order of this Court, the custody order of August 2, 1994, shall remain in effect. By the Court, / " i , , , , ." / J, v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW SCOTT C. ROMBERGER, PI.lntlH . . DEBORAH L. ROMBERGER, aka DEBORAH L. GORDON, Defendant : NO. 94.1914 CIVIL TERM . . : CUSTODY PETITION FOR RULE TO SHOW CAUSE NOW comes the plaintiff, by his attorney, Harold S, Irwin, III, Esquire, and presents this petition for a rule to show cause, representing as follows: 1, On agreement of the parties, the Court entered an order dated August 2, 1994, providing for joint custody of the parties minor children, 2, On April 15, 1998, plaintiff filed a petition for modification of the current custody order, seeking primary physical custody of the children, 3, A conciliation conference was held on June 26, 1998 during which the parties were.unable to settle this matter. However, during the conference, defendant's counsel maintained that plaintiffs counsel, Daniel DeArment, Esquire, of the law firm of Irwin, McKnight & Hughes, had a conflict of interest in that his firm previously represented the defendant's present husband, 4. On or about July 6, 1998, the Court entered an order setting August 27, 1998 as the date for a hearing regarding the requested modification of custody, >- <:) E ~ c "-. flf? ..:r ':I o~~ ~j '"'" :c U:.? 2..: Q.. "" C\;:1 Zo II') ,',,, >- n.: '~Q} 0, , ff!tl. ~ .-r-~ :.t1LJJ "i'.o :;, ,no.. "'" "',; 15 ('Q "'- en d 5. Plaintiff was unable to immediately secure alternate counsel, but did obtain his file from Attorney DeArment and retain counsel on or about July 28, 1998. 6. Plaintiff desires to have a child custody evaluation performed to aid the parties and the Court in making an appropriate decision in this matter and plaintiff is prepared to pay the costs thereof, 7. Plaintiff's counsel has discussed this matter with defendant's counsel, who indicated that she had previously discussed this with defendant but that defendant was unable to pay any of the costs of such an evaluation though did not object to one being performed at that lime, 8, Defendant's counsel suggested two psychologists for such an evaluation and plaintiff is in agreement with using either of these two professionals, has contacted both offices for an estimate of the costs involved and is prepared to pay such costs in full. 9, The parties require a continuance of the hearing set for August 27, 1998, in order to give them adequate time for the evaluations to be performed, 10. Defendant will suffer no harm or prejudice as the result of a continuance as the present order in effect since August, 1994 will remain in effect during the period of the continuance and custody evaluation, 11. Defendant's counsel has been unable to contact defendant for specific permission to agree to a continuance for this purpose and owing to the time constraints involved, plaintiff seeks a rule to show cause why such a continuance should not be granted, returnable in as timely a manner as the Court may deem sufficient. WHEREFORE, defendant requests that the Court grant a continuance in this case, set a new date and time for a hearing in this matter and continue the existing temporary protective order in full force and effect in the meantime, August 4, 1998 35 East High Street Carlisle, PA 17013 (717) 243.6090 VERIFICATION Counsel for plaintiff is executing this verification due to the time constraints involved, but does have personal knowledge of the facts averred in this petition or they are a matter of record. I verify that the statements in the above petition are 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. Section 4904 relating to unsworn falsification to authorities, August 4, 1998 SCOTl' C. ROMBERGER, Plalntiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : CUSTODY DEBORAH L. GORDON, DefendantJPetitioner : NO. 94-1984 CIVIL TERM CERTIFICATE OF SERVICE I, Nichole M. Walters, Certified Legal Intern, certify that I sent a true and correct copy of Defendant's Petition to Modify Custody Order by placing the same in the U.S. mail, first class, postage prepaid, addressed to Plaintifrs counsel, Harold S. Irwin, m, Esq., at Hinter House, Suites 201 and 202, 35 East High Street, Carlisle, PA 17013, on August 6, 1998. 