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IN mE COURT OF CQt.MlN PLEAS OF
CUMBERLAND COUNTY, PF1mSYLVANIA
NO. 94-:n ~8 CIVIL TERM
MARK J. llARTRANPI' ,
Plaintiff
JUDY K. llARTRANPI' ,
Defendant
: CUSTODY
aJIlLAINT roR aJST<JOY
\. The plaintiff Is Mark J. lIartranft, residing at 4 West Dulles Drive,
Apt. 80, Camp 11111, Cumberland County, Pennsylvania 17011.
2. The defendant Is Judy K. lIartranft, residing at 2107 North Ben, Apt.
1817, Victoria, Texas 77901.
3. The plaint Iff seeks custody of the following chi Idren:
tiY!l
Present Address
IiJ!&
Allison Marie Shuff
4 West Dulles Drive, Apt. 80
Callp lIill, PA
7 years old
D.O.B. July 24, 1986
Zachary Allen lIartranft 4 West Dulles Drive, Apt. 80
Camp lIill, PA
3 years old
D.O.B. May 25, 1990
The chi Idren were both born out of wedlock.
The chi Idren arc presently in the custody of the plaintiff, who
resides st 4 West Dulles Drivc, Apt. 80, Camp lIill, CUmbcrland County,
Pcnnsylvania.
During the past five years the chi Idren have resided with the
following persons and at thc following addresscs:
tiY!l M!lnH!1! I!Il1Il
Plaintiff and his 4 West l)\Jllcs Urlve, Apt. 80 From October, 1993
girlfrlcnd, Stefanic Camp II I II, PA to the present
Allison
Plaint iff 4 West Dullca Urlve, APt. 80 From July 14, 1993
Camp IIi II, PA to October, 1993
Plaintiff and dcfcndant 4 West lJullcs Urlve. Apt. 8 From November, 1992
Camplllll,PA to July 14, 1993
HIIaIl
hklfollll
Ulrul
January 1991
to Novellber, 1992
November, 1990
to January, 1991
1988
to November, 1990
1'1 /llnl! rr IInd dufclltlllllt
221121i C:odllr Hun Ilrlvo
1~lIl1p lilli, I'A
22111k' ('crillI' RUII 111'1 vc
('lIl1plll II, I'A
1'IIIIntl H IInd tlcfcndllnt
llefcf't1l1nt, hcr I'nrcnt N,
Terry anti Undll ShuH,
her brothcr, l~lI'clI shurr,
anti her IIll1tcrN, I'nrol Hhlln
IInd Junlllfer shurf
Wilt ur St l'I'ut
Now ('umbc I' Inntl, I'A
Tho nxlthor ollhu chllrlrclI III Judy K. lIartranft, currently residing at 2107
North 11011, Apt. 11117, Vil'tollll, TCXIIN.
She Is IIIIrrlllll.
The fllther of thu chllrlrclI IN MIIrk J. lIartranft, currently residing at 4
West Dulles Ilrlvo, Apt. 110, ('limp lilli, Cumberland County, Pennsylvania.
lie IN 11II1'1'10.1.
4. Thu rcllltlllllHhlpof tho plnlntlff to the children Is that of father.
Thllpl/lllltiff cUHently reNltlulI with thu following persons:
HMlI
RIlJJ,UPllllbiP.
AI I IlIotl Mllrle Shurr
Zactl/lry Allun 1111 I' t ranft
IItoflllllll All I NOll
his daughtur
his son
his girlfriend
~, Thu rellll IllllHhlp of thc llufentlunt to the chi Itlren Is that of IDOther.
The pin lilt IH III unUW/lI'e of perllon the defendant currently resides with.
fl, The plnlnt IH hUll nol I'urt Iclpllted as a party or witness, or in
IInothor Cllllucl ty, In ot her II t1gutloll concerning the custody of the children in
this or IInother court.
7. The plnlnt I H hllll no Informnt ion of a custody proceeding concerning
the chi Itlrcn pcnding In II court of this Commonwealth.
.
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IIIARK J.
HARTRANFT,
Plaintiff
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IN THB COURT OF COHIION
PLBA8 OF CUIIBBRLAND
COUNTY, PENN8YLVANIA
NO. 94-2788 CIVIL 'fBRH
vs.
IJUDY K. HARTRANFT,
I Defendant
i
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II ... NOlI. "" /7 d" ,[ co5. . '99'. ,po, ""jot ,[ ".
'1lconciliator,s report, it appearing that the parties have agreed to the terms and
II provisions of this order which was dictated in their presence and approved by them and
'I their counsel, we hereby order as follows:
I
I
!
