HomeMy WebLinkAbout94-03767
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JEANNE M, TRITT,
PLAINTIFF
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IN THE COURT OF COMMON PLEAS OF
CUMijERLAND COUNTY, PENNSYLVANIA
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94.3767 CIVIL TERM
I,:,
RONALD L. TRITT,
DEFENDANT
IN CUSTODY
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AND NOW, this q.,... day of December, 1994, IT IS ORDERED:
(1) The temporary order of September 26, 1994, Is vacated and replaced with
this order,
(2) Jeanne M, Tritt and Ronald L. Tritt shall have shared legal custody of
Jason Tritt, born July 1, 1986, and Ambyr Tritt, born November 13, 1988,
(3) Until the mother establishes a residence In the Big Spring School District
during this school year whereby the children will not have to change schools, the
mother and father shall have shared physical custody of Jason and Ambyr, The
father shall have the children from 6:00 p,m, each Saturday until 6:00 p,m, each
Wednesday, and the mother shall have them from 6:00 p,m, each Wednesday until
6:00 p.m, each Saturday,
(4) The mother shall have primary physical custody of Jason and Ambyr If,
during this school year, she establishes a residence In the Big Spring School District
that will allow the children to complete the school year In their current school, If that
occurs, the father shall have temporary physical custody on alternate weekends from
Friday evening at 6:00 p,m, until Sunday evening at 6:00 p,m" or until Monday
evening at 6:00 p,m, If Monday Is a school holiday, If the mother Is working on any
of her alternate weekends, the father shall have the children during any time she Is
working If he makes arrangements with her at least two days before, The mother
shall keep the father advised, In advance, of her work schedule,
(6) During summer school vacations, the parents shall each have Jason and
Ambyr for alternating weeks,
(6) The mother and father shall make special arrangements during the
Christmas season so that each have the children for some period during that time,
(7) If the mother does not move Into the Big Spring School District by the start
of the 1996.96 school year, and stili seeks primary physical custody by that time, a
further hearing before this court will be scheduled upon her e ueal.
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Robert L. O'Brien, Esquire
For Plalntlff
Thomas J, Williams, Esquire
For Defendant
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JEANNE M, TRITT,
PLAINTIFF
V,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94-3767 CIVIL TERM
RONALD L. TRITT,
DEFENDANT
IN CUSTODY
BAYLEY, J., December 9, 1994:--
At a hearing on this custody case on November 30, 1994, the evidence was as
follows, Jeanne M, Tritt, age 27, and Ronald L. Tritt, age 31, are the parents of Jason
Tritt, born July 1, 1986, and Ambyr Tritt, born November 13, 1988, The parents were
married on March 29, 1986, and separated In August 1994, Elght-year-old Jason Is
In second garde, and slx-year-old Ambyr Is In afternoon kindergarten, at the Oak Flat
Elementary School In the Big Spring School District. Both are In good health,
The father Is a dairy farmer and the mother a factory worker, They are both
high school graduates, They rented a 143 acre farm eight years ago, a few months
after Jason was born, The father continues to live In the marital residence on that
farm which Is In Newville, Cumberland County, Each child has a bedroom In that
home, The mother Is temporarily living In the home of her brother, Robbie, age 29, In
Pleasant Hall, Franklin County, At that three.bedroom residence, Jason has his own
bedroom, The mother sleeps in Ambyr's room, except every other weekend when
the brother's daughter visits and stays In Ambyr's room, The mother sleeps on a
couch during those visits,
The mother did not work outside of the home for six months after Jason was
94.3767 CIVIL TERM
born, She then started factory work at GS Electrlo, A cousin cared for Jason while
she worked, The mother was laid off just before Ambyr was born, She started caring
for three other children In her home when Ambyr was about four months old, She
continued that child care work until October of 1993, when she started factory work
at General Mills, She worked four days a week: three twelve hour days and one six
hour day, When she worked, the children were always cared for by a family member
other than the father, The mother has since changed employment to the Carlisle Tire
and Rubber Company, She now works on three cycles, She works one cycle of
seven days with two days off, on shifts of either 2:30 p,m, to 10:30 p,m" or 10:30
p,m, to 6:30 a,m, Then she repeats that cycle, The shifts do not change within each
cycle, although they may change between the cycles, The mother theu works five
days from 6:30 a,m, to 2:30 p,m, with five days off, after which she starts the three
cycles again,
There Is no dispute that the mother has been the primary caretaker of the
children, The mother's complaints about the father spending too much time working
on the farm and not enough time with his family are the root-cause of the marital
breakup, The parties had a trial separation from April through June, 1994, when the
father moved out of the marital home, He continued to work on the farm during that
period and did see the children, He started living In the marital residence again In
June but the marriage was not salvageable from the mother's point of view, so she
separated In August. She testified she would have stayed In the marital residence If
.2.
94.3767 CIVIL TERM
the father had not moved back,
The father testified that for years he did spend most of his time working seven
days a week from early morning until late at night, with little time for his children, He
stated that finances were extremely tight In that he and his wile had started out with
nothing, It took five years to pay for the purchase of his cows, and until this year to
retire some other substantial debt lor equipment. The family seldom went places
because of the hours he worked and the fact that they had little money, The father
testified that he wanted to spend more time with his family, but the debt load was
always on his mind, Since early 1994, the lather has taken more Interest In and
responsibility for the children, which the mother acknowledges, The father has given
up cultivating 75 additional acres that he rented In order to grow crops to support his
dairy herd, He has stopped working late at night, and on Sundays except for two
mllklngs,
Following their separation, the parents made a temporary agreement pending
litigation of this custody case, The father has the children lrom 6:00 p,m, each
Saturday until 6:00 p,m, each Wednesday, and the mother has them from 6:00 p,m,
each Wednesday until 6:00 p,m, each Saturday. When a conciliation conference did
not produce an agreement, that schedule was entered as a temporary order on
September 26, When the lather has the children each Monday, Tuesday, and
Wednesday, he gets them off to school on a bus and meets them when they come
home on the school bus, The children spend a good bit 01 time with him In the barn
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94.3767 CIVIL TERM
while he works the remainder of the day, normally unlll 8:00 p,m, He takes them to
Sl'nday school on most Sundays, and they have dinner at his mother's on Sundays,
On the Thursdays and Fridays each week when the mother has the children
and they go to school, the children get on a school bus and come home on a bus
from their maternal grandmother's residence In Newville, That house Is about sixteen
miles from where the mother lives In Pleasant Hall. When the mother works 2:30
p,m, to 10:30 p,m" she puts both of the children on the school bus, The children
stay with their grandmother when they arrive home, When the mother works 10:30
p,m. until 6:30 a,m" she goes to her mothers In the morning after work, She puts
Jason on the bus and Ambyr on the bus for afternoon kindergarten, The mother gets
both children from the bus after school. When the mother works 6:30 a,m, to 2:30
p,m" the grandmother puts Jason on the bus In the morning and Ambyr on the bus
In the afternoon, The mother picks them up from the bus when they come home
after school, which Is always at about 4:00 p,m, When the children are with the
father on school days, they use a different bus that stops at the farm,
The mother plans to move Into the Big Spring School District as soon as she
finds adequate, affordable accommodations, She Is earning $200 a week, t However,
even when she moves, she stili plans, because of her work schedule, to use her
mother for child care and her mother's residence as the plck.up and drop.off point
1, The family Is without medical Insurance, The father used to carry medical
Insurance but dropped It because of finances, In January 1995, medical Insurance
for the mother and children will become available through her employer,
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94.3767 CIVIL TERM
for the school bus.
Both parents seek primary physical custody of Jason and Ambyr, In
establlshlno a custody order, the test Is what Is In the best Interest and welfare of the
children, ~,529 Pa, 198 (1992), Positive weight should be given
to the primary care provider, ~,393 Pa, Super, 256 (1990), The work
schedules of both parents make It difficult to adequately provide the care the children
need without the assistance of others, The mother has a good arrangement with her
mother to fill In those gaps, The father, who has Just recently begun devoting any
considerable time to the children, always has to work long hours on the farm, even
when the children are under his direct care, Although It Involves some travel between
the mother's home and the home of her mother, the stable care and direction the
children need during the school week Is best being provided through that
arrangements, We are satisfied that the overall care the children need can best be
provided by the mother, who has been their primary care provider, Thus, we are
satisfied that the mother should have primary physical custody of Jason and Ambyr,
The mother's temporary living arrangements, however, cause us to delay the
start of such an award, Since the mother Is living In her brother's home In Franklin
County, starting her primary physical custody now will mean the children will no
longer be legally able to attend the Big Spring School District, at least without a
tuition payment which this family cannot afford, Since these young children have
obviously been affected by their parent's recent separation, and since they have
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94.3767 CIVIL TERM
gotten a good start Into this school yoar, we do not believe It Is In their best Interest
to enter an order that could result In a change of schools while they are In their
current grade, Furthermore, the mother has no plans to send the children to school
In the district where she Is now living, Therefore, we will malntaln the current shared
custody arrangement during this school year unlllthe mother establishes a residence
In the Big Spring School District. If and when the mother obtains primary physical
custody, we will provide the father temporary physical custody on alternate
weekends, and at times during the mother's weekends If she Is working, There Is no
reason why the children should be with an alternate care provider during those
weekends when the father can be cementing a strong relationship with them, which Is
In their best Interests, During each summer school vacation period, we will provide
the parents with alternate weells of temporary physical custody,
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AND NOW, this q ~ day of December, 1994, IT 18 ORDERED:
(1) The temporary order of September 26, 1994, Is vacated and replaced with
this order,
(2) Jeanne M, Tritt and Ronald L. Tritt shall have shared legal custody of
Jason Tritt, born July 1, 1966, and Ambyr Tritt, born November 13, 1966,
(3) Until the mother establishes a residence in the Big Spring School District
during this school year whereby the children will not have to Change schools, the
mother and father shall have shared physical custody of Jason and Ambyr, The
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94-3767 CIVIL TERM
father shall have the children from 6:00 p,m, each Saturday until 6:00 p,m, each
Wednesday, and the mother shall have them from 6:00 p,m, each Wednesday until
6:00 p,m, each Saturday,
(4) The mother shall have primary physical custody of Jason and Ambyr If,
during this school year, she establishes a residence In the Big Spring School District
that will allow the children to complete the school year In their current school. If that
occurs, the father shall have temporary physical custody on alternate weekends from
Friday evening at 6:00 p,m, until Sunday evening at 6:00 p,m" or until Monday
evening at 6:00 p,m, If Monday Is a school holiday, If the mother Is working on any
of her alternate weekends, the father shall have the children during any time she Is
working If he makes arrangements with her at least two days before, The mother
shall keep the father advised, In advance, of her work schedule,
(5) During summer school vacations, the parents shall each have Jason and
Ambyr for alternating weeks,
(6) The mother and father shall make special arrangements during the
Christmas season so that each have the children for some period during that time.
(7) If the mother does not move Into the Big Spring School District by the start
of the 1995.96 school year, and stili seeks primary physical custody by that time, a
further hearing before this court will be scheduled upon her request.
.7-
94-3767 CIVIL TERM
Robert L O'Brien, Esquire
For Plaintiff
Thomas J, Williams, Esquire
For Defendant
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,IEANNE M, I\II.UNGlm,
I'hllntllY
IN TIlE ('OllltT OF ('OMMON I'U:AS OF
('IIl\1UEllI.ANU ('OlIN'J'\',I'ENNS\'I.V ANIA
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<'1\'11. ACTION - LA W
ItoNAW I.. TllIT'!',
IMtndllll1
NO, 94 - 37(,7 ('1\'11.
IN ('IISTOU\'
<:oUlrr OIU>!':H
ANI) NOW, Ihl~. JI/(J da)' of March, 21KI3, ullon cUlIsldmltlollof Iht IIl1l1chtd Cllstody
CUllclllllllollltcllOI1, Ills ordtnd ulld dln-cII'd liS fulhmsl
I. A heurlllll Is scheduled III CIlI1I1roolll N!I, 2 <<,If Ihl' CUlllherlulld COIIIII)'
CuuI1hollse UII Ihl' jf It. dll~' uf ..J.t'I,( 1.___..._________. 2003, III
/, 3(0 _ ~~,I\1. lit whkh IIl11e Il'sthll IIY will hc lukl'lIIII Ihe uhuve clIse.
At this hearlllll, Ihc Fllllwr, Ilullllld L. Trill, shllll hc IIIl' 1II00'IIIIIIIUI1)' alld
shull IlrUCl>M 1IIIIInll~' wllh IcslhIlUII~', Cclllllscl fur thc (III 1111'S shllll file wllh
Ihe cOllrt IIl1d Ollllushlll colIlISel II IlICIllIII'IUuIIllU sclllllll furth the hlslory of
e\lslod~' III this cnsc, the Issues I'IIITCIIII)' hcfol'e the cOllrt, I'llch Illlrtles IIOSltloll
011 these ISSIII'S, II list of wllllesses who will he l'lIlIed to tcsllf~' lit the hearlllg
ulld II SIllIllI1lIIJ' IIf the llllllcl(llltl'd leslhllulI~' of I'llch wltlless. This
lIIel1l0l'lUIIIIIII1 shllll he flied III Il'lIsl Ihe (5) dll)'s (11'1111' tll the l1Iellllolled
hellrhlll dllte.
2, I'elldhlll fllrther IIl'der uf this 1'1lI111, Ihls l'ullrt'S Ilrlol' Ill'del' UIII'IIStod)' shull
remulnln efTl'!'t.
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ThomllS J. WlIIlllms, I~sllnlre
Itobert L. O'Brien, ESllnlre
II\' TilE COUll '
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I IN TilE COlllrl' OIl COMMON I'I.!-:AS Ofo'
ClJI\IIIEIU.ANU ('OllNTY.I'ENNSVI,v ANIA
CIVIl. ACTION -I.A W
.IEANNE 1\1, KII,L1N<mlt.
1'llIlnllO'
IUlNALI) L. TIU'J1',
Uefendllnt
N().l)4 -37(.7 CIVIL
I IN ClISTOUY
1'1'101' .hulgel Edgllr n. nll~'le~'
{;QN~II.!A l'lQN rPNn;!mN<;!~slJ~ !MAIn'JUU'QH'f
IN ACCORDANCE WITtI TIm CUI\I\IE1U,ANU COUNTY CIVIl. RULE OF
I'ROCEUUlm 19I5.3-8(1I), the undersigned Custod)' Concllllltor submits the following
rellOrtl
1. After a custody eVlllulltlon. legal counse! for the Jlllrtles contacted the conciliator and
re1luested a hearing be scheduled. IIl1sed nllOn that re11llesl, the conciliator
rl.'Conllllends the entry' of an order III the forllllls Illtllched,
?/r/() 3
- nATI~ -
uti!- ((J
Ih.bert X. Gllro)'. Esquire
C..stod)' Conciliator
JEANNE M, Tlun
IN TilE COlmT OF COMMON PLEAS OF
CIIMIlEIU,ANIl ('()\ INTY.PENNSYLV ANIA
PLAINTIFF
v,
94-37(,7 ('IVII. ACTION LA W
RONALD L. TIUrl'
IlI!FI!NIlANT
IN ('I ISTOIlY
OIUlEIt OF ('0\ I It'!'
AND NOW, Frida)', JUII~ 28, 2002 _____,"pon considcration of the uttached Compluint.
it is hcreby direcled thut purties omllhcir resp~'ctil'c cooosel uppcur belilrc lIub~rl X, GUru)', .:111, , Ihe conciliutor,
at 41h ."Ioor, Cumberland COUIII)' ClIllrll!Ollle. Car!l!~ on Frida)', July 19, 2002 lit 8130 AM
for IIPre-lIeurillg Custody Confercncc, AI such conlerenCL', IIn cflintwill bc Illudc 10 resoll'e Ihe issues in dispule; or
if IhlS cllnnot be IIccolllplishcd, 10 dclinc IInd mmow Ihc issucs 10 hc hcurd hy the coort,lInd 10 cntcr inloll tcmporary
nrdcl'. All childrcn ugc lil'c Ill' older IllUY 1I1so hc present ullhc conlercncc, FlIilurc IOllppcur at the conference Illay
prol'ide grounds IiII' enlry of u 'clllpOrUI)' or pcnllllncnl nrder,
The courl herehy directs Ih~ III'rll~s 10 rurnlsh IIn)' uud all cxlsllnlll'rolecllon 1'1'011I AbUSe orders,
SII~c1al Ueller Inders, and Cuslod)' orders 10 Ihe conciliator 48 hours flrlor 10 scheduled hearlug.
FOR TilE COURT,
Ill': iii
ll1tllcrl..&.Gilray, Esqlflr
Cuslody Cuncilialor
The CourlofCummon Pleas otTul11bcrlllnd County is required by luw to cOI11f1ly with the Americans
with Disubilites Acl of 1990. For intil1111ution ubout uccessiblc lucilitics und reasonuble aceol11modatlons
ul'uilublc 10 disubled indil'iduuls hUl'ing business hclill'c Ihc court, plclIse contucl our ornce, All urrungements
Illust be Illadc at Icust 72 hours prior to uny hCllring or husiness hclilrc Ihc courl. You Illusl attend Ihe
schcduled conlerence or hearing,
YOII SIIOlJlJ} TAKE TillS PAPER TO YllIJR AtTORNEY AT ONCE, IF YOU DO NOT
IIA VE AN ATl'ORNEY OR CANNOT AFFORD ONE. (iO TO OR TFLEPIIONE TIlE OFFICE SET
FORTIIIlELOW TO FIND OIlT WIIERE YOII CAN (iF)' IHiALIIEt.t',
('Ul11hcrlUlId ('ounly Bllr Associlllion
2 Llher,y Avcnue
1'1Irlislc,I'cnnsyll'uniu 171113
Telephonc (717) 249.3166
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CAR-IlHf, l'fNNU1"ANI.\ 17111.\
JEANNE M, TRITT,
Pluintinmespollllent
IN TilE COURT OF COMMON PLEAS OF
CUMBERl.AND COUNTY. PENNSYLVANIA
v,
NO, 1)4.3767
CIVIL TERM
RONALD I.. TIUTT,
l)efellllunt/Petil ioner
IN CUSTODY
ORDEI~OF('OURT
AND NOW, this __ duy of , upon considerution ofthc ul\uchcd Pctitlon
10 Modify, it is herehy directed Ihut the purtics und Iheir rcspcctivc counscl Ullpcur bcfore
,thc conciliutor, ut
onthc _ duy of _ ___'_' ut ,Ill, for u Prc-Hcuring
Custody Confcrcncc. At such confcrence, un cffort will hc Illude 10 rcsolvc thc issucs in disputc; or
if this cunnot bc ucclllnplishcd.to dcfinc und nurrow thc issucs to hc hcurd hy thc Court, und to cntcr
into u IClllporury ordcr, All childrcn uge fivc or older IIlUY ulso hc prcscnt utthc confcrcncc, Fuilurc
to uppcur utthc confcrcnce IIlUY provide grounds for cntry of ntclllporury or pcnnuncnt ordcr,
FOR TIlE COURT.
By:
Custody Conciliutor
Thc Court ofCollllllonPlcus ofCulllhcrlund County is rcquired hy luw to cOlllplywith thc
Alllcricuns with Disubililics Acl of !I)I)(), For infonnution uhout ucccssihlc fucilitics und rcusonnblc
UCCol11l1lodulions uvnilublc to disubled individuuls huving business bcforc thc court, plcusc contnct
our officc, All ulTungclllcnls lIlust bc Illudc utleusl 72 hours prior 10 uny hcuring or busincss bcfore
thc court, You lIlust ullcnd thc schcdulcd confcrcncc or heuring,
YOU SIIOULD TAKE TIllS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO
NOT IIA VE AN ATTORNEY OR CANNOT AFFORD ONE. GO TO OR TELEPIIONE THE
OFFICE SET FORTH BELOW TO FIND OUT WIIERE YOU CAN GET LEGAL IIELP.