'iil;/r;,,{( 11/ (rj'li'fr,1L1) Ni hole M. Walters Certified Legal Intern Dated: August 6, 1998 c-' i c:: \S ~ 'i~~t~. rf. ft-L 'bf,: ~~c..\., t'i:'iE '6 ,',: <-, !S.c': t.1 f:; '.J ...._ 7 (.)~.: ".c() ..-1..)-;::. .'.~ ".:-ttlJ \Oc-- ..,;; ;.:; U ..0 , (.!l a c:> '" HAIIOLD a. IIIWIN, III, EaQUllIE ATTOIINEY ID NO. ZIIZO 31uaT HIGH aTIIEET CAIILlaLE PA 1701:1 (717) zaolDlO ATTOIINEY '011 PLAINTIFF v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA : CIVIL ACTION. LAW SCOTT C. ROMBERGER, PI.lntlH DEBORAH L. ROMBERGER, aka DEBORAH L. GORDON, Defendant : NO. 94.19114 CIVIL TERM : CUSTODY PRAECIPE TO THE PROTHONOTARY: Please withdraw the appearance of Daniel W, DeArment, Esquire, and enter the appearance of Harold S, Irwin, III, Esquire for the plaintiff in the above malter, August 1;1998 c~ ~~(~ ;;(!:A~~;T . HAROLD S. IRWI ,III August .s-: 1998 ~ \D i;. 0 ,.. I-' .. 5< w9 ~ 8~ ~(1 a.. ,'.jE ,~::. gf ",.....;;J 0 ;1'([) '.1". J7- L~ ,;..-; o:lL ,Ci (jJ f-: ::;. ~B c.. .u 15 00 ::> 0" U , .. · Sco\-\c. ~~r-5e\ Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, : PENNSYLVANIA v. · bd::c"on L . GorCe0 Defendant : CIVIL ACTION LAW :' No.IQ8L\ CIVIL 19'1L\ : CUSTODY VISITATION ORDER OF COURT And now, this 81 \DI'1.8., upon considerotion of the attached co that the above parties and their re ective counsel appear before Esquire, the conciliator, at . '. e.., Pennsylvania, on the rl. day of , 1998, at q ,DO j\, .I P.M" 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 be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: By: ~)X '/..AA,~. Custody Conciliator (T.t).) YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 r:L' F~^\-t".::;t"\c -.,'" ....", IV 0: ""c' c,'~' '-" ::'T'J]'{ . , . .. '.'.. .I," ~ r'.. ",' .' g""c:, .\L t:'-',' r" ~ I,: ~ : l ' , t 98 Wr, 1;: Pi! 2: ?? ..~ , } CU\,,~:,;, I" .. ", iT HU:-::"'l. ~lj"'J ~.'.)J":l Y I':-J'J":~VI '!",' , " ... i,..J I L~' '.\!\ -(/:J 48' dd _ ~ pI<- -t; V(;.::-f ~~ 11.;1 -fir 'n~ M~. Z 4 6k.41A- ~./,) .ff' ~ "dd,~,/ ~ -If xifup -fA . " AUG 7 19~af:' ,- . . .. SCO'IT C. ROMBERGER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . v. : CIVIL ACTION . LAW : CUSTODY DEBORAH L. GORDON, DefendantIPetitioner : NO. 94-1984 CIVIL TERM ORDER AND NOW, this day of ,1998, upon consideration of the attached petition it is ordered that Defendant's Petition for Modification shall be heard at the same time as Plaintifrs Petition for Modification. By The Court J. , SCO'IT C. ROMBERGER, Plaintiff/Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : CUSTODY DEBORAH L, GORDON, Defendant/Petitioner . . : NO. 94-1984 CIVIL TERM DEFENDANT'S PETITION FOR MODIFICATION OF CUSTODY ORDER Deborah L, Gordon, by her attorneys, The Family Law Clinic, respectfully represenl:i that: 1. The Defendant, Petitioner herein, is Deborah L, Gordon, The Plaintiff, Respondent herein, is Scott C. Romberger. 2, On August 2, 1994, the Court entered a Custody Order in this case, a true and correct copy of which is attached and incorporated here by reference. 3. The Custody Order gave the parties shared legal and physical custody of their two minor children, Corynne Victoria Romberger, born February 19, 1988, and Scott Cody Romberger, born November 9, 1989. Under this Order the parties have alternating weeks of custody. 