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Home My WebLink About94-03537 Ore /3 t rll'H '9~ ',h} ~: , Dc'';' ,j ~ :091 , I} \.,,1 It Jt. ANGELA GORDON, 1 IN THE COURT OF COMMON PLEAS OF plaintiff I 1 CUMBERLAND COUNTY, PENNSYLVANIA V. I 1 NO. 94-3537 CIVIL TERM THEODORE P. GORDON, III, 1 Defendant I CUSTODY ORDER OF COURT AND NOW this 3rd day ot October, 1994, the hearinq loh.duled for October 24, 1994 at 1130 p.m. i. continued until ~ t:;'J..I'L...J.'tV /4_, 1994 at I';)O~ .m. to afford tilDe for the psychological evaluation ot the defendant to be completed. By the CDurt J.SI ~et. c. ~ Harold E. Sh.ely, 1'..'1. If"." ,'~ _.. '. ,.. .,. 't. I, " I ,: i\ '." tJ' '.i' ~.I, ,,_~.. I h'lt ..I" .. l"t . t _ _ - _ IIIL'.... ',' :.,'''.I\l,'':~' lI':.rn:'.i, ,1"~!fJ loiM ~," n~ ...". " . .. . .".., llC .", '.oi"'r. AI '..ll'lIfM. fl. " .,i -,;t'. II .".1, 'l~, .,3.IJC,.~.I,' ,;.M..,h IU,lt- ~J.;~.'L_Jl~JtY~ --..- ' ;.:: pri i'rothllllO ,'. v.. I IN TilE COURT OF COMMON PLEAS OF I I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. V4~)B)7 CIVIL TERM I I CUSTODY I I ANGELA GORDON, plaintiff TIIEODORE P. OOROON, II I, Defendant ORDER AND NOW, '2tll l)4o~CI thil ~ day of lepta.lIer, lllU, upon ot the within Petition, the tollowin9 Order i. conlidaration entered I 1. The detendant, Theodore P. Oordon, eha11 .ubmit to a peychological evaluation to be compl.ted bet ore hearin9 ot the cu.tody ca../ the evaluation ahall addre.. the i..ue. rai.ed in the within Petition and any oth.r is.uee which may b. rel.vant to the d.t.ndant'. ability to have un.upervi.ed visitation with the child. 2. Legal servicee .ha1l arrange tor Bruce Kelly, MA, a licen.ed pachologiat, to perform an evaluation to be compl.t.d as aoon as poaaibl.. The dsfendant ahal1 contact Bruce K.lly, 37 S. Hanover street, Carli.l., 258-1706, to .chedul. the .valuation. 3. The defendant ahal1 incur the expense. involved in the evaluation. 4. A writt.n report of the .valuator .ha11 be .ubmitted to oppo.ing oounael and the Court. !5o Th. defendant .hal1 oonunt to allow the evaluator access to all reports and information relating to any of his therapy, family coun.eling, parenting 01...../ or medical hiBtory, and the detendant Ihall r.l.... the evaluator to .end a ANGELA GORDON, I IN TilE COURT OF COMMON PLEAS OF plaintiff I I CUMBERLAND COUNTY, PENNSYLVANIA I VI. I NO. 114-3537 CIVIL TERM I TIIEODORE P. GORDON, UI, I CUSTODY Detendant I I fJTITION FOR PSYCHOLOGICAL EVALUATION The plaintiff, ANGELA GORDON, by and through her attorn'Y, Joan carey, of Legal Servicee, Inc. .tatee the following I 1. The plaintiff, hereinafter referred to ae the mother, il an adult individual currently re.iding at 30 stephen Road, Camp Hill, cumberland county, Penneylvania. 2. The defendant, hereinafter referred to al the fathar, ia an adult individual currently raaiding at 321 Weet Shady Lane, Enola, PennayIvania. 3. The mother and father are the parenta of chri.topher Michael Gordon born september 11, 11180. 4. On June 2B, 11194, the plaintiff filed a petition tor Protection from Abuae tor heraelf and on behalf of her minor child which included a count for cu.tody of the Child, and a Proteotive Order and Temporary Cuatody Order were entered on July 8, 1994. 5. The Temporary Cuatody Ordlr \Java the mother primary phy.ical ouatody and the tather auperviaed viaitation. See attached Exhibit A incorporated by reterance. 6. A CU.tOdY conciliation Conference w.. held on Auguat 34, 1994, to reaolve the matter ot ouatody. 7. The parties were not able to agree to a custody schedule; therefore, on september 7, 1994, a conciliation Conference summary Report was issued and a hearing was scheduled for october 24, 1994, at 1:30 p.m. Bee attached Exhibit B incorporated by reference. 8. The plaintiff requests that the Court order the defendant to submit to a psychological evaluation prior to the hearing for reasons including the following: I a. Immediately prior to the parties separation on or about June 24, 1994, the defendant punched the child in the mouth, knocking out a loose tooth, causing the child to bleed and suffer pain. The defendant on another occasion around this time, kicked the child in the face, causing pain and bruising about the child's cheek. b. During the child's toddler stages and into the present, the defendant has abused the child in ways including but not limited to the following: kiCking, slapping, pulling hair, throwing the child across the room, and punching the child about the face and body, causing bruises and lacerations. c. The father also force fed the child when he did not eat or did not eat as quickly as the father wished; he shoved food into the child's mouth, holding the child's nose shut and covering the child's mouth, often causing the child to choke and vomit. On one occasion, the father mads the child eat ths vomit. d. When the child was not paying attention, or got an answer wronq on his homswork, the tather snapped the child in the head above the ear with hi. tingers, cauling the child pain and tear. e. The tather taught the chUd to hate Atrican Americane, physically challlngsd peopll, and oVlrweight people. t. When greeting the child, the tather hit the child in the chest and back with enough torce to cause the child to cry out in pain. When the child cried, the tather yelled at him to shut up or to grow up. II. In the opinion ot Samuel Amlls, the Custody conciliator, this cue "cries out tor either psychiatric or psychological evaluation." The conciliator turther stated thet there should be a thorough examination ot the tather and his relationship with the child. See conciliation Conterence Report, paragraph 6 ot Exhibit 8 attached. 10. The mother has concerns regarding the tather's stability based on hi. erratic behavior including hi. actions at the conciliation conterence on August 24, 111114, when he behaved in a threateninq manner including using obscene language with the LegAl Service. statt, becoming enraged and leaving the conterence room during the attempts at nlgotiating the ca.e, and lunging at the Le~sl Service. .tatt in an attempt to d..troy exhibits reSUlting in the conciliator and his statt having to intervene aaying they would call the polies it the tather's behavior continued. 11. Tlls rather adm! ttsd that he nseds parenting .ki 11. and counseling regarding his patience with his child. See exhibit B paragraph 7. 12. since the tather is seeking visitation, he should incur the expensss ot the psychological evaluations/ the mother is represented by Legal Services, Inc. and does not have the tunds to pay tor the evaluation. WHEREFORE, the plaintitt requssts this Court to require a psychological evaluation ot the detendant, before a hearing regarding cuetody. The plaintiff requests that this Court continue the matter until the psychological evaluation is complete. The plaintiff also requssts that this Court impose the costs of the evaluation on the detendant. The plaintiff seeks any othsr relief which is just and proper. Respectfully submitted, 0ic' ( / / :\- .,.J (, t..:-r...- /' ,oan Carey /, Attorney tor plaintiff LEGAL SERVICES, INC. a Irvine Row carlisle, PA 17013 (717) 243-9400 . ANDELA DO ROaN , Plaint Ifr for herself Ind on behalf of her minor chlldl CIIRISTOI'HER MICIIAEL GORDON Va, THEODORE p, GORDON, III, Defendant TE~PORARY <...r. AND NOW. this ...l.L- day of r I IN TilE COURT Of COMMON PLEAS OF I I CUMBERLAND COUNTY, PENNSYLVANIA I J NO 94-J5J7 CIVIL T~RM I PROTECTION FROM ABUSE I AND CUSTODY I I I I CUSTODY ORDEII JUly, 11194, upon conlld.ratlon or the part In' Consent Allrellment, thl followlnll CUltody Order II Intlred with relard to custody of the part III' child, CHRISTOPHER MICHAEL DORDON, I. The plaintiff. hereinafter referred to el the mother, will have primary phYllcal and IIII1 cUltody or the child. 2. The defendant, hereinafter rlferrld to al thl rather. wi II hive supervlllld vii I tat Ion wi th thl chi Id at t 10111 and places to be alreed upon by the partill. Includlnl the YWCA tn ea r II s Ie. J, Neither party shal I do anythlnll which may 'Itranle the chi Id froOl thlt olher parllnt. or Injure thl optnlon of the child as 10 the other parent or which may hamplr the frel .nd natural dll'elopment of th" chilli', lovl or roepect for the uth.r parent. 4. The mlltter [If cu.tOlI)" shill I hi Ichedul.d fur ft cuncl J lilt Ion conferonce. I\nd th. hmllOrary CUllolly Order rImllnw IOWlun A ( ANGELA GORDON, ) IN THB COURT OF COMMON Pldntitt ) PLHAs OF CUMBERLAND 'I ) COUNTY, PENNSYLVANIA VI. l I NO. 94-3537 CIVIL TElH 1'11180DOR8 P. GORDON, III, ) Defendant ) CUSTODY "JUDGE PREVIOUSLY ASSIGNBDI The Honorable Harold B. Sheely I !I II OONCILIA'I'OI COHPRllRUI"R SUItIIAIlY DIIPnD.. I- .1 IN ACCORDANCE WITH CUMBERLAND COUNTY RULD OF CIVIL PIOCBDURE 1915.3-8(bl, the :, ., 'Iundersigned CUstody Conciliator submits the tollowinv reportl , 1. The pertinent information concerninv the child who is the subject of this ,litivation il as folloWl1 II IfW BIRTlfPATIl 11 September 19S5 CUlREN'J'Ly IN CUSTODY Or Plaintiff/Kother Christopher Hichael Gordon 2. A Conciliation Conference wss held on 24 Auvust 1994 and the tollowinv individuals were present I the Plsintift and her cOUDsel, Leval Servicel, Inc.; the Detendant appeared without counsel. 3. Items resolved by avreementl The tather avrees that the lather should retain pr1mary phys1cal custody at the child. 4. Issues yet to be resolvedl Status of leval custody and the tather's tile with the child. 5. Need tor separate counsel to represent ch11dl Not yet. It may be appropriate at a later d.te to appoint separate counsel tor the child, dependinv upon what evidence there is to support the mother's accusst10n about the father's physical abuse ot the child. At this point, however, I do not believe separate cOUDlel for the child is necessary, [XI/111fT II Ii /1 /, I' 6. N.ed tor lnd.p.ad.at Plycbolovlall 'VI1UltlDft or aoua..lla;1 Tbl1 all. arl.. out tor .1tb.r p.yabl.trlo or p.yabolovlc.l ,vIlultloD. Th. IOth.r'. 'ccu.ltlon. about th. t.tb.r Ir. .xtr.... If .v.a 10M. of th.. Ire tru., th.re .bould b. . lborouvb .xa.laatlon ot the f.th.r .ad hl1 relatlon.hlp vlth the cbl1d. 7. Otber .att.rl .ad OOll.ntll Th.re v.e · t..por.ry order .nt.red In July of 1". In r'.poDI' to lb. IOth.r'l p.tition tor prot.ction troa Ibule. Th.r. blv. b.ea dltflculti.. la Irrlnvinv the lup.rvll.d vl.lt.tion .It.bli.b.d by th.t ord.r lbd lb. t.th.t b.. ouly ...a lb. child , a t.v ti..1 durinv th. IOnth. of July aad AUvu.t. H. 1. obviou.ly dl.tr....d by that I '1llnd und.retaadably v.nt. to ..t.bll.b .0.. .cb.dul. th.t viII viv. bim ti.. vlth th. I chUd .0 th.t b. c.a vhit vith th. chUd .nd t.ke the cbUd to ... bh ,otber, vho llvlI vith hi.. ;' Ibe latber cl.I'e thet th. tlth.r be. pbYlicelly ebu.'d the cblld. lb. 0111.. 'I 'that b. bl. tore. ted lb. child, c,u.lnv hi, to cboke, lb.t b. b.. r.p..t.dly punched 11th. cbild In tb. cb..t and b,ck .nd .n.pped th. cbild on lb. b..d vith hil tlnv.rl. " I 'lb. 01.1.. to blv. vltn..... lad photovr.phl to aonflrm tho.. cl.I... 8b. .1.0 01. 