CUlllherluml Counly Bur Associution
2 Liherty A vcnue
Curlisle. Pennsylvuniu 17() 13
Telcphonc (717) 241).316(,
JEANNB M, TRIIT,
PlnlntllTlRcspondcnt
IN TIIB COURT OF COMMON PLBAS or
CUMBERLAND COUNTY, IIENNSYL VANIA
v,
NO, 94.3767
CIVIL TERM
(WNAW L. TlmT,
DefcndantIPctltloncr
IN CUSTODY
PEFENDANT'S PETITION TO MOplFY CUSTODY
AND NOW, comes thc Dcfcndant, Ronuld L. Trill, by ullllthnlUllh his ullomcys, MARTSON
DEARDORFF WILLIAMS & OTTO undl1les this I'clition us follows:
I, Defellllunt, Ronuld I., Trill (hereinatler "Petitioncr"), is un udult individuul residing
ut 77 Funn Roud, Newvillc, Cumbcrlund County, Pennsylvuniu 17241,
2, PluintifT, Jcunnc M, Trill (hcrcinutler "I~cspondent"), Is un udult Indivlduul residing
ut 728 B10scrvllle Roud, Newville, Cumbcrlund County, pcnnsylvuniu 17241,
3, The purties urc thc purents of Juson Trill, bom July I, 1986 und Ambyr Trill, bom
Novcmber 13, 1988,
4, On Deccmber 9, 191)4, this Court cntercdun Ordcr of Court grunting shured legul
custody of Michuel betwccnthc purtlcs, with Petltioncr huvlng pUl11ul physicul custody,
5, Respondcnt rcmurricd und thc chlldrcn, during her time of custody, reside with
Rcspondcnt, hcr husbund, und his 60n,
6, 11rimury custody with Rcsllondcnt und hcr ncw husbund is nol inthc bcstlntcrcsts of
thc chlldrcn,
7, PClitioncr rcqucsts prlmury physicul cllstodyoflhc chlldrcnus hc cun providc u stublc,
nurturing and sufc cnvlnlnmcnt for thcm, which thcy ure prcscntly lucking,
WHBRBFOIW, Pctitloncr, Ronlllll L, Trltl, pruys your Honoruble Court to Issue IIn Order
umendlng the Order oroeccl11her 9, 11)94 whcreln dlrcctlng thut he hus prhl1l1ry physlcul custody of
the children, Juson Trill, und Al11hyr Trill, und Respondent, Jellnnc M. Trill, sholl huve partial
physical custody oSlhe purtlcs muy IIgree, The hulunce onhe Decemher9, 1994 Order would rel110ln
In elTect.
Dote: June 20, 2002
MARTSON DEARDORFF WILLIAMS & OTTO
By ,,1k11'~ 1'\1 jQ~
Thol11os J, WIlIU IS, Esquire
Ten East High reet
Carll sic, P A 17013
(717) 243.3341
AlIomeys for Dcfcndont/Pctitloner
Ronald L. Trill
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YI!RIFICATlON
The foregoing Petition to MOlllly Custody is hused upon intbnnution which hus been
guthered by my eounscl in the prcpurution of thc luwsuit. Thc lunguugc of Ihe documcnlls Ihul of
counsel und nol my own, I huve reud Ihc doculllenl lInd 10 thc exlenl Ihul It is bus cd upon
intbl1l1utioll which I huvc givcn to my counsel, It is Irue lInd correcl to Ihc hcst of my knowlcdgc,
infl1rmUlionllnd hcllcf, To Ihc extcnllhutthe conlcnl of the documcnlis Ihul of counscl, I huve
relicd upon counsel In muklng Ihls vcril1cution,
This stutclllcnt und vcri !iculion ure mudc suhJcctlo thc pcnultics of 18 I'u, C,S, Section 4904
rcluting 10 unswom fulsil1eution 10 uUlhoritics, which provides Ihut if I muke knowingly fulse
UVCl1l1cnts, Imuy he subJcct to criminul pcnultics,
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Ronuld L, Trill
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WHEREFORE, Plaintiff/Respondent, Jeanne M. Killinger, requests that the Court
not modify the current Custody Order.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
'~.v.'
Robert L. O'Brien, Esquire
I.D, # 28351
17 West South Street
Carlisle, Pennsylvania 17013
(717) 249.6873
rlo,dlr/dom.ltlc/kllllnlllt,ln.
~
The statements In the foregoing Answer To Petition To Modify Custody are based
upon Information which has been assembled by my attorney In this litigation, The
language of the statements Is not my own, I have read the statements; and to the extent
that they are based upon Information which I have given to my counsel, they are true and
correct to the best of my knowledge. Information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa,C,S, ~ 4904 relating to
unsworn falsifications to authorities,
DATE:
~.), l/t2.
~ -'
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I hereby certify that on June n, 2002, I, Robert L. O'Brien, Esquire of O'Brien,
Baric & Scherer, did serve a copy of the Answer To Petition To Modify Custody, by first
class U S, mall, postage prepaid, to tha party listed below, as follows:
Thomas J, Williams, Esquire
Martson, Deardorff, Williams & Otto
Ten East High Street
Carllsla, Pennsylvania 17013
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Robert L, O'Brien, E8qulre
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.IEANN.: M. 1\1l.L1Nmm,
1'lMlnllrr
IN TilE COllin OF COMMON I'L.EAS OF
ClIMlmIU.AN\) COlINn', I'ENNSYLV ANIA
\'
CIVil, ACTION. LA W
IWNAI.I) L. Tlun,
IM~ndanl
NO, 94 - 37(,7 CIVIL
I IN ClIS'\'O\)\'
COURT OU\)ER
_._-_.-_!~----.,-
AN\) NOW, this 1-l~da)' of Jul) , 2002, ullOU cousldemllou of Ihe allnched Custody
COllclllallou ReJlOrt, Ills ordered und directed as follows:
I. The Ilal1les shall suhlllll IlIelllseln'S and the IIIlnor children to a cllslod)'
evaluallon to he IJerfonned II)' Guidance Assoclnll'S, Cosls of the evaluallon
shall be pllld fill' h)' Ih~ .'alher, nllllllld L. Tritt, excepl for those costs which
lIIay he conored h)' 1I111111cllhle Insumnce of either IIIIrt)'. The IlIlrtll'S shall
coopemle In Ihls I'\'ulullllon, Ilmducl' Ihe chlldrl'/I us required for the
e\'aluallo/l lI/1d IIlso Ilrlllhll'e II/1Y slgnlfll'u/ll olhers hl\'oh'ed with elIch
respectln 111111)' Ihal (Juldnnce Assoclllll'S fl'Cls /ll'Cds 10 he Involn'd 1/1 Ihe
evaluatlo/l.
2. UIIO/I cO/lcluslon of this cnslod)' I'\'alllatlo/l a/ld In Ihl' e\'I'/lt the Ilartles url'
lI/1ahle to reach U/l ugrl'Clllent 0/1 ClIslod)' ut Ihat tillie, cou/lsel for the parties
lIIay conluel Ihl' I'oncllllllor dlfl'CtI)' to schedule a custody 1'0111'11I011011
conferellce callaRer which Ihe 1'0111'11I0101' I'UII refer this lIIulll'r to COllrt for a
hl'arlllg.
3. Ilendlllll further order of this court, the cOllrt's prior order shall relllaln In
errect.)/
II\' TilE COlan. )
/
/.'
1'1'1 '-ji1ll1l105 J. WII11111115. ESlllllrl'
"r Itobert l., O'Brlell. ESllulrl'
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l IN TIlE COl!RT (W COMMON I....:AS 011
CllMIIEllLANIJ COl!NTV,I'ENNSVLV ANIA
CIVIL ACTION. LAW
.IEANN.: M, KILUNClEll,
1'llllnCl"
RONAW L. TR!'''''.
I)efcndllnl
NO, 94 - ,1767 CIVIl.
IN <lJSTOU\'
I'rlor Judgel Edgar D. 1I0,'le,'
~QNC!JJATJQ[Il CONI1E!m[llC~,~l1M~.AJ!Y RErQRT
IN ACCORDANCE WITH Tim CUl\lUEllLANIJ COUNTY CIVIL RULE m'
PROCEDURE 1915,3-11(b), Ihe undersigned Custody Conciliator submits the following
report:
l. The pertlneut Information pertaining to Ihe chlldreu who are the subject of this
litigation Is as follows:
~
HATE
Jason Tritt, bom Jul" I, 1986; and Ambyr Tritt, born November 13, 1988.
2, A Conciliation Conferl'nce was held ou Jul)' 19, 2002, with Ihe following ludlvlduals
In attendance:
The Mothl'r, Jeanne 1\1, Killinger, wllh her couusel, Robert L, O'Urll'U, Esquire; and
thl' Fathl'r, Ronald L. Trill, with his counsl'l, Thomas J, Williams, Esqu"'e,
3, The Mother currentl" hilS primaI')' custod" of thl' 111'0 minor cblldrl'n from on order
of allproxhuotel)' 8 ,'ellrs lillO, Tbe Fllther Is nO\\' SUllllc8tlng Ihllt at leasl one of thl'
cblldren Is l'XIJresslug 0 deslrl' 10 come 1I\'e with him, The IlOrlles IIrl' lu ollrccment to
have an e\'oluotlon done on Ihls Issue subject to thl' Flllher Incurrlug the cost with
reslll'Ct to the el'l\lullllon.
4. The concllllltor recolllmends the l'nll')' of IIn order In the lilrm as ottllched,
lIubert X. Gilroy, squire
Custody Concllla or
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Who Wus Sf. Putrid, :\II~'\\:ly'!
by Jane Lebo
SI. Patrick, the patron saint nf Ireland, is a
widely known figure in the Roman Catt olic r l-
ion but his life romains somewhat of (
,
What we do know is thnt he was born In r n to lam lilllsler 10 Chrislians already living in lre-
weallhy parents near the end of the fourtl~I1f""'lfIlIJ, '111(1 10 !le\llll to convert the Irish, Familiar
tury, At age sixteen, Pntrick was taken r""'V' "W1tT1 Irish lilll!)lJil[]e nnd culture, ho choso to In-
by a group of Irish rniders allncking his '- te trndltion into his lessons of Christianity,
estate, They took him to Ireland for si us bonfiros to colebrate Easter since tho
captivity, During this timo, he worked ( e used to honoring their gods with fire,
herd, outdoors away from peoplo, L III gh thore were a small number of Chris-
afraid, he turned to his religion lor solnc 1S the island when Patrick arrived, most Irish
ing quite a devoted Christian, d n nature-based religion, Irish culture cen-
Aller his years as n prisoner, Patrick esc, d on n rich tradition of oml legend 01 myth,
A voice he believod to be God's, spoko to him When considorod, it is no surprise that Patrick's lilo
telling him that it was time lor him In lonvo lro- became oxnggorBted over the conturies,
land ^ftlH nscapln[] to Britain, Palrlck mportud
Ihat he had a second vision; an angel in a dream
told him to Ifltllfn to Ireland as a missionmy, Pat-
ri(' egan wli[JlolJS training, v-hich lasted for more
ilt' n years. Soon niter, ho wns sont to lre-
School Board Prcsidcnt Speaks Wilh The Watchdog
by Desiree Scalavino
Mr. Wolf is the Board President of Big Spring School Dis-
trict. As a school board president, Mr, Wolf helps review
agenda in the school sctledule, and he also conducts and
coordinates meetings, Mr, Wolf, and the other members of
the school board, are there to provide the policy under which
the school Is conducted, Tho school board has broad goals
in store for our school district.
1m Mr, Wolf would like tho studonts
',' :::.~.... of the middlo school to know
'1 "'":::;r:l ~a what ho wants for thorn, "I care
I , that thoro Is a good opportunity
, for tho studonts to loam and get
a [Jood education," Mr, Wolf ad-
vises studonts to tako ndvflntn[J8
PlI1slIJenl 01 11m :icll/lolllo;ud, 01 illl school nnd oxtrn curriculnr
M, Wlllf oppoflunllins,
--~~- (Pf(!~ltlf'II' ,t;Jl"dK'j (O/ltlnu/'d IlI1 fl,l!}/.' ;'J
-, .., .... -, -, ... .., .., -. .., '.)
Insldo this Issuo of
tho Watchdog;
Pagos 2.3:
.Ar1s Festival
.ThentricHlly Well [Jane
Panos 4.5:
.Pellrl 01 the World
.Arc You I-LIP?
Panos 6.7:
,School News
.Sports
fillIos 8.9;
,Pnrty Dllncos
.^nswor Iino
Panos 10.11:
.Oig Spnn() lllVlil
,VOI(;US IIllllo I bll
..' '.. ..'
1'1 AltJllfF'H
IXIIIIIIT
Arts Festival
by Lauren Newman
On Wednesday, March 19, the Big Spring Mlddlo
School held its annual Arts Festival. 1\ was a won-
derful opportunity for tho BSMS parents to soo and
rocognlze the work that their sons and daughters
have accomplished in their arts classes, They were
welcomed with the smiles of the teachers and a froe
bag of popcorn, M,s, Piper put out some great art.
work of the students such as pottery, color wheels,
snow trees. and many other pieces, Dlsploys pro-
moted healthy habits encouruged by Mrs, Neidlin-
ger, Mr. Artz, Mrs, Kuntz and Mr. Stovor.
At 5:00 p,m, the select ensemble, conducted by
Miss Brophy, performed wonderfully, They began
with the favorite America Tile Beautilulto honor our
country and then wrapped up with Simple Gifts, Ayer
& Dance and the Strasburg Railrood, At 6:00 p,m,
Counterpoint had open karaoke, where many stu.
dents had as wonderful a time singing as many par.
ents did listening as they passed by, In the Tech.Ed
department, with Mr. Lewis and Mr. Kembring, stu.
dent work was on display. Mr. Mistishen shared a
computer display with some neat features,
Finally, Mrs, Showaker held her annual baking
contest, with some scrumptious looking and tasting
desserts I Mrs, Showaker claims, "Everything was
delicious and we're proud of your effortsl" As usual,
the Arts Festival was a big success,
Winners of the Bake A Cake Contest:
1'1 Placo: Lauren Kump-Peanut Butter Ice Cream
Cake
2nd Placo: Sara Porter-Orange Cream Cake
3'd Placo: Carly Stevens & Lizzy McElwain.
Cheesecake
Honoruble Mention To Those Who PartlcllJated:
61h Grado:
Saru Calaman
Madison Fisher
Tyra Hosfelt
Tyler Wonders
Mike Stoudt
Doshell Fittry
6"1 Grado:
Martina Bonos
Joromy Dunlap
1~(lY Smyser
'J
~
Shannon Chronister
Nathan Shoemaker
Felicia Lynch
Adam Stoner
Kelly Vaughn
Sarah Boncal
Desiree Scalvino
Sam Weyant
(I'wsilielll Speaks, colllillllOd lrom puge Ii
Mr, Wolf first started to get in-
volved at the PTO at Centerville,
His first term as school board presi-
dent began In 1981. The terms of
board presidency is for four years,
This is Mr, Wolf's fourth term, From
1990-1996, Mr. Wolf was not the
president of the board, Then In
1997 ho Jumped right back In and
has been the president ever since,
Mr. Wolf was only defeated once In
his career,
Mr, Wolf is most proud of raising
his family, He Is also very proud of
his decision to build the new high
school and his decision to close
down Centervllle and Jacksonville
schools and to build Oak Flat. Mr.
Wolf would like you all to know, that
no one can tell you how to run your
life, except you,
Thculrlcully Well nOllel
by Lauren Danleluk
On March 27, the eighth grade students
traveled to the Scottish Rite Cathedral In
Harrisburg to see five one act plays, The
first play pe~d as Tile Tell Tale
Heart," by agar Aim . ext, Tile Leg-
end of SI ~rJ,JIo(/o ,(!/1PJ nkey's Pow,
Tile Nec IElce, Jln inallt,' I Celebrated
Jumping '\Jg; df.Jc Vj1(!f 0 nly by Mark
Twain, ~'t~o of l~ strobe lights
were use Ivf~c 0 p Ii med all of the
different ro ' ,Ia'ea h pay, hey were well-
acted and enl ai n, ter the plays, we
were loaded on oar buses and then we
rode to various fast food restaurants to eat
lunch, The students enjoyed the experience,
thanks to organizers: Mrs, White and Ms,
Barnett,
F. y,l.
Due to the snow days in Feb-
ruary, school will be open
April 17th, There will be a half
day on April 18th, School is
opened on the 21 st of April
as well.
lIuwling Fur I\hl's Sukl!
by Emily Seltz
On Sunday March 30, the members of the Na-
tional Junior Honor Society participated In the
Bowl-A-Thon for Big Brothers, Big Sisters, This
very successlul event was held at Midway Bowling
Alley,
Each member was required to raise $75 to be
able to participate, At the bowling alley, the memo
bers received a free T.shlrt, mug, 2 games of bowl-
Ing, pizza, snacks, and a soda,
All together tho National Junior Honor Society
raised $ 2,415,50, Somo top money raisers were
Emily Seltz with $1 GO and Kendra Sheaffer with
$140.00 Big Brothers, Big Sisters goal lor the
Bowl.A-Thon this year was $32,000, The mem-
bers of National Junior Honor Society helped out a
great deal In reaching this goal,
President of NJHS Kate Manna said," I think
the bowl-a-thon was a groat success, and it felt
good to know we wore helping out our community,"
As you may remember. during lunch tho NJHS
membors walked around with coffee clIns asking
for your spare chango to donntn to tho howl-a-
than, You donated
$208.981 The members
of NJHS would like to ( ((
thank everyone who
chipped In, and helped
make this successful.
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I\IIIHII 4 llutol4
by DilIlIollo Dolin Voccllln
As 1I10s1 01 yuu plohnhly ~IlUW hy IlOW, wu hllvu
'UU/ OWII slar loarlllll[1 1110 hulls 01 tho 1I11dlllll
selloul MIS Nuidlrllgur, i'hys Ed tooehm, SIll/lOll
In II COlllllllJlelUl fur thu lunuwnull lU/nilU/o SIOIO,
N,I3 Liubll1ull To Ihu [llOnl SlIIpllSU Ilnd oxcilo,
1I10nl ollllilny stodenls, MIS, Ne!dllngOl WIlS sud,
dOllly In Iho spolllghl. Whon InlcrvIowod abou'
, IhlS, sho sllnply sloted, "Thoy lI10de Ille leel spe.
cI1l1 Ilnd spoctacular when In leality unyone can
do it," She ndmllled she was a Iitlle IlUlVOUS when
it cUlI1e '0 show Iill1e with all the cameras and
lights, Ye', Mrs, Neidlinger stands by everything
she steted In the cOl1lmerclal and backs up N.B
Liebman, "100 [lcrcenl," When asked If sha
would pursuo a coroor In ecting she loughed and
sold, "1'111 not quite reody for the big screen,"
'i't.t 'l't- 1~ i't.t it- 'it( '/'>.r 1'if 1k 1k 1fr
'i~ TIll' "'"'l'IlIlu" SINIl *
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l~ Amh;1 IlIlt hhllll }\f
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J
Pearl of The World
by Ashlee Himes
If you'ro on tho U"l grado maroon team and havo Ms,
White you know what I'm talking about when I say Pearl
Projects, We have recently read a story in our English " .
books by John Steinbeck called The Pearl. . '~.
There wore a few different choices to pick from: you \'. ",j'" '"
could have chosen building a diorama, cooking, making ca. ~'>" :' ,',
noe, painting a scene, or an idea of your own, Nate ~
McCulloch and Justin Barrick both carved canoes," I figured
I'd do a conoo since I already know how to work With wood,"
stated Nate, It took Justin seven hours and eloven minutes to complete his project. Justin
staled his canoo earned an At, Sam l3eouchamp built a diorama, "I did a diorama because I
didn't know how to do anything olse and I thought it would be cool." Jace Barkley also did a
diorama and worked on it for twelve hours,
Ms, Whito was usked how she came up with the Idea for
Iho pearl projects, She responded, "Some students under.
sland the concept, but havo trouble wllh wrltton test. I wunted
to come up wilh a projoct to show that they understood the
novd l3asicnlly it's an opportunity to show off their other tal.
ents," I asked which projoct Impressed her the most this yeur.