4. On April 13, 1998, Respondent filed a Petition For Modification of Custody Order asking the Court to award him primary physical custody. A custody conciliation was held on June 26, 1998 and a hearing is scheduled for August 27, 1998 at 9:30 a.m, with Judge Kevin A. Hess. 5. This Order of August 2, 1994 should be modified because there has been a substantial change in circumstances, to wit: a) Petitioner resigned from her job effective June I, 1998 and is now home through the day and able to take care of the children. b) Petitioner and her husband, Theodore Gordon III, have a minor child, Devon Gordon, born 10/1/95, with whom Cody and Corynne have a close and loving relationship. c) The interests of the children would be better served if the present Custody Order were . modified to give Petitioner primary physical custody of the children. WHEREFORE, the Petitioner, Deborah L. Gordon, respectfully requests that the existing Custody Order be modified to give her primary physical custody of the minor children, Respectfully Submitted, 11:idu. t.{c..lJ{, I Oae.tt.l aJ Nlchole M. Walters JEI~ Thomas M. Place Robert E. Rains Katherine C. Pearson SUPERVISING A TIORNEY Donald Mamtz STAPF ATIORNEY FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.~ 4904 relating to unsworn falsification to authorities. Date: .0 1'7 ~ lC)q"i ,-Or 6(L,~ {} h Y \t.-!o-v/. ex./ Deborah L. Gordon ' ~ ('I b ~5 c ..: & :.J<( I ) . ...' 6:; C ;c S'iC 0-. :.~. ()-.::s ~' 'D :'.::;; @" "0.\. I ., -~;~ _I ...~ c.c ~~, (.f) luiiJ F: -.:I i~:J.. :d u. c:c ::J 0 u' () HAIIGLD a. IIIWIN, III, EaQUIIIE ATTOIINEY ID NG. ZIIZO U uaT HIGH aTIIEIT CAIILlaLl PA 170n (717) ZO."" ATTOIINEY '011 PITITIONEII v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW SCOTT C. ROMBERGER, PlalntlH . . DEBORAH L. ROMBERGER, ak. DEBORAH L. GORDON, Defend.nt : NO. 94.1914 CIVIL TERM . . : CUSTODY ORDER OF COURT NOW, this I r' day of August, 1998, on petition of the plaintiff and on motion of Harold S, Irwin, III, Esquire, it appearing that both parties have agreed to continue the hearing scheduled for this matter on August 27, 1998, a general continuance in this matter is granted in order for a child custody psychological evaluation to be performed prior to any hearing hereon, Either party may request that the Court reschedule the hearing in this matter upon completion of the evaluation or sooner as the best interests of the children may require, Pending the hearing in this matter and further Order of this Court, the custody order of August 2, 1994, shall remain in effect. By the Court, v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW SCOTT C. ROMBERGER, PlalntlH DEBORAH L. ROMBERGER, aka DEBORAH L. GORDON, Defendant : NO. 94.19114 CIVIL TERM . . : CUSTODY PETITION CONTINUANCE NOW comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and presents this petition for a rule to show cause, representing as follows: 1, On August 5, 1998, this Court issued a rule upon defendant to show cause why the hearing in this matter scheduled for August 27, 19984 should not be continued pending a custody evaluation to be performed, 2, The parties' counsel have discussed this request and defendant's counsel indicated that provided the parties agreed on a psychologist and the scheduling of the first appointment, defendant had no objection to a continuance (See letter from Family Law Clinic, dated August 6, 1998, attached hereto as Exhibit "A"), 3, Since that time the parties have agreed to use the services of Dr, Arnold Shienvold and the first appointment has been scheduled for September 1, 1998. 