1m. , lb.t tb. t.tber b.. t'uvbt lb. child to b.t. v.riouI ainority vroup., Ip.cifia.lly lacludiav bl.ck. .nd hlndlcapp.d P.opl.. Th. t.th.t d.nl.. .11 ot thll. It lbee. .CCUlltioD. .re tru., tb. court .bould be very c.utioul In .llovlng the t.tber to be .10De vith the chIld. It th.y .re not tru., ot cour.., the MOther'l conduct il open tor ....In.tlon. I the t.UIIII VII very 'vH.ted It the contenhcD and bad cUtticully a.k1nv IIh ;Polltion clelr. It do.. Ipp..r thet h. hi. be.n dOlnv 10m. coun..lihV vith Guld.nce I ., Auocl.tu In C"p lUll. FrOM the v,y be dllcrlbed H. tbl coun.'lIng appeared to b. d.,luned 10 Improve bl. .,Il-conlrol Ind his Pltonl!nu skill,. 2 .' r , 'I I. Ii I' " . .. !! I Th. partiel GOuld not avre. on a lohedule for thl father to have the ohildren !beyond vhlt V.I e.tablilhed UDder the ordlr Intered tn July. A heering viii bl nlolll.ry to deterline the .ocur.oy ot the IOther'l .oculltionl Igllnlt thl flther, Obvloully it thole IOOulltionl Ire trul, thl court vll1 hive to talhlon .ny ordlr Olfltully, I hive Ittlched In order lohedullng I helring, 2!1 Augult IllV4 &: croQ .a L. ADd.. CUltody Conoiliator I I, Ii .. . Ii I' , /I '1 I. .. ) Chent. Gordon, Theodore (l ad) Dllto 01 llirth' 6I8J84 Dalo 01 Evaluation. 817,8/6,619, 1995 Age. 31 yews, 2 months ~ Tod IS currently 58eklng unsupervised vlshaUon 01 his 6 Yllr old IQn, Chrll(OOB 9/11/89). while the mother. Angola Gordon. prelers ilto remain supervlsod u I1lpulated under the Temporary Custody Order 01 7/6194, Ted sought unsupervised visltalion, and on _~0I3194 the court ordered him to undergo psychological evaluation to address Issues raised In the Pelllloo for Psychological Evaluation, presented by mother's counsel. as well as any olher issues which may be rolevanl 10 Tl.l(j's ability 10 have unsupervised vlsltalion With the child Issues raised In Ihat Pelitlon Included numerous allegellons 01 VIOlence by Ted toward the mother and Ihelt son. as well as a claim Ihlltthelathertaughllhe child 10 hate AIIICan Amellcans, physically challenged people, and overweighl people II appears a relorral lor evaluation was lurthor prompted by a display 01 aggravated behaVior by Ted at the conciliation conlorence. Ted was otlglnally directed to undergo psychological evaluation lor a 12194 hearing but did not arrange lor thiS nor attended the heanng Ei.9~t months later. he arranged the prosentevalustlon ~ Ted and Angela met In Germany In t984 while he was In the milrtlllY, and Ihey married 2 years laler DUJlng her pregnancy With Chris, Tod recalls 'gelling scared' at Ihe prospect 01 being a lather. lhough Angela clalmslhal Ted then said that he did not want to be a lalher Sho recalls then starting to 'become aware 01 how Tod acls and reucts' She alleges Ihat whIle pregnant. ahe conlronledhlm_!!Qo.J/llU!! un1il!lbMntll !o which he rcsponded by slamming her uguiMithe /cllJuuralor. She allils Il1a\ she conlwnlod him on tho saine IS5uu one year latcr. WhlchJ)lompl,cd him 10 Iracture her ribs by thrOWing her li9!ln!i1fur.rlll\,J!.e, Angela purports that there was ongoing phYSIcal abuse 01 both he/sell and Chris until sheleh hnn in Juno. t994 Her all89atlons Include hltling, kicking. Slapping the child aboul the lace and body. llB well 88 DUlling hair WId thrOWing the child. Slnce he was 8 toddler Ted is 81so alleged to have lorce led tho ~'hild when ho did nol eat or did nol eat liS Quickly as wished. sometimes holding thll child's now !.Ilul llnd ~'Qvenng hiS mouth, ollen causing t1lm to choke Rnd vomit; on One occaBlon Ted rnude Chns oat Ihe vomit. Angela also a88el1S thai whon ChriS was nol paYing attenllon. or got an answer wrong on hill homework, Ihe lather would then snap him in Ihe head with his linger.. cauMQ pwn und teaF When grueling the child, the 'ulher hit him In the chest and back with enough lorce 10 cuuse hll1l to cry oul II) pain; when ho Cried, the lalher yellod at him Other Ihan these uJlegatlone found In the Petlllon, tho moltlcr claimed numerous otheF Incidentll at thiS evaluation, one recent incident being that red lolluwod hl!ll/l her car, 3fl(>roachod it when s1oJlpOd lor a train. olHlnlld Iho door and tulel Chile to UO wllh him now despite the mother'soblocllons 1 1(111 'J'j'.. I',: 1', III ,'.j., ,'illi, f'/\,:,[ iJ~' Ted denies all eJlfIOallona. .nd orlOlnlllly Maled Ih.1 he doos noll\flow Why Ihe mothef would claim them. though 1.1.,- said It "II II WI' h." ullempt 10 have CMa all 10 heraell Ted In81eM ruportalhallhoy had a "greal mlmlQe' tic Bald Ihalltletr retallonltllp was line up until Iho lalll day when llho Ie" without notICe. lhough did IHllhal thlllrnlly mllY have drittod apat1l1Ome whIch hll blamea on Angola', 'partyl/1\j'. golno out dancing, and Wlall to lvold lesponlllblhly SUptlrvl8~ VlllllllOn u.uln at Ihe YWCA lhough lOon oeased, .Ich blaming Ihe olher lor Ihls. It Wll9 llIsumed In HW" al It" Luthelan Church Ihough Ihll, 100, SlOpped wtthln 2 visits as Ihe lalher said ho could nOI aNotd II AnUlla nolOtl dlprewon in Chrl8 and look him 10 counl4lllng Sho observed him 10 have dllllcully adjusting 101 Ihll first 3 monlhs O"Of /lltparallon, but 10 have 51abilized In Iho lollowlng 3 months bolor. un~upervll;lId Vlllllalion beijlln AI the .Ime lime. Tod told Angela that he was 111110 1I11endlng oounlthng, Ihua, Ihl repollu hoping Ihat a change In Too would allow him to salely visil ChnG which could only help III ChIlI aOJLJ!lIrnent. Shu '''en allowed unsupervised vi$itatlOn to oocur every olher week fOI Ii monlhs whe/l ehll oguin halled II dUll to her Ob$ervllllon thaI Chri,' behavlol revolted 10 pre- IlOparaUon plobllm' IlIcludlng Iyfng, "10allng. 100Jng frtends, nol ObeYing. Bnd lalklng aggF86SIvcly. 1 ad 10011 ahe relnllltuted Ihe IIUptlIVISod vllltahon order due 10 his locent dlvorca filing Since 12194, Ted hl8 been liVing Wllh R nllw womu'l, and they are l)(pectlnU a ~y nelCt 1I10nlh, lourCM Df.ln',umattRn lW7/IM Inll1V1ftW of lalhor. I lid Gordon ~ hours. 4~ minutes I flSting 01 'lid (boon I hour. 4!l mlOutes Tilts admulillered 1 hematic Apperception T 881 (TAT), Rotter Incomplete Senllnoes Blank. PereonaJAy 5d'tem.lnvel1lory, IIart Mlnnaeota MU~lphQsic PorlOnallty Invonlory. 2 (MMPI'2) 8A/11\1:l Inle.Yiuw 01 motile'. Angela Gordon. 2 hoUls 8AAW5 TeAtlng 01 J ed Gordon 1 hour finished Ihe MMPI.2 O~ Int.~lw and pelt/a! t."Ing at 8011, Chlill Gordon lell rullonl of Chlldrun's Appltrception TlI8I(CAT), Oespert Fables. Childron's S."lel\c. Compllltlon. drawings UA:J9.9!'i InlllV1ftW 011 ad Gordon 1 haUl leltlnll of I ad Gordon 1 hOUf leelllldmlnllllere(l Mllllllng and hilllory forma QQII.leraf Inform.tion Courloll1., 01 10f3194 lor Paycholoulcal [valuatIOn. Petillon Por Psychological FvaJua1lOn. T ampal.ry CUlilody Order 01 718/94, Conahllor Conlorence Summary Report; PwlochvllMIII, alld Conlen, Agleemllll of 7~, PIllllon for PlolecllVI Order OI1d Cuslody, H800IlJ of m,Ii'IIY proclHKllrtgll, Guidance Aasoclale" Counle/lnll discharglaumrnalV 01 t/\)!llor led. tlu<<hlMCI AIf;()(JlulfJlI' Counwng dlllCl1arge ,ummary 014195101 Chll8 ObHfyatl.2nl...awLI.ttL1!llWJlJ 'ed 1Jt...ntld 0& a \lflrY cuuaJly olen4ld, 1I1rongty 1xJ11t. CIIJ()lI8111h m.le appearing his chronologlclll age UJlOn Inllllllly II!Ulltlng lod kllocklfd. IInnlt'dllllllly enlllred lite .Kamlner's ollice, 881 down and boglln lalklng wUltouIIlPI)()jnlrll\Jnl 01 Invltallon tioW8V81. ho WM congftl1lal and promplly left when IIll0rmlld Ihalll/lolhor .ppollllfllfJl11 w.. wail/nil H. WI8 1fl(IIJObllld 10 walt in thl! wallrng are8 101 llPpolOtmenls ItwlUQh fallltJ III (klth'i 101 11111 flll~f '" mooting., lInd lHICO showed up 1 b ,"lnullI al1o, leuVlng II monag. 011 Ihl IllloWlIIlnU mlchhl4l Illulllll was OOlllttlU 10 lalco an unlChedllloo loll Hlr; IifHlttCh w.. clear Ihough 011"11111I\1001'11 86 hll '81 0111h8 ftOyll 01 the IDOla lInd 11IIkoo In 10nU, olton rambling. monolOlJuos Ihal IVQUtt.u IHillllttlCI H1tnr~""tloll which occ/I,lon.lly cau8e.J rlllll II 1I111r i11101 I or WUIIl unsuccessful In delefllll(J hllll IIlull YlII Itll arlf16UllllJ 10 want 10 bo holplullo Ihe QUU'"0nl lill altemp10d 10 anllWel nil QU/lblkll1!( IhollUh !I(l(llllntly required promplll1fj 10 bIllY on 'OplC; Wl1tllllhf~ f))(/Iflllner f1tllllllllll!d to rp.ad .1/ 'I ,.\, the allegatlonallUalllst him 10 oblllln hlalHdback, he bocamllllnpohenl Rnd intoll\lpled, ungnly ..ying 'hal hi could not explain some\hl/lg thaI did not hopPlln. Yet he rllmllJned gonlrally OOOpllfaUve and uongerllal throughoul thl ovaJuallon 1-10 put lorth u gOOd llIfor1 011 IllI lollllnu llOd Ihl loIloWlng rUI01I6 are bellovlJll 10 be a valldlndicnlor 01 his plfl!MI pertl)nallty functIOning rUIlIUnallty evaluation rllVeaJed "rength. 01 which Tod III OWITO ho pt~Mlu", M well M W~nftlMl 01 which he hl9ulllicully Melng T od I, outgoing IlI1d OflIlmlSlIC which IIklly 841rVII him will tIOOllllly 1-10 WOO appearl to hllVll e 81ncer. II1tOle61In lullllllf1lI kllentlOfll which are good ^ plOblem wi... In Ihlll he III unable to 880 how thell8 I/lIOlltlons may be Impeded by Iho realrty 01 hlG wellknDslOb and IUUlli Ihlll oonously anec1 hlaoctlons and relatiolllhlpa. For oxampla. Ted hilS a mar1lad lack ollnlllght into hlm88", and thus othera A p&lliOnaJ pilotlly 18 to maintain a SITOllg, pt)artlve. imlVJll 01 hlmliGlf which III donu In VlllY eXll\Xllfated IIllhluf1 Thill II an urgency to do this, os il 10 pSYChologically BYrVlVO, nnd raprelMtnlS a nNCllIIlsllc pel sonallty lItyIe I tl loelo he has no laults whateoDvlr. Ao he Illateo, 'I don', tecogntZo llny wllaknostws In my IJ(lf lilJ/lalrly 01 olllludu". AYOldlllK:e 01 problomnlic petllOnaJ IlI9Ueo Is doni at both U OOllllCIOU9 Illld eubcooKiousl.VII (Deeper. more OObconBCIOUS, avoidance IS especially noted III his Inlol/nahon plo<Je8lllng nIannet' HI doell l1ollnoorporale Inlorrl1fttlon Irom Ihe post or preMnl to lnereaae hi~ undllltarldlnu, l.th'l, he menially ,ulll8POIl8S ",IOImallon unlil t1 creatll8 B morlpellOllally ICC~ f.lic1urelll<l IhulI remlmbot6 '<It this WilY ThuI, he dolS nOl l\dequltely lesoss past problems to oorrect lor luIurll CIlCUllltlIancn yet I~ IiUIpneed when IOInelhlng eubMqultntty goes IIWlY IV1d OOIlectll lor lhis new, threall/1\flO InlOlmalioll by blaming others He then delend9 his procarious se".concopllut1her by ollOllng prool Ihlll his Intlllholll aFe good VIa superflclal, IdealiBlIC statements designed to demonstrate Ihlll his ultlmat, mlele$lls In 'others II othera pet"SIb1 In demanding he be oooountBble, then he leels vicllmlze<J Ted is largely, then, unable 10 undel1lland the COI'ISoeQU8I'ICOI of his actions This hae obvious impllcltlOllS 101 his ability to sustaIn po~UVll, clo.. Fclatlon&hlpa though he stated Ih.I he orlngl no laul18 Into relalionsl1lpe and Iha' none 01 hi. relationship 8llillll need oven sllghl implovolllent '(el, he doN hlvo great dlHlcultly achieving empathy a8 he Is rsther tell. abso rbed. H, wlllellPtCtIUy dailY awarlnl.. 01 another's distrOi$II he helped cause It ThMe problooHl we likely \0 manit8$l to hl8 relatlon!lhlp with hili ..'/.'\' eoll, especially 811 he is unable to recognize olheF'll netldll He WI\$ unable IUll)I..1OQnlZI thu net<le of hi. . !lOn III thIS ovaluatlOn, e.cep4 in 'erTT1& 01 hie own wants O1h8rwl80, hu ela'ed ('.hIi.'s neMll in the lIIl/11e vague, "l'Osy'-iiilnncidl1iirne lilieS to de5crll>ll hlmeell T !'d~s~..,lCIorl$liCS 01 impul8lvrty at1(l gei1:nOb!f:l!?