"I watched a wonderful film produced by Mickey Clifford, Bront
T1lUObllld, and Drew Gordon, Another was n gnme devised by
Curlls Kull," Sho nlso mentioned Jaco I3mkloy and SllIn
, I3liauctwmp's dioranllls, Ms, While has beon offering tho
pllonl projects for about nine yoars.
lIallway Brha\'illl'
by l<aUe WlnllH
Mr ~;milh, BSMS Dean of Sludents, has
been oxperllH1Clnu sOl11e conflicts in t1w hall-
ways, Students havo been pushing and
shoving, Muny pooplo do not uudorstand that
simplo SllllVIllU can turn into serious prob-
loms,
Some of tho probloms tho teachers nnd
Mr, Smith havo oxperioncod am pushing
shoVing and just silly little things, Most of the
pushing and shovll1U is just to 101 somOllno
knllw you am there, but some people may
luke it the wrong way, They then push bock
and people sturt to get mad and tho pushing
keeps happening, Students have been hurt
because a "friend" kiddingly pushed them and
4
t1wy fell. Water fountains and stairwnys me
dangerous places for horsing around,
For one thing tho hallways me not places
III socinlizo with your friends, If someono
pushes you nnd ho or she won't stop or they
aro trying to be mean you need to let tho clos.
est teachor know you don 'I like it or that you
mo having a pmblem, Mr. Smith has had [l
meeting with nil of the sixth grade classes, Ho
warnod, "Pushing and shoving will not be
tolerated, Thore are no excuses; there is no
roo son for Ihings to happen," Ho spoke on be.
half of toacllOrs and administrators, "The stu-
donts have beon here long enough to know
that these things will not be tolerated In the
middlo schooL" If you are caught pushing or
shoving or running, you will be given a lunch
dolentlon, If they accumulate a significant
amount of lunch detentions It will be taken to
the next love I of discipline,
B~hllld thr Sl'lllll'S with Stlld~lIt ('Illllldl
by Chelsoy Long
In Studont COlJncilthis month limy mo look-
ing to put togothor n "Supply Drive", tho 8"1
orado Somi, and a Spirit Weok and pop rolly,
Thoy uro concentrating on the "Supply Drive" for
soldiors who mo fighting for our counlry in Af.
ghanistan and in tho Middle Enst. Tho Supply
Drive is for itoms the soldiers don't have, but
could use, 1\ is a wny to show our opprociallon
for thom, So for limy IHlve only illons nhoutlhis
projocl, but will gotmoro nows out lator,
Tho Soml is cOl11lng faster IIwn most eighth
gradors want; realizing it is tho ond of tholr mid.
dlo school yems, Tho eighth grade Studont
Council mombers mo gelling right to business
with planning a fun, memorablo momont that
last a lifotime, Thoy oro picking out decorations
and deciding on an oxciting theme that will bo
enjoyod
by all,
Lastly,
Stud ont
Council is
sponsor.
: ing Spirit
Week and
a pep rally
coming up
soon, This
isn't just
like a
regular pep rally, This is a cross botween wacky
games and a "who's-who's at the middle
school," says Mrs, Stover. This pep rally is to
honor not only students but teachors, too, Each
team of teachers will nominate a "who's-who"
list from the team, Nominees from oach cate-
gory will have their names put in a hat and the
winner's name will recoive a prize. Tho pop rally
will include icebroaker cheers, music, contests,
and recognition of the groups and students ot
the mlddlo school. Tho Spirit Woek days havo
not been talked about yet, but you will bo noti.
fied as soon as possible,
In conclusion, 1110 watchdog members would
like to thank Student Council for pulling in nil
their hard work for our school.
A I'l' \'1111 11.1. P'!
.
by Molissa Brandl
As you may nlrcady know, on March 1&1
every year we have Increase the Peace
Day, This yem It fell on February 28"1,
Sixth graders, you may not know what
H,I.P means, If you've ever been to the li-
brary and noticed the big banner hanging,
I-UP means Help Increase Peace, The
past year we had a Lock-In, ond a march
through the streets of Newville the yom be-
lore with bonnors domonstratlng our nood
lor poace,
Tho Peor Modiotors only have one
mooting a month, usually on the first Tues.
day, so you can Imagine how hard it Is to
plan such a big event, with so little limo,
Whon I askod Jane Lebo (8111 grader) why
they didn't do something bigger than just
signing a poster and handing out lollipops,
she informed me, "We just didn't have
onough limo to plan the whole thing, There
was supposed to be two parts," When I
asked Coloman Welbley (8"\ grade) If Peor
Mediation had any other
ideas for Incroase the
Peace Day he stated,
"Many people wanted to
do the Lock- In again but
we didn't want to do the
same thing again," How-
ever, the poster signing
was a success,
lh.' 11'1i ~'1"1JlII S(kJ'~ (.~1I1llli.'1 I'quill t'I'I'Ol'~\,ly edlJLolIJOlljtlln,I,IIII';1I1 pllll ",,'111'.1
IJ.~l ,,,,,flall' I,nllie tdl'l vi Ill' l! l(~nf "llt>I~Hll (llllI'll, "I, 1\lI!. Il'I'l,I'fJll 'lid d,U!~',l~ HI .!~
'l,t'"ln 1"IIIJ'lIfll\ II' l'!\'4~OIIl..nll",Hhll'$.I ,e'IUlled IJY TJlle VI t!1I1! 11 Ilnd GilLh.'
t>L)4
I Ul 1I',.u";J'11 IntO'rI\11U)I\ II'\JJf!tUlllJVI! "gIll' Of gUholfll' llfOU"I.j.tt I. kw U""ln~lt")'.
ff'\,lJld,ny lflflflCU Otll\'lt,I." i1"" I;tUb',.... Ihlll "e ,L:IIUl'bI... III .'ld lltwlld. h tHaPt<1
l'I>I\tlfl' Wllldtl Ille S"~,,,,"'ll'nrlf"ll 01 btllooll 1.1....1-. .nd Sl!lilln &iJ~ l:(~"d"I.llJl H
1.""1111 H(}[~ HOdii pjl'~vllil! f'A U,l41 'I' 11111"6,000, hi ;Ql
5
School News
__,+ +r~ ._, r .___.~-
An Evoning of Honor
by Desiree Scalavino
On Marcil 3"1, 2003 thoro was a
Board Meotlng hold at Oak Flat Elomen-
tary School. Many topics wore brought
up at the meeting, such as high school
students who wore rocognlzed for aca-
demic achlovomonts, Aftor the high
school students talked about their lives,
Doctor Wilson talked about the Watch-
dog and NJHS, After Dr, Wilson con-
gratulated the Watchdog on their good
work on their student run paper, she
handed the microphone over to Mrs,
White who introduced the students re-
porters and editors, The school board
gave all the members of the Watchdog a
pen and certificate of recognition,
Mrs, White could not stay away from
the microphone, She came up again to
recognize the National Junior Honor So-
ciety (NJHS) for their service project at
Oak Flat and Plainfield, Mrs, White pre-
sentod a slide show of what the mem-
bers of the NJHS did while acting as
Santa's elves, at the elementary
schools, The NJHS also received a pen
and a certificate of recognition,
After the Watchdog and NJHS were
recognized, The Scholastic Writing win-
ners were recognized, Kim Sheeler
from 8M5 oarned a Certificate of Merit,
along with-
five other
higl1 school
students,
Congratula-
tions to all
students
who were
recognized
at the meet-
ing and
keep up the Some of Ihe Watchdog members
good workl who ollended the board meellng,
"
,
j
Chcclullalc
by Madison Miller
Do you know how to play chess? Well, Mr, Manweller
and his chess-playin~_ ~lq~.~-rl~~o' Mr. Manweller ex-
plained why he, formllp !hq~cnes~ club, "I pl,ayed chess
when I was a k,d and'l; eDJoyqd It becau se It was com-
petitive an(m~'(mQ Jplnk."" Dllrlng the first half of the
rotation, the~studentfpracticed their chess skills, A
chess tour~m~nl w~~,Jleld duri~g the~eepf1d hall 01 tho
rotation, F ~, tOl1m~ment, each stu~ent was in [) dif-
feront lovel 2~9 xx~rQ. threo 10ve!sth~J'stlidonts could
chooso frO/fI~I\le~~1 b98lil~ n c1amplon, I<ylo Rich-
mond, was ~ Jllir~'18vol tJ(,h~,~ploIJ!.. Br~d Zionkowski
won '11 thof~qpmt',~veJ, ti11T/lq overall,chnl1lpion was
Jacoby l3uckor:' Chess Is bolt,. comrlClltlvo and slratogic,
Think allout it when you cl1ooso c1ulls !lOxl yom,
()
Sports
Ulldatc 011 Thc Ilo\'cs
by Amanda Webber
The Middle School Indoor Guard competod at thoir
home show on March 1,,1, They performed to the remix of
Prince's "Whon Doves Cry" from the movio Romeo Il/ld
Juliet, The show went groat, and tho guard would like to
thank the Band Boosters for all tholr support, The guard
would also like to thank everybody who carne to the show
and gave their support, Since It was the home show, the guard members were hon-
ored to be hosts for the other schools, As host, they directed the groups to where
they needed to be at different times throughout the day,
On March 151h, the guard also traveled to Mechanicsburg for their second
competition, At this show, they performed very well and took home first place, On
March 291h the guard will travel to Hershey for their final competition of the season,
Way to go guardl
BelloI' not say, "Can't"
by Sam Weyant
Volleyball tryouts were held from March 5 to March
7, About 40 girls in grades sovon, oight and nine tried
out, but the coachos could only pick 22, Tho coachos ~
Are Coach Keller, Coach McCulloch, Coach Saville and -Eb,
Coach Groover. Everyday the girls worked on tho skills
needed to make the team. On day ono thoy worked on
passing and stepping frantto back and side to side, On
day (We they worked on more passing, sets (over head
pass) and on spikes, On the last day they practiced
passing, spikes, serves, and then they scrimmaged,
WARNING: If you say can't, you've eurned yourself II lap around the gym,
Congratulation, team!
Seventh
1, Bea\lle, Allyson
2, Beecher, Zora
3, Graham, Danlollo
4, Morbeto, Sorah
5, Shoop, Komi
6, Shoop, Kayla
7, Singer, I<eirston
"..'Jl';--
Eiqhth
1, Adams, Alexllndria
2, Alleman, Kotu
3, Fortini, Erica
4, Johnston, Jessica
5, Kotnor, Holly
G, Long, Chelsoa
7, Morodith.Mnllor, Raven
8, Piper, Brokun
tw!h
1, Brenizer, Kim
2, Cohick, Cholsy
3, Ditzler, Ashloy
4, Johnson, Katlo
5, Loa, Mandy
G, Shull, Mandy
7, Still, Mlchollu
7
'.~ ,,,_ __..__~H_ __.. __
. -I
PARTY DANCES
. ~ ~ T . ~~....... -...... . -- -
Tht.' St. Patrkl,'s DUIIl'l' II lIit
by Alox Adams
On Marcil 14, ;Jllll:!, Iho Willchdo!J Slilll illld NJIIS
mBl11bors Spollsol!Jd Iho Sillnl I'alllck'!; lJilY dilnCl!,
The pool was c1osod, hilt tho gYI11 was oponlHt fOl
playing lHlskotbal1. Evoryonu did his or hor pill I by
110Iping to doeoralo and 10 supply t110 food, Tho cilfo-
lerin was docoratml with IJrtJon shul11rocks of nil silOS
nlld chain IlI1ks hunIJ from t1m coillnu, 1ho NJIIS and
the Watchdog would liku to thank uvuryono who par-
Iicipntod ill to ImlpllllJ l11ako this duneo 1I hit. It wnsn't
just U normal dallce oither, WatchdolJ Slaff alld NJI IS
l11embers put oold coins in studollt's lockers and if
you recuived ono you oarned a prizo
for your COill, such as II freo soda, 50
conls off food, or 0 freo tuttoo, Sarahl30neal suppliod allyono and ovoryono with u
shamrock tattoo, but you had to pay !.ill eonts.
DozolOa Whistler, (Bug) said, "It was alright, Poople wero complaining about tho
prices 01 tho sodas, but hesides that it was good and Ihow were a fair alllount of
people who attended,"
O ' ,
I ./ # )1'
~ - "\. "7
. ('
9
I DlnCI'Or Romlnce
by Carol Dunn
On Fobrumy 20lh tho middle school finally had the Valentine's
Doy donee, Aller boing postponed for two weeks, mosl people
thoughl W13 weren'l going to havo one, But we did and it was
worlh tho wnil. Whon the doors opened
al 7:00 P,I11, tho crowds col11o pouring in
Wid quickly fillod Iho danco floor, The
Illusic rnnged from "Tho Cha-Clla Slide"
to "Good Charlotte" All tho cute couples
slow dancod to S0l1g11 liko "Alii Hovo" lJy
.Jol1nifer Lopel and "Ilack At Ono" by Brlnl1 McKnight. AI 0:00 tho
floor omptiod m; quickly as it had filled as poople headed IWIlW,
Everyono who uttlJlldlJd wally IJlljoyou tl10 dallco,
.1
x
..
",,,'.'
li~ ~.
JI~5!-:111,;J '.11-'11111[11:f 1H1Il .Jessica
HillUll tlt!1 ~4~d IJlIIIOl 1I11) danClJ
- ~. ,--". - - --. . - ~ ..
. .If'''-~
EDI1'ORIALS
~ r~_
7i/ C//{'II' O/' Not to CIII'II'
by Janelle Clouse
Should students be allowed to chew gUIll in
school? Mrs, Evolhoch, a sixth grado loucher,
thinks that wo shouldn't bo allowed to chew gum in
school because students leave gUIll in tho books
and under desks, Tho librory has had to throw out
a lot of books because students put Iheir gum in
tho books,
Ashley Barrick, sixth groder, "Yes, we should
be allowed to chew gUIll in school because teach-
ers should choose if they want us to chew gum in
their classes or not."
"I agree and think we should be allowed to
chew gum because then we wouldn't have to chew
gum behind their backs," replied Molly Kardos of
6B1, Cody Bloser of 7M4 says that we should be
allowed to chew gum in school because it keeps us
The Answer Line
- - -- -.
by Carolyn 11011
Thc Watchdog didn't get as many
qucstions this issuc; thcrcl'orc. it was-
n't as hard to choose only four,
Please, only put appropriatc, suitable,
and reasonablc questions in thc three
boxes, located in thc offiec, library,
and in the uppcr anncx, Rcmcmbcr to
put your namc and section allcr your
qucstion,
.Why do wc have to go to school
scvcn hours a da,t
(Megal/ ^'fl'L'rs (/ I ,~rade)
It is thc law that school districts must
havc sewn hours or scholll a day,
awake, An eighth grade teacher, who chooses to
stuy anonymous suys," I don't care If my students
chew gum, just 50 they don't put II In my books or
illY plunts,"
However, Ms, White says, "No, I um trying to
teach students to spoak correctly, How can you
speak clearly with EOrnethlng In your mouth?"
1 think we should be ullowed to chew gum in
school because we are not doing unythlng wrong
by chowing gum," remarked Eric Gulshall of BG4,
I agreo with thoso who think gum chewing is
okay, Wo should be allowed to chew gum uny
time wo wont to, Aftor 011, they chew gUIll in high
school.
.How many kids arc in thc middlc
school?
(/IIIII/al//lel Pe.Der 8,h grade)
This question was already an-
swcred in thc Novcmbcr issuc, Thc
answcr is about 800 students,
. Who is thc youngest female
tcaehcr (present) in the Big Spring
Middle School?
(Carl Heinell/ann 8,h grade)
That would be Miss HolTman, 70
Scicnce tcacher, who is currcntly
23 ycars old,
<)
Bulldog Fun
Big Spring Trivia
by Dayna GlpO
101 the M~lIChl!;~I/(! 01 ill(! Watchdl1(] a
new luatuw was ~Iarted illld Ihls IS iI! 1'01
tillS ~lIt1c1e I had 10 do SOllie dl(](]lIllJ and find
ullusunllacts about Olll teocllels helo In the
middle school When I had my onswers, I
asked sludenls to guess and I gal sOl11e
very humorous onSWelS,
Wlllell 8tll grade teBellor lias a
sigll proelaimillg " Beware of
Attack Teaeller"?
Deondra Still, 6'" Grode: Mrs, While
Kylle Albright, 7'" Grade: Mrs, White
Mockenzie Bell, B1" Grade: Mrs, While
Josh DUlham, 61" Grade: Mrs, While
Autumn Casey B'" Grade: Mrs. While
Answer: Mrs, While
Wlllell 7tll grade teaeller used to
be a preaeller?
Zora Beecher, 7'" Grado: Mr, Heusner
Kelly Adams, 7'" Grade: Miss Davis
Kirsten Bowers, 7'" Grade: Mrs, Magee
Justin Miller, 7''' Grade: Mr, Heusner
Carly Stevens, 7'" Grade Miss Davis
Answer: Miss Davis
Wille II 6tll grade teaellOr is tllo
only toaeller tflat lias beell
teaellillg IIere III tile middle
sellool silleo it opelled ill 1969?
Cody Dunning, 6'" Grade: Mr, Hhodes
I<ayla Hinlon, 6'" Gmde: MIS, Slover
Lizzy 13erry 7'" Grade: MIS SlovOl
Allswer: MI. I~hodes
10
Wille II Arts Team toaeller was a
paid EMT alld played III all alter.
lIat/ve band?
Kmilla Goulordara, 7'" Glade: MIS, Piper
Jamie Cunningham, 61" Grade: Mr, Arlz
Shayne Golden, BI" Grade: MI. Mislishen
Saul Cohick, 6'" Grade: Mr, Artz
Smah Morbeto, 7'" Grade: Mr, Kel11brlng
Answer: Mr, Mislishen
Wlllell 8tll grade teaeller was a
mate on a flslllllg boat?
JelOlllY Piper, B'" Grodo: Mrs, Brechbill
Leoh Iiwin, B'" Grade: MI. Roberts
Corilln Eby, B'" Grade: Mrs, Brochbill
MifOlldo Mentzer, B'" Gmde: Mrs, Brechbill
Ryan Bailon, B'" Grade: Ms, Markley
Answer: Mrs, Brechbill
~~~~~~~~~~~~*,*,"A-'*,*,*~ '.,
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~ LETTERS TO THE EDITOR ~
~ Havo somothinu on your mind? Want ;t
~ your o~)inion to known? Write a l?lIer 10 ;
*' tho mlllor. All letters are 10 bo glvon to *.
-r MIS, Whltllln 100m 303, *'
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Voices In the Hall
I\uportur: .Jussica CfUS(!Y
[VUfYOIlU l1as dllh!I(!lltOpIIlIlJI1S Oil wlwllwr IV'! :,1101lId or :;l1ollld IIOt !lO to war We ,uikud differ-
1!lllllldIVllhl;lI:; ,1f1l1/WIl! ;Ill! 1I1l!1f OWIl OpllllOIlS Oil till:; (OpIC
GM1 Krystal S(olle
"No, bec(luse we could die,"
7M1 Meagan Oiler
"No, too many if1l10-
cent people will die,"
~, ,"
,-.
,
,
II" !lrade !lold 5C1()IICl! 1(),ll,IIl:l,
111,:; '111t1l1l1l1;l
'VVI! bllould d,,',,"d {'"It"""
oI"d wl,oI\ 1\ ',\'II11j,. h"
GB 1 Hyan Irvin
"Yes, to stop all (urrollslll,"
)~'~,
I,~
,1
8M3 Dilll Erickson "Yes,
Saddam IIus5ein is a bad
person alld sl10uld die,"
MADE
IN
U.S.A.