CU8TODY
1.
Legal custody of the minor children, Allison Harie Shuff, born July 24, 1986,
II and Zachary Allen Hartranft, born Hay 25, 1990, shall be shared by their mother, the
II Defendant, Judy K. lIartranft, and their father, the Plainlitt, Hark J. Hartranft.
Ii 2. Primary physical custody of the said minor children shall remain with the
I father.
I
i
3. The mother ohall have the following periods of temporary or partial custody of
both children:
A. Alternating weekends from Friday at 4:00 p.m. until Sunday at 8100
p.m., commencing on Friday, October 14, 1994.
D. Bvery week Honday through Friday from 8:15 a.m. until 4:00 p.m. 1:1
addition, while the father is attending school through March of 1995, she
shall have the children every Thursday from 8:1~ a.m. until 9130 p.m. When
the [ather's schooling has been concluded, the parties will agree upon
another time for the mother to return the children Thuroday.
C. The folloving holidays, on an alternating bauis, fro. 10100 a.m.
until 8:00 p.m.: Labor Day, Nev Year's Day, BasteI' Sunday, Hemorial Day, and
July 4th. The mother's first holiday vith the children will be New Year's
Day in 199~.
D. 10:00 a.m. until 3:00 p.m. every Thanksgiving Day. Notwithstanding
the other provisions of this order, the children shall be with the father all
I' other times on Thanksgiving Day.
E. In odd-numbered years, from 6:00 p.m. on Dece.ber 24 until 12 noon
on Dece.ber 25 (and the father shall have the children froll 12 noon on
December 25 until 12 noon on December 26). In even-numbered years, from noon
on December 25 until noon on December 26 (and the father ahall have the
children from 6:00 p,m. on December 24 until 12 noon on December 25). The
provisions of the Christmas holiday shall prevail over other provisions 01
this order.
F. From 10:00 a.m. until 8:00 p,m. every Hother's Day and on the
mother's birthday each year (June 16). In exchange. the lather will have the
children every Father's Day and on his birthday each year (August 27) from
10:00 a.m, until 8:00 p.m. 1'he provisions of this sub-paragraph will prevail
over the other proviaions of this order.
4. 1'he mother w1l1 be responsible to provide the transportation 101' the custody
exchangeD so long as she lives within one-hall mile 01 the lather's home, as the
parties currently live. In the event that the mother moves so that her residence is
more than one-hall m1le away lrom that ol the tather, the parties will agree upon the
method 01 transportation. II they cannot agree, we will schedule a briel hearing to
resolve that issue lor them,
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MARK J. HARTRANFT, I IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
vs. )
I NO. 94-27S8 CIVIL TERH
.JUDY K. HARTRANFT, )
Defendant ) CUSTODY
I;
ORDBR
AND NOW, this
day of
, 1994, upon receipt of the
.iconciliator's report, it appearin9 that the parties have agreed to the terms and
: provisions of this order which was dictated in their presence and approved by them and
their counsel, we hereby order as follows:
1. Legal custody of the minor children. Allison Harie Shuff, born JUly 24, 1986,
land Zachary Allen Hartranft, born May 25, 1990, shall be shared by their mother, the
'Defendant, JUdy K. Hartranft, and their father, the Plaintiff, Hark J. Hartranft.
2. Primary physical custody of the said minor children shall remain with the
father.
3. The mother shall have the following periods of temporary 01' partial custody of
'both children:
A. Alternating weekends from Friday at 4:00 p.m. until Sunday at 8:00
p.m., commencing on Friday, October 14, 1994.
B. Every week Honday through Friday from 8:15 a.m. until 4:00 p.m. In
addition, while the father is attending school through March of 1995, she
shall have the children every Thursday from 8:15 a.m. until 9:30 p.m. When
the father's schooling has heen concluded, the parties will agree upon
another time for the mother to return the children Thursday.
ji
C. The following holidays, on an alternating basis, from 10:00 a.m.
until 8:00 p.m.: Labor Day, New Year's Day, Easter Sunday, Hemorial Day, and
July 4th. The mother's Brst holiday with the children will be New Year's
Day in 1995.
D. 10:00 a.m. until 3:00 p.m. every Thanksgiving Day. Notwithstanding
the other provisions of this order. the children shall be with the father all
other times on Thanksgiving Day.