\J'!IOBs make 1 datlQelQUe rombillllllOn L valuallOn ') Indicates thiil I1ijIS Impllleive In bolh action and .motlOn, imd leelalustijiOd in folloWing ttlQll, InlOf',ll"IIOI1 Irom other a al this point nre likely to be mill wt1h Indlgnltion. denSlOll, an<J pOseIbIy Fage For II-ample, lie was Indignant 01 Ihis evaluallon whon questioned al 10 why he did not notify Chns' molher Ihat hi WIO changing plcVIOU&ly Slated plans arxilaklllg 111m out 01 ~1ulelo thl beach, Instead. hi rOWlIIKJed lhlt he I would take Christo Colorado without notice r1 he Ie" like It 1 here Ippeor 10 be IrttJe II1tllbrlory pow".lhul -i'\ would keep hlmlrom placing Chris in nn Inappropriale, dOnQeroU8, or neglectlul 8itullioo Ted (1(lM nol underetand Ihal sometimes he may eruate sIlUatJonll or activities thllt ho gfJllulnely Ihlnks WIIli/ltlll'lI . child but more directly aatisly his own Interest, ospeclally all it may prOVide tHmlMJlf ploof Ihat he Is /I "lathlr1y'typo. 8(lln9 ImpulSIve, sellllbOOFbed, and narcl&.~stlc, he hilS dl"lcully recogll1l1nu lIegatlve omollon.lllmpact he nlay have on another, ovC!l II eenous. 'lvl\lllatlOn dOllS Indicate mllllY Illcluts Ihat Incroase lhllllllk that I cd will he dll1\lslOU& III . phYINq,' llllUlnfJI ImpulllVt1y IS II hlll)tl rlli< lac1or.QfWII n()l~ llIllIlI rnnnftUlt11l8l1t dfffl('~Y llnd mood IIWIrlU", hil could Feadlly movo In\o nn agliaied state ond Impul81Vllly vent it phyelcally The W{jllltlve ~1'lJ{;tUIU lIe already In placu 'MI would allow thIS to happen: he Wf.IIJId bl/lll\8 tho OItICl for Inciting Ute lIlelllen!, \llutOll whal happened 10 In hl8 needed self.lmage, and then lelll 88".lusII1IOO in Rny 01 III' 1l(.1klOS, ..ptlnlllly 0& he doos not ILocogntzo a need 10 IJe accountable His nIlld to 1II1\1ntnln an 8KIlOI.ltlfuted 1MI"~tlncor~ And 3 10 do all he pI....s 1.llrOI1Q lnough Ihll he might u.. Inythlng to malnlaln 1I11s .xpellenoe of hlmlMllf 1fl(,~Udlng violence ..s hlllllCkS In liUlflclenl IOhlbltory conlmls(empalhy, recogntzlng Ihe equality 01 01 hers' neods) 10 negate lhll polSlbllity Evaluallol1 a110 IIV8l11od Ihat 1 ell places an Ixcnsive empl\881s 011 malnlalnlng oonlrol 01 his envtronmenl and his amotion.. and lhl1lhrlllll to this ar. onen IIIlolernble. .. OIher Ihan Angela's 1Il1eg.l1on. II \0 Ted', history of \1olenoe. there pll. no documllOtallon to that end In a lOaner "IltoJ 10 vIolenc. pottnll." Ted had allegedly Injured hllT1M1110 alJOld milllalY duty on "VOIP] oooallOnl which hl! Ilally denlld II Ihls evaluallon. IIV"'9 IhBllhlS had OOl.:urrld with one 01 hl.lriunds only and Ihal he hlmeel1 hid nevur 0010810 Ihe att.nllon 011l1e mUlla/Y under such allogatlons HowlIVer, mllllary dor.umenlatlon produced sl ""1 ev.luallon outline. lh... very ..98l1lon8 against Ted, and was eigned by him. lhlS untrulh calls 1010 qu.51lon olller Ilallment. and allegltion dentale made allhls evaluatIOn lhi, denial wee dOl1o In tho lime PIlle," as denials 01 aUeglltions' he would Initially lIC1 vtcllrnlnld and eXPfe&l apparenl conhJllon II 10 why Angell would say such II thing, Ihen ramblo Inlo an explanlltlon, ollen lar.reachlng, lor wh'" aclually hupponed and how 11 mlQhl have been percoivod Olhll/'WllMl Similarly, Ihere WIle many incon&Jllonctee In Tecf. "elemenll flCfOn Inletvlew', u well as large 'holes' In hi. cllcplanlllOnl and 1lI01le, lhl. W811 not the CU$e with Angell 'I pPIanallon. which roherently IllIed in Ihe.. hol.. Alto, ehe evlden,*, no lendency to paychollcally dlstorl rflallly al Ihll uvi!ulllon, 1101 · need lor reveng', bolh ruuons thll mlghl caulIll her 10 lalsely creale the llllegaUonl 01 viol.nce stilled in "" Petlllon lor PllVcholog~ EVIluaUon lhe above pertonahty nnding. and oonelualon' are largely gleaned lrom inl"vtews and peychOloglClI 1"11, excep\lor Ine MMPI.;l lhe MMPI.2, an objecllv.11II 01 paftonallty baaed on eXlonslvCl rlll.arch, rellerllled Ihe above hndlngli The MMfJl.j/ yielded a clalllc profile 01 an IndlVlduallryinv 10 presenl hlm..Uln an ov.rty pcllllive Iil/ht and 10 glv, an lPPearance 01 contlol, lIdequacy and etIlCliven... It Indicate. Ihat he ov.rlvalulll,,! his own worth. utilizes r.prnstOn and denial excMSively, hu poor IOleranc.lor llreu and pllllwe, and ahowllrttle awareneaa 01 oonaequtll1Cea 10 other people 01 his own behaVIOr. It allo Indlcale8 Ihll he II ngtd. mt>raJliOC, and Intolerant Relallve to Ihe rMll'Tal queatlon 01",15 evalulllon, he Vl.ld&d r.oorell Ihll ar. 8Ugg8lllv. 01 per eon. who lend 10 reapond 10 provoclllon approprlll1lty molil ollhe Ume, bul who oc.callon.lly dlapl8Y ell8QOllflllod aggreMIve ruspo"~ wlthoul eppllool provocallOn VII, he Is denYing haltH. and aggr,,,lve Impul..., while lending 10 be QUlle Gtntlllvel.boul how olhel. raspeno 10 him .... may deecnbe himMlf illS comlortable and oonlldenlln IIOclal .~uatlont while hiVing I\IOI1Q opinions abOut mllny things 01 WhICh he Is nol reluctanl \0 delend VlOOroualy It allO IndlCales Ihel he may be overoontroll4ld and not approptlelely a8lMlltive moM 01 IheIilna, Ilul Ihat pMOdt 01 impvlaivl! ooUng oul may occur Tha MMPI.2 allO shed further IIghl on hll del.n..s 01 dlnl.1 by luggtttJOO an &leman! 01 nlllv..., In olhar word II, lnterpeloonlll and attitudinal dllflculU.. pi" but mlY nol be intolltiOnal or mAlIl:lou., rlllher. a lIerce oplmllm blinds him to these problems. II wal dlllievll 10 ontlln lelevarlt and peroonallty l"IorTTlallon 11"010 th'lIton, Chris, due 10 hiS Illl.08se1ve pefllVllalkm, ill olher word" he would malnlaln onl menlllll()(,'Va on 110\lIC. &uch Oil Michelli JlIlCkson, 10 weh a degr" thl1 hl! oould nol be aufhl'lenlty Shined Imm II oven l1IJrtng IlltJng II appealed he wanled to VlSiI hl"lllhar ber.SUII his Ilthet dool "lun IhingS' (;llnolUIIIDnl Iud IttlQflIDJMIldal'unl 01 tOIll/lfl, p,ycholl>\jIGnl flvahllllon cannot cxmllrm whl1hClf Inclde"le did or did not occur Il1lhe PISI; huw,vlr, the plOL&t11 IVllulllol1 '\JOUIIIS Ihet Ih. 1I111ig.tlone 01 paat vlol.nee may be 01 some ~UtJ"hllICIl \la.1d on psychologlcll 1,"'''''0111, Ihero Oxlll, a IlOIId blllBIOtlhe mother'. ooneernil 'eullllllng Ihe Illhll'.' "Iabllltv tuch 1& 01111110 behevlO' Reiher Ihan making predlcllonl 01 phYsical danOllfoullIl... IlI/YCholOgIC1I1 IVll'lIC1t1011 II moro helpful In useSllng whelher 01 not rllk laCloF. 01 4 dangerousnoss exlst Such risk IQC10rs .,elignlllcantly ptnenlln Ihe case ollhls clienl as d.tllled In the ISlh and 61h paragraphs ollhe 'Obaervallon and Reaults' aecllon Ollllls report, There Is also Iht likelihood Ihat Ted wHI push his rigid bellels and wlehes upon his son 10 Ihe poinl 01 IntimIdation Il8 ht a110 on.n has dllllculty ....lIIng Chris' ntedl. Psychological proWe allO augoe$1S Ihal he can allO be eKpeoIed 10 place Chns, and Chris wilh hla mother, In emotionally compromising siluatlons which would conluse their IOn. T_h!J~lJ.Ll~ggtlled Ihallh. mode 01 V1lltatlO!!.~roN!Q.J~l"corp()rale a large degree 01 ClullOn: it IS reoommondtd IhalaupeMMd vlsilal!9n oont!n.UUUh!".~_ nn_ - .n~_ To reduce the rilk lactors preMnt It Is lelt Ihe T&d will need 10 become more oware 01 hIS lnull and dynamic8, inclUding how he avoldslhose luuee He al~ could ben.tlit from I~lng 10 better manllge his Inger and, more lpeclllcally. his Impulsivity. HII IOn was diagnosed with Anenllon Dellcll DllOrdlf(AOD), and Ted allO eVIdences many Qualltl" of thai dleordet; Ihll would a180 ellp/aln his dlttiaJtIy Understanding Ihe Importanl aspecls 01 any situalKln 0' properly rtldlng hfl own behavior, Other ldentilYlng qualitl.1 ttllll he evidences InclUde Impulsivity, 8nger managemenl problems, 8Kceulve lalkllllvonoss Including rsolng tangenll.lity, Impatience, rellleune.., mental vilCOlI\y(lOme perseveratlvcmese llimllar 10 Chris'), and dlfflcu.ltlellln connecting oon.S8Quenc.es 1.0 hll actions, seeing GOClal convention, and Iracklng vi requests._AI_he_ellllrflased_dllt!tU"Jll'l~_'epugnll"c"'IlJ1jI..JQn'lI diagnosis, ills not expected thai hs 04/ would be able 10 submit hhns8l110 evaluation which requires Irank asseasmenl of Mil, but II would be 8llOughlf h. COUld Imp/ove aw.enell 01 per:lOnalrty IlIUtI and especially manage hlslmpul_vtty which Is one 01 Ihll dllOl'der's major symptoms A general, IntUll1ve Impte88loh of Tod 61Jslalned throughout this evaluation WI' one 01 an ADD adult who perhaps did not know how to covor lor his symptoms Ind thtlr elCtenuallng Impact us others do. To this end, Ted al:lO needs 10 become more awart 01 Chris' individual noed.; on. uptCl 01 ttlle Is IHI1\lng how Chris manlltlts his diagnosed ADD and thulllearnlng his special nHels. It is suggested Ihat Ted have a conference With the psychOlogist that UlItmd and diagnosed Chris In order that he can 19am In delallthe ramlllCallons and whalled 10 Ihls conclualon It does nol appear Ihat tht ADD dlag...,sls Is jU5l an elCCUII8 lor Ih8 mother'slulness lUI Tod bellavOl; II was apperent to thiS examiner within an hall hour Ihlt Chris doe. hive special needs at h, clearly eVIdenced symptoms 01 ADOnronlallobe syndrome through severe peraeVtratlOl1 and moderato d1strlctiblllty. .RJgw.Q!!~enllna, Ihl. dictates the need lor l!nusuII/y close llItenllon 10 guidllnce and $1ructur. whICh Wlllllke/y be precluded by Ted'lllIue.. ' --~----~-~--~... . --._---- -- -.- -. ._.._.._.~----_.---_._--_..-~--------_. lithe reader has any ques1lOns, please contact the Undtrligned. , tf:.~" !~ PA LlcenNd PsychologiSt 5 , assume oare and oonlrol 01 the minor child every-other weekend, and one day per week II he so desires, Thoy have been oxerclslng this agreement and abiding by It Irom January 7, 1995 through June 17, 1995, Petitioner has been picking up the minor child Friday evenings and assuming care and conlrol through lale Sunday afternoon, at which time the Respondent picks up the minor child. 5, Respondent has admllled to Petitioner over the speaker phone, with witnesses present, that the minor child has greatly Improved In his academics In school, due greatly to Ihe lactthatthe minor child has been seeing the Petitioner on a regular basis, Respondent also stated that It was not In the best Interest 01 the minor child to go without contact with ellher parent for three weekends in a row. e, Your Petitioner Is 01 the opinion that the Order In the Instant proceeding should be modllied so that he continues to have unsupervised visitation every-other weekend and alternating holidays, along with one day per week II he so desires, or as mutually agreed upon by the parties. Additionally, Petitioner requests sharod legal custody of the said minor child, as he alleges, believes, and therelore avers that It would be In the best Interest 01 the minor child that he be able to loin In the decisions that are being made concerning medical and educational mailers. 7. On June Co 1995, Petitioner flied a Complaint In Divorce In Cumberland County entered to number t'_'-~LJ..L._u. which raised a count for custody. Petitioner was unaware that an Order 01 Court had previously boon Issued - 2 . -=='.- '.1'."'->.' ...,l:r.}.>,._....,-.,.-,.,s... ,. - .mV" . Y/ .'V.!::i.'ti~;~...r;[;'r:'";j~'gr} ...., ................ .. C"\.::.......... .~ it' '" ..' ... ... . ..... .' ". "., . ,,-, ci ";;~:'.,- .' rJii-~;: 'i " ~rL'_'" .: ~/r:\:- ~1':f _ ~,.' ~<,.,- :' ~:,;::-r; :;< .~'\'>- ~r'-:l~~ Ir'. ifi,;;',:,,~ ~~-;~~~'. '. j(.y,if-;): I~; JUl 13 ..r . ti,';it 'i [ !~H ,n>- ~~~It~ ~~~/.1t _'-~ri-':i---;' ~:' ~+il;-r-:;-;: . "'.,c'cC....,, f/~'t\: "':' '7':[' - .""" , ",i.,<' --co' ";'-- -;'0;--- ;,.i ,,~";', ~;.