7M2 Dan Mowery
"Yes, we should be-
cause they deserve il."
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8M5 Stacey Hoover
"No, bec(luse my
cousin will go to wm,"
j, I
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JJ ~, '~i.J"
tY:1 J I.
A .....'jjl
t'
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1111 qriH1IJ lJli!f()(1I111:ilI1U1U
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II
..
<5P.GUIDANCE
ASSOCIATES
OF
, PENNSVL VANIA
C3n,p Ullh (717) 7J2,2917
UmheYI (71715]],4]12
Carllllel (7171245.22119
Chamhmburgl (7171 21>J.9J92
FAXI (7171 7J2.5375
MAIN OFFICE
412 [rlord Road
Caml' UIII, ItA 17011
Stanley E, Schneider, Ed,!>,
Director
Junuury 18, 2003
Thol\lus J WiIliul\ls, ESlluin:
Murtson, Deurdorn: Wllliul\ls,
& Olio
10 Eust High Strcet
Curlislc,I'A 17013
[;1,\ \,
/EXIIIIlIT
IlkLiL'l\ \ V' )
Robcrt L. O'Oricn, Esquire
O'Bricn, BllriC & Sherer
17 West South Strcet
Carlisle,l'A 17013
Re: Tritt V, Tritt (Killinger)
Cumberland County CourtofCol\lmon Pleus
No, 94.3767
Dear Attorneys:
I am scnding my findings und rccoml\lcndatlons rcgarding custody of Amhyr, nge
fourtccn, und Juson, ugc sixtccn,
Ronald Trill, thc childrcn's luthcr, tilcd u pctitionto modlly custody uverring thut, "hc
Clluld provide u stublc, nurturing und sule cnvironmcnt Ihr thcm. which they ure presently
Iad;ing,"
Ilntcrvicwed both Ronald und Jeunnc, thc childrcn's mothcr und rcvicwcd their conccrns,
issucs, cxpcricnccs und prclercnccs, I mct with both Ambyr und Jason whcn brought In by
cach parcnton scpurutc occasions, Thcy complctcd custody.rclatcd Instrumcnts including
Parcnl Rcport Cards und Scntcncc Complction tcsts,
In udditionto rcvicwing Court Order Ulllt rclatcd plcadings, I rcvicwcd ulcllcr Aml1yr
uddrcsscd to hcr mothcr und Brucc (sICplhthcr), which wus undatcd, cusc lllflllulution by
D,B. Sundcrs, M,S" datcd Scptcmbcr 12,2000 und Dcccmbcr 13,2000 rcgarding Ambyr
und Jcannc's thcmpy, Amhyr's report curds Ihull sixth through eighth grudcs (first
marking pcriod) und Juson's rcport curds Irol1llillh, elghlh und ninth grudcs,
COnllHehenslve I'sychologlcal Services
Drug and Alcohol Treatnu'nt
.
.
11111 I I' ill (I"lhlllll'll
2
Itolluld md'I'ull'lllhuI hl'llIllIlIlI'd IIINl'IlIl~1I1 l'IIKlod)' pelhiolllllld is goillg through the
I'mlod\' l'lulllllllllll 1"'1'1111,1111 hcnlll.c Ihc dllldlclIlIsked hi III In oblllill cuslody, His
InIlC. 111111 \'I1I\l'l'III. IICIC 11'1 \CIII'd II ilh h'illllle Addlliolllllly, his (Olleems were
Illlthcuclllh,Ollllh IlItilllllillllllll1hlillllC" linlllllllllllhnullhe children
Amhy I '. ll'III". nil ", 1\'I1l'l1 ';111,,11111111 \' Illlldc. TClldlCll'lllllmcnts ol'er the IlIstllumber
ofH"". '1I1'hllll-, hili Ull' 11111 hllll'I'" II. hl'l clidclldng, sunil!! or salislilclory progress in
MII',ulllcll'lllllIlll'nl unll 1I11lk huhi,. II II ilK Illlled Ihal she has II strong work elhic, is Il
pll'aNIIll'lll IIlIIC In 1'111", illld m,"' nollll' IIlllkilli! In Ihe best of her ability in malh but
1'llIlellrt""II1I1I1l'llllllhlc iI,,., pilllldl'lItlllll Similnr l'llnllnellts were noted on Jason's
1I')Il\lt IUIlI. Ilc i. IInll'll III hI' n pll'II,II1C 10 hilw ill class, el'idences commendable elfOlt,
hus U p.uilill'lIl1illllll' tllllcullllnll, Is l'llopclalil'e and dependable and has good
1I111k/sllllly' huhitN ill n""llIlln 10 hdnll i"cntitlcd as COllrteollS lIis grades are acceplable
liS Ilell Thc lhildll'lIlli\le hl'l'n IIIlhcir mnlhcr's primary custody,
Theil' is JlOlllllludIlP'III'IIl'11I1I1l1I linmd in eilher Amh}'r or Jason. Unlh children are
hlil/hl, hall'llllllll sclt~c.II'I'n\, 1'\llIhilUpplllpriule interper5ollalllmctiollillg (with different
M)'les) IIn" Pll'scnt Ihl'm\dll" u. t'cehnll safe und Sl'Cllre in their environment,
AmhYI p,c.cnl.u, U mOil' "Illhol.intl'n,i\e" )'ollnlllldolescenl She is engaging in a quest
11',lIlIcnlion, IC'l'cd, ul'knollll'dllcmcnlullll Ileedolll while nccding support, structure and
pllllcl'lion liS ~hc 1II01l'~ tlllollllh IIdobL'ellcc She is a nOllllalleenager who Is lIIeeting
lypil',t11 t1ge'lellllclllll'll'Iop"ll'llal dlllllenl!e~ These include increased lIIuvelllenlluward
tleedolllunll illlhlilllltlllll' t1~ she ~1I11l!l!ll'S wilh Ihe lIependency I1fchildhood and the
IIIdepcndclILe of 1Il11llthollll AlllhYI' s IIIlllhcl t1l1elJlllltely t1ddresses A IIIbry , s gender
hlenlilktltion hl'l lilliil'l plllllllc~ needed lespecl, a(Leptan(e IInd support while
UIII'lIIplill1! 10lc~poll,ihly' hI' 1II0ll' pCllnissiw in his pllrelltillg approach lhan is Jelllllle,
II hi' is 11I1111' I'onllollillll
lIolh AllIhYI 1111I1 Jtlson, indepcndcntof one another, cxpressed opinions, regardless of
Ilhil'h palcnt 111l')' \lelC \lilh IIllhe lillie, exp,essilll! Iheir observatiun thallheir
1'lI\lIOlllllenl inlhl'il I'UII enl hOllle has Ielnxed n hil since Ronald initinled this custody
nL'lion IInppcllI~ 1111I1 1I'II1111e nlld Blllec nle cunently lIIeeling the demands ofthree
lecnugcl s inllll'il home \lIlh 1110101' strU(tllle .. 10 whkh Amll)'r in pal1lcular, mllY be
1l'1ll'11IIl! Both indil'ulc IhatlhdlmolhelS' hehavior tl1wnrd Ihem hilS hecome more
10ll,illlll'lIUlld pcilmps 1II0lC ~lIkl sin(e BIII(e elltcled Jeulllle's lile,
lIuSI'IIOIlIII)' nndillgs, IUlIIll'I'omlllcllllill/lthnl hoth AmhYllllld Jasoll remain ill Ihe
1"1111111)' physkull'lIStody oftheilmothcl The clIllenl willterlsdlool Sdlcdule Is
ndl''iUilll'Il'lIIcctlll/llhcillll'I'lIs Amh)'I, in pnlllculnl, could hal'e more flexibility ill
.
Tritt v, Trill (KlIIinger)
3
the amount of time that she spcnds with her father, so long as she maintains her patterns of
scholastic achievement, The alternating weeks In the summer seems to be working well
and there Is no nccd to rceommcnd a change In that rcgard, Howevcr, the traditional
'cookie cUllcr' schedule that typically Idcntifies time with each parcnt will not continue to
meet the realities and practlcalltlcs of the children, As notcd, Ambyr prescnts as a more
challcnglng young udolescenl. She needs order, structure und predlctuhllity while at the
same time needs to maintain her involvcmcnt in actlvitics and pccr relationships, which arc
important to her, These will rcquirc morc flcxibillty and rcsponsivencss in the parenting
urrangemznt hetwccn Jcannc and Ronald.
Jemmc's relationship with Amh)T could be bolstercd, Jcannc openly noted that she and
Amh)T ure, at times, in conflict with one anothcr, The Scptember 2000 case fommlation
refers to "mother desires to improve her relationship with Ambyr and provide Amhyr with
a safe place to talk...... At that time, thcrapy hclped, Both Ambyr and Jeanne talk about
their relationship being somewhat straincd and challenging, It is, thercforc, rccommcndcd
that mother and daughter re-initiate counscling to smooth out their relationship,
Both Jeannc and Bruce will benefit from increasing thcir knowledge ofmorc
effective/appropriate response patterns to the cI'cr-changing devclopmcntalnceds ofthc
three adolescents in their chargc,
Finally, Ambyr and Jason will benefit whcnthcir parcnts, Jeanne and Ronald, consult with
one anothcr directly conccrning the needs ofthcir childrenund their oll'nneeds as co-
parents, Counseling for co.parenting Is strongly suggested,
Bes~ctfully,
!
.~
Stanley E, Schncldcr, Ed,O,. R.C,E,
Psychologist
Rcgistercd Custody Evaluator
SES/aW/cs
MDW&:6
1I><1'.kll\ll".... All\l" . 4.1l\1~~, \
APR 1 1 2003 I
Tf'N FA\l 1t1~,1I ~1""1
CAltll\lI, PfNN'\I\'.4.~m 17111.'
JEANNE M, TRITT,
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNS\'L VANIA
v,
NO, 94-37(17
CIVIL TElH\1
RONALD L. TRITT.
Dcfcndunt
IN CIJSTODY
FATIIEIt'S IIEAIUNG I\IEI\IOI{ANIHJI\I
I. HISTORY:
This Court hml u hcaring on Dcccmhcr I), 191)4, and issllcd un Ordcr thc snmc day, which
Ordcr hus bccn followcd by thc parlics cvcr sincc. Esscntially, Mothcr hus primary physical custody
und Fathcr hus ultcmutc wcckcnds during thc school ycar uud allcmutc wccks during thc sumll1cr
vucation,
On Junc 2n, 2002, Fathcr filcd u Pctition to 1\lodify Custody in ordcr to changc primary
physical custody to him, A Custody COllciliutioll Confcrcncc was hcld 011 JlIly 19, 2002, bcforc
Hubcrt X, Gilroy, ESlJuirc, followillg which thc partics lInd thc childrcn submillcdto un cvaluation
by Stun Icy E, Schncidcr, Ed,D, Thai cvalllatioll hus 1I0W bccn complctcd; howcvcr, thc purtlcs urc
stillunablc to ugrcc and havc rClJucstcd thut Futhcr's Pctition to Modify Custody bc sct for u court
hcmillg,
II. POSITIONS OF THE PARTIES:
Mothcr wanls to continuc thc cxisting custody ordcr unchungcd, Futhcr Wants It modlncd
so that hc will havc Ilrimury physical custody of both childrcn,
III. WITNESSES:
Fathcr illtcnds to call himsclfund his two childrcn us witncsscs dllring his cusc in chicf, Thc
childrcn mc clllTcntly 14 und I () ycurs of agc, so thc Court muy Wlll1ttO hcar thcir tcstilllony olltsldc
thc prcscncc ofthcir parcnts. In uny cvcnt, tcstimony would bc Iimitcd to cvcnts sincc thc hcuring
on Dcccmbcr 9, 1994,
I. Alllh~T Tritt. burn NU\'ember D, 1988, Shc hus becn vcry unhuppy sincc thc
tinnily mOl'cd in with Brucc (I'l'lothcr's prcscnt husbullll) and his SOil, Brllcic, Ambyr
rcports daily 10lld conllict iu t\lolhcr's houschold which shc hud cscupcd by going to
her bedroom; howel'er, 01'1'1' the lust yeur or so, shc hus hccn Ihrccd to (10 hcr
homcwork ulthe kltchclltuhle with her hrothcr uml Brucic. She I1mls it dlll1cult to
concentrute there (umllng IIthcr Ihlngs, Brucie, who hus chronic Hlillng grudcs,
PCl1llcrs hcr with queslill1l8) und her grllllcs hul'c suffered reccntly,
Amhyr Is eurrcntly un eighth grllllc 8tudcnllnthc Big Spring School Dislrict.
Atthc hcglnning of sel'enth grade, Amhyr WU8 "moleslcd" hy Brucic, Wc do nol
\\'untto gct inlo Ihc dCluils oflhis (Iuc to the emotional distress il causcs Ambyr, hut
Brucie wus ulTesled hy thc police und placcd on pruhution, l'umherlulld County
Chlldrellund Youlh Scrl'lccs ulso Imposed requlremcnts on Mothcr's houschold,
includillg counseling, und including thc rcquirement ofncl'cr Icu\'illg Brucie ulone
\\'Ith Amhyr witholllllllllh supcrl'ision which requiremenl continues 10 bc I'lolllted,
Although Brucic hus not uttempled to physlcully molcst Amhyr IIguin, he docs
constontly belitlle hcr, including her physicul churucterlstlcs (eating, weight) und
choice of clothing (Amh}T'S pussioll is riding und she fUl'ors Wcstcm wcar),
As an egrcgious example of Ihis, onc of Amb}T'S c1ussmutes committed
sulcldc this YCllr, \\'hich wus cmotionully de\'usluting 10 Amb}T umllhe olher sludcnts
who kncw him, Brucie enjoycd necdling Amhyr uhout Ihis Irugie el'cnl, uPllurently
just to see her get \\'orked up, lelling her how it wus "uhoUI timc" Ihc hoy did
something right. Sceing how Ihls distressed Amhyr, Mother could only suggesl she
"Igllore him,"
Signilicuntly, Amh}T' did nollcll her MOlher Ihut Brucie hud molested her
becuuse Amb}T feurs Ilml she call1lot shurc conlhlellccs with hl'r Mothcr, uml ulso
feursthul her Mother Is under the inl1ucllcc of Brucc umlwhulcl'er Ambyr tells her
Mother, her MOlher would Ihenlcllllruce,
Brucc uml her Mother dllnol gclulollg, Thcy I1ght u lot, I'crhully, culling
euch othcr Ilumes,
Amhyr ulld Bnll'e 1111 not gelulollg, Bruce fil\'ors yelling uml his yclllng is
lueed with ohsl'enities, E\'ery nighl, he HillIs something to yclluhout. Amh}T Is nllt
comfhl1uhlc with Brucc whl1appcms tl1l'njl1)' nel'llling hcr, Amhyr fcurs Brucc tukcs
un unusuul inleresl in her, including Ihe seleclion of her c1olhes,lnc\uding hrussleres,
Amhyr hus usked to shop only with her Mother, hUI Bruce insisls on coming ulong,
Recently, Bruce looked down Ihe Ironl of her hlonse (pulling the collur out 10 see
down) hecuuse he lhought she wus wearing a durk colorcd hnt, which he opposes;
uCluully, Amhyr was wearing u swimsuil under hcr c10lhes al tlllll time,
In lhe ahsence ofhcing uhle 10 eonlhle in hcr Molher, Amh>" con lilies in her
riding inslructor till' female advice,
Amhyr will reLjueslthe Court to permit her to live primarily with hcr Futher,
She feels her Futher hus her hcst inlercstat heart und she can confide in her Futher
ubout uhnosl unything, Moreover, hcr Father lives on u 11\l'ln uml Amhyr's pussioll
Is riding, Therc ure stables on thc fal'ln, Ambyr ami her hrothcr do ehorcs on the
funn und usuully cnjoy doing Ihcm. Amhyr is active in 4-11 Club and also likes to
ullend various riding evenls, lieI' Falher always goes out of his way 10 take her to
these events; whereus, she has difficulty gclling her MOlher to take her, though her
Mother has bccnmore helpful in this regard since mceling wilh Dr, Schneider,
Ambyr is uctive in school activities, She is on the school newspaper, She is
pari of u Peer Mcdiulion Program in the Big Spring School Districl: lhese studcnts
do things Iikc oricntule new students und counsel studcnts who huvc
disugrcemcnlsllights with one unother, Ambyr was un honor studenlln pust yeurs,
bul not this ycar, a IIICt which she allributes 10 the dislractions of having to study
uround the kitchentuhle, It is much cusicI' to do homework ut her FUlher's house.
Ambyr is hothered hy her Mother and Bruce belillling her Father, They
usuully refer 10 her Father as "the lI\1'1ner," Whcn Ambyr docs somcthing wrong in
the eyes of her Mother or Bruce, she is ollenlold: "That you getlrom your Dud,"
Her MOlher hus lold Amhyr thaI hcr Father rcally docs nol wlllll her, 111111 this is u
mailer of his support paymcnls amllhat he is ullcmpting to "huy your love,"
Mothcr's housc is in a neighborhood whcre thcrc ure u lot of llrugs und
Amhyr fccls uncomlllrtahlc, The kids in hcr ncighhorhood me vcry dlll'crent fmm
hcr ti'iclllls in 4-11. Amhyr's 1I'iclllls do not fcel cllmllll'tahlc going to her Muthcr's
hOllse; Ihey 1I0 feel comllll'luhle going 10 her Futher's hOllse, Ambyr's futher lives in
u sell1l.lsollltell ureu where Ihe neureslneighbor (nol u rclullve) Is u lenth of u mile
uwuy,
2, Joson Trill. horn ,1111)' I, 198(" Juson is in the tenlh grude utthe Big Spring School
Dlslrlct. lie shures u helll'lllllll wilh Brllcie, his slephl'llthe!'. Juson gels utong with
el'eryone uml he generlllly gets ulong wilh Brucie; huwever, Brucie's behuviur is
oceuslonully irrituling um! dislurhing, Recenlly, Brucie mlnulell inlo u hottle on the
school blls cuusing u greut eOlllllloliun. Brucie slllokes, Brucie picks on Juson's
sisler, Ii'eljuently culling hcr lut. Brucie hus usell drugs inlhe pust, hul J uson hus nol
seenlhis since ujuvenlle pl'llhutionllrtleer hegun stopping by Ihe house to see Brucie,
Jusonlloes nutlike schuu\. "I just gu hecuuse I hu\'e 10," He is nol Involved
in unylhlng ut schuu\. llis goal is lu Hnish Ihe linullwo years of high school unlllhen
move 0111. lie thinks he wunts to he u lin111er, pruhuhly wilh his Fulher, He likes the
11Ieu ofwlll'king ut home und heing his own huss, lIe docs chores urounll the funn
when he visits his Futher, whutel'er needs 10 he done: feeding the steers, bunllllng Ihe
huy, plowing Ihe drivewuy, or Illowing the gruss,
It docs nol reully Illuller 10 hi III where he lives, lie cunlive unywhere for Iwo
more yeurs, unlil he is uhle tOlllo\'e out.