E. In odd-numbered years. from 6:00 p.m. on December 24 until 12 noon
on December 25 (and the father shall have the children from 12 noon on
December 25 until 12 noon on December 26). In even-numbered years, from noon
on December 25 until noon on December 26 (and the father shall have the
children from 6:00 p.m. on December 24 until 12 noon on December 251. The
provisions of the Christmas holiday shall prevail over other provisions of
this order.
f. from 10:00 a.m. until S:OO p.m. every Hother's Day and on the
mother's birthday each year (June 16). In exchange, the father will have the
children every father's Day and on his birthday each year {August 271 from
10:00 a.m. until 8:00 p.m. The provisions of this sUb-paragraph will prevail
over the other provisions of this order.
4. The mother will be responsible to provide the transportation for the custody
exchanges so long as she lives within one-half mile o( the (ather's home, as the
parties currently live. In the event that the mother moves GO that her residence is
more than one-half mile away from that of the father. the parties will agree upon the
method of transportation. If they cannot agree, we will schedule a brief hearing to
resolve that issue for them.
2
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the following address: 810 Erford Road, Camp Hill, Pennsylvania,
Cumberland County, 17011.
6. Since said conference, Respondent/Defendant has moved in
with her boyfriend named "Dave."
7. Petitioner/Plaintiff seeks to amend the custody order and
seeks custody of said children on all weekends, Thursday evenings
at 8:00 p.m., and during the school week so that he can take said
children to and from school.
8. The best interest and permanent welfare of said minor
children will be served by granting the relief requested because:
a) Respondent/Defendant fails to pick up said children
on most of her alternating weekends visits and fails to contact
Petitioner/Plaintiff in connection thereto, in violation of the
custody Order;
b) When Respondent/Defendant does pick up said children
for an alternating weekend visit, she does not spend time with said
children, but has Allison stay with her grandmother and has Zachary
stay with "Dave," which upsets said children;
c) Respondent/Defendant works every weekend, although
she assured all parties at said Conciliation Conference that she
would not work on alternating weekends;
d) Respondent/Defendant refuses to transport said
children back to Petitioner/Plaintiff's care Sunday evenings after
her alternating weekend visitation is over, in violation of the
- 2 -
custody Order I
e) Petitioner/Plaintiff is now done with schooling and
would like to alter the time of custody on Thursday evenings
pursuant to the Court Order;
f) In the mornings during the week,
Respondent/Defendant fails to consistently pick up said children
and take Allison to school, and fails to notify
Petitioner/Plaintiff of same, in violation of the Custody Order;
g) Respondent/Defendant consistently keeps the clothing
Petitioner/Plaintiff has dressed said children for the day in at
her residence and sends said children back to the residence of
Petitioner/Plaintiff in different clothes;
h) At times, Respondent/Defendant sends said children
back to the residence of Petitioner/Plaintiff without all of their
clothing on:
i) Respondent/Defendant swears and uses profanity in
front of the children, which upsets them;
j) Respondent/Defendant smokes in front of said
children, which upsets them;
k) Respondent/Defendant retains in her possession,
without notifying Petitioner/Plaintiff, who has primary custody of
said children, important school papers.
WHEREFORE, Petitioner/Plaintiff requests this Honorable Court
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MARK J. IlARTRANFT, I IN THB COURT OF COMMON
Plaintiff PLBAS OF CUMSBRLAND
) COUNTY. PENNSYLVANIA
vs. )
) NO. 94-27S8 CIVIL TERM
JUDY K. IlARTRANFT, I
Detendant ) CUSTODY
JUDGB PRBVIOUSLY ASSIGNBD: The Ilonorable George B. Ilotter
CONCILIATOR CONFERENCB SmtIAIlY REPORT
IN ACCORDANCB WITIl CUMBBRLAND COUNTY RULB OF CIVIL PROCBDURB 1915.3-8Ibl. the
i
i undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the children who are the SUbject of this
litigation is as follows:
NAME
Allison Marie Shuff
Zachary Allen Ilartranft
8IRTIlDATB
24 July 1986
25 May 1990
CURRBNTLY IN
CUSTODY OF
Plaintiff/Father
Plaintiff/Father
2. A Conciliation Conference was held on 18 April 1995 and the following
individuals were present: the Plaintiff and his attorney, Madelaine 8aturin. Esquire:
, the Defendant and her attorney, David P. Perkins, Esquire.
3. Items resolved by agreement: None
4. Issues yet to be resolved: An adjustment in the schedule to accoMmodate the
. mother's working on weekends.
5. The PlaintiU's position on custody is as follows: The father wants the order
changed so that the mother will not have the children on the weekends when she works.