~',~> '"" -''''.'''- :";€ .-;.;'}; 2 5S li~ '95 'Ji H:( \'i~; r ^hY i'l\) n' itl! , ), .Il . . I i I .,1- \ .. . . . II. ' . j . , . . .-- A f~": I _'1' '~, ! , . THEODORE P. OORDON, III, Petitioner VI. IN THe COURT OF COMMON PLEAS OP CUMBERLAND ONlY., PENNBYLVANIA NO, 114.3537 CIVIL ACTION. LAW CUSTODY ANOELA T, OORDON, R..pondenl ~rlQtt.f~UIf 1. Pelilioner Is Theodore P. Gordon, III, relldlng al Welt Main Street, P. 0, 202, Plalnlleld, Pennsylvania 17081. 2. Reapondenlll Angela T. Gordon, rellding at 20 Slephen Road, 78, Camp HIli, PA ,70", 3. The parlies are the parenti alone minor child, Chrllloper M. Gordon, date 01 blrlh Seplember ", 1988, FOlldlng with Relpondenl at 20 Slephen Road, 78, Camp Hili, PA ,70". 4. An Order 01 Court wa. IlIued on -1~-lJ:1~__~_ granllng R8Ipondent phYllcal and legal cUltody 01 the minor child, and Pellllone' having lupervlled villi allan only. Pelltioner wal not prelent althe hearing regarding cUllody and W81 not made awaro Ihallhore wal an okllllng Order 01 Court until July 12, 1995 On June 24, 1994. ovor a yoar go, R8spondonllelllhe marital dwelling, laking tho minor child wllh hor and almosl all 01 the marital property and all 01 the couple's money. Respondont then obtalflod a 1 ornporary Rostrainlng Ordor with no hearing on tho mallor. Polltlonor allog08 Ihal nOlpondonl did Ihl8 with tho lollllnlenl 01 gaining 1010 caro and conlrol ollhe minor child Aftor coming homo Irorn work on Juno 24, 199410 a vlrlually ompty hOUS8 and his Wile and son gono, and duo 10 tho Tomporary Roslrainlng OFdor, not bOlng POrtllltlod to .=~'it.~ _ __.......,,,""_~llJlflf~,~ !"':i:-,_",_.,:litr-f'ff'~l "-~::=~ .. " , ,:.~~}';,1 ,.".- ,:c- -t,,~:~lj '?;i JUL 1'1 3 n fK '1 i ,ij I jel Df I', ,i ;;Il.lh'l/.lt~ I,OHf HI I.HII C' JNH I'tHN~ fL- .'.',j~ j I I . I , If . . I , . . \ .\ " i . , . . . , !'"- !' ANGELA' GORDON, Plaint.iff IN THE COURT OF COMMON PI,EAS,O CUHIlEIlLIINll COUNTY, PENNSYLVANIA vs. NO. 94-)!i)7 CIVU. '1'ERM TIIEODORE P. GORDON, Ill, Dehndant CUSTODY AND NOW, this -, .t...( ~day ORDER ()l.I, . of aeplle.lter, 1994, upon ooneideration of the within Petition, the followin9 Order i. entered I 1. The defendant, Theodore P. Gordon, Ihall submit to a plyoholoQioal evaluation to be complsted before hearinQ of the cUltody cale, the evaluation shall addrels the issue. raised in the within Petition and any other issuel Which may be relevant to the dehndant's ability to have unsupervised visitation with the child. 2. LeQal Services shall arrange for Druce ~elly, MA, a licenled plchologist, to perform an evaluation to be completed as soon as pOllible. The defendant shall contact Druce ~elly, 37 S. Hanover Street, Carlisle, 250-1706, to Ichedule the evaluation. ). The defendant shall incur the expens.s involv.d in the evaluation. 4. A written report of the llvaluator shall be eubmitted to OppOI i Ill:J coun.. 1 and the Court. ~. The defendant shall Donlent to allow the evaluator access to all reports and information relatiny to any of hil therapy, family oounaeling, parenting ola.s.l, or medical hiltory, and the defendant ahall releale the evaluator to lend a VI. IN THE COURT OF COMMON PLEAS.OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-3517 CIVIL TERM CUSTODY ANGELA. GORDONl Plalntiff THEODORE P. GORDON, III, Defendant r~TITION FOR PSVCHOLOGICAL EVALUATION The plaintiff, ANGELA GORDON. by and through her attorney. Joan Carey, of Legal Services, Ino. states the followingl 1. The plaintiff, hereinafter referred to as the mother. 1s an adult individual currently residing at 20 Stephen Road, Camp Hill. Cumberland county. pennsylvania. 2. The derendant, hereinafter referred to as the father. is an adult individual currently reliding at 321 West Shady Lane, Enola, Pennlylvania. J. The mother and father ar. the parents of Christopher Miohasl Gordon born september II, 1988. 4. On June 28, 1994, the plaintiff filed a Petition for Protection from AbuI. for hereelf and on behalf of hsr minor child Which included a oount for custody of the child, and a Protective Order and Temporary cUltody Order were entered on July 8, 1994. 6. The Temporary custody Order gave the mother primary phy.loal au.tody and the father supervised visitation. Bee attached Exhibit A incorporated by reference. 6. A cu.tody conoillation Conference was held on August 24. 1994, to resolve the mltter of ou.tody. 7., The parties were not able to agree to a custody schedulel therefore, on september 7, 1994, a conoiliation Conference Summary Report was issued and a hearing WAS scheduled for October 24, 1994, at 1130 p.m. Bee attached Exhibit B inoorporated by referenoe. 8. The plaintiff requests that the Court order the defendant to submit to a psychological evaluation prior to the hearing for reasons inoluding the following 1 I a. Immediately prior to the parties separation on or about June 24, 1994, the defendant punched the ohild in the mouth, knooking out a loose tooth, causing the child to bleed and suffer pain. The defendant on another oocasion around this time, kicked the child in the face, causing pain and bruising about the child's cheek. b. During the child's toddler stages and into the present, the defendant has abused the child in ways inclUding but not limited to the followingl kicking, slapping, pulling hair, throwing the child across the room, and punching the child about the face and body, causing bruises and lacerations. c. The father also force fed the child when he did not eat or did not eat as quiCkly as the father wishedl he shoved food into the child's mouth, holding the child's nose shut and covering the child'e mouth, often causing the child to choke and vomit. On one occasion, the father made the child eat the vomit, d. When the child was not paying attention, or got an anlwor wrong on hil homework, the father Inapped the child in the head above the ear with hil fingerl, causing the child pain and fear. e. The father taught the child to hate African Americanl, phYlically ohallenged people, and overweight people. f. When greeting the child, the father hit the child in the chelt and back with enough force to caule the child to cry out in pain. When the child cried, the father yelled at him to shut up or to grow up. 9. In the opinion of Samuel Andes, the Custody Conciliator, thi. cale "ories out for either psychiatric or psychological evaluation." The conciliator further ltated that there should be a thorough examination of the father and his relationship with the child. See conoiliation Conference Report, paragraph 6 of Exhibit B attached. 10. The mother hn conclllrns regarding the father's Itability baled on hil erratio behavior inclUding hie actions at the conciliation conference on August 24, 1994, when he behaved in a threatening manner inoluding uling oblcene language with the Legal Servicel staft, blllcoming enraged and leaving the conference room during thlll attempt. at negotiating the cal8, and lunging at the Legal Services ststf In an attempt to deetroy exhibits relulting in the conciliator and his staff having to intervene saying they would call the police if the tather'e behavior continued. 11. The fathllr admitted that he needs parentinq .kills and ANGELA GORDON, t IN 'l'HB COURT OF COMMON 'WntlU f PLBAI OF CUHBBlLAND I COUNTy, PENNSYLVANIA I VI, I NO. 9.~3531 CIVIL TERH TIlBOPORE p, GORDON, III, t Def.adant t CUSTODY 'IJUDGB PREVIOUSLY A88ION801 Th. Honorlble Harold B, Sbe.ly ,I , I! ~CILU'l'01 MtmlllRIICB 8111lNUY IIPOl'l' ,I IN ACCOlDANCB WITII CUHBBRLAND COUNTY IULE or CIVIL PROCBDURB 19l5.3~8(b), tbe und.rlign.d CUltody Concililtol lub,itl tb. folloviog reporl, I, Tb. pertinent iafor..lion concerninv lll. child vho it tbe Iubject of tbis litigltion il II fo110VII II lfW lJlrUOATB 11 8.pte.ber 1988 CURlBNTLY IN CU8TODY OF Plaintiff/Hother Chrhtopblr Hh:b..1 Gordon 2. A Conciliation Conference VII beld on 24 Augult 1994 IDd tbe folloving individu.1. v.r. pr.I.Dtl tb. Plaintiff and h.r counl.l, L.gal S.rvic... IDC.I the D.f.nd.nt .pp..r.d witbout couD..1, 3. It"1 r..o1v.d by .9r....ntl TIl. flth.r 19r"1 tblt th. MOtb.r .bould retl1n prl.lry pby.iell cUltody af th. cbi1d. 4, IIIU.. Vlt to b. r..olv.dl 8tltu. of 1'9a1 cu.tody .nd tb. fltber'l time vitb Ihl child. ~. Need for upuatl Ilounul to repr"'Dt child I Not yet. It ml)' be Ipproprhte It I liter d.te to appoint "plrat. counl.1 tor tb. child, d.p.ndin9 upon IIhlt evidence IhelO II 10 lupport lb. lRollin'8 ,ccuuUuP Ibulll tbe felbn'l phYI1cIl IbuII at the diU, H Ihta polllt, bOVlvet, I do 1101 !leUtyl lepall\l! (lOunael for the chlld i8 PHeu., y. iII- - r"" TLnmJ UJ .or! IIIIi I \1111', I I " I II I, " " 6. Need for independent peycbologioal evaluation or aoun.elingl Thle aae, criee out for eitber peychiatrio or peyobological evaluation. The Motber'e aacueatione about the father are extreme. If even some of them are true, there ehould b, a therough lexamination of the father and his relationship vith th, child. ! ~ 7. Other matters and comments, Tbere vas a temporary order entered in JUly of 1994 in reeponse to the IOth,r's petition for protection fro. abuse. There have been difficulties in arranging the supervised visitation established by that order and the father has only eaen the child a fev times during the months of July and August. He is obviously distres.ed by that , '!and understandably vants to establisb some schedule that viii give him ti.e vith the " II/Child so that he can visit vith the child and take the child to see his mother, vho ;IUvIB vith hi.. The motber claims tbat the father has physically abused the child. 8h, olaiMs " that he has force fed the child, cauBing him to choke, that he has repeatedly punched I' Ithe cbild in the cbest and back and snapped the child on tbe he.d lIith his fingers. 1 Bhe claims to have vitnesles and photographl to confirm those cllim.. 8he al.o olaim. that the father has taugbt the child to hate various minority groups, specifically including blacks and handicapped people. The father deniee all of this. It the.. accusations are true, tbe court should be very cautious in alloving tbe father to be alone vith the child. It they ere not true, of course, the mother's conduct II open for examination. The fathor vas very agitated at the conference and had difficulty lIaking hb i position clear. It does appeer that he has been doing some counleUng with auid.nee 'I Associates in Camp H11l. Prom the vay ho describod It, tho coUnleUnq appeared to be dosiqncd to Improve his self-control and hla parenting akllls. 2 __:~'fW-,,, lit~2~-F . :: 'x,~;;'.r ~'-cr---M~'l ! -~; \ "-,,,-,,>,,;;!<~-'.;:;';:,;"'-'""""'--" '111it.:.... r" 10/ J Iq ~. ~.f, '-."'''...' ..'. t." j" . f . . , - . II , ..j"- ; , i . i i i \. I I . I j L , ! ,f J". ~ -1.' '~ '~ (~ ~s l- I ! II(I-J ~! '" .CIIi .. ;.I 0.... W Mill u.t:l ~I .. ...." III I'" 0 ...." .... W .,. .~ Q f- .. ~...... ..,.. ..... f-O ~' ...J ... 8&t .... .... Oil I-Vl ~i ... ClIl . CIIi loL/\.H- .... ~ .. t:l II-::~ ~ ~~ u IJl !