3, Itonutd L. Trill. born October 13. t %3, Allhe tillle oflhe heuring in 11)1)4, he wus
u lIuiry fumle!'. Shortly uncI' the hearing, he sold his cows und went oul of Ihut
business. lie wcntto wurk for Excll.ogistics where hc openllell u forklill onlhe II-
7 shill for IlhoUI six Illonths, Then, lor Ihe next eights yeurs, he worked ut eurllsle
Synlec Systellls us u Iuhorer, working ul'lItuling shill. From Septelllber 13, 2002,Iu
the presenl, he is employed hy I'enn Township us un elJUiplllenl operutor, working
7:00 U,Ill, to 3:30 P,Ill,
lie hus Illll\'ell to his uunt umluncle's lill'l11, which is inl'enn Townshlll unll
the Bill Sprint! Schuull>istrict. In 11)1)1), he inslulled u I (J x 80 COlllmodore Ihree
hedl'llolllllluhile hOllle next 10 Ihe 110m house, II is in u counlry selling on u hulflo
three.quarter IIcrc 101 wilh wulcr uml scwcr. llis lIunl uml uncle Iivc Inthc funnhousc
ncxl door und hc works Ihc limn in udditlonto his duy Job,
Hc supports his chlldrcnln whulcvcr Iheir inlcrcslS huppcnlo bc, Ambyr's
Ilfc rcvolvcs llround riding, IIc lukcs her 10 riding IIclivitlcs, such us round.ups IInd
4.H cvcnls, Therc is II slublc on thc limn, Futhcr houghllhc lirsl horse, Amhyr
houghl ulllhc resl, using hcr ownmoncy. Ambyr wllllls to he IIn cquinc vclcrinllriun
IInd bc is supportivc of this,
Hc is IIwllrc of lhc police und Childrcn und Youth Scrvices invcstiglltion
rcgurding lhc molcslulion of his duughter, IInd Ihis hus ellused him quile u bit of
IInguish; howcvcr, Amhyr hus not volunlcercd uny inlonnlltion conceming this und
hc bus nol prcssed hcr on ii, scnsing lhul il is 100 puinllll tor herdiscuss, ullcusl wilh
hcr Futher,
Juson is u quiel, eusy going boy who is gcncrully coopcrulivc, Juson hus his
chorcs uround thc funn which hc usuully perfonns with minimlll "cncourugcmcnl"
from his fUlhcr, Juson docs nol seem to wunllo lulk uhoUI school. Hc lulks uboul his
fricnds, Hc Iikcs 10 listen to music, Hc docs not scem to huvc u lot of umbitlon,
Although Juson docs notlikc school, FUlhcr will not lei him quil,
Futher is willing (und. with his Job ul (lenn Township, now ublc) 10 lukc
primury physicul custody of his childrcn,
Rcspeclfully submitted
Dulc: April II, 2003
MARTSON DEARDORFF WILLIAMS & OTTO
By I kllV-/-. vV~,Lt~-H'L."
Thomlls J, Willi I s, Esquire
Ten Eusllligh S eet
Curllslc, P A 17013
(717) 243-3341
Attomeys for Futher, Ronllld I.. Tritt
Ulr!'lJiICATE OF SI~It\'ICI~
/, Tricla D, Eckcnroad, an aUlhorizcd agcnllor Murison Delll'llorll'WlIliums & Olio, hcrcby
certify thalli copy ofthe forcgoing Fllthcr's Pre. Trial Stutcmcnt WIIS serl'cd Ihis dUlc by dcpositing
slImc in thc I'osl Oll1ce at Carlisle, I'A, Ihsl class mail, poslugc prcpuid and I'iu lllcsimlle, uddressed
us IbllllWS:
MAIn-SON DEARDORFF WILI.IAMS &. OTTO
, ! )
Robcrt O'Brien, lJs4uire
O'BRIEN, BARIC & SCIIE/WR
17 Wesl South Slrecl
Carlisle, PA /7013
, IIJ
(By : (,C .
: Trlciu 0, Eckcnroad
Tell Easllligh Slrect
Carlislc, I' A 17013
(717) 243.3341
Dalcd: April 11.2003
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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
STATE OF ~I PENNA.
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JEANNE M, TRITT,
1'\ II. 94 - 3 76 7 CIVIL TERM lfXJX
PLAINTIFF
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RONALD L, TRITT,
DEFENDANT
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DECREE IN
DIVORCE
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AND NOW.
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JEANNE M. TRITT
RONALD L, TRITT
19 91", II Is ordered and
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, , , , , ' , , , " defendant,
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decreed that
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are divorced from the bonds of matrimony.
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The t;ourt retains jurisdiction of the following claims which have
been raised of record In this action for which a final order has not yet
been entered;
NONE
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JEANNE M, TRITT, '
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 94-3767 CIVIL TERM
CIVIL ACTlON.LAW
IN DIVORCE
v,
RONALD L TRITT,
Defendant
PRAECIPE TO TRANSM~
To the Prothonotary:
Transmit the record, together wilh the following Information, to the court for entry
of a divorce decree:
1, Ground for divorce: irretrievable breakdown under Section 3301 (d) of the
divorce code,
2, Date and manner of service of the complaint Sheriff on 7/~ see CODV
Qf Sheriff's return attached hereto,
3, (Complete either paragraph (a) or (b),)
(a) Date of execution of the affidavit of consent required under Section 3301 (d)
of the divorce code: by the plaintiff nla
by the defendant refused
(b) (1) Date of execution of the plaintiffs affidavit required by Section 3301 (d)
of the divorce code siQned 03/12/97 filed 03/13/97
(2) Date of service of the plaintiffs affidavit upon the defendant
03/12/97 via first class mail to attornev of record
4,
!illill;hed
Related claims pending none-Praecipe To Withdraw Claims in divorce
5, Indicate the manner of service the notice of intention to file praecipe to
transmit record, and attach a copy of said notice under seclion 3301 (d)(1 )(1) of the Divorce
Code see attached
~J-Of2r~
Robert L O'Brien
Attorney for the Plaintiff
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JEANNE M. TRITT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs, CIVIL ACTION - LAW
i; RONALD L, TRITTt NO. 94- 376,7 CIVIL dJ.t,,,
" Defendant IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
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'I You have been sued in court. If you wish to defend
,I against the claims set forth in the following pages, you must
j take prompt action. You are warned that if you fail to do so,
.1 the case may proceed without you and a decree of divorce or
':",'11 annulment may be entered against you by the court. A jUdgment
may also be entered against you for any other claim or relief
requested in these papers by the Plaintiff. You may lose money
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Ii or propertr or other rights important to you, including custody
il or visitat on of your children.
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When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the Prothonotary at the Cumberland County Court House,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL
PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE
DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO
ANY OF THEM.
OF
CLAIM
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE.
IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONEt GO TO OR
TELEPHONE THE OFFICE SET FOR'rH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
Court Administrator
Cumberland county Court House
Fourth Floor
Carlisle, PA 17013
Telephonel (717) 240-6200
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JEANNE M. TRITT, I IN THE COURT OF COMMON PLEAS
plaintiff I CUMBERLAND COUNTYt PENNSYLVANIA
I
vs. I CIVIL ACTION - LAW
I
RONALD L, TRITT, I NO. 94- CIVIL
Defendant I IN DIVORCE
COMPLAINT UNDER SECTIONS 33011CI
AND 3301101 OF TilE DIVORCE CODE
!;OUNT 1
1. Plaintiff is JEANNE M. TRITT, an adult individual who
currently resides at 1691 Walnut Bottom Road, Newville,
Pennsylvania, 17241
2, Defendant is RONALD L. TRITT, an adult individual who
currently resides at 1691 Walnut Bottom Road, Newville,
Pennsylvania, 17241.
3. Plaintiff and Defendant have been bona fide residents in
ths commonwealth of Pennsylvania for at least six months
immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on March 29t
I 1986 in Cumberland county, Pennsylvania.
"
!I COUNT I - DIVORCE
"
I Plaintiff hereby incorporates by reference averments 1
through 4 as if each averment were set forth fully hereunder.
5. There have been no prior actions of divorce or for
annulment between the parties as to their current marriage.
6. Neither Plaintiff nor Defendant is in the Armed Forces
of the United statee.
7. Plaintiff avers that the marriage between the parties ie
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irretrievably broken,
0, The Plaintiff has been advised of the availability of
counseling and that she may have the right to request that the
court require the parties to participate in counseling.
COUNT II - DIVISION OF PROPERTY
Plaintiff hereby incorporates by reference all of the
averments contained in Count I of this complaint.
9. The parties have acquired real estate during the course
of their marriage located at 1691 Walnut Bottom Road,
Newville, PA.
10, The parties have acquired home furnishings, motor
vehicles, bank accounts, and miscellaneous items of personal
property.
11. The aforesaid items are marital property and the
Plaintiff requests that they be equitably divided.
COUNT III - PAYMENT OF FEES
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Ii costs and counsel fees.
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12.
Plaintiff requests alimonYt alimony pendente litet
WHEREFORE, Plaintiff prays that a decree be entered in favor
of the Plaintiff and against the Defendant as follows:
a) That a decree in divorce be entered;
b) That the herein described marital property owned by the
Plaintiff and Defendant be distributed according to law;
0) Suoh other additional relief as the Court deems
necessary.
WHEREFOREt the Plaintiff requests the court to enter a
decree of divorce in favor of the Plaintiff and aqainet the
Defendant,
Respectfully submitted,
O'BRIEN, BARIC & SCIIERER
By r--~~~
Robert L. 0 Brien,' Esquire
Attorney for Plaintiff
1.0. H 28361
17 West South street
carlisle, VA 17013
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Ii true and correct.
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I verifY that the statements made in this ccmplaint are
I understand that falee statements herein are
made sUbject to the penalties of 18 Pat C,S, S 4904, relating to
unsworn falsification to authorities,
(/64l1i?E Yl1 Clldf
JEANNE M. TRITT
Datel
)-6.91/
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JEANNE M, TRITT.
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
. CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
V,
RONALD L. TRITT,
! Defendant
. NO, 94.3767 CIVIL TERM
: IN DIVORCE
If you wish to deny any of the statements set forth in this Affidavit, you must file a
, Counter-Affidavit within twenty (20) days after this Affidavit has been served upon you or the
statements will be admllled
o
1. The parties to this action separated on or about July, 1994 and have continued to
live separate and apart for a period of at least two years,
2, The marriage is irretrievably broken,
! 3, I understand that I may lose rights concerning alimony, division of property, lawyer's
,
I
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I fees or expenses If I do not claim them before a divorce is granted,
I
I I VERIFY THAT THE STATEMENTS MADE IN THIS AFFIDAVIT ARE TRUE AND
I CORRECT, I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT
I TO THE PENALTIES OF 18 PA C,S SECTION 4904 RELATING TO UNSWORN
I FALSIFICATION TO AUTHORITIES,
II It . -11'1 tU
JEANNE M TRITT
Date: ",,3/12/Q 7
SHElll 1'1" S IU'iJUHN
aM>lCWwEM:J1t OF PENNSY1NANIAI
COUto.'J'Y OF CLMBEIllJ\l'/J)
Jeanne M, Tritt
VS
Ronald I.. Tr it t
Robert L. Fink
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No. 94-3767 Civil Term
Order of Court, Petition for Apeciel
Relief Complaint Under Hbctione
3301 (C) and 3301 (0) of The
Divorce Code and Notice
, S1l>>ltKNX~lI Deputy Sheriff of
Cunberlend County, Pennsylvania, who being duly sworn according to law, says,
Order of Court, Petition for Special Relief
that he selVed the within Complaint Under SEctions 3301 (Cl and 3301 (D) of
The DIvorce Code and Notice
upon Ronald L. Tritt , the defendant, at 8145 o'clock
A ,M.X\5M I EnST, on the 18
1691 Walnut Bottom Road, Newville
Pennsylvania, by handing to Ronald Tritt
day of July
, 1994 at
, Cunberland County,
Order of Court, Petition for Special RelIef
a true and attested copy of theComplaint Under SEctions 3301 (C) and 330,1 (D)
of The Divorce Code and NotIce
and at tha sal1~ ti/l1(! directing his attention to tlm contants thereof and
the "Notice to Plead" endoreed thereon.
ShCl:iff 'e Costs I
Docketing
Service
Affidavit
Surcharge
14.00
5.60
2.00
21.60 I'd. by Atty.
7-19-94
Swom and subscribed tu before Ire
this ,J I.. . day of ~_
19 'l'f A.ll,
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Prothonotary
;;~~~
R. 'J'haMs Kline, Shariff
by ~~n;L ~
Deputy Sheriff
-.--.
JEANNE M, TRITT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
: NO, 94.3767 CIVIL TERM
: IN DIVORCE
V,
RONALD L. TRITT,
Defendant
NOTICE OF INTENTION TO REQUEST
ENTRY OF DIVORCE DECREE
TO: RONALD L. TRITT
(Defendent)
You have been sued in an action for divorce, You have failed to answer the complaint
or file a counteraffidavit to the plaintiffs affidavil. Therefore, on or after April 2, 1997 , the
plaintiff can request the court to enter a final decree in divorce,
If you do not file with the prothonotary of the court an answer with your slgnatura
notarized or verified or a counteraffidavit by the above date, the court can enter a final decree
in divorce, Unless you have already filed with the court a written claim for economic relief,
you must do so by the above date or the court may grant the divorce and you will lose forever
the right to ask for economic relief, A COUNTERAFFIDAVIT WHICH YOU MAY FILE WITH
THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Court Administrators Office
Cumberland County Courthouse
Fourth Floor
Carlisle, PA 17013
(717) 249.6200
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JEANNE M, TRITT,
Plalnllff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION. LAW
: NO, 94.3767 CIVIL TERM
: IN DIVORCE
V.
RONALD L. TRITT,
Dafendant
DEFENDANT'S COUNTER-AFFIDAVIT UNDER
SECTION 3301(D) OF THE DIVORCE CODE
1, Check either (a) or (b):
(a) I do not oppose the entry of a divorce decree,
- (b) I oppose the entry of a divorce decree because
(Check (I), (Ii) or both)
(I) The parties to this action have not lived separate and apart
for a period of at least two years
- (Ii) The marriage Is not irretrievably broken,
2, Check either (a) or (b):
(a) I do not wish to make any claims for economic relief. I understend that I may
lose rights concerning alimony, division of property, lawyer's fees or expenses if
I do not claim them before a divorce is granted
- (b) I wish to claim economic relief which may include alimony, division of property,
lawyer's fees or expenses or other important rights,
I VERIFY THAT THE STATEMENTS MADE IN THIS COUNTER.AFFIDAVIT ARE
TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE
SUBJECT TO THE PENALTIES OF 18 PAC.S, SECTION 4904 RELATING TO UNSWORN
FALSIFICATION TO AUTHORITIES,
DATE:
.'
RONALD L TRITT
, NOTICE: If you do not wish to oppose the entry of a divorce dacree and you do not
I' wish to make any claim for economic relief, you need not file this counter-affidavit,
,
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JEANNE M. TRITT,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
NO, 94-3767 CIVIL TERM
IN DIVORCE
V,
RONALD L. TRITT,
Defendant
T
AND NOW, this day of
,1997, I, Thomes J, Williams,
Esquire, Attorney for Defendant, Ronald L. Tritt, hereby accept service of the Notice to
the Defendant, Nollce of Intenllon to Request Entry of Divorce Decree and Defendent's
Counter-Affidavit.
Thomas J, Williams, Esquire
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d.c.-
JEANNE H. TRITT,
Pla.tntUI
v
tIN THB COURT OF COMMON PLEAS OF
,CUHBBRLAND COUNTY, PENNSYLVANIA
,
'NO, 3767 - CIVIL - 1994
,
I
ICIVIL ACTION - CUSTODY
RONALD L. TRITT,
Defendant
2. Pend.tng further Order of the Court, the Mother, Jeanne M.
Tr.ttt, and the Father, Ronald L. Tritt, shall enjoy shared
legal oustody of Jason A. Tritt born July 1, 1986 and Ambyr L.
Tritt, born November 13, 1988. Physical custody shall be
handled with Father having physical custody each week from
Saturday at 6 P.M. until Wednesday at 6 P.M. and the Mother
having physical oustody from Wednes~a at 6 P.M. until Saturday
at 6 P,M.
.h~ {Jt:. r,/;t..,/N,
.Jf.
AND NOW, this 1J~ day of
of the attache5custody Con
directed as followsI
1. A Hearing is scheduled in Courtroom No. ~ of the Cumberland
County Courthouse on the ~ day of~~, 1994 at
~M. at which time testimony in~e will be
~At this Hearing, the Mother, Jeanne M. Tritt, will be
the moving party and shall proceed initially with testimony.
Counsel for the partie~ shall file with the Court and opposing
Counsel a Memorandum setting forth each party's position on
custody and also a list of witnesses that will be called to
testify at the Hearing along with a summary of the antioipated
testimony of each witness. This Memorandum shall be filed at
least ten days prior to the Hearing date.
~ 1994, upon oonsideration
Report, it is ordered and
001 Robert L. O'Brien, Esquire _
Thomas J. Williams, Esquire
Sf' 2,; I 10 In '9~
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JEANNE M. rRIfr,
Plaintiff
, IN rHE COURr OF COMMON PLEAS OF
,CUMBERLAND COUNrl', PENNSYLVANIA
,
'NO. 3767 - CIVIL - 1994
,
,
,CIVIL ACrION - CUS2'ODl'
v
RONALD L, rRIrr,
Defendant
CONCILIArION CONFERENCB SUMMARY REPORr
IN ACCORDANCE WI2'H CUMBERLAND COUNrY RULE OF CIVIL PROCEDURB
1915.3-8(b), the undersigned Custody Conciliator submits the
following report'
1. rhe pertinent information pertaining to the children who
are the subject of this litigation is as followsr
Jason A. Tritt, born July 1, 1986, and Ambyr L. Tritt, born
November 13, 1988.
2. A Conciliation Conference was held on September 15, 1994, with
the following individuals in attendance,
The Mother, Jeanne M. Tritt, with her counsel, Robert L.
O'Brien, Esquire and the Father, Ronald L. Tritt, with his
counsel, Thomas J. Williams, Esquire,
3. The parties separated in August. Currently, the parties have
reached an agreement on custody in the nature of a shared
custody arrangement such that Father has the children from
Saturday at 6 P.M. until Wednesday at 6 P.M. and Mother has
the children Wednesday at 6 P,M. until Saturday at 6 P.M.
4. Mother is starting a job at Carlisle Tire and Rubber in the
next few weeks, Father is a dairy farmer.
5. The parties are at odds on the issue of custody, Both parties
feel that they should have primary physical custody of the
minor children. A Hearing is necessary.
6. The Conciliator recommends an Order in the form as attached.
r/~~/ ?L
DATE
re
1174,I.,ornildwl..
RONALD L, TRlIT,
Plaintiff
IN TIlE COURT OF COMMON PLBAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 94-3767
CIVIL ACTION LAW
v,
JEANNE M, TRlIT,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this ~;Jll~ay of ~, 1994, upon consideration of the Bllached
Complaint, It Is hereby direcled Ihat the parties and their respective counsel appear before
H'lht/l 'I. b,'llcJf ("I "theconclllator,at 1111\ fi".:, ("lilt. (" (c1,,'!lttd,
on thev:?,~rtUBY of c..)(, flf '/1,ht.- ,1994, at (f,' ).J o'c1ocl(LM for a Pre.
Hearing Custody Conference, At such conference, an effort will be made to resolve the Issues
in dispute; or if this cannot be accomplished, to define and narrow the issues to be hearn by the
Court, and to enter inlo a temporary orner, All children age five or older may also be present
at Ihe conference, Failure 10 appear at the conference may provide grounds for entry of a
temporary or pennanent orner, Pending sa~onference, Plainti~ granted temporary
custo~ 'I '
FOR TIlE COURT.