6. The Defendanl's position on cuslody is as follows: The molher's weekend work
'schedule has changed and she nOli 1I0rks Friday and Saturday evenings. She 1I0uld like to
MARK J. HARTRANFT, I I" THB COURT OF COMMON
Plaintiff PLBAS OF CUMBBRLAND
) COUNTY, PBNNSYLVANIA
vs. )
) NO. 94-27SS CIVIL TBRM
JUDY K. HARTRANFT, )
Defendant ) CUSTODY
ORDBIl OF COURT
AND NOW this
day of
, 1995, a hearing is hereby scheduled in
the above matter to be held in Court Room No.
of the Cumberland County Court House
in Carlisle, Pennsylvania, commencing at
o'clock _.m., on
the
day of
, 1995.
Counsel for each of the parties is directed to file with the Court and serve upon
opposing counsel, at least twenty (20) days prior to the date of the hearing, a list of
witnesses they intend to call at the hearing, which list shall include the name,
address, daytime and home phone number of the witness, and a general summary of the
nature of the witness's testimony.
By the Court,
J.
Madelaine Baturin, Bsquire
Attorney for Plaintiff
David P. Perkins, Bsquire
Attorney for Defendant
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HARK .1. HARTRANFT, I TN T1fR COURT OF COMMON PJ.HAS OF
Plllintiff I ClIHRRRJ.ANO COUNTY, PRNNSYJ.YANTA
.
.
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NO. q4-;!7RR CTVTJ. TRRH
.roOY K. HARTRANFT, :
Oefendllnt CUR'J'OOY
ORORR OF COURT
AND NOW,
thi. " ~.v of ''"'.,
1995, it i8 hereby Ordered
that the Hearinq scheduled for 1:30 p.m. on .Tune 7, 1995, in
connection with the above-captioned matter be qenerally continued.
J.
cc: David P. Perkins, Hsquire
(Attorney for Defendant)
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OF 11 1': /':10TUO;\I(JTAQY
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CUMI3U;U\4U COUNTY
PENI\'$fl.\iWA
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JUDY K. IIARTRANFT.
PclitioncrlDcrcndont
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v.
No. 94-2788 CIVIL TERM
MARK J.IIARTRANFT.
RcspondcnllPlointifT
Custody
PETITION TO MOIUIIV ClJSTOJ)V OIlIum
I. Thc Plointill' is Judy K. Ilurtrnnll, nuturnlmothcr. rcsiding ut 810 Erlilrd Rood, Comp
llill, Cumbcrland County. Pcnnsylvunio.
2. Thc Dcfcndont is Murk J. 1I0rtrnnll, nuturnlluthcr, rcsiding ul 4 Dullcs Drive,
Apartmcnt 80, Comp lIill, Cumbcrlund County, Pcnnsylvonia,
3, PlointilTsccks custody ofthc lilllowing childrcn:
Namc
Prcscnt Addrcss
Age
Allison Muric Shull'
4 Dullcs Drivc, Apt. 80, Cump llill, I' A 170 II
9
Zochury Allcnllurtranll
4 Dullcs Drivc, ApI. 80. Cump 1Ii1I,PA 17011
5
Thc childrcn wcrc born out ofwcdlock,
Thc childrcn urc prcscntly inlhc rcsidcntiul custody of thc nuturnlluthcr who rcsides ut4
Dullcs Drivc. ApI. 80, Cump lIill, PA 17011. Pcnnsylvoniu,
During thc pust fivc (5) ycurs, lhc childrcn havc rcsided with the following persons ond ot
thc lilllowing uddresscs:
I. NAME AlmRESS J)ATE
Murk J, Ilurtrnnll und 4 Dullcs Drivc, ApI. 80 Approximotcly July
Stcphunic Allison Complllll. PA 1701 I 1994 - prcsent
Murk J, 1I0I1fllnll und 4 Dullcs Drivc. Apt. 80 Octobcr 1992 to Moy
Judy K, Ilurtl'Unll Comp lIi11,PA 17011 1994
Murk J, Ilurtrnnll ond Orchurd Pork Apartmcnts 1989 to Scptcmbcr
Judy K. Ilurtfllnl\ Comp 1111I, PA 17011 1992
MARK, \.\IF.liilE ANI. Ilrl~I(INS Al1UUNlVS AT lAW I.W "A51 .<INn SlU[[T -- 5IUf!PENSlluRn, "^. 11251
MARK J. HARTRANfT, ) IN THE COURT Of COMMON
Plaintiff ) PLEAS Of CUMBERLAND
) COUNTY, PENNSYLVANIA
vs. )
) NO. 94-2188 CIVIL TERM
JUDY K. HARTRANFT, )
Defenclant ) CUSTODY
~
Nfl) NOW, thIs
:tJ..