~ IJl Vlo(W ..... . . ::tl- M 0( II- ;!:I-J. III -J f- a i~ i M W VI .....I-J w~ 1 I ~ .0 ., W -' I1l I( CI :111>>0( I: ... i~ ... I...... IX a: 0(0-. w. u::l:U I . V, I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I I I 94-3537 CIVIL TERM I I I I CHARGE I INDIRECT CRIMINAL CONTEMPT ANGELA GORDON1 Pet tioner THEODORE P. GORDON, 111/ Defendant ORDER OF COURT AND NOW, this ~ day of ~, 1994 in consideration of the attached Commonwealth's petition, th~ defendant, Theodore P. Gordon, III, is to appear before the Court on the ~ day ot-llH/'\>t"'-lX'~ , 1994, at "J'LJ() ~.m. in Courtroom' n of the Cumberland County Courthouse, carlisle, Pennsylvania, to show cause why the defendant should not be adjudicated in indirect criminal contempt of Court. The defendant has a right to be represented by an attorney. If the defendant cannot afford an attorney, one will be assigned to represent the defendant. Further, if the defendant fails to appear an arrest warrant will be issued.. / rhO Edgar B. Bayley, J~dge Thomas A, Placer Assistant Distr ct Attorney Theodore P. Gordon, III, Defendant public Defender's Office ANGELA GORDON, Pet1tioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 94-3537 CIVIL TERM THEODORE P. GORDON, III, Defendant CHARGE I INDIRECT CRIMINAL CONTEMPT COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES OF INDIRECT CRIMINAL CONTEMPT Thomas A. Placey, Assistant District Attorney of Cumberland County, brings the following Petition for a hearing on charge. of Indirect Criminal Contempt I 1. A Protection From Abuse Order was hsued by the Court. A true and correct certified copy of the Order is attached III exhibit U. 2. The defendant's violation of this Order is averred in the incident reports attached as exhibit '2. 3. The police received a call from the victim on leveral occasions from September 25, 1994 to September 30, 1994. 4. The victim requested the police to file chargee of indirect criminal contempt upon information received. 5. The Commonwealth is requesting a hearing on the charg.. of indirect criminal contempt pursuant to 23 Pa.e.S.A. s.ction 6113. . ANGBI,A GORDON, ) IN THB COURT OF COHHON Plaintiff ) PLBAS OF CUHBBRLAND ) COUNTY, PBNNBYINANIA VI, ) ) NO. 94-3537 CIVIL TERH TIIBODORE P. GORDON, Ill, ) Defendant ) CUSTODY JUDGB PREVIOUSLY ASSIGNBDI The 1I0norable lIarold E, Sheely CONCILIATOR CONFBlBNCE 8\JtIItAIY REPORT IN ACCORDANCE WITH CUHBERLAND COUNTY RULE OF CIVIL PROCEDURB 1915,3-S(b), the underalgned cUltody conciliator submits the following report 1 I. The perl/nent Inlor.allon concernlnll the child who II the lubject of thh lltlllatlon 18 al folloW81 twm DIRTIIIlATIl 11 Bepte.ber 19BB CIJRRIlNTI,Y IN CUSTODY OF Plalntiff/Hother Chrlatopher Hlchael Gordon 2, A Conciliation Conference was held on 24 AUllust 1994 and the followinll Individuals were present I the Plalntlfl and her counsel, Legal Bervlces, Inc,1 the Defendant appeared without counsel. 3. lIemo resolved by allreement I The I at her Bgrees that the MOther should ret.aln primary physical cust.ody of the child, 4, losueo yet. to be reoolvodl Bt.at.ue of legol custody and t.he fot.her's time wlt.h the child. 5. Need for ueparste counsel to repreoent chlldl Not yel.. It may be appropriate al. a later date to appoint Reparate counsel for the child, depending upon IIhat evldeuce there 10 to support the mother'u accuRat.lon about the fother's physical abuse of the child, At this Ilolnt, however, [ do not. believe sllparall. counsel for the child Is nllcoouary, ~ 6. Need tor independent psychological evaluation or counsellngl This case crle8 out for e1ther psychiatric or psychological evaluallon. The mother's accullllons abuut 'the father are extrelle. If even somo of tholll are t.rue, lhere should be a thorough oxaminalion of the father and hls relationship lIith tho child, 7. Other matters and cOMments I There lias a tOlporary order enterod in Jul y of 1994 In responle 10 lhe lut.her's petilion for protecllon frol abuse. Thero have beon dlfflcullles In arranging the supervised visitation established by t.hat order and lhe father has only Been the child a fell limos during lhe months of JUly and August. lie is obviously dlslleued by lhat and understandably lIants to establish some schedule lhat will gi ve hill lIle lIith lhe chlld so that he can visit lIith lhe chlld and lake lhe chlld lo see his mOlher, IIho 11 ves lIilh him. The molher claims that t.he falher has physically abused lhe chlld. Bhe dalms that he h.s forco fed the chlld, causing him to choke, that ho has l'epeatedly punched the chlld in the chest and back and snapped the chlld on the head lIilh his lingers, Bhe caims to have IIltneuel and photographs to confirm lhose clalll1s. Bhe aho claims that the father hae laught the child lo hale various minority groups, specifically inclUding blacke and handicapped people, The lalher denlos all 01 this, II Ihese accusations aro lruo, tho court should be very cautious In allOWing the lather to be alono lIith the child. If they are nul truo, 01 course, the mot.her's conduct Is upen lor oxamlnalion, The fathor lias very sgitated at. the conllllenLle and had dlllleulty Making tala position clear. It does appear thal ho has been doln9 somo counseling with Guldanee Ausoclatou In Camp 11I11. From tho lIay ho doserlbod Il, lhe counaolln9 al'll0818d to bo doulgnod to Improve hiD sell-control and his parontlng uklllu, 7. ANGBLA GORDON, I IN THB COURT OF COHHON plaintiff PLBA8 OF CUHBBRLAND COUNTy, PBHNBYLVANIA va. I I NO. 94-3&37 CIVIL TBRM I THBODORB P. GORDON, III, I , Defendant I CUSTODY , I paDS OF roUtT AND NOW tbls day of , 1994, a bearing is bereby scbeduled in the above matter to be held in Court Roon No. __ of the Cumberland County Court House 'in Carlisle, Pennaylvania, commencing at o'clock _.m., on ithe I day of , 1994. By tbe Court, oJ. Legal service./ Inc. Attorney for Plaintiff Theodore P. Gordon, III, pro II 321 Sbady Lane Enola, PA 1702& u1l (>, Thl: de f l'lIt1 1111 I , nllhuul/,h elllerllll/, IlIlu lhlN AI/.l'eumunl, .lm'lI IInl ndl1lil Iht' IlIle!lnllunH IIIlHle in lhlll l'elili<1I1, 7, The defendlllll uIHlerlllllfHl1I I hul I he I'loll'cl i ve order elllell'd ill thlll l1Iuttel IIhllll he ill u1lt'<:l fOI II purlnd of 0110 yellr, K, Tllc .lull'IHlullt UIlIlclHllllldH lhul lhill Ortlcr will hI: 1'lIforcellhle ill lhe HUllle 1II111111cr UH I hI' cOun'H prtor TUmpOf/HY' I'lolel:llvu onil'1 CIIIl'lell III lhill CIISC, '1, TIll.! dvll'lIdlllll 1111,1 the pluillllff IIgrel' In lhl' elllry of lhv fulluwll1/1 1l'l1IpornlY t:UHlud)' oldcl 1l'1/,/ll"dinll lhclr chilLI. ('UR I STOI'UEll M, OOIWoN I II. The 1II01hcr will hllvl' I'riUllny physl<:/l1 /ll1d lellnl ,'u!illHly ut lhe <:Iii Id, b, TIlt.! flllhcr will hllVt. Hupt'lvlscd villilllllul1 wilh lhe ('hlld nl 1111le" /llId I'I/lc"" to hc ugll'llll UPOII by lho parties, IncludlllM Ihl' YWCA III Cnrlislc. c, TIll: IHlllles reulin. lhnl llll'ir dlild'l-; wcll bl'lll!! III purnUlllulI1 10 UII)' lit frl'l elll"eH thl:)' I1Illlhl hnl'l' belweell lhcUllI1'I VI'II, ThlHefull'. llIllY' u!!n'l' Ihlll l\lollhl'l purly will du IIllylhllljl which UlII)' t'Hll'UII!l1' Ihe dill" frulII lhl' olhur pUIl'1I1, 01 IIIJun' llll' Upilliull ul Ihl' d,lltl /IS lu lhl' nlhl'l' p/l 1l'1I I 01 which 11I11) hllUlI'UI the 111'1' lIf1d lIulurul dl'VldllPtlll'1l1 nf lhl' .hlld'" ILlle III 1l"'I'l'L'1 1111 thl' olhl'l pUIUfll. In, The 1'111111'" !l1I1l'I' thlll lhl' lIIulll'l uI ,'ust'lIly will hI' ,,,hL'dlll.,t1 '01 it 10llLlliitltOll '1l1l1"lt'I1LI', 111111 till' '11'IIIIl"rIlIY I . fit"" "~"^,,~,'J.".~""'" ___"',"",~.,",~.~"'7"_"'Z.:,o;!.M="*"';""""",-"h':-...'",,,,....~~_~_~.:f~T.,~~'i'ri'.""._<:....fi!_..,.."'..'""C-..'fl...44"C....-"'..".~, , JUI ij II tu ail '9~ ~ .i f~ I f , . . . Ii , .. . . , .. , tI . . ~- '.. .- ,1 -J>> " . 4. ,XS!~:J . ~.,,"l- t: -,/';7_,:;;: ." ._'-..J_...' c_ --"0;,-:0.0::; . 'T' . 1 ...--.,..-."...;.>.-...."""",,. ,oj .;:.i:. . "'~:f4j.'-- . .. . -".;R,tl""",~"I;,.ti~_."",...~_......4~~~ j; ,~~-~.;..,..",............'"'. ., (JJU\ \, u II ~IJ rIa 1M . \ 'II i~ .q", iii , '.\ ~:~_~~O'; ~ ,1; ui';"~'''''i:d!l'-~ "".Iol!llTI:' ,tj!~",~~::-,- .' l j 1-' I . j . 11 \ \ . .. " .. '1. , . . , ...~- ! . , * A"'i \", T. b cv,I,\ \ /Je{olldant , IN fUr COURr OF CONNON PLEAS OF ,CUHBEIlLAND COUNTY, PENNSYLVANIA , 'CIVIL ACTION - LAW , a~'~ ,. :n ,NO. -,. J CIVIL 19 ,CUSTODY/VISITATION * 'ThvrcL,(I p, 61Yll"''P~I~int.ut V ORDER OF COURT AND NOW, this 't~akh) 7, "l'f~ , upon consideration of the attaohed oomplaint, it is hereby directed ,that tile par~les. and th.,tr reBpeoUve counse appear before S'II!'<.t' I L.Jj.lJf-} {~. , the cono,tliator, at ., h. ,,.' .If on the ~)I\~ day 0 "~I d ~ , 19q,{ , at 3 jJ.k' M., lor a Prehearing Custo y Conference. At such conference, an etfort 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. Either party may bring the child who is the subject of this custody action to the conference, but the ohild/ohildren'e attendanoe is not mandatory. Failure to appeu' at the oonference may provide ground. for entry at a temporary or permanent ordor. FOR THE COURT' Oy, c~"Jyld~~"J YOU SHOULD 'l'AKI THIS PAPER TO fOUR LAWf.ll'R AT ONCE. IJo' YOU DO NOT IIAVB A LAffl'lrR OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TlIE OFFICE .'In FORTH BILOW TO rIND OUT W"lrRE YOU CAN GET LEGAL lIBLP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE PA 17013 (717)240-6200 . COURT OF COMMON VLEAS OF CUMBERLAND COUNTY /V\>. (\ 'i - 35- 3'1 (',,"/,1 /'/1 , CASE NO.1'l (,)I OF 1994 PLAINTIFF ) CIVIL ACTION-PARTIAL CUSTODY THEODORE P. GORDON III ) V ) ) ANGELA T. GORDON DBFENDANT ) C-\I...J; I T~ I'IY\ COMPlAINT FOR CUSTODY 1. The plaintiff is Theodore P. Gordon III, residing et 321 WEST SHADY LANBL ENOLA PA, 17025. 2. The defendant is ANGELA T. GORDON, residing at AN UNDISCLOSED RESIDENCE. J. Plaintiff seeks partial custody of the following childl Name Presant address Age CHRISTOPHER MICHAEL GORDON, The child was not born out of wedlock. 5 The child is presently in the custody of who resides at UNDISCLOSED ADDRESS. During the past five years, the ohild has the following addresses, (List All Persons) (List All Addresses) THEODORE P. GORDON 2908 B STRAUSE LANE. ANGELA T. GORDON COLO. SPRINGS. COLO. ANGELA T. GORDON resided with the following persons at (List All Dates) SEPT 88 TILL MARCH 89 SAME 3344 B. WILLET CIRCLE FORT. CARSON. COLO. 247 ENOLA ROAD ENOLA. PA, 17025 321 SHADY LANE ENOLA. PA, 17025 The mother of the child is ANGELA T. GORDON.ourrently residing at UNDISCLOSED RESIDENCE. She is married. The father of the child is THEODORE P. GORDON III, residing at 321 WEST SHADY L~E ENOLA. PA, 17025. He is marris!l. MARCH 89 TILL APRIL 90 SAME SAME APRIL 90 TILL JULY 90 JULY 90 TILL JUNE 24. 1994 4. The relationship of plaintiff currently Name NONE the plaintiff to the ohild is that of resides with the following personsl Relationship Father. The 5. The relationship of defendant to the ohild is that of mother. The defendant currently resides with the following personsl Name Relationship _.JiQ1'...KNQWN . 1 . " 6. plaintiff IlAllJiQ'r partidpatlld .. a Ilarly or witneu, or in another capacity, in other litigation conoerning the custody of the child in this or anothar court. The court, term and nUlllber, and ita relationahip to this action ism.....___.._....___. ---PT.fntiif. -1iJi~.llii. in f i;;:matTon-of -'a". cuiitotiy-proce'ldlng-co-.t'c-'-irilng-t:h;- ch i 1d pending in a oourt of thia Commonwealth. The COU1"t, tarm and number, and ita relationahip to thia aoLion ia _____.._________._...__..