4, On or about August 11, 1998, defendant's counsel advised plaintiff's counsel that based upon this arrangement, defendant has no objection to a continuance in order to complete this evaluation (See letter from Family Law Clinic, dated August 6, 1998, attached hereto as Exhibit "B"), WHEREFORE, defendant requests that the Court grant a general continuance in this case and continue the existing temporary protective order in full force and effect in the meantime, August 13, 1998 Harold S. Irwin, III Attorney for Plaintiff 35 East High Street Carlisle, PA 17013 (717) 243.6090 VERIFICATION Counsel for plaintiff is executing this verification due to the time constraints involved, but does have personal knowledge of the facts averred in this petition or they are a matter of record, I verify that the statements in the above petition are 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, Section 4904 relating to unsworn falsification to authorities, August 13, 1998 Harold S. Irwin, III Attorney for plaintiff CERTIFICATE OF SERVICE I, Harold S, Irwin, III, do hereby certify that I have this date served a copy of this petition upon plaintiff and defendant by personally delivering it to their offices as follows: Nichole M, Walters FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 August 13, 1998 Harold S. Irwin, II Attorney for plain' 35 East High Street Carlisle, PA 17013 (717) 243.6090 EXHIBIT "A" FAMILY LAW CLINIC A ..rvice 10 the communil)' by ltudcnll rrom Th. Di,kinaon School or Law 0(111. Pennsylvania Slal. Univcnily Th. 0.1. F. ShuaJwl Community Law C_ 45 Nollh Pitt Stroot Clllisl.. PA 17013.1899 (717) 143.2968 Fox: (717) 10.3639 August 6, 1998 Harold S. Irwin, III, Esq. Hinter House, Suites 201 and 202 35 East High street carlisle, PA 17013 RE: Romberger v. Gordon Dear Mr. Irwin: Enclosed and served upon you is a true and correct copy of Defendant's Petition for Modification of Custody Order. I spoke with Mrs. Gordon and she continuance of the hearing scheduled for opposed to the psychological evaluations. that a psychologist be chosen and the appointments be known by August 14, 1998. Please let me know if these conditions are agreeable to your client. is not opposed to a August 27 nor is she However, she has asked dates for the first sincerely, 71 ~1.f-'-<..'- )1 J . L.U~V'J...J Nichole M. Walters Certified Legal Intern Enclosures cc: Deborah Gordon PENNSrATE . The Dickinson School of Law An Equal Opponunily Univonily .--- -..- ... EXHIBIT --B" FAMILY LAW CLINIC A ....i.. \0 Ill. community by .lUdcnll (mn Th. Dicklnlon School o( Law o(Th. PeMlylvonl. SIeI. UnivenilY Tho DaIo F, ShuaJwl CoImIunlty Law C_ 45 Nolth Pin Str.., Carlisi.. PA 11013-1199 (117) 24].2968 F..: (717) 24],3639 August 11, 1998 Harold S. Irwin, III, Esq. Hinter House, suites 201 and 202 36 East High street carlisle, PA 17013 RE: Romberger v. Gordon Dear Mr. Irwin: Per your request, I am writing to confirm that Mrs. Gordon has no objections to a continuation in the above case. Mrs. Gordon has asked that I relay to her information about scheduling appointments with Dr. Shienvold. If you have any information about scheduling would you kindly relay that to me so I can pass it on to Mrs. Gordon. sincerely, 71:u/w<<."/I7, WaJ.tuAJ Nichole M. Walters certified Legal Intern PENN STATE .. The Dickinson School of Law An Eque1 Opporlunily Univenily - ,.,..., -, "','-;e'"' MAY 0 9 2000tl v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94-1984 CIVIL IN CUSTODY SCOTI' C, ROMBERGER, Plaintiff DEBORAH L, GORDON, Defendant COURT ORDER AND NOW, this r day of May, 2000, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes j urisdiction, BY THE COURT. (/) ?; Cl:J C Lr. ;:5: c;.: .:5..~ (', ~')~; UI..; Q(; :r:: :j~~;> -- H-'I C- -J;:::; r:': 6c >;;&j c. :::'5z LUCJ. "J.-2 ff!ll' :- ,11,u "'. c:: Hole. '"" :t: ~ii ~ <::I ::.