.-
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RONALD L, TRlIT,
Plaintiff
IN TIlE COURT OP COMMON PLEAS OF
CUMBERLAND COUNTY, PBNNSYLV ANlA
NO, 94.3767
CIVIL ACTION LAW
v,
JEANNE M, TRlIT,
Defendant
IN DIVORCE
COMPLAINT FOR CUSTODY
I, Plaintiff is Jeanne M, Tritt, adult individual, who is currently residing at 1691 Walnut
Bottom Road, Newvll\e, PA 17241, Cumberland Counly, Pennsylvania,
2, Defendant is Ronald L. Tritt, adult Individual, who is currently residing at 1691
Walnut Bottom Road, Newvll\e, PA 17241, Cumberland County, Pennsylvania,
3, Defendant seeks custody of the children, Jason and Amber, who were born on July
1,1986 and November 11,1988, respectively,
The children were not born out of wedlock, Since the childrens' birth, the children have
resided with the parties hereto at their above address, TIle naturnl mother of the children Is
Jeanne M, Tritt who resides as aforesaid, TIle naturnl falher of the children is Ronald L, Tritt
who resides as aforesaid,
4, TIle relationship of the Defendant to the children Is that of father,
5, The relationship of the Plaintiff to the children is that of mother,
6, The parties have not participaled in previous Iitlgallon concerning the custody of the
children In this court or any court, The Defendant has no infonnatlon of a custody proceeding
concerning the child pending in any olher court,
7, 11le best Interesl and penllanent welfare of the child will be served by granting
custody to Plaintiff because Plaintiff can provide stability through the separation In the same
home the children grew up In, and Plalnllff, as a self.employed fanner, has greater flexibility
in being available for the children, and Is beller able 10 sUJlervise them on the fanll,
WHBRBFORB, Defendant requesls your Honorable Court to set a time and place for a
hearing at which Defendant requests the Court to grant them the Custody Orner, Pending said
hearing, Defendant requests temporary custody,
MARTSON, DEARDORFF, WILUAMS & OTIO
BY~Mi~~
11\Omas J, IlIIams. Esquire
Ten BaSI High Street
Carlisle, PA 17013
(717) 243-3341
Allomeys for Respondent/Defendant
Date: July 19. 1994
VBRlflCATION
TIle foregoing Complaint for Cuslody Is based lIpon Infonnatlon which has been gathered
by my counsel In the prepamtlon of the lawsuit, TIle language of the document Is that of
counsel and not my own, I have read Ihe document and to the exlent that It Is based upon
Infonnatlon which I have given to my counsel, it is tnle and correcl to the best of my
knowledge, Infonnatlon and belief, To the ex lent that the content of the document Is that of
counsel, I have relied upon counsel In making Ihls verification,
TItls statement and verification are made subject to Ihe penalties of 18 Pa, C,S, Section 4904
relating 10 unsworn falsification to authorities, which provides that If I make knowingly false
avernlents, I may be subject to criminal penalties.
Il..^,u i ~~
Ronald L, Trill
t" \J'lItMII~l"tlU \111 "11lA1.IIlIl'UIH 1~"u\l..
.mANNg M, '1'Im,,,
PlllintifT
IN 'I'Im COUH'I' Ol~ COMMON PUMA
CUMBl~IU.AND COUNTY, PI~NNSYLVANIA
CIVIL ACTION. CUSTODY
v,
nONALD I" '1'lm'I"
Dofl!mlllnt
NO, :\7li7 CIVIL I!IlJ4
FA'I'Illm'S MgMOHANDUM
I~ATHEIt'S POSITION
Fllthel' desil'l1s pl'imlll'Y physicIII custlldy with the mlltlwl' hllving nllol'lllllll weekends
IInd hulidllYs during the schlllll yell 1', IInd extonded custlldy to the 1II0thlll' dming tho SUlllmel'
mllnths,
SUMMAItY OI~ '1'H1~ TI~S'l'IMONY OI~ ItONALIl L, 'I'IlI'I"!', I~A'I'HEIt
Flltlwl' WIIS hili'll 10/1 :lma, IInd Mlltlun' WIIS hlll'll 4/11/li7, Bllth b'1'lIdullh~d from Big
Spring High Schlllll . Iw in W8 I, sho in 1!J84 . IInd Iwitlwl' hilS IIny further educlltillll,
'I'hey WI~1'I1 IIIl1l'ried a/2!J/86, in Shippenshlll'g, Cumlwrlllnd County, IInd this WIIS the
first mlll'l'illge for hoth, Tlwy hllvetwo childl'on, hoth hol'll of tho IIIIl1'1'illgellnd bllth bol'll in
Cm'lisll! Huspitlll: ,llIson hol'll 7/1/86 IInd Amhyl' hllm IIIJ:l/88, Thoy 11I'0 hoth IIthmdlng Ollk
Flllt Ell!Inm\tlll'Y School. .llIson is in the sl!cllnd gl'llde IInd Alllhyl' is ill IIflol'lluon
killdel'glll'lon, 'I'hoy lIl'O hoth in gOlld helllth,
'I'he III IIl'i till l'llsidonce is II la:l IIcro dllil'Y flll'm in Penn Tllwnship, CUlllberlllnd
Cllunty, 'I'his is the llnly I'osidonce the children hllvo (WOI' knllwn, IInd they ench hllve their
own lwdl'oom, 1~lItlwl' wlll'ks thol'e liS II so!f.omplllyed dllil'Y fll!'OWI', Mother is employed liS
II Munpowel' TI!ll\pussib'1wd to tho GmlCl'lIl Mills plllnt in the Wults Imlustl'illl Cllmplex,
There she wllrked II 40 hllul' woek, hut Cllnsisting of three long dnys nnd one.hulf duy .
nJlJlIIl'enlly tho plllnt runs seven dnys II week, Her homs III'l1 gl!lwl'lllly reflective llf till!
oxisting tomplll'lll'Y custlldy lll'del', Howevm', lit the Concillllliun Cllnfol'lmco on lJ/lli1ll4,
Mother stilted tlllltslw hml socun,d employment lit ClIl'lisle 'l'ire IInd nuhbol' wOl'ldng MllndllY
thl'llugh FridllY on IIltol'llllting shifts: dllY (7.:1), ovm\lng (a.II), IInd night (11.7), Sll II1IIt sho
wllnld I'lltllte through ollch shm OVCl')' thl'oo wool(s, Mothol"s hl'ollwl' IIlso wud(s nt ClIl'lisll!
'I'il'll nnd Hublml' Ow I(otlwl' tho joh there) nnd tlwil' pllln WIIS thlltthey would Cllmmuto
togetlwl', workinl( till! sllnw shifl.
'1'hlll'll WIIS UIIO pl'iUI' SUPIII'llUUII fl'UIll 4t:111/4 tull/'2li!ll4, 011 /l/'2Ii!ll4, llluthlll'mUVlIlluut
ul' tho III lII'i till l'osidollClI IIl1d in with IIllI' hl'llthl!I', Huh Hhllff, ill I'lnllsuut IInll, 1~l'IIuklill
Cuuuty, Mllthm' hus sllid tu 1~IIt1wl' thnt thm'l! is SUn1l1 dlluhlillg up till hlllh'lIullls ut hm'
hl'lltlu1I"s Iwnw, nlld thntthis is II hHnplll'lll'Y IIITnllgllllll!lIt, hut shll WUS UIIClll'llllllus tu how
10llg it wlluld IIll Ill'fhl'll Shllglltlllll' UWII plllCI',
1~IIt1wl' wlllll'sli~v lhnl MIIIIIl'I' gllVl', liS IIII' I'I'IIS01l fill' II'IIVillg, thutslw wlllllml n1l1l'l!
l!xdh!nlllnl ill hl'I' Iil'll, Ihul sllll wllnlt!d "spncl'," ullllllIl'UIllI! IInd go liS sIll! pIIllISI'S, HIIllUl80
luld Ihl!1ll tllIIl slw hud /lilli'll tlllln ulln "l'lInllllll'tl" with tlthl!I' nll'lI, Ill! will h!slll'y thlll hilI'
Iil'll-Styll!, prim' 10 llw SI!Plll'lllillll, hils 11Ill!1I III fl'l'llUtllltly sIllY lIul lull! ut lIight wilh hilI'
fl'illllds,
HillClI lho plll'lil!8 80plll'lllod, Mllllwl' IIl1d hilI' l'Ullllly hllYl! IIllldo u Ctlllcol'tnd t!ffol'tto
illl,'1'lIlilllothlIIllSI!lvl!1I wilh Iho chlldl'l'lI hy huyillg lillII' loys 1I11ll0llt I!VlII'Y wlll!k, Thoy huvc
IIlsl1 hllllll cl'ilicul of Flllhol' 10, Ill' ill tllll PI'lISI'IICO of, llll! childl'llll, Mothol"s futhCl' cnlled
Fntlllll' "il,'1)ol'lllll." Mtltlll!1' hel'slllf rulll'd hilll u "fuckillll' jncknss," Fnthlll' hns lIellt school
pl'ojocls wilh till! childl'llll 1111 Ihllh' visils III Mllllll!l', hUlthoy hllvo IIl1t hllOIl I'l!tul'llod,
I~nthel' will submitthuttlw hesl illtel't!st8 ulld pel'/lIlInl'nt wolfnl'll of tho chlldl'oll will
ho 11ll8t SI!I'Vtld by stllying ill the I'llsidenclI Whtll'll tlwy hllYlI livlld SillCI1 bil'th ill n stllhlo
ollvil'unnwllt. l~utlll!1' dllllS lI11t dispuhl thllttllll nwtlll!1' 10VllS llw dllldl'llll nnd is cnpnhle of
clIl'ing fol' thOlll, hutlw hnlh,vnll sho is guillg Ihl'llugh u Plll'iod in hm' lifil whoi'll till! chlldl'llll
nm IIl1tlwl' pl'illlnl'Y CllIIClll'lI, M0I110Vel', MlllllI'l"s work sdll'duh' lIlukns it impl'llclicnl fill' hol'
III hllvo tlw childl'Oll, 011 till! dllY shift, slw would hnvo 10 h'IIVIl 1'01' wOl'k by 1I:00 lUll.,
WlWl'll1l8 tlw scholll bus pidls up ,11I811n IItllhllUt H::IO lI,m, IInd Amhyl' IItllbout 12::10 p,m,
Wlllln Mlllhl'l' wlll'ks Ihl' I!Vllllillgllnd lIighl shifts 111ll1'll would Ill' 110 lJIU' to wlltch the chihll'llll
UIlItISS sllll brings ill II IiVII.ill bllby-siltl!l', 011 IIIll otlWI' hlllld, 1~lIllwl' is (>SSlllllilllly t11111'll 1111
dllY, Whlll' Ill' C1!l'llIillly WlIl'Ils thn flll'lll, ulld so willllotllll physiCIIlly pl'llSllllt ill the huusll
100 plll'l'l!llt of 11ll! tilllll wlll'1l till' chlldl'l'lI 1I1'1! tllI'l'l', his Ilnll! Is f1l'xibln IInd he is 111 thn
illllllmlillln viclllity,
'I'I~S'I'IMONV OF MICIIAI~L TIlI'I"I', ImNm ANn JUJ.m IIImClllm, ANn TOM ImAM
If nlll'I!S8I11'y, thllSl1 witnl'8SI!8 willl'l'Inh! tlwlt' obs\lI'Vntiuns tlf Mollwl' Inhlllt Ilight ill
tlw C11Ill)lnny uf Vllrious nWII III IIIYIH'IlS 111 IIlld II1'0UIIII CIII'I1811' whlln IIItlwl' WIIS IWIl\(! with
Ihlll'hildl't'lI,
AddlUonlllly, Mothor told M." nOllm thllt 8ho didn't wllnt custmly uf tho chlld,'on until
Rho ruundout 8ho wuuld hllVll to \lilY SUII!lUl't,
HosJloctfully RuhmlUllll,
MAH1'SON, D1~AHnOHl~I~, WILLIAMS & OTl'O
By: .,~)W~
1'humns II, WilllnmR, Esquiro
Ton Eust High StrlJllt
Cnrlislll, PA 17013
(717) 24:1.3341
AUurnoys fur Dofondant
Dntll: November 4, 1994
Qlm'lWICAT~ OF BEHVICE
I herllby certify thllt II COllY of tho fnrolllllngl~lIther's Mllmnl'lllldum WIIS served this
dllte by deJlusltingsllme In tho Post omcn lit ClIl'llslo, PA, first c1I1SS 011111, IlllStllge llreJlllld,
nddressed liS follows:
Hebort I" O'Brlon, Esquire
Q'BHlEN, DAHlC & l:lCIIEHER
17 Westl:louth l:ltreet
Cllr1ls10, PA 1701:1
MAHTSON, DEAHDOHI~F, WILLIAMS & ono
By-1 ~ 6J ) /)vJL--.
1'homns J, Wililnms, Esquire
Ten Enst High Street
Cllr1lslo, PA 17013
(7171243.3341
Attornoys for Defendnnt
Dnted: November 4. 1994
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vs.
IN 'mE cnJRr OF o::tfl:)N PI..lWl
aJMBERIl\ND cnJNl"{, PalNSYLVANIA
CML ACTION - lAW
JEANNE M. 'mI'lT,
Plaintiff
OONAID L. 'mI'lT,
Oeferdant
NO. 94-3767 CML 'I'ERoI
I IN DIVORCE/CUSTODY
Kn'HER' 8 M1'HlRNmUH
SlHIARY OF TES'l'lM:lNY OF JFANNE M. TRITl', t-PrnER
Jeanne M. Tritt graduated in the class of 1985 aOO married Ronald L. Tritt,
the follONing year. lIer husband is a dairy farmer, who leases the fann. Mrs. Tritt
was the primary caretaker of the children from their birth until such time as the
father wanted her to take 8l11Jloyment outside of the home. After the mother took
8l11Jloyment outside the home, her husband still expected her to maintain the
household, as well as to arrange for child care while she was at work, as he did not
want to watch the children. Accordingly, the mother was forced to make aOO pay for
child care arrangements when she took her job.
'ilie cause of the parties' separation and perding divorce, was the father's
refusal to spend time with her and the children. Prior to the parties' separation,
the father shCMed no interest or inclination to maintain a close relationship with
his children. On April 3, 1994, the father IT'OVed from the family's residence. On
June 25, 1994, he IT'OVed back in and announced that he was putting his wife out of
the home. 'ilia father attenqJted to force her out of the home without the children in
an effort to coerce her back into his failed marriage.
'ilie mother, for the past year, had an application pending at Carlisle Tire aOO
Rubber. lIer eJ1tlloyment at General Mills was through a t8l11JOrary labor service
organization aOO provided no job guaranties or additional benefits. In rnid-
September, 1994, she was hira:) at Carlisle Tire aOO Rubber aOO works a alternating
week schedule. Mrs. Tritt, at the present tilOO, is not OOO11llting with her brother,
bocaUEG of a different time frame for starting aOO erding her shift.
She will testify as to the situation in her home in reference to caring for
the children, as well as the child care arrangements. 'I1le mother denies any moral
wrongdoing of any nature in referenoe to the children. She will testify that
contrary to the father's allegations, she did not frequently stay out late at night,
but to the contrary, the father was the one, who on a regular basis, would stay out
at bars late into the evening.
'lhe ITOther ard her family have not IItteJ1pted to ingratiate themselves with the
children by wying them toys. 'lhe problem arose when the father would not permit
the mother to have any of the children's toys aOO playthings when he forced her out
of the haoo. In an effort to obtain some of these items, the mother requested a
special relief hearing. 'lhe court did not direct the father to give any of these
items to the rother, 60 she Is in the process of providing playthings for the
dlildren as her budget permits. 'lhe rother denies tilat she is critical of the
father in front of the children aOO, in fact, suggests that the father is at fault..
'I1le mother believes that the best interest aOO welfare of the children will be
served by grantirg hor primary physical custody. She intends to call as witnesses,
her brother, Rob ShOff, who lived with the family for a lengthy period of time ard
who has observed each parent's relationship with the children. She will call her
rother, Darbara Shoff, in reference to child care abilities aoo her grardmother,
(Jetty IlatIer, who will testify liB to her observations of tile father placing the
dlildren in an unsafe position in his farming operation.
Respectfully subnitted,
a/BRIm, BllRIC & SOIERER
BY~IO~
Robert L. a ien, EsqUire -
Attorney for Plaintiff
I.D. # 28351
17 west South street
Carlisle, PA 17013
(717) 249-6873
JEANNE M. 'l1U'1T!
Platntiff
I IN 'mE CDJRl' OF cnt<<lN PlEAS
I CllMBERl/IND cnJNl"{, l'ElmSYLVANIA
I
I CML ACTION - lAW
I
I NO. 94-3767 CML TfRoI
I IN DIVORCEjCUsroDY
va.
OONAID L. 'l1U'1T,
Defendant
CER1'IFICATE OF SERVICE
AND NaoI, rxIlleB Robert L. O'Brien, Esquire, Attorney for Plaintit11n the above
captioned case, Jeanne M. Tritt, ard certifies that he did this /8' day of
.
NavE!lTber, 1994, make service of a true aOO correct copy of the attached MeIoorandurn
upon 'I1lanas J. Williams, EsqUire, attorney for Deferdant in the above-captioned
case, Ronald L. Tritt, at 10 East IUgh Street, Carlisle, PA., 17013, by placing same
in the U.S. Mail, postage prepaid.
O'BRIffi, BllRIC & SOIERER
Byr t=2U~~ ~/-
,
~
Robert L. O'Brien, Esquire
SAID Rule-to-Show-cause returnable at hearing set for
VI..J ..1 <,lAtA
".j.r.~'n ) Lt'.J cut iI_ , the >IV day of
"
at 9: dl.' a.m./(hilI. in Courtroom # tj
tJttCy
, Cumberland
, 1994
vs.
I IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I
I
I
I
CIVIL ACTION - LAW
JEANNE M. TRITT,
Petitioner/Plaintiff
RONALD L. TRITT,
Respondent/Defendant
NO. 94- {III)
IN DIVORcl!
CIVIL ,~
AND NOW, th is
9(t t >'-
attached Petition for Speoial Relief
ORDER OF COURT
/ j71) day of
, 1994, upon
review of the
filed by
Petitioner, Jeanne M. Tritt, this Court issues a Rule is issued
upon Respondent, Ronald L. Tritt, to show caUse why said relief
should not be granted.
County
Courthouse, Carlisle, Pennsylvania.
PENDING hearing, the Petitioner/Plaintiff shall have the
right to remain in the marital residence without interferenoe or
harassment from the Respondent/Defendant.
BY TilE COURT,
-/) Lr4J~.
J.
,/
"
':C1
to...
n
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-
...-...
l'~
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il
Ii
11
'Iii JEANNE M. TRITT,
Petitioner/Plaintiff
II
II
I!
Ii
Ii
I
I IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I CIVIL ACTION - LAW
I
I NO. 94- CIVIL
I IN DIVORCE
vs.
RONALD L. TRITT,
Respondent/Defendant
PETITION
Em
SPECIAL RELIEF
1) Petitioner is Jeanne M. Tritt, Plaintiff in the above-
captioned divorce aotion.
2) Respondent is Ronald L. Tritt, Defendant in the above-
captioned divorce aotion.
3) Respondent has stated to Petitioner that she oannot
take her motor vehicle with her when they separate. The parties
were married on March 29, 1986 and they currently have two
vehicles, a piok-up truck, as well as a Ford Bronco. Petitioner
has at all times during the marriage utilized the Ford Bronco as
her vehicle for transportation for herself and the parties' two
The automobile is titled in the name
II children, Jason and Ambyr.
II
I
I
of Respondent.
In order to insure that she has adequate
transportation for herself and the children and to enable her to
get to and from work, Petitioner respectfully request that the
Court set a hearing and issue an order granting Petitioner the
use of the parties' 1986 Ford Bronoo automobile.
I
i
j!
I! Respondent allow her to remain in the marital residence pending
Ii
4)
Petitioner request the court order and direot that
the hearing in thie matter without interference or harassment.
!i
"
I'
,i
,I parties' residence so as to ostablish a separate residence for
5)
Petitioner also needs to take belongings from the
herself and the children. In order to establish said reeidence,
she requests the items listed on Exhibit "A" attached hereto and
incorporated herein by reference.
WHEREFORE, Petitioner respectfully requests that Your
lIonorable Court issue a Rule upon Respondent to show cause why
said the relief requested should not be granted.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
I
II
II
II
il
I
I
I
I
;- ~~;;Ja ~~-
Robert L. O'Brien, Esqu[re
Attorney for Petitionsr
1. D. . 2835l
17 West South street
carlisla, Pennsylvania 17013
(717) 249-6873
,
I
I Speoial Relief are true and oorreot.