__....._..._..._._. Plaintiff ~. not know of a peraon not a party to the procaadinga who has phyaical cuatody of the child or claima to have cu.tody or vi.itation righta with rupect to the child. The name and addre.. of auoh penon ill ..__._.._._.._._.. _..__.._._."".__.liQI._KHQWH~___.__..._._. ..____._..__________.__._.__ ......._....__._..__.. . ..-.- -..._._.. .__. 7. The but intareat and permanent walfare of tha ohild will ba ..rved by granting the relief requeated becau.e (aat forth faota ahowing that tha granting of the reHef requutad will be in the baat intereat and parmanent walfara of tha ohildl. A. Tha pldntiU_.iL.A._U.LRUIJl.t...tUllL..2.AILb.lli_tW_ilUL--2t rnIUJl.IQfllllLK1_ GORDON. B . Il1L.RlIlnU.lLhu_.btllL_1hI_llr illluY.__2..AII taker .JlL.QliRUIQ1'1II1LIL. GORDON . C, IJa...d.IUnllAnLlaL .hown by..hu.l1tgltil.t of the plUntUl..AWlJI.hil!L .tla.t.thl.i1lhndanLll.no.LthL aDDroprh te~AI.ltUlr 11'011 lIIodel .to.Ltbt.Sl.hi.li1L B. Eaoh parant whoaa parantal right. to the ohild have not been terminatad and the peraon who hea phyaioal ouatody of the ohild hava baan named a. partial to thia ItCtioll. All othar paraona, named below, who are known to have a olaim will ba given notioa of tha panding of thia aotion and tha right to intervana. NAMB ADDRBSS ANNA .IWl'iltHAN 247 ENOLA ROAD BNOLA. PAt Wherefora, plaintiff requa.ta tha oourt to grant (ouatody) (partial cuatody) Viaitation) of tha ohild. Attar-n"y.. tcr.th".pT.TiltTir-. I verify that tha atatalllanta iliad. in thll oOlllplaint an true and oornot. I undaratand that fal.. atat.m.nt. harain are iliad. .ubj.ot to the p.nalti.. of lB Pa C.O, 4g04 ralati~ to un.worn fal.ifioation to authoriti... , ~ ( ". I ' 1 pT.lni:rtf,.r;~I~~1 1>>. 'OOItDON. Jt . 2 i ANGELA GORDON, Pet! t!oner IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-3637 CIVIL TERM v. THEODORE P. GORDON, III, Re.pondent AFFIANT I DET. DAVID FONES IN REI PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this 3rd day of November, 1994, this matter having been called for a hearing, and upon agreement of the parties, it is ordered that Paragraph 2 of the Protection From Abuse order entered on July B, 1994 is deleted and amended with thie paragraph: 2. Defendant, Theodore P. Gordon, is enjoined from having any contact at any location with Plaintiff, Angela Gordon. Defendant is further enjoined from going to or being at the residence of Plaintiff's mother, Anna Baughman, at 247 Enola Drive, Enola, Pennsylvania. 3. All visitation of the father with hie child shall now be pursuant to a temporary custody order entered July B, 1994 by Judge Harold E. Sheely. 4. As long as Defendant is not in violation of the terms and conditions of this amended Order for protection From Abuse in the next 90 days, the petition to hold him in contempt shall be deemed dismissed without further order of Court. } .lly the 9~;I / V. ',.' / i ..' './ I \, ' /q i\ ~ I Edgar B. 'Bayloy, J. ANGELA GOIWON, Plaintiff for herself and on behalf of her minor childl CHRISTOPHER MICHAEl, GOIUJON VS. THEODORE P. GORDON, III, Defendant I IN '1 liE COUI1'I' OF COMMON PLEAS OF I t CUMnERI~ND COUNTY, PENNSYLVANIA I t NO, 94 - ]', \ 7_ CIVIL 'I'ERM I I PROTEC'I'ION FROM ABUSE I AND CUSTODY I I TEMPORARY PROTECTIVE ORDER AND NOW, this Jb (I, day of June/ 1994/ upon pres.ntation and consideration of the within Petition, and upon findinq that the plaintiff / ANGELA GORDON, and her minor child, CHRISTOPHER MICHAEL GORDON, now residing at an undisclosed location, are in immediate and present danger of abuse from the defendant, THEODORE P. GORDON, 111/ the following Temporary order is entered. The defendant, TIlEoDORE P. GORDON, now residing at 321 W. Shady Lane, Apt. A, Enola, Cumberland county, Pennsylvania, is hereby enjoined from physically abusing the plaintiff, ANGELA GORDON, or her child, or placing them in fear of abuse and ie ordered to stay away from any residence the plaintiff hae now or may establish for herself in the futuro. The defendant is hereby notified that if he resides in tho plaintiff'S domioile contrary to this Order, he may be in indirect orlmlnal contempt whioh is punishable by a fine not to exceed 01,000.00 and/or by a sentence of up to six months in jail and any other appropriate punishment. Resumption of co-residence on the part of the plaintiff and defendant shall not nullify the prOVisions of the Court Order \ directing the defendant to refrain from abusing the plaintiff. Temporary cuetody of CHRISTOPHER MICHAEL GORDON, i. hereby awarded to the plaintiff, ANGELA GORDON. The defendant is ordered to refrain from having any contact with the plaintiff including, but not limited to, destroying or damaging the plaintiff's vehicle, entering the plaintiff's place of employment, harassing or stalking the plaintiff, and harassing the plaintiff's relatives or minor children. This Order shall remain in effect until a final order is entered in this case. A hearing shall be held on this matter on t~ [JI LJ~, / V / / :,)t/ II .m. in the day of Jumr,' 1994, at Courtroom No. I , Cumberland County Courthouse, Carlisle, Pennsylvania. The plaintiff may proceed in fcrma pauperis pending a further order after the hearing. The Cumberland County Sheriff's office shall attempt to make service at the plaintiff's request, but service may be accomplished under any applicable rule of civil Procedure. The appropriate Police Departments in the area whe;"e the plaintiff lives and works will be provided with a copy of this Order by attorneys for plaintiff. This Order shall be enforced by any law enforcement agency where a violation occurs by arrest for indirect criminal contempt without warrant upon probable cause that this Order has been violated, whether or not the violation is committed in the presence of the police officer. In the event that an arrest is made under this section, the defendant shall be taken without unnecessary delay beforo the ANGELA GORDON, Plaintiff for her.elf and on behalf of her minor childl CHRISTOPHER MICHAEL GORDON vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - CIVIL TERM PROTECTION FROM ABUSE AND CUSTODY THEODORE P. GORDON, Ill, 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 promptly after this Petition, Order and Notice are served, by appearing personally or by attorney at the hearing scheduled by the Court and presenting to the Court your defenses or objections to the claims set forth against YOII. Ycu are warned that if you fail to do so the Court may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Petition or for any other claim or relief requested 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 ONE, GO TO OR TELEPHONE THE OFFICE SET FORTI! BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 Tl!:LEPHONE NUMBERs (717) 240-6200 ANGELA GORDON, PlIlintUf for herself and on behalf of her minor ohilds CHRISTOPHER MICHAEL GORDON Vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - CIVIL TERM PROTECTION FROM ABUSE AND CUSTODY 'l'IIEODORE P. GORDON, 111, Dehndant rETITION FOR P~OTECTIVE ORDER AND CUSTODY ~ELIEf UNDER TilE PROTECTION FROM ABUSE ACT ~~ r.B. SECTION 6101 A. ABUSF; 1. The plaintiff is an adult individual who is temporarily staying at an undhclosed location for her own protection and to avoid further abuse as is more flllly set forth herein. This address will be furnished to ths court upon request. :I . The defendant is an adult individual residing at 321 W. Shady Lane, Apt. A, Enola, Cumbsrland county, Pennsylvania, 17026. 3. The defendant is the plaintiff'S husband. 4. sinoe approximately 1986, the defendant has attsmpted to cause and has intentionallY, knowingly, or recklessly caused bodily injury to the plaintiff and her child, and by physical menace has placed the plaintiff and her child in fear of imminent sedous bodily injury. '1'hh has included but is not limited to the tOllowinq specific inetAnce. of abu"l a. On or about June 20, 1994, the defendant punched the ohild in the mouth, knocking ollt a 10088 tooth. 'rhe child cried, suffered pain and bled. b. In or around the beginning of June 1994, the defendant kicked the child in the face, leaving a bruise on the child's cheek and causing the child to cry. c. In the past, the defendant has abused the child in ways including kicking, Slapping, pulling hair, throwing the child across the room, and punching the child, causing lacerations and bruising. The defendant also shoves encrmous amounts of food into the child's mouth, causing him to choke. The child is fearful for his safety. d. On or about June 19, 1994, the defendant became enraged, approached the plaintiff and raised his elbow as if to smash it into her face. The plaintiff is fearful of her safety due to past incidents of abuse. e. On or about June 18, 1994, while the plaintiff was sitting in a chair, the defendant kicked at the plaintiff's face, missing her by inches. f. In or around the middle of May, 1994, the defendant grabbed the plaintiff, and threw her against the dishwasher and the wall, causing soreness. g. The defendant abuses the plaintiff on a biweekly to monthly basis in ways including the fOllowings throwing her into things, Slapping her, punching her, backhanding her in the face, ramming his fist into her face and forcefully pushing against it. In the past, the defendant slammed a large tire onto the plaintiff's foot, causing it to swell and bruise, and necessitatin~ that the plaintiff u.e crutches. The defendant hae fractured the plaintiff'S ribs by throwin~ her into an open sofa bed, and ohipped her tooth by hitting her in the mouth with his ring. The defendant has threatened the plaintiff many time. saying that if she left him, he would find her and slit her throat. 5. On approximately June 24, 1994, the plaintiff and her child left their residence at 321 W. Shady Lane, Apt. A, Enola, Cumberland County, Pennsylvania in order to avoid further abuse. 6. The plaintiff believee and therefore aver. that she and her child will be in immediate and present danger of abuse from the defendant, and that she and her child are in need of protection from such abuse. 7. The plaintiff desires that the defendant be reetrained from destroying or damaging the plaintiff'a vehicle, ent.rin~ her place of employment, having any contact with her, haraseing or stalking the plaintiff, and from harasling the plaintiff'S relative. or minor child. B. TEMPORARY CUBTOD~ 8. The plaintiff leeks temporary custody of the following childl HImI rr,ssnt R8.idIngJ Christopher Gordon undisclosed location The child was not born out of wedlock. The child is presently in the cu.tody of ANGELA GORDON, who ~ a 1/2 yrs. resid.. at an undl.o1os.d looation. Durin; the pa.t five yeare, the child has reaidod with the fOllowing peraons and at the following addresses I UAmi ~ddreasea plaintiff . Ft. carson, co defsndant plaintiff, dafendant, 247 Enola Road . plaintiff'e parents Enola, PA plaintiff . 321 Shady Lane defendant EnoIa, PA plaintiff undisclosed location Dates 9/11/88 - 4/90 4/90 - 7/90 7/90 - 6/24/94 6/24/94 - present The mother of the child is ANGELA GORDON, currently residing at an undiaoloaed location. She ia married. The father of the child is THEODORE P. GORDON, III, ourrently reaiding at 321 Shady Lane, Enola. The plaintiff currently resides with the following persons I UAmi Relationshio Chriatopher Gordon son 9. The plaintiff has not previously participated in any litigation conoerning clIstody of the above mentioned child in this or any other Court. 