17 day of
Llo;.T-
, 1994, upon receipt of the
conciliator's report, it appearing that the parties have agreed to the terms and
provisions of this order which was dictated in their presence and approved by them and
their counsel, we hereby order as follows:
1. Legal custody of the minor children, Allison Marie Shuff,/born JUly 24. 1966.
and Zachary Allen Hartranft. born Hay 25, 1990. shall bo shared by their mother. the
Defendant, Judy K. Hartranft, and their father, the Plaintiff, Hark J. Hartranft.
2. Primary physical custody of the saicl minor children sball remain with the
father.
3. The mother shall have the following periOdS of temporary or partial custody 0
botb children:
A. Alternating weekends from Priday at 4:00 p.m. until Sunday at 8:00
p,m., commencing on friday. October 14, 1994.
G Every week Monday through Friday tram 8:15 a,m. until 4:00 p.m. In
uddition, while the [ather is attendiog school through Harch of 1995, she
shall have the children every Thursday from 6:15 a.m. until 9:30 p.m. When
the [atber's schoolinq bas been concluded. the part1es will agroe upon
another timo for the mother to return the children Thursday.
1
C, The follovinq holidays. on an altcrnating basis, from 10:00 a.m,
until 8:00 p.m,: Labor Day, Nev Ycar's Day, Easter Sunday, Hemorial Day, and
July 4th. The mother's first holiday with the children viII be New Yoar's
Day in 199~.
~ 10:00 a.m. un~il 3:00 p,m. ev~ry ThanksgivinQ Day, Notvithstandinq
the other provisions at lhis order. the children shall be wilh the tather all
ol~,r times on Thanksgiving Day.
~~ In odd~numhered years. from 6:00 p.m. on December 24 until 12 noon
on ~her 25 (and the tather shall have the children from 12 noon on
December 2~ until 12 noon on December 261. In eyen-numbered years, from noon
on December 25 until noon on December 26 (and the tather shall/baye the
children from 6:00 p.m. on December 24 until 12 noon on Dece~er 25). The
provisions of the Cbristmas boliday shall prevail over other provisions of
thin order.
P. From 10:00 a,m. until 8:00 p.m. eyery Hotber's Day and on tbe
mother's birthday each year (June 16). In exchange. the tather vill have the
children every Pather's Day and on his birthday eacb year (August 21) fro.
10:00 a.m. until 8:00 p.m. The proviSions at this sub-paragraph will prevail
over tbe othcr provisions of this order.
4, The mother will be responsible to pr~vide the transportation for the custody
exchanges so loag as sbe lives within one-half mile of the father's bomo. aa tbe
parties currently live, In the eyelll that the mother moves so that her ruidence is
more than one~half mile avay from tbat ot tbe tather. the parties will agree upon the
method of transportation. If they cannol agree, we vill schedule a brief bearing lo
resolve tbat issue tor them,
~
5. Each party shall have the partier. tor two consecutive weeks each SUmmer for
vacation purposes (including no more than two consecutive weekends). on the condition
that each party will provide the other at least thirty ()O) days advance notice, in
writing, o( the vacation period they Gulect,
6. NeHller P4l'ty will move out of the Commonwealth ot Pennsylvania and take the
;children with them without the other party's written permission or without further
order of this Court.
7. Each party will notify the other promptly it the children require medical care
or attention while in that party's care and shall promptly notify the other party at
any medical treatment the child receives,
8. The parties realize that their children's well being is paramount to any
,differences they ~ay have between themselves. AccordinglY, they agree that neither
party will do anything which may estrange tile children trom the other parent or injure
the opinion at the children regardinQ tbe other parent or whiCh may hamper tbe free,
natural, and healthy development of the children's love or respect for the other
I
,
parent.
By the Court,
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J.
Legal SerVices, Inc.
Attorney tor Plaintiff
JUdy K. Hartranft, pro S8
Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND, PENNSYLVANIA
JUDY K. HARTRANFT,
Respondent crvr L ACTION - CUSTODY
'''"
v. NO. 94-2788 Civil Term
MARK J, HARTRANFT,
Petitioner
ORDER OF COURT
AND NOW, this 99,ltl day of ,~V~\flh . 1'l96,
upon consideration of the attached Complaint, it is hereby
directed that the parties and their respective counsel shall
appear before --1l,di(iI f t"II'1 t'''1 , the Conciliator,
at ~" l-'lH Ct> h (( / ~,q \ If.-'.)( on
the ~ day of ~ "I ,1996 at i.lI ."'11 .m., for a
Pre-Hearing Custody con1e ence, At such con~erence, 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 Ord~r. All children age
five or older l11ay also be present at the Conference. Failure to
appear at the Conference may provide grounds for entry of a
temporary or permanent Order,
FOR THE COURT,
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The Court of Common Pleas of Cumberland County is required by law
to comply with the Americans with Disabilities 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 l11ust attend the scheduled conference or
hearing,
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.