,I
!
i
I
I verifY that the statements made in this Petition for
I understand that false
statements herein are made subjeot to the penalties of 18 Pa.
c.s. I 4904, relatinq to unsworn falsification to authorities.
~~fJ6 -fl7, c:;;ttd!
JEANNE M. TRITT
Oatel
7- b- 9V
i
I 1)
II 2)
,
Ii
,I 3)
! 4)
5)
6)
7)
B)
9)
10)
11)
aXKIB:lT "A"
clothing, jewelry and other personal belonginga
children's clothing, toys and personal belongings sufficient
to establish a separate residence for each child
Home Interior pictures and all other items on the walls
Floor model television, vcr and vcr tapes for children
Children's beds and dreBBerB
Kitchen table and chairs, microwave, microwave stand and
dishes
Washer and dryer
stereo
one-half of family and children's photos
Two end tables and lamps
Antique table bequeathed to Petitioner/Plaintiff by her
great-aunt
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va.
I IN '11m CXXJRl' OF lXtoHlN PI..lWl
I OJMBERI.AND cnJNl"{, PENNSYLVANIA
I
I cML ACTION - lAW
I
I NO. 94- 371..' 7 cML.::Jt~
I IN DIVORCE/CUSTODY
JEANNE M. 'l1U'lT,
Plaintiff
JnUill) L. 'l1U'lT ,
Oefenlant
QBDf;R OF CXXJRl'
AND NaoI 'I1US ~ day of -n' \ i ' 1994, upon CXlnsideration of
the attadled carplaint, it is hereby directed that the parties and their respective
counsel aweat' before \ \L' ~t\ ~ ~, (:"" \ 1\'1 {~(, , the conciliator, at
---Lt{ \, '\ \l..-"UI lvn,\), (0, { ''''1'\\..,'<1 on the -;ill day of Sr/JIl'fIlbt, 1994
at {t.' ,?iJ ~)P.M., for a Pre-Hearing custody Conference. At such conference, an
effort will be made to resolve the issues in disputel or if this cannot be
aooarplished, to define and narrow the issues to be heard by the court, and to enter
into a t8l11JOrary order. All children age five or older ~ al60 be present at the
conference. Failure to appear at the conference may provide grounds for entry of a
tenporary or permanent order.
BY 'mE CXXJRl',
./;ll.tt!ttA- ~.gAl,tJl"(.q,
custody Concililitor ' F~;J /
Ya.! SIlOOW TAl<E 'I1US PAPER 'ID YOOR lAWYER AT ONCE. IF YOO 00 NOT HAVE A lAWYER OF
CANNcn' AFFORD ONE, GO 'ID OR TEIEAIONE 'mE OFFICE SE:l' FORm BEIrM 'ID FIND oor WHERE
Ya.! CAN GE:l' I.OOAL HELP.
BY
OFFICE OF '11m CXXJRl' AOONISTAA'IDR
<nnmIOOSE, 4'll1 FIDOR
CARLISIE, PA 17013
(717) 240-6200
JUl b q 13 rH '9~
i'fl:t,
:~d
. r
I
,-;
JEANNE M. 'l1U'1T!
PIa lnti f f
I IN 'mE 0XJRl' OF cnMlN PlEAS
I aJMBE:RlAND o::mtI"{, l'ElmSYLVANIA
I
I CML ACTION - lAW
I
I NO. 94- CIVIL
I IN DIVORCE/CUS'fODY
vs.
InIAlD L. 'l1U'1T,
it Defendant
II
,
,I
cn-tPIAINT FUR aJS'fODY
,
I
II 1. Plaintiff is JEANNE M. 'l1UTl', an adult individual, currently residing at
1691 Walnut Bottan ibad, Newville, UI1TOOrlard County, Pennsylvania, 17241.
2. Defendant is InIAlD L. 'l1UTl', an adult individual, currently residing at
1691 Walnut Bottan ibad, Newville, UI1TOOrlard County, Pennsylvania, 17241.
!
II
i 7/1/B6, age 7 yearsl and, Anbyr L. Tritt, born l1/13/BB, age 5 years.
3. Plaintiff seeks custody of the follo,.ting childrenl Ja60n A. Tritt, born
'llie children were not born out of wedlock.
'I1le children are presently in tile custody of Plaintiff ard the Oeferdant, who
reside at 1691 Walnut Bottan Road, Newville, UI1TOOrlard COUnty, Pennsylvania.
DJrill;J the past five years, or since the children's births, the children have
resided with Plaintiff and ~fendant at 1691 Walnut Bottan Road, Newville,
Pennsylvania.
The natural mother of tile dlildren is Plaintiff, currently residing at 1691
Walnut Bottan Road, Newville, Pennsylvania.
She is marriErl to the ~fendant but has recently tiled for divorce in tile
court of Umoon Pleas of UI1TOOrlard County docketed to No.
'I1le natural father of the dlildren is ~fendant, currently residing at 1691
Walnut Bottan Road, Newville, Pennsylvania.
lie is married to tile Plaintiff.
'i
,
Ii
i:
4. '1lle relationship of the Plaintiff to the children is that of natural
i'
I:
"
i rother. Plaintiff antioipates separating fran the Defendant Father in the near
I
!i future.
5. '1lle relationship of the Defendant to the children is that of natural
father .
6. Plaintiff has not participated as a party or witness, or in any other
capacity in other litigation, concerning the custody of tile children in this or in
any other court.
Plaintiff has no information of a custody proceeding concerning the child
perding in a caJrt of this CamPnwealth.
Plaintiff does not knCM of a person not a party to the proceedings who has
(ilysical custody of the child or claims to have custody or visitation rights with
respect to the children.
7. 'llie best interest and permanent welfare of the children will be served by
granting the relief requested because Plaintiff is able to provide a stable and
secure hare for the children.
B. Each parent whose parental rights to the children have not been terminated
ard the person who has (ilysical custody of the children have been named as parties
to this action. No other persons have or claim to have a right to custody or
visitation of the children.
I
Ii
;1
I verify that the st:otemlll1ts lMde in the foregoirg CDrplaint for
t\1Stody are ttue ard correct. I Wlierel:arxl that false Btatemants herein are made
subject to the penalties of 18 Fa. C.S. i 4904, relatlrg to WlSWOm fillsification to
authorities .
!~~M -(1'1. Ci/(.:)i
JEANNE H. 'l1U'1T
lY\TE I
).6.ttr
11741-fulltllftlU
JEANNE M. TRITI,
Pelltloner/PllIhulff
IN mE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PBNNSYL VANIA
v,
NO, 94-3767
CIVIL ACTION LAW
RONALD L, TRITI,
Respondenl/Defendnnt
IN DIVORCE
RESPONSE TO PBTITION FOR SPECIAL RBUBF
TO: Jeanne M, Trill, Pelltloner/Plnlnliff. and her allomey, Robert L, O'Brlen, Esquire
AND NOW. comes the RespondenllDefendnnt. Ronald L. Tritt, by his attomeys
MARTSON. DEARDORFF, WILUAMS & OTIO. and responds to Petition for Special Relief
as follows:
I, Admitted,
2. Admitted,
3, Admitted in part and denied in part. It Is arhnltted that Ihe parties were married
on March 29. 1986. thai they have two children, and that Respondent owns a 1988 Ford Bronco
that has usually been used by Petitioner. The children have been tmnsported In both the Ford
Bronco, as well as another vehicle owned by Respondent, a pick-up tnlck. It Is further admllled
that. on advice of counsel, Respondent has told Petitioner that she cannot simply lake his Ford
Bmnco and use It as her own after the parties sepamte, If indeed Petitioner Is going to leave the
marital residence, TIlls advice Is due to Issues Involving Insulllnce, maintenance and liability,
nespondent has no objection to Petitioner receiving the Ford Bronco as Jlart of the equitable
division of marital JlRlJlerty.
4, No answer required,
5, Admitted In part and denied In part. While some of the Items requested by
Petitioner and listed on Exhibit "A" belong to her and she can take them if she wishes, many
Items lire necessary for Respondent to maintain the mnrltal residence, both for himself and his
two minor children, ResJlondent's Jlosltion with regard to the Items requested by Petition Is as
follows:
I, No objection;
2. Objectloni
3. No objection as to plclures belonging to wife; however, Respondent
objecls to the removal of olher items from the walls, such as clocks, elc.;
4. Objection;
S. Objection:
6. Objection;
7. Objection;
8. No objection:
9. No objection;
10. Objection;
11. No objection.
WHEREFORE, Respondent respeclfully requests Your Honorable Court to deny the
Petition for Special Relief except to the exlent conceded herein.
MARTSON, DEARDORFF, WIWAMS & 0170
By "'d._,; VvJl.,~
TIlomas J. WI lams, Esquire
Ten Easl High Street
Carlisle, PA 17013
(717) 243-3341
Allomeys for Respondent/Defendant
Date: July 19, 1994
VBRlFlCATION
TIle foregoing Response 10 Plaintiff's Petition for Special Relief Is based upon Infonnatlon
which has been galhered by my counsellnlhe prepamllon of the lawsuit. TIle language of the
document Is thai of counsel and not my own, I have read the document and to Ihe extent that
It Is based upon Infomlatlon which I have given 10 my counsel, It Is true and correct to the best
of my knowledge, Infonnatlon and belief. To Ihe extent that the content of the document Is Ihal
of counsel, I have relied upon counsel In making this verllicatlon.
This statement and verification are made subject to the penallles of 18 Pa. C.S. Section 4904
relating 10 unsworn falsification to authorities, which provides that If I make knowingly false
uvennenls, I may be subject 10 criminal penalties,
1~~1 1. 7-dr
Ronald L. Trill
CBRllF1CATB OF SBRVICB
I hereby certify Ihal a copy of Ihe foregoing Response 10 Pelltlon for Special Rellef was
selVed Ihls dale by deposlllng &Bme In Ihe POSI Ornce al Carllsle, PA, firsl class mall, postage
prepaid, addressed as follows:
Robert O'Brien, Esquire
O'BRIBN, BARIC & SCHERER
155 Soulh Hanover Slreel
Carllsle. PA 17013
MARTSON. DBARDORFF, WILUAMS & 0170
By '1~--~ 'kFJP. ~
11lomas J. WII ams. Esquire
Ten BaSI High Slreet
Carlisle, PA 17013
(717) 243.3341
.L
Allomeys for Respondent/Defendant
Dated: July 19. 1994
117..I.lJllIWwfu
JEANNB M. TRITI,
Plaintiff
IN TIiB COURT OP COMMON PLBAS OF
CUMBBRLAND COUNTY, PBNNSYL VANIA
NO. 94.3767
CIVIL ACTION LAW
v.
RONALD L. TRITI,
Defendanl
IN DIVORCE
ANSWBR
TO: Jeanne M. Trill, Petitioner/Plaintiff. and her allonley, Robert L. O'Brien, Esquire
AND NOW, comes the RespondenllDefendant, Ronald L. Trill, by his allomeys
MARTSON, DHARDORFF, WILUAMS & OTIO, and responds to Plaintiffs Complaint as
follows:
COUNT I
I. Admllled.
2. Admilled.
3. Admitted.
4, Admllled.
COUNT I . IN DlVORCij
5. Admllled.
6, Admllled,
7. Denied, On the contrnry. Defendant believes, therefore avers, that the marriage
Is nol Irretrievably broken, and has requested counseling 10 reconcile Ihe parties.
8. No answer required.
COUNT II - DIVISION OF PROPERTY
9. Denied. The parties own no real estatc.
10. Admilled.
II. Admitted only lhat Plaintiff and/or Defcndant own marilal property: Ihe balance
of the avcnnelll Is dcnlcd.
COUNT III . JlA YMENT OF FBas
12. Denied that Plaintiff Is cntltled to nllmony, alhnony pendenle lito, cost and/or
counsel fees.
WHBRBPORB, Defendant pmys that Plalntlfrs Complaint be dismissed with prejudice.
Respectfully submllled,
MARTSON, DBARDORFP, WILUAMS & 0110
By "'T ~"" ') wlL ~.. ~_
-
TIlOmas J. Williams, Esquire
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant
Date: July 19, 1994
VERIFICATION
The foregoing Answer to Complaint In Divorce Is based upon Infornlatlon which has been
gathered by my counsel In the prepamtlon of the lawsull. The language of the document Is that
of counsel and not my own. I have read the documenl and to the exlenl that II Is based upon
Infonnatlon which I have given to my counsel, It Is tme and correct to the best of my
knowledge, Infornlatlon and belief. To the extenl Ihal Ihe con lent of the document Is thai of
counsel, I have relied upon counsel In making this verification.
TIlls statement and verification are made subJcctlo the penalties of 18 Pa. C.S. Scctlon 4904
relating to unsworn falsification to authorities, which provides that If I make knowingly false
avennenls, I may be subJcctlo criminal penalties.
1liJ7U1?1 i ~~
Ronald L. Trill
CBRTIFICATE OF SBRVICij
I hereby certify thai a copy of Ihe foregoing Answer was selVed this dale by deposlilng sallie
In the Posl Office at Carlisle, PA, first class l1Iall, postage prepaid, addressed as follows:
Robert O'Brien, Esquire
O'BRlBN, BARIC & SCHERBR
155 South Hanover Street
Carlisle, PA 17013
MARTSON, DEARDORFF, WILUAMS & 0170
By ,.~~? ~i.-.."","\
TIlolUas J. Willial1ls. Esquire
Ten Bast High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant
Dated: July 19, 1994
\
JEANNE M. TIU'I'1',
Plnlntlff/Pctltluncr
IN nm COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
94.3767 CIVIL TERM
VK.
RONALD L. mil'!'.
Dcl'cndnnl/RcKplllldcnt
IN DIVORCE
I~ HE: PETITION FOR SPECIAL IUlUEF
ORDER
AND NOW. thlK .2 o' dny 01' July. 11)1)4. I'ulluwing hcnring un pctltlun uf the
plnintiff, in cunjunctlun wilh any KuhKcljucnt Keparntion ul' Ihc pnrticK. It iK directed that the
fulluwlng items ul' perKunnl pruperty hc tnlllKl'errcd luthe wil'c:
I. Clothing. jcwelry nnd othcr pClKllllul itemK;
2, Those Humc Intcrior picturcK or other itemK on the walls which arc personal to the
wil'cj
3. The stl.rCOj
4, One-hnll' 01' family nnd chlldrcn'K phutuK; nnd
5. An unllljue Inhle hCljucnthcd tll plainliWpetltloncr hy hcr great nun\.
In addltiun, nnd provided IllIItlhc pnrties eun ngree on the vnlue thereof prior to nny
transl'cr, title 10 nnd pllKscKsion 01' II cl'ltnin Furd Bronco 01' the pnrtics Khnll he trnnsferred to thc
wil'c. The wife thcrcnfter Khnll hnve hl'cn dCl'med to huve rccelvcd Its vnlue for the purpose 01'
cljultnhle dlstrlhutilln, OthcrwiKc, thlK ordcr IK entered withllut prejudice 10 either pnrty with
rCKpcctto the ultimnte cljultnhlc disttlhutllln 01' mnrltnl nSKC!K:
~ ' i,. I .',
\'); JlV',ri'i~E COURT,
, ,.
v.
IN nIB COURT OF COMMON PLBAS OF
CUMBBRLAND COUNTY, PBNNSYL VANIA
NO. 94-3767
CIVIL ACTION LAW
JBANNB M. TRlTI,
Petitioner/Plaintiff
RONALD L, TRITI,
Respondent/Defendant
IN DlVORCB
ORDBR
AND NOW, this 2."~ day of July. 1994, and appearing that Plaintiff has filed a
Complaint In Divorce under 03301(c) of the Pennsylvania Divorce Code, and that Defendant has
requested counseling pursuant to 23 PACSA 03302(b), is hereby ordered and directed that
Plaintiff allend up to a maximum of three counseling sessions within ninety days following July
11, 1994 or suffer judgement of non pros.
Said counseling shall be with such counselor or agency as the parties may agree;
however, In the absence of an agreement, counseling shall be with Christian Services, Inc.,
Christ-Center Counseling, 60 West Penn Street. Carlisle, PA 17013. Counseling shall be at the
sole cost and expense of Defendant/Petitioner,
Pending completion of the counseling. all proceedings herein are stayed.
BY 11IB COURT
t,jJ L
J.
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J.' ..'" _.'.'1\ 1
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M. HJ f!,:: DZ lnr
1174.1,dclII/ldwl'l
JEANNE M. TRI11',
Petltloner/PllIllIllff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PBNNSYL VANIA
NO. 94-3767
CIVIL ACTION LAW
v.
RONALD L. TRI11',
Respondent/Defendant
IN DIVORCE
DEMAND FOR COUNSELING
TO: Jeanne M. Trill, Petitioner/Plaintiff, and her allomey, Robert L. O'Brien, Esquire
AND NOW, comes RespondenllDefendant, Ronald L. Trill. by his attomeys,
MARTSON, DEARDORFF, WILLIAMS & 011'0 pursuant 10 23 PACSA fi3302(b), and, In
support thereof. avers as follows:
I. Plaintiff filed her Complaint in Dlvoree on or about July II. 1994, and the slime
was selVed upon Defendant on July 18, 1994.
2. Plaintiff's Complaint, inler alia, demands divoree pursuant 10 fi330l(c) of the
Pennsylvania Divoree Code,
3. Defendant believes, and Iherefore avers, Ihat Ihe marriage is not irretrievably
broken, and that counseling would allow the parties to continue to live together as husband and
wife.
4. Defendant has consulted with the following agency listed on Ihe Cumberland
County list of marriage counselors, and Ihal agency Is available for said marriage counseling;
Christian Services, fnc"
Christ - Center Counseling
60 West Penn Street
Carlisle, PA 17013
(717) 249-7410)
5. Defendant/Petitioner Is willing to pay for said counseling sessions.
WHBRBFORE, Defendalll/Petit ioner prays Your Honorable Court pursuant 10 23 PACSA
fi3302(b) to order and dlrecl Plaintiff to allend uJl to a maximum of three counseling sessions
with thc said Christian Scrvlccs, Inc., or anothcr agency which thc partlcs may agree upon,
within ninety (90) days of July II, 1994, or suffer judgement of non pros.
Respectfully submitted,
MARTSON, DEARDORFF, WILUAMS & OlTO
by '1'~ '\ l/vi~~A .
Thomas J. Wlllla~s, Esquire
Ten East High Street
Carllslc, PA 17013
(717) 243-3341
Allomeys for Defendant/Petltloncr
Date: July 19, 1994
VBRlFICATION
The foregoing Demand for Counseling Is based upon Infonnatlon which has been gathered
by my counsel In the preparation of the lawsuit. TIle language of the document Is that of
counsel and not my own. I have read the document and to the exlent thai II Is based upon
Infonnation which I have given 10 my counsel. II is tme and correct 10 Ihe best of my
knowledge, infonnalion and belief, To Ihe extent thai the content of the document Is Ihat of
counsel, I have relied upon counsel In making this verification.
TIlls statement and verification are made subject to the pcnallles of 18 Pa. C.S. Seclion 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
avennents, I may be subject to criminal penalties.
11n.4/Jd. t ~
Ronald L. Tritt
C~l1FICATB OF SnRVICB
I hereby certify that a copy of the foregoing Demand for Counseling was served this date
by depositing same In the Post Offlce at Carlisle, PA, Orst class mall, postage prepaid,
addressed as follows:
Robert O'Brien, Esquire
O'BRlBN, BARIC & SCHBRBR
I SS South Hanover Street
Carlisle, PA 17013
MARTSON, DBARDORFF, WIWAMS & alTO
By 1 },;;; ~",t~,:-
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Respondent/Defendant
Dated: July 19. 1994
v{(adJoH, Q)efl)lrl~JlI! 'Jhlla mJ cS' {Ito
A ,lmUSIONAL t:Ol'OIlATlUN
A1IORNEYS AND COUNSELLOIIS AT LAw
TEN EAST HIGH STREET
CAIU.ISLE, PENNSYLVANIA 17013
WILLIAM F. MARTlON
DANfIL K. DEAROORlF
TUOMAI J. WILLIAMI
lvo V, Orrn, 111
SnrlUN L. DLllllM
GIORGI II. FALLER, JR,
WILLIAM O. P"WUL
TUOMA' G, COLLIN'
March 18, 1997
c.c: t:;..t:i
.