10. The plaintiff hae no knowledge of any custody prooe.tUn9a oonoerning tilt. ohild pending before a court in this or any oth.r juri.diction. 11. 1'IIS plaintiff doe a not know of any person not a party to this aotion who haa physical custody of the child or claims to have custody or visitation rights with respect to the child. 12. The best interests and permanent welfare of the child will be met if custody is temporarily granted to the plaintiff pending a hearing in this matter for the following reasons I a. The plaintiff is a fit parent who can best take care of her child. b. The defendant has shown by his abuse of the plaintiff that he ie not an appropriate role model for the child. o. The defendant has demonstrated by his abuse of the child that he is an unfit parent. d. The plaintiff hae been the primary caretaker of the child. C. EXCLUSIVE POSSESSION 13. The plaintiff is currently living at a residence never shared by the partiee, the address of Which she feels must remain confidential for her protection. 14. It is necessary to exclude the defendant from this residence, as well as any residence the plaintiff may establish for herself in the future, for the safety of the plaintiff and her child. D. SUPPORT SECTION 15. The defendant has a duty to support the plaintiff and their minor child. 16. The defendant is employed at CMRA and has hourly salary of approximately $9.90. 17. The plaintiff currently ie employed at the Pennsylvania Farm Bureau and hu an hourly salary of epproximately tB. 00. 18. The plaintiff's income ie insufficient to pr.ovide for her minimal needs and thoee of her child until such time ae a eupport order can be obtained by filing at the Domestic R.lations Off ice. 19. The plaintiff intend. to petition for support within two weeke of the issuance of a protective order. E. ATTORNEY FEES 20. The plaintiff asks for attorney faaa to be paid to Legal Bervices, Inc. pureuant to the Protection from Abus. Act. F. STATUS TO PROCEED IN FORMA PAUPERIS 21. Tho plaintiff doe. not have fund. available to pay the feee for tiling and .ervice .ince sh. ha. had to relocate to a neW re.idence with har child. WHEREFORE, punuant to the provision. of the "Protection from Abus. Act" of october 7, 1976, 23 P.B. Section 6101 At. I.I.Q., as amended, the plaintiff pray. this Honorable COllrt to grant the following r.liefl A. Grant a Temporary Order pursuant to the "Proteotion from Abuse Act s " 1. Requiring tha defendant to rsfrain from abusing the plaintiff and har minor child or placing them in fear of abuse. 2. Requiring the detendant to retrain from having any contact with the plaintiff, including, but not limited to, refraining from destroying or damaging the plaintiff'S vehicle, entering the plaintiff'S place of employment, harassing or stalking the plaintiff, and haraseing the plaintiff'S relatives or minor child. 3. Granting temporary custody of the minor child to the plaintiff. 4. ordering the defendant to etay away from any residence the plaintiff has now or may establish for herself in the future. B. Schedule a hearing in accordance with the provisions of the "Protection from Abuse Act," and, after such hearing, enter an order to be in effect for a period of one years 1. Requiring the defendant to refrain from abusing the plaintiff or her minor child or placing them in fear of abuse. 2. Requiring the defendant to refrain from having any contact with the plaintiff, inclUding, but not limited to, refraining from destroying or damaging the plaintiff'S vehicle, entering the plaintiff'S place of employment, harassing or etalking the plaintiff, and harassing the plaintiff'S relatives or minor child. 3. Ordering the defendant to stay away from any residence the plaintiff has now or may establish for herself in tho fllture. 4. arantin9 .upport to the plaintiff in the amount of '70 per week, to be .ent by mail to Le9al Bervice., Inc. D. ordering the defendant to pay attorney fees to Le9al Servicee, Inc., pureuant to the Protection From Abuse Aot. The plaintiff further asks that this Petition be filed and served without payment of costs, pending a further order at the hearin9, and that a copy of this Petiticn and order be delivered to the appropriate Police Departmente in the areas in whioh the plaintiff lives and work., as the Police Departments with jurisdiotion to enforce thie order. The plaintiff praye for euch other relief ae may be juet and proper. COUNT II CUSTODY UNDER PENNSYLVANIA CUSTODY LAW aa. The allegatione of count I above are incorporated herein as if fully eet forth. 33. The beet intereete and permanent welfare of the ohild will be .erved by confirming custody in the plaintiff .e .et forth in Paragraph lZ of the Petition. WIUtRltFORE, punuant to Z3 I'.S. seotion !.DOl at. J..I.Q., and other applicable rule. and law, the plaintiff praye this Honorable court to award cuetodY of the minor ohlld to her. x;: ' ,..,=......"..=~..~;;;."".... . ~ r u ".,..--,~;. <___~"""-""',.'..,~~-c::",'f;ii,+.,, 'All:"::; ~. ..- ",';" I ","- t ~.~ . . .,,__n..'-- ~.1 ,"': -- _-)'.l~.>r~f ifif/~ ' cO; JUH 29 3 12 PM '9~ i \(f 'Jf 1" ClI!;!:' .,< <\! n.h'i'.: ,iI,;" , 'M !In " , ,,'i 10, -,aJ.L c.,., Jl '" ..;...---;- @ -M 3S. Oil .. ,< ...:; ,..C"""'~'~'"'^"'Jf" .,-.m;'h''':;W;="''"~'' ~"'1J..."._." .. r \ f . , ';.~-.,...' f>T~: " i ,- . '" ~ ." -4[ ,It" , it -f ~ . JUI U II ~J ~K 19~ , ~ ifl t 'i:,';{ "Mtl ..e 'Jl In' j ~ . . . , -. . . ' v \ *' . -......... GORDON, Plaintiff IN TilE COURT OF COMMON PLEAS OF v. CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-3537 CIVIL TERM THEODORE P. GORDON, III, Defendant CUSTODY ORDER OF COURT AND NOW this 3rd day of October, 1994, ths hearing schsduled for October 24, 1994 at 1130 p.m. is continued until WL,J. If, 1994 at 1:.1~/.m. to afford time for the psychological evaluation of the defendant to be completed. By the Court .I J ~\-\.:J. r: .Jl~ Harold Il. heely; P,J. / _"e , .,~...' ,.,,,,,~,,,.>~_.,~,,,,,,,,,;,';;:. ......"".... .~.'" "..:c*-.'.;:;,,,,,~..,,;;-;;F'",~.''''~';'':' - . ~'-'_-__'""'''-'T_ @ Ot' .~ 2)~ r~ '9~ illl-J Ql 'Jl' :Ii," 111.' \:1,\'11\ I' .'''; ..11 I U It '; '~ {\ l~ \, .. I ...,,~ f#'f1""o""/f' ..,A. ~ -..;,;;.__.~;, :.... . . I. . " ; , . , .-"".~.. . . .. ANGELA GORDON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTy, PENNSYLVANIA THEODORE P. GORDON, III, Defendant CIVIL ACTION - LAW 94-3537 CIVIL TERM IN CUSTODY IN REI TEMPORARY CUSTODY ARRANGEMENTS ORDBR OF COURT AND NOW, this 21st day of August, 1996, a heering ws. set today on a petition by the father to modify the present partial cu.tody arrangements that he has with his Ion, Christopher M. Gordon, who wal born on September 11th, 1988. Both partiel sre represented by counlel today. The partiel were able to reech a temporary agreement without a hearing being required, and the agreement is as folloWl1 1. Mother Ihall continue to have primary phyeical custody of their son, Christopher, hil birth date being al noted above. 2. There was a psychological evaluation conducted on Theodore P. Gordon, III, the father of Christopher, which psychological waB prepared by Bruce Kelly, M.A., Pennsylvania Licensed Psychologist, and it was hil reoommendation that at this time eupervised vilitation only be ~armitted between Mr. Gordon and his son. Hopefully with Mr. Gordon'e oooperation that type of limited vilitation in the future can be broadened, but, however, based on the report at thil time the Court direots thet the father only have supervised visitation with hiB Bon approximately two hours one time per week, and hops fully visitation will be at the Carlisle YWCA or the Harrisburg YWCA. '.. 'I i ,.~. C. I .. III' (j , ~ /',".' I' ' , I, ( ,. Ii,) , c- , I ,~ t.'. ~I t... .. ',. .... sf II fig 'H .... ~ !I .... ~ " ... .~ e: .... 8 I- al if 'e ~ ... I . .~ . 8... ... .. ... u il ~i p . '... ,.. ... " ..::l QI '" j'" III '" I " I .... iJ. i (:. . m Ii ~ .. /!!l ~ . ,I.f j i V,i I, ' .., L 'i ~ \. on 21 Augu8t 1996 granting the Defendent 8upervlsed visitation, a copy of which Is attached to thl8 report. The Plaintiff belleve8 that the supervised visitation should continue. She does not believe thot the Defendont hos resolved his problem8 and thinks thot tho Defendont stili has e personellty dl80rder. The Plolntlff oleo relatod thot the child had suffered obuse ot the hands of the Fother previously which resulted In the supervised visitation order. Plaintiff indicated that she wanted him to continue to attend 8upervlsed visits with Inner Works for a period of six months, and she would then consider If It wos appropriate for him to hove unsupervised vlsltotlon. 6. The Defandont's position on custody Is as follows: Defendant believes that he Is capable of hovlng unsupervised visits at this time. He wants to heve a regular schedule with the child which would Include evary other weekend and shoring the holidays. He was willing to compromise et tha conciliation by agreeing to pheslng It In with no overnights for 0 period of six months, end then gradual overnights leading up to every other weekend. The Defendant molntelned that he Is continuing to go to the V,A. Hospital In accordance with the previous Order, and thot he currently resides with his Honcee', and her two sons, Corynne and Cody, who ere eight and six years old respectively, as well as their new child, Devin, who Is seven month8 old. He wants to have Chrl8topher Involved with that femlly. 7. Need for seperate coun8el to represent child: None. 2 8, Need for Indep.ndent pIvchologlc.1 evaluation or coun..llng: Both partlel Indlcatad that thev could not afford another evaluation. The Conciliator doel fsel that an evaluation maV rBlolve thell IIIUII, but Ilnce thev cannot afford It economlcallv, there Ie no other choice but to lend thll cele to the oourt for a hosrlng. 9. A haerlng In thll moiler II o~pocted to take one-helf dav. 10, Other mellerl and comment I: The Defendant hed a verv r8ltrlotlve Order 21 Augult 1996 that provided him with lupervlled visitation. It eppeered from the Ordar that the goal was to have him ox pend thll time end the Order speclflcallv IndlcatBl that ha had to continue with his counlellng selslonl. The Defandllnt presanted hlmlelf to the Conciliator suggesting thet the time hed come lor him to have unlupervlled vllltatlon, while Mother It III protaltl having supllrvlled vllltetlon. Thara II ablolutelv no communication bat ween the partlel. Mother luggeltl that the Father harallel her when thev see one another, end thereforu relulel to provide him with her eddrell end her phone number. Fether of courle denlBl herelllng Mother and complains thet he cennot even have phone accell with hll child. The Court will have to determine what her or not Father h81 relolved lome of hll probleml luch that he Ihould obtain unlullervlled vllltatlon. If the Court determlnel that the Defendant hili addra...d lome of hll probleml, It mav be 3 . , -, " I 't,' ;, . .. .. ~ I' . ' " ",I't :, . ','1 nj , ' I ,I,t' "~I 1.\/ , , '.' . I .: 1 ~. ',I I ~ " ~ t ' ,,' \,.,( ;1." ',I' i" , , . AHOlLA GOIDOM, '1a1ntUC , IN TBI COURT or CONNON PLIAI 0' , CUMJI..UND COUNTY, 'INNIYLVANIA , , QlYn ~OTloar - LAN , , '.