LAWYER REFERRAL SERVICE
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
717-240-6200
I nlloflu 'O""~I' IIU'!<''''-fll,J/'' ut ""I
5. Pursuant to the Order of Court dated October 17, 1994,
Mother shall have partial physical custody on alternating
weekends from Friday at 4:00 p.m, until Sunday at 8:00 p.m. and
Monday through Friday from 8:15 a.m. until 4:00 p.m.
6. Mother has failed to exercise this partial physical
custody for several months.
7. In addition, pursuant to the Order of Court dated
October 17, 1994, Mother has partial physical custody every
Thursday from 8:15 a,m, until 9:30 p.m. while Father attends
school. Father has completed his school and the parties have
been unable to agree upon another time for the Mother to return
the children on Thursdays.
8. On Thursday, March 7, 1996, Mother picked the children
up from school and failed to return them to Father at 9:30 p.m.
The Father picked the children up at the babysitters on Friday,
March 8, 1996.
9, On Thursday, March 14, 1996, Mother picked the children
up from school and failed to return them to Father at 9:30 p.m.
The Father picked the children up at the babysitters on Friday,
March 15, 1996.
10. On Thursday, March 21, 1996, Mother picked the children
up from school and failed to return them to Father at 9:30 p.m.
11. Mother failed to deliver the children to school today,
March 22, 1996, and Father is unaware of their whereabouts.
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12. Mother is without jUBtifJclltion or legal excuse for
failing to abide the Order of Court, dated October 17, 1994.
13, Father believes that Mother's pattern of contemptuous
behavior will continue, unless or until the Custody Order dated
October 17, 1994, is modified to give Father sole physical
custody,
14. The Father believes it's in the best interest of the
minor children to modify the Custody Order dated, October 17,
1994, vesting sole physical custody of the parties' minor
children with Father.
15, The Father has, due to the Mother's willful contempt of
the Court Order dated October 17, 1994, incurred and will
continue to incur legal fees to enforce his right.
16. As of April 12, 1996, Father will be moving his
residence from Camp Hill to Quail Drive in Carlisle, Cumberland
County, Pennsylvania,
17. This move is in the minor childrens' best interest as
it will provide the children with a larger home where each child
will have their own separate bedroom.
t' 'lJIlll1MIl'I''lI'~)'f1.u:lll-\M''Ni'Jtlr11
VERIFICATION
I VERIFV that the statements set forth in the attached
document are true and correct to the best of my knowledge,
information and belief. I understand that false statements
herein are made subject to the penalities of 10 Pa. section 4904
relating to unsworn falsification to authorities.
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JUDY K. HARTRANFT, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I
I
V I NO. 94-2788 CIVIL TERM
I
MARK J. HARTRANFT, I CIVIL ACTION - CUSTODY
Defendant I
COURT ORDER
AND NOW, this ~ day of _\\\(1' \
conaideration of the attached Custody Cbnciliation
ordered and directed as follows:
, 1996, upon
Report, it is
1. This Court's prior Order of October 17, 1994, is vacated.
2. The Mother, Judy K. Hartranft, and the Father, Mark J.
Hartranft, shall enjoy shared legal custody of Allison Marie Shuff,
born July 24, 1986, and Zachary Allen Hartranft, born May 25, 1990.
3. The Father shall enjoy primary physical custody of the minor
children.
4. The Mother shall enjoy temporary physical custody of the minor
children as follows:
A. On two out of every three weekends from Friday evening at
5:30 P.M. until Sunday evening at 8100 P.M. Mother shall
provide transportation for pick up and delivery of the
children on weekende.
B. On Thursday evenings from 4:00 P.M. until 8:30 P.M. during
the school year and from 8:00 A.M. until 8:30 P.M. in the
Sununer monthe. During the next few months, until the children
are out of echool, Father shall transport the children to
Mother's on Thursday afternoon, and Mother shall return the
children to Father on Thursday evening. Once the Sununer
schedule starts, Mother shall pick up the children at Father' s
on Thursday morning and again return the children on Thursday
night.