> 0 u " AUG 9Z~ scon ROMBERGER, PlaintilT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY . PENNSYLVANIA v. : CIVIL ACTION-LA W : IN CUSTODY DEBORAH L. GORDON, Defendant : NO, 94-1984 CIVIL TERM AGREEMENT TO AMEND CUSTODY ORDER Defendant, Deborah L, Gordon ("Mother"), through her attorneys, the Family Law Clinic, and PlaintilT, Scott C, Romberger ("Father"), hereby stipulate to amend the prior custody Order in this matter of August 2, 1994, regarding Corynne Romberger, born February 19, 1988, and Scott Cody Romberger. born November 9. 1989, as follows: 1, Mother and Father shall have joint legal custody and joint physical custody of the children. 2, The children shall reside with and be in the care and control of Father one week and Mother the next week, and continuing thereafter on alternating weeks, with the two children to remain together and with the transfer of the children to lake place on Friday evenings at approximately 5:00 p,m. 3, In addition, Corynne Romberger shall have the option of residing with Mother for one extra weekend per month. 4. During the weeks that Father has the children and would employ the services ofa babysitter, Father shall take the children to Mother in lieu of a sitter, 5, The following holiday schedule shall take precedence over the arrangements listed above: a, For Thanksgiving Day, from year to year the children will choose with whom they wish to be with for Thanksgiving each year, F': l:n~~':F'''J: C,,,," ..' '.."" ..~;', '::-"::..,-AOY r' ,.. ,." --,I.,;, ;..Jl/Vl 00 Wr, III AH 10: I 0 CUiv:bci"lu'.:'.O COUNW PENNSYLVANIA ... ..........-....: .. t" b, For Christmas, the parties will altemate from year to year, in each case with one party assuming physical custody on Christmas Eve through Christmas day at noon, and the other party having physical custody from noon Christmas day through December 26 at 6:00 p,m, Father shall have physical custody on Christmas Eve through Christmas day at noon for 2000, c, For Halloween, the parties will alternate from year to year the designated Trick-or- Treat night scheduled in the Carlisle Borough. Father shall physical custody for Halloween, 2000. d. On Mothers Day and Father's Day. regardless of which parent would nonnally have physical custody of the children, the parent whose celebration is designated by the day in question shall assume physical custody of the children for the entire day. e, For Easter, the parties will alternate from year to year with Father having physical custody for Easter, 2000. f, For Memorial Day, the parties will alternate from year to year with Mother having physical custody for Memorial Day, 2000, g. For Independence Day (4'h of July), the parties will alternate from year to year with Father having physical custody for Independence Day, 2000, h. For Labor Day, the parties will alternate from year to year with Mother having physical custody for Labor Day, 2000. i. For New Year's Eve, the parties will alternate from year to year with Father having physical custody for New Year's Eve, 2000. 6. The above provisions may be modified by mutual consent of the parties. 7. Transportation of the children will be shared by both parties. The meeting time will be agreed upon by both parties, . , 8. The parties agree that this Stipulation and Order of Court shall replace and supersede any existing Custody Order between the parties. 9. The parties intend to be legally bound by this Stipulation and that it be made an Order of the court, , (Jsa1t. L.1t?1~~ _.. , / Scott Romberger 1.01 bn.Jt.n h 01 'f-/lHrl('JJ Deborah L. Gordon ~~~.~ 7P;Ji~ THOMAS M. PLACE ROBERT E. RAINS Supervising Attorney DO"" ~. '7 I ?-sa; FAMILY LAW CLINIC 4S N, Pitt. St. Carlisle, PA 17013 717 243-2968 ORDER AND NOW, this 1'1 ~ day of 4 'JI' ... I' , 2000, the foregoing Agreement is approved and entered as an Order of Court, AfL /1 ;L ./ J. t I ~ .~ 'l '} ~ ..:r ~ .:s .. 8~ ~9 - - 0 ::c: '*, ocr ~~ ~c; CO r' jU- I '..) c..:> l2: 0:" . 1.IW I!: ::;, '~. C.l. oct .,: U, 0 J 0 C> G , ,