-1117 OIVIL TaaM , nr CV'TODY I, , " TBlODOU P. GOIDON, III, DehAdellt , :." ., nr p, TlllPoaAIlY CV'TODY U'''NCJIDWIT. .,':, PiPU Q" ~9p1lT AND MOW, tbis 21.t day of August, 1"1, a h.ariaa was ..t toclay ou a p.tiUon ~y the bthu to IIOdUy th. pr..ut .. puUal auatQCIy uruggaat. that be baa with bJ.. .ou, Cbd.topber M. /JoI'dOA, wbo wa. bon ou 'eptUlbu 11th, UII. Both partie. all" repr..ut.d by oouneel today. Th. partie. were able to r.aall a t.-porary agre..-at without a bearing being required" u4 the alJl',~t it a. Collow., 1. Motlaer .ball oOAtinue to bave priaary pby.1oal auatody of tbe1r 'OA, Cbr1.topber, b1. birth date ~.iDg a. DOted, above. ' . ',. ,11. : , 2. 'l'bue WIl. a P'fobologiGal evalut10u oonduot.d OA Theodore .. /Jordon, III, tb. cather of Cbr1.topber, wbiob payobolog1oal w.. preparad ~r .ruoe l.lly, M.A., '8DDIflveoi~ L1olA.ed .efoholog1.t, aDd it wa. bie reo,: -'Ddat1ou that at th1. tta. eupervieed vi.1tatioA only be p~rai.tted b.twelA 1&&'. /Jordoa u4 au. 'OA. Hopefully with Mr. /Jordon'e oooperetion that t~. "'- ~ limited v1.itetiou in the future oan be broedaned, but, however, bleed on the report at this ti.e the Court direot. that tile 'atllu oalr ban 'Vi'lI~'Yi..cI vbiutioa with bJ.. eou IIlproact,..'dr two Iao\&l" oa. tta. P'" _ek, and hopefully I v1.itatioa will b. at the Carli.l. YWCA or the Harrieburg YWCA. > ,f1.>." '",~~ i I J.:~" ,~~;.;~.,~.., 1'....J'i\.~'},'.. I....I\.,\~,. th..... b a; 'abal'g. t~ ba ..da fa&' the.. auparvhed vidt., th. . ' , 9barg...':l(~~'~~~~~~ ~ ~a~e~, t'i - J. ~. fatbn eball be p.ra!tt.d to bAve two pbODe'oalll w1tb Cbr11topher eaoh weak. .aoh pboDe oall to lalt " j I', ~)I, ',', ' '. , . . ..;' . ,.,It I "1 I, DO lODger ~ 10 or 15 .!Qut... Tbe pboDe oall lball be i.DJ.tbt.d by the IIOther, aDd the Unt four pboD. oelll OaD be ~"PRV!_:"'~',the'IIO.~~,~f a.bs ,4e,~.1I'el to do.lo. ne CQurt w111 nta~ ~ud.d10t1OD, lUlcS upOD a patit!OD ba!Dg fils4 will hold a baar1Dgat a lat.r elat.. Th. court woul4JI\1so direct that Mr. Gor4oD oODt.lDue bh oOWlleu'q ....L~ al pPW.prov~.br tha V.tlraD. A~_ffti.tratiOD. , I ..",'. ~ " \' ' .' . '1' J~,J:. .,:<ji.lo'~:: '8y t;bsl~t, .' "',,i)t, ',", " . , ' ,.., ' "~.''il'"'' '. f:,",l.~'.I.; ..... " ,I, ';..i,,'.,~, f= II' ",., \ ~ '1'1 '." , f I ""1" A . ..4o ". . ,. - .,It...." '. Me I.." .', ..iI. . . \.. . , .' " I'L . " ",: " ~~",'''''. ,'''1 r;:." :..,,," '~:'" 1 ' ,L,I(I"""~ \'''' ,...t. d..".._. ~..,..... ...I....<....;.\\,. I ; ;~;:..~' ~l..~.::!~Ls4~UO_~~.I.~.lDlf'i'~.' ",,'~ .",. /' If1'l"'I' .....11' '.'.'" ..l~.l.." '.' ~' .... .' . t " , , \",11.<1"" '~f4. ..I .~;.~.It i' ,11,.,_ ~ ".!l~~ooa 'Il\IfU.';"I.~"". . ~;.~ .. lo&' tb..!Pt',~~ftt . , .. ,I.. 1 . r-. .'j ,,~,..' ~I"I .. .' ,.,. 'I. ." oJ' ' I ,~ " ~ j'o#" , ~ '1 . 'f ,.' ft- ,I \ ,', -.1 ., ."",':,' , I oi I"'f' ."1 '~l ' ''','' "~'I ~ l4;. .... "-1!. ~ .41>,;' , ~II . :- ~ t ' , i .. ,. ",lo . \"', ;,.' " . . 'I,!:\, "'I ',lV.t.' ,i,~"", .' ,I "..l" ,. ... ~' '" '. , I ,:., '. '. -lit", , , ,,;,iollL. .' '. qf", '.~ \, " ' , . ,~:-,,; '\'-\ 1 . .',: " lJi""'l"" . .. ,'- 1.....-..,:;' , " "-W .1,' . , .... ............,,~~J...H -\.\1 j I"", . ....... . ., . ;cl.fl'..... .. '. .," '1014 ' ' I,," I 4" ~.'~1j;,. .. " . . . " '. . .., ,I .' . . . ..~ f.,t . ~ ,/ , . . , TRUE C'lPY FROM RECORD In T,.l rn~'l' . ',of, I hw. unlo ..I my hand end the ~ul of said Court al CarUI'e, Pa. . Thl....Q.~~~y . .Of...~..~ __'9..,2't. ...............,~..~;~ih~~.~- . " t- , " .w f ;j;\ ' J~ .- ~ " . " t, , . ,.. ' .-;l~'" ',. ,.., ..W~I"~." ' . 'f ....'}f It., '~ " ,.. .,'tl,,":~'~'!~~'J ,i ""'l~,,~::l.~..~ 't, .'. . , '.' .... t '"', , > ~,_..,....:.t.l..'J'f ".J ~;t.:.'" \:..i ',,, , ~ ~ '. ,J .J.. " ,\, 'I " , \.....t: '-'. t' '(~,., I II. .' I' ij,w," .. I. ~ ,-, ..~~.,:; "". 'I" , :'1. "1.' " .' I .. w t t, . " ,.' ,. ", ,~ . ,'. .' . ',. '" " . 'bitt-.,., . 1-' -I: ' I' I ",,,. ,~..;.",\,." h.'l '~4-..1 '-'t. ,. ., :. .. .' '. ~. !. ANGBLA GORDON, I IN THB COURT OF COMMON PLBAS Plaintiff I CUMBBRLAlID COUNTY, PENNSYLVANIA I v. I NO. 94-3637 CIVIL TBRM I THEODORB P. GORDON, I CIVIL ACTION - LAW Defendant I IN CUSTODY ORDBR ,If AND NOW, this ~ day of 199...k., b.c c c ~ ~ ..l-.{.....---. IT IS HEREBY ORDBRED AND DBCRBED that the Custody Agreement entered into between the parties and attached hereto as Exhibit "A" is hereby approved by the Court. BY THE COURT, ~GL( ~ll~ . 4l. . OLD E. SHEELY, . J . Iii i ;~(nICF ',' ." "t,J !If'; I %nn:~o WIOI?7 el',1 '., ,." ''''''1'' \fh-,~_.!,I.!, -tt:.i l;.yl..-",_ I f'll!'." ,If"" .. _""'~ II, 1.,f\ " .. . . " 3. Fllther Ihell heve periods 01 pertlel cUltody with the Child et the following timet: I. Ev.ry other weekend from 6:00 PM Friday evening until 6:00 PM SundlY evening. b. One 111 week 01 v.cetlon during the cllendlr veer of 1996 end two /21 weeks of vlcltlon every cllendar year therelfter. Fathsr Ih.1I give Mother It 1.lIt thirty /301 day. written notlc. of the d.t.. during which h. wlllu.rcl.e laid period. of p.rtlel cu.tody, 4, Flth.r egrll. to me.t with Chrlstoph.r'. school p.ychologl.t end .chedule thre. /31....,on. with a psychologl.t of hi. own choice. Th. purpo.. of the meeting. Is to eddrell Chrlstopher'lottentlon dlflclt dl.ord.r. It I. .peclflcllly agreed thot the Fother's cho.en p.ychologl.t sholl not be coiled by either pllrty el 8 wltnell In ony further Iltlgltlon In thlslllalter. 1he partlee ogree thot completion of the three (31 sessions with the plychololJlltll /I prarequlllte to Fath,r'. pertllll cUltody rights liS Bot forlh IIbovlI. The partlelare to evenly Iplll the cost of the psychologist. Flther sholl only bo entitled to periods of partial cUltody every Baturdey from 3:00 PM until 7:00 PM until IIIld .elllon. 1111 completed, and a report Is provided to Mother Indicating that Father has oompleted /llIthrae (31"lIlonl, and Indicating that Father d, Thll holiday lohedule IUllorledol other perlodl of primary or partlnl oUltody al set forth In othor paregrllphll e. The nbove provisions mDY be modllled by mutual oonlent of the partlBl. 6. The Ilorllel sholl altornate cUltody of the ohlld on Chrlltmal Eve through 12:00 PM Chrlltmas Day end from 12:00 PM Chrlltmal Day through 9:00 PM Decembar 26. This holiday schedule sholl supersede other periods of primary or perllal custody os sot forth In other paragraphl. Mother Ih.1I have ouslody on Chrlstmal Eve 1990, with the holidays alternating thereafter, 7. If either party Intonds to remove their resldance from the Commonwaalth of Ponnaylvanla, sold party agrees to give three (31 monlhs written notloe to the othar party of thalr Intention to remove their relldence from the CommonwBBlth of Pennsylvania. If elthor perent II taking tho child from his/her relldence for a period of time In excoII of 48 hours ha/she Is to provide the other with the eddre.. and telephono number of where the child will be staying. " B. Each party sholl be ontltled to reasonable telophone privileges when Child 18 In the custody of tha othor party. Each party shall provide tho other party with telophone numbars of alllooallonl where Child will ho whllo In Ihalr custody 10 as to facilitate ollorclle of tlllephonn prlvllegOl by the other pllrty. F!i, , F'''''\'' ,l n._ ~l~it:1'-~J:l'ii;X~:~\},':- ': ....... ::::,",~kj.,'.'~' '..-':" "..~.. , ~",-.',,,,il i"1'.;'....iiiii.:'d;ir'" ,tiW;."'''iI.~!JJifI''ii';w: ~, .', " I.; - OF ~TNff 9& DEe 23 PM 31!iZ ~:: :--, ",. " "."." CUMUI:HUN:J LUvlHY PENNSY\.VmA . , , " .I" '. . . '''l''i-'''~~'''t'-''~--~.''''-- I'. , A . " f , , i ~. .~'!!'-- .~ '.:".-.-. ~ .."..,'l...., '. -_.l;i",;:,?!,,'f. ~ '1 ',I H f~ i [ r' !' i I i , , , I''! " I <;I , .. . ' " 1: , ANGILA GORDON, I IN Till COURT or COMMON PLEAS Plaintiff I CUMBBRLAND COUNTy, PBNNSYLVANIA I v. I NO. i4-3537 CIVIL TIRM I THBODORB P. GORDON, I CIVIL ACTION . LAW Dehndant I IN CUSTODY NOTION TO APPROVB CUSTODY AGRIININT AND NOW, comes Defendant, TIlEODORE P. GORDON, by and through his attorneys, Knupp &. Kodak, P.C., and rupectfully repreeents I 1. Plaintiff filed a Petition for Modification of existing CUBtody Order in the above matter on or about March 29, 1996. 2. A Custody Conciliation was schedUled for April 1, 1996. 3. A hearing was scheduled in this matter for June 21, 1996. Said hearing was continued generally by Order of this Court dated June 26, 1996, 4. The parties have come to an agreement I'll to all pending iIlsU811. A copy of said Agreement 111 attllcned hento .. Exhibit "A" and incorporated herein by rehrence. 3. Father shall have periods of partial oustody with the Child at the following times: a. Every other weekend from 6:00 PM Friday evening until 6:00 PM Sunday evening. b. One (11 week of vacetlon during the calender year of 1996 and two (21 weeks of vacation every celendar year thereafter. Father shell give Mother at least thirty (30) days written notlca of the dates during which he will exercise seld periods of pertlal custody. 4. Father agraes to meet with Christopher's school psychologist and schedule three (3) sessions with a psychologist of his own choice. Ths purpose of the meetings Is to address Christopher's ettentlon deficit disorder. It Is specifically egreed thet the Father's chosen psychologist shall not be called by either party as a witness In any further litigation In this matter. The parties agree thet completion of the three (31 seBBlonB with the psychologist IB a prerequisite to Father's partial custody rights OB set forth sbove. The portleB ore to evenly split the cost of the psychologlBt. Father shall only be entitled to periods of partial custody every Saturday from 3:00 PM until 7:00 PM until Bald seBBlonB are completed, and a report IB provided to Mother Indlcatlllg that Fether has oompleted all three (3) sesslonB, and Indloatlng thet Father d. This holiday schedule supersedes other periods of primary or partlel oustody os set forth In other peregraphs: e. The ebove provisions may ba modified by mutuel oonsent of the parties. 6. The parties shall alternate custody of the child on Christmas Eve through 12:00 PM Christmas Day and from 12:00 PM Christmas Day through 9:00 PM Dacembar 26. This holiday schedule shall supersede other periods of primary or partial custody as set forth In other paragraphs. Mother shell have custody on Chrlstmes Eve 1996, with the holidays alternating thereafter. 7. If either party Intends to remova their residence from the Commonwealth of Pennsylvania, sold party agrees to give threa (3) months written notice to tho other party of their Intention to remove their residence from the Commonwealth of Pennsylvania. If either parent Is taking the child from his/her residence for 0 period of time In excass of 48 hours he/sha Is to provlda the other with the address and telephone number of where the child will be staying. ~ Ij 8, Each party sholl be entitled to reasonable talephone privileges when Child Is In the custody of the other party. Each party shall provide the other party with telephone numbers of alllocatlot1s where Child will ba while In their ouatody so as to facilitate exercise of telephone privileges by the other party, ~.."..".- . CI~~ 96 ore ~ 3 f"~' ~z ~~NW @ .. '71ftZ".... ~<t 1b./3019'- ,.J.(J . ...' .~ ~. f , ~ '. ! '. , , " ~ . . . -- .~~' t'