C. At such other times as agreed upon by the parties.
5. This Order is entered pursuant to an agreement reached by the
parties at a Custody Conciliation Conference. In the event either
party desires to modify the Order, that party may Petition the
Court to have the case again scheduled with the Custody
Conciliator.
JUDY K. HARTRANFT, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUHBERLANDCOUNTY, PENNSYLVANIA I
I
v I NO. 94-2788 CIVIL TERM
I
MARK J. HARTRANFT, I CIVIL ACTION - CUSTODY
Defendant I
PRIOR JUDGEI The Honorable George E. Hoffer
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
19l5.J-8(b), the undersigned Custody Conciliator submits the
following report I
1. The pertinent information pertaining to the children who are
the subject of this litigation is as follows I
Allison Marie Shuff, born July 24, 1986, and Zachary Allen
Hartranft, born May 25, 1990.
2. A Conciliation Conference was held on April 18, 1996, with the
following individuals in attendance:
The Father, Mark J. Hartranft, with hie counsel, William C.
Vohs, Esquire, and the Mother, Judy K. Hartranft, with her
counsel David P. Perkins, Esquire.
J. The parties agree to the entry of an Order in the form as
attached.
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A, Approximately a week ago, the minor child, Allison, attempted to commit suicide after
yet another fight with FATHER's paramour. The Incident occurred at FATHER's home late In the
evening hours, The Incident went unnoticed by FATHER, and It was not until Allison reportad for
school the next morning that school officials rushed her to the hospital. Immediately upon learning of
the Incident, MOTHER arrived at the hospital and Allison has been In her care ever since, MOTHER
notified FATHER Immediately after arriving at the hospital, however FATHER elected not to come to
the hospital to check on Alilson.
B. After the above Incident, FATHER agreed to transfer primary custody of tho chlldron
to MOTHER, however has refused to sign anything In writing for fear that his rlghlto collect child
support from MOTHER would be waived,
C. Since the above Incident, both children have been In the primary custody of
MOTHER.
D, MOTHER cannot enroll the children In school In her district unlll FATHER agrees In
writing to a transfer In primary custody. Therefore, the children have not been In school for
approximately one (1) week,
E. In addition to the events described above, MOTHER conllnues to have serious
concerns regarding the supervision of the children while at FATHER's home. FATHER has on
numerous occasions left the parties' 13 year old daughter, Allison, In charge of baby-sitting her
younger brother, Zachary, as well as FATHER's two other children with his current paramour (ages 1
and 2) which responsibility far exceeds Allison's capabilities,
F, FATHER continues to exercise poor judgment with respect to the approprlata care of
the children. Approximately two (2) weeks ago, while In FATHER's custody, the minor child,
Zachary, telephoned MOTHER to say that he was scared and home sick from school, however no
one was there to care for him, Zachary did not know where FATHER was, nor did he know where
FATHER's paramour was, nor was he left any emergency contact numbers,
AUG 2 4 199~)
v
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
NO. 94-2788 CIVIL
IN CUSTODY
JUDY K. HARTI~NFT,
Plaintiff
MARIU. HARTRANFT,
Defendant
~OU81' OltDEl!
AND NOW, this .:J.t; day of August, 1999, upon consideration of the attached Custody
Conclliatlon Rcport, it Is ordered Wld directed ns follows:
I. 11115 court's prior order of May 9, 1996 is vacated.
2. The Mothcr, Judy K. lIartranfi, and thc Father, Mark J. Ilwonfi, shall enjoy shared
legal custody of Allison Marie Shun~ born July 24, 1986 WId Zochor)' Allen
HartrWlfi, born Moy 25, 1990.
3. 111e Father shall enjoy primory physicol custody of the minor children.
4. 111e Mother shall enjoy periods oftempornry physicol custody of the minor chihlren
ns follows:
A. On two out of three weekends from Friday at opprmdmolely 5:00
p.m. until Sundoy evening 01 approximately 7:00 p.m.
B.
During the summer months, the parties shall oHemote cuslody on a
weekly bnsis on 0 schedule os oITWlged between the porties. Fur Ihe
remainder of the summer of 1999, Mother sholl hove custody of the
minor children from Monday, August 16d. through Monday, August
231d at 6:00 p,m. 01 which time she will retunl the children 10 the
Father for the childrcn to stort school on August 25th.
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The parties shall alternate holidnys to Include 1.1Ibor Day, New Yenr's Doy, Easter,
Memorial Day and July 4th. '\1le Mother sholl hovc I.obor Day of 1999 with Ihe
parties alternating thercat\er. :ow ,
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111e parties shallllltemnte custody on '\1ulIlkslllvinllunder two time framcs, the llrst
time fnune beinll from Wednesday afiemoon 01 3:00 p.m. unlil '\1ll1rsdoy nt 3:00
p.m. Wld the second time fmmc beinll from Thursday at 3:00 p.m. until Friday at
6:00 p.m. 111e Father shall hove the llrslllme period in 1999 for 11mnksllivlnll.
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99nrc-z PH ~ln6
CL7.ilji:I./JV\O COUNTY
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
JUDY K. HARTRANFT,
Plaintiff,
NO. 94-2788 CIVIL
v.
CIVIL ACTION - LAW
MARK J. HARTRANFT,
Defendant.
CUSTODY
COURT ORDER
AND NOW, this 11\... day of =:i) Jr~ '
Stipulation of the parties, it is ordered and di~ected
1999, upon
as follows:
1. This court's prior order of August 25, 1999 is vacated.
2. The Mother, Judy K. Hartranft, and the Father, Mark
Hartranft, shall enjoy shared legal custody of AlIi
Marie Shuff, born July 24, 1986 and Zachary A
Hartranft, born May 25, 1990.
3. The Mother shall enjoy primary physical custody of the
minor children.
4. The Father shall enjoy periods of partial physical
custody of the minor children as follows:
A.
Every other weekend from Friday at
5:00 o'clock p.m. until sunday
approximately 7:00 o'clock p.m.
B. During the summer months, the parties shall
alternate custody on a weekly basis on a schedule
as arranged between the partip.s.
approximately
evening at
5. The parties shall alternate holidays to include Labor
Day, New Year's Day, Easter, Memorial Day and July 4th.
The Father shall have Labor Day of 2000 with the parties
alternating thereafter.
6. The palties shall alternate custody on Thanksgiving under
two time h-ames, the fit-st time frame being from
Wednesday afternoon at 3:00 o'clock p.m. until Thursday
at 3:00 o'clock p.m. and the s8cond time frame being from
Thursday at 3:00 o'clock p.m. until Friday at 6:00
o'clock p.m. The Mother shall have the first time period
in 1999 for Thanksgiving.
7. The parties shall alternate the Christmas holiday under
two time frames, the first being from December 24th at
Labor Day, New Year's Day, Easter, Memorial Day and
July 4th. The Father shall have Labor Day of 2000
with the parties alternating thereafter.
D. The parties shall alternate custody on Thanksgiving
under two time frames, the first time frame being
from Wednesday afternoon at 3:00 o'clock p.m. until
Thursday at 3:00 o'clock p.m. and the second time
frame being from Thursday at 3: 00 0' clock p. m.
until Friday at 6:00 o'clock p.m. The Mother shall
have the first time period in 1999 for
Thanksgiving.
E. The parties shall alternate the Christmas holiday
under two time frames, the first being from
December 24th at 6:00 o'clock p.m. until Christmas
Day at 2:00 o'clock p.m. and the second time frame
being from Christmas Day at 2:00 o'clock p.m. until
December 26th at 6:00 o'clock p.m. The Mother
shall enjoy the first time frame for Christmas in
1999.
F. The Mother shall always have custody of the minor
children on Mother's Day and the Father shall
always have custody of the minor children on
Father's Day. The time frame shall be from 9: 00
o'clock a.m. until 5:00 o'clock p.m.
G. For exchange of custody, transportation shall be
handled with the parties selecting a point
equidistant between their two homes at which they
shall arrange a meeting for exchange of custody.
5. The parties agree and stipulate that this Stipulation may
be entered as a Court Order and shall have the full force and
effect of a Court Order whe:her or not entered as such, and in any
event shall be incorporated into the original Custody Order and
made a part thereof.
IN WITNESS WHEREOF,
the parties hereto execute this
Stipulation with the intent that it be legally binding upon
themselves on the date first above written.
. . I'
IN 'I'IIB COURT OF COMMON PI,BAS OF CUMBERLAND COUN'l'Y, PENNSYLVANIA
JUDY K. HARTRANFT, NO. 94-2788 CIVIL
Plaintiff,
v. CIVIL ACTION - LAW
MARK J. HARTRANFT,
Defendant. CUSTODY
CONSENT '1'0 ENTRY OF COURT ORDER
I, MARK J. HARTRANFT, do hereby consent to the entry of a
Court
Order adopting the
1;111" (lq
terms and conditions of the stipulation
dated
i cJ-0L\ctV
MA~K J. HARTRANFT