.3Fr;;/ti-7
TlUPUONI
(717) 24].3341
FAClIMIU
(717) 24].1850
INTUNIT
mdwollmdwo,com
I have yours of March 12, together with enclosures pertaining to the divorce, I am not
presently In communication with Mr, Trill; however, I am trying to reach him, Consequently, I
don't want to accept service of these documents until I can receive actual authorization from him
in order to do so. I would request that you not take any action with regard to the divorce until I can
do that, and then get back to you,
~
Robert L. O'Brien. Esquire
O'BRIEN. BARIC & SCHERER
17 West South Street
Carlisle. PA 17013
RE: Trill v. Trill
No, 94.3767 . Cumberland County C,C,P,
Our File No, 8174, I
Dear Rob:
Thank you for your assistance and courtesy in this maller,
Very tml>' yours,
q~
Thomas J, w\lIlams
TJW/tdw
~. \HLti.I\OArAFIL~'",nN1.11l"'.I'''kU a
cc. 9.A.-.l I' ..... 7:..vt:t
r;'/,~
vltclJllJol/., gea ,d(YJljt: 'fj;(llt'mnJ 6' (! 110
A rlOIUSIONM. CUlUOMTlUN
AnORNEYS AND COUNSELLOIll AT LAw
TEN EMf HIGH STREET
CARLISLE, PENNSnVANlA 17013
TIWItONI
(717) 24,.,,. I
WillIAM F, MAmoN
DANlll K, DlAllOOm
THOMAS J, WillIAMS
lvo V, Onu, III
SnrltlN L, BLOOM
GIOp.G1 B, FALLU, Jk,
WilLIAM D, PO"'lLl
THOMAS G, COLLINS
FAtslMILI
(717) 245.1150
March 21. 1997
INTIlNIT
mdw"mdwo,com
Robert L, O'Brien. Esquire
O'BRIEN. BARIC & SCHERER
17 West South Street
Carlisle, PA \7013
RE: Trill v, Trill
No, 94-3767 . Cumberland County C,C,P,
Our File No, 8174.1
Dear Rob:
\ had an opportunity to discuss this divorce again with Mr, Tritt, He remains emphatically
against the divorce. and continues to hope for a reconciliation, He told me quite clearly that he Is
not going to sign anything, and he has not authorized me to sign anything on his behalf. He Is aware
that Mrs. Trill may proceed to finalize the divorce without his consent; however. he feels that Is
strictly her decision,
Very truly yours,
"l'~
Thomas 1. WIlliams
TJW/tdw
cc: Mr, Ronald Trllt
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JEANNE M, TRITT,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO, 94-3767 CIVIL TERM
: IN DIVORCE
V,
RONALD L. TRITT,
Dafendent
-::rv"'c.. ,1997, I, Robert L. O'Brien,
Esquire, Attorney for Plaintiff, do hereby certify that I did make service of the Notice to
the Defendant, Notice of Intention to Request Entry of Divorce Decree and Defendant's
Counter-Affidavit upon Thomas J. Williams, Esquire, Attorney for Defendant, Ronald L.
Tritt, 10 East High Street, Carlisle, Pennsylvania, by placing same In the U,S, first class
mall, postage prepaid on March 12,1997.
~408;vl' __
Robert L. O'Brien, Esquire
O'Brien, Baric & Scherer
11tuM~
1:1001 th~ d~,k of
KEVIN A. HESS
.Iud..
To____ "'J.,1...
Dale )-1."
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JEANNE M, TRITT,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 94.3767 CIVIL TERM
: IN DIVORCE
V,
RONALD L. TRITT,
Dafendant
Notice Is hereby given that the Plaitnlff In the above matter, having been
granted a Final Decree In Divorce from the Bonds of Matrimony on the 4 t h day of
JUNE ,1997 hereby elects to retake and hereafter use her prior name of
Jeanne Marie Shoff, and gives this written notice avowing her Intention in accordance
with the provisions of the act of May 25,1939, P.L. 192 (23 PS 96), as amended
Dated: /JUJu. 11, I q (17
t
JEANNE MARIE TRITT
o BE KNOWN AS
'11/
EANNE MARIE SHOFF
COMMONWEALTH OF PENNSYLVANIA
: SS
COUNTY OF CUMBERLAND
'J \
On the '...r day of , WLt' , 1997, before me, a nolary public,
personally appeared JEANNE TRIT to be known as JEANNE MARIE SHOFF, known
to me to be tho person whose name Is subscribed to the within document, and
acknowledged that she executed the foregoing for the purpose therein contained
IN WITNESS WHEREOF, I have hereunto set my hand and official 8eal
I
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JEANNE M. KilLINGER,
PLAINTIFF
V.
RONALD L. TRill,
DEFENDANT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
,
: 94-3767 CIVil TERM
QBQ!:.B. OF COUBI
AND NOW, this
merits, IT IS ORDERED:
2\
day of April, 2003, following a hearing on the
(1) All prior custody orders are vacated and replaced with this order,
(2) Jeanne M, Killinger and Ronald L. Tritt shall have shared legel custody of
Jason Tritt, born July 1,1966 and Ambyr Tritt, born November 13,1966,
(3) The mother shall have primary physical custody of Jason and Ambyr.
(4) Tho fathar shall have temporary physical custody of Jason and Ambyr 01
follows:
(a) During each school year, on alternate weekends from after
school on Friday until Monday morning before school or If Monday II a
school holiday to Tuesday morning before school.
(b) During each summer for two four-week consecutive period I to
be separated by a two-week consecutive period that the children are with
their mother. These weeks shall be set by the parents not later than two
weeks before the end of each school year,
(c) Each Thanksgiving from the morning tho day alter
Thanksgiving until the morning schoolltar1., The mother .h811 alway.
have the children on the evening before Thanksgiving and Thanksgiving
Day.
(d) The parents shall make arrangements during each Christmas
season so that each shall have the children for t
(
..-Robert L. O'Brlen. Esquire
For Jeanne M. Killinger
v-Thomas J. Williams. Esquire
For Ronald L. Tritt
:sal
lm
T C RK5
Cy.~~-~
JEANNE M, KILLlNOElt F/K/A JEANNE M,
TIt!'r!'
IN TilE l't)UltT OF COM~ION 1'l.EAS OF
PI.AINTlH:
CUMIlERl.AND COUNTY.PENNSYl.VANIA
\"
94.3767 CIVIl. ACTIoN LA W
ItoNALIlI., TltIlT
IlI'l'ENIlANT
IN CUSTODY
OHIlEI{ OF COllin
AND NOW._.__._ ~~~!.d!,_e.!.d.!l)'!~.l.nrch}O! 2005 ..u' upon cunsidcrullonoflhc ulluchcd Complillnl,
it is hcrchy dircctcd Ihill pilrtics und lhcir rcspcctilc counsel uppcur hclllrc Hubert X. Gilroy. EIII' .thc conclliulur.
UI_._~III..~!~Il~!c,:Il!'!iJ~~!~ndQl.llI!I)'COIl!lhIl1l5e,-~nrIl5Ie un u _ .. ..l:'rldnv.A'lrIL!5L2lJ!l5. .__ _ III .~I~~__AM
Ill!' u I'rc.llcilring Custudy Conl'crcllcc, At snch cunl'crcncc, IIn cllllrt II III hc It1l1dc 10 rcsolw Ihc issucs in dispnlc: or
Iflhis cllnnol hc lIccomplishcd. to dclinc lIl1llnurrOIl Ihc issucs to hc hCllrd hy thc ,'oln1. ulld 10 cnlcr Inlo u tcmporury
ordcr. All childrclllluc Ihc or uldcr It1l11 ulsu hc I1rcscntlit thc conl'crcllcc, I'IIi1nrc 10 utll1Cllr IIIlhc conl'crcnc,' mill'
prolidc gruullds Illr clllry of IIIClt1porury or pcrmllllcnt ordcr,
The cnurt herell)" IlIrecls thc purllcs In furnish un)" uud ull cxlsllUlll'rulcClluu frum Ahuse urders.
Slleelul Hellcl'urders. uud Cusllllh' urdl'rs luthe cuudllutur 48 huurs Ilrlur lu scheduled heurlull.
FOI{ TilE COURT.
lIy: _-'~'-_ _ .._!i!lIJ!!rr~r. fjj/[(J),fisq,___..J:.__
Cusludy ('onclllutur
Thc Cuurt nf C'ult1monl'lcus of Cnmhcrluml Conl1ly is rC4nircd hy lull' 10 comply lI'ilh Ihc Amcrlcuns
with Disllhililcs Act uf 11)1)0, Fur inll1l'll1l1llon uhont ucccssihlc lildlillcs IInd rcusonuhle IIccommodlllions
uluilllhlc 10 disuhlcd individullls hUllng husillcss hclln'c thc cuur!. plclIsc cUlllUctour onkc, All urrllugcmcnls
must hc mudc ullcusl n hours prior 10llny hCllring or husincss hclllrc thc conr\. Youmusl ullcnd Ihe schedulcd
cOIlI'crcl1cc or hcuring,
yOU SIIOU\.D TAKE TillS l'APm TO YI IUR ,\Tllli{NI:Y AI! IN! 'E, IF YOU D() NOT
IIA VE AN ATTORNEY Ol{ CANNOT AHOIW ONE.liO TO OR TFl.FI'IIONF 1'111; OFFICI' SET
FORTIIIlELOW TO FIND OUT WilERI' YOU CAN liET l.EliAl. IIFl.I',
Cult1hcrlllllllCounly lIur Asslldlllilln
32 South Ilcdlllrd Strcct
Curllslc, I'cnnsylluniu 17013
Telcl'hunc (717) 24l).) 166
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RECEIVED MAR 29 looi-
Tholllas 1. Williallls, Esquire
MARTSON DEARDORFF WILLIAMS & OTTO
f.l),17512
10 Easllligh Street
ClIrlisle. I' A 170 J:\
(717)243-3341
AHorneys lilr Plaillliff
JEANNE M, KILLINGER IIk/u
JEANNE M, TRITT.
pluillliff
IN THE COURT or COMMON PLEAS or
CUMBERLAND COUNTY. PENNSYLVANIA
v.
NO, 94-3767
CIVIL TERM
RONALD 1.. TlUTT.
DefelllJunt
IN CUSTODY
OIWEI{ OF covin
ANI) NOW,Ihis _ duy of .2005. upon considerulion oflhe attachcd
. il is hereby directcd Ihallhe pllrties 1I1llltheir respcctivc counscl uppcar bcforc
. the COllciliator. at on
.2005.at _,Ill, for u Pre-HcllnngCustodyConfercnce, AI such
Conference. un el1i1l1 will he Illude to resolve the issues in dispute; or ifthis cannot be accolllplished.
10 denne ullllnulTol\' the issues to he hellrd hy Ihe court. lInd 10 enter ulelllporllry order, All children
age nve or older Illay ulso he presenlllllhe conlerence, Fnilure 10 uppenr III the conference may
provide grounds lilr cnlry of utclllporury or pcrlllllncnt order,
The coul'l hereh)' dlreels Ihe pllrlles 10 furnish IIIIY uud ull exlsHng I'roleellon from
Abuse Orders, Slleclul l{ellel'Ordel'S und CUSlod)' Orders 10 Ihe Conelllulor 48 hours 111'101' 10
scheduled helll'lng.
FOR THE COURT:
I3Y:
CUslody Concililllor
The Courl OI'CollllllonPlells otTulllhcrlllnd Counly is required by law 10 cOlllply with the
Alllcricuns with Disabilitics Act of 1')1)0. For inlill'llllllionuhoulaccessible facilities und reusonuble
lICCOllllllOllllliollS uvuiluble to disuhkd illllividuals huving business helilre Ihe court. please conluct
our ornce, Ailarrungelllenls IllUst hc Illllde 1I1lellsl 72 honrs prior 10 uny heuring or busincss bcfore
the co1ll1, You Illust attend Ihc schedulcd confcrcncc or hCllring,
YOU SIIOULD TAKE TIllS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO
NOT IIA VE AN ATTOltNEY 1m CANNOT AFFORD ONE. GO TO OR TELEplIONE THE
OFFICE SET FORTH BELOW TO FIND OlJT WHERE YOU CAN GET LEGAL HELP,
CUlllherlund Counly Bill' ASSllcilllion
32 SoUlh Bcdtillll Slrcet
('i11lislc. Pcnl1syllllnill 17013
IciL'plllll1C (717) 241)-311111
JEANNE M, KII.LlNGER IMiI
JEANNE M. TRITT,
PluinlilT
IN TilE couln OF COMMON PLEAS OF
l'UMIlEIH.AND COlJNTY.PENNSYLV ANIA
v,
NO, \)4.37h7
CIVIL TERM
RONALD l.. TRITT,
DcfcmJunt
IN CUSTODY
MODIFICATION OF DI;FENDANT'S COMPI.AINT FOR CUSTQDY
I, Delcndunt is I{onuldl.. Tritt, unl\llult individuul cUlTently residing ut 77 Furm Roud,
Newvillc, C'umherlund County, I'ennsylvuniu 1124 I,
2, I'luintiffis Jeunne M, Killinger. I/k/u .Ieunnl! M, Tritt, un udult iudividuul currcntly
rcsiding ul 121l 1lI0serville Roud. Ncwville, CUlllherluml Connty. I'cnnsylvuniu 17241,
3, Dclcndunt sccks custody of lhc child, AllIhyr Tritt. who wus hOIll on
Novcmber 13.1')88, The child II'US not hOl'lloutofll'edloek, Sinl'c thc ehild's birth.lhe child hus
rcsided with thc lallowing persons ut the IlJllolI'ing uddrcsses lar thc Illllowing periods oftimc: The
child hus lived with the Mother until.lunuury 28.1005. wlwn shc \\'US rcmoved li-orl1 the Mother's
rcsidencc hy CUlllherlund County Childrcn & Youth Services, uml pluced with Futhcr. Ronald L.
Tritt, und she hus rcsided there uplO und including the prcsent.
4, The relutionshipofthc Delcmlunt to the child is thutof Futher, IIc is divorced und
living sepurutely, The Dclcndunt cUllcnlly rcsidcs wilh the lollowillg:
~ Rcluliollshill
AllIh}T Tritt Duughler
5, Thc rclutionship of the I'luinlilTtothl! child is thut of Mother. She ismurried und
living scpuratcly, The I'luiutilTl'lllTently rcsides with Ihe lullowing:
~ Rclutionshill
Bruce E, Killiugcr, .II', lIushuml
Tristun Killinger Slcpson
(I, Thc hcst iutcrcst uml pCrlllunenl wcllllrc of thc child 11'111 bc servcd by grunting
cuslody to Dclcndunl hceuuse llfphysicul ul\lll!n\lllionuluhusc llllthc IJUrt ofthc stclllillher. Bruec
E, Killinger,.I1'.
7, Dclcmlunl d'll'S not knilli' llfuny pl'lSllnl\llt iI purty to thcse proceedings who c1uillls
III huve custody or visilulion righls \I ilh respeclllllhe child.
WIIEREFORE. Dcfcndunt rcqucsls your Ilonoruhlc Court to scl u timc uml plucc for u
hcuring ut which Dcfcndunt rcqucsls thc Cuurt 10 grunt him thc Custody Ordcr. Pcnding suld
hcuring. Dcfcl\llunt rcqucsls tcmpol'llr)' custody,
MAlrrSON DEAIUJORFF WILLIAMS & OTTO
By ~~/k'~ () /,It)~~
Thumus J, WlIllills. Esqulrc
Tcn Eustlllgh Strcct
CurUslc, P A 17013
(717) 243.3341
Allomcys for I'lulntlfTs
Dute: Murch 24, 200$
CEltTlJlICATE OJl SERVICE
I, Trlelu D. Eekcnrollll,unuulhorized IIgcnllol' Murison DClll'dorlTWlIllulIls & Olto, hcrcby
cerlli)' Ihulll copy orthc foregoing COllllllulnllor Cuslody \\'us sCl'vcd this dutc by dcposltlnll sUllle
lnlhe 1'0sI OOlce ul Curlislc, I'A, 111'51 cluss IIlllil, l10stugc pI'CI'Uid, uddrcsscd 115 follo\\'S:
Robcrt L, O'Bricn, ESllUll'c
O'BRIEN. BARIC & SCIIERER
19 Wcst Sonlh Strcct
CUI'IlsIc, I' A 17013
MARTSON DEARDORFF WILLIAMS & OliO
Duled: Murch 24. 2005
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RECEIVED APR 16 21m>
JEANNE /11, KILI.INGER I/k/n
JEANNE M, TRITT,
PlnilltitT
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v,
NO, 94.37Cl7
CIVIL TERM
RONALD L. TRITT.
Dclcl1lhlllt
IN CUSTODY
STIJlULATlON
AND NOW. this 2-1lh duy of/l1nrch, 2005.lhc pnrties hercloslipululC thut the lollo\\'illg Order
shull he elltcrcd with regnrd to Iheir duughtcr, All1hyr Trill, hllrn Novembcr 13. 1988,
Jcnnne
(.~III;
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, Killinger lik/( Jeunn 1\1, Trill, Mother
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I{onuld L. Tritt. Futher
~~~
Robert O'Oricn. ESljuire
AlIomey lilr Mothcr
AND NOW. thi~.1 oL;u: 11/~n consideration of the toregoing Stipulation.
it is Ordered und Decrecd thut CllSt~lUY of All1hyrTritt, horn NOl'emher 13. 1988. shull be us follo\\'s:
1, Prill1ury cuslody of All1hyr Tritt. shull hy wilh Illlher. Ronuld L. Trill.
2, Mother, .Ieunllc M, Killinger. Iik/u.leunnc M. Trill. shull hUl'e lell1porury custody ut
such times the p1ll1ics muy ngree.
3, The Ordcr ofApril21. 2003. is hcreby rcsclnded in lis entirely und rcp~ ith the
BY TilE cO\Jlq~lf
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JMNN.: M. TRIn',
Plaintiff
II
RECEIVED MAY 02 2005 V~
IN TilE COURT OF COMMON I'I.EAS OF
CUMDERLANJ) (,OUNT\',I'ENNS\'L\' ANIA
\'
CIVIL ACTION. LAW
q'l ~ 'fl(, ~
NO. J994 3ft!
IN CUS'J'(}J)\'
ItONAU) I.. TRITT,
J)dendant
COllRLURlU.m
AND NOW, this 1. ~ da)' of ~, 2005, Thc Conciliator bclnll advised that the
parties havc reachcd an allreemcnt, "IC Conciliator relinquishes jurisdiction.
/1/- .
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rt x, Gilroy, Esquire
ustody Conciliator
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JEANNE M. KILLINGER f/kla
JEANNE M. TRITT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 94-3767
CIVIL TERM
RONALD L. TRITT,
Defendant
IN CUSTODY
MODIFICA nON OF DEFENDANT'S COMPLAINT FOR CUSTODY
I. Defendant is Ronald L. Tritt, an adult individual currently residing at 77 Farm Road,
Newville, Cumberland County, Pennsylvania 17241.
2. Plaintiff is Jeanne M. Killinger, f/kla Jeanne M. Tritt, an adult individual currently
residing at 728 B10serville Road, Newville, Cumberland County, Pennsylvania 17241.
3. Defendant seeks custody of the child, Ambyr Tritt, who was born on
November 13,1988. The child was not born out of wedlock. Since the child's birth, the child has
resided with the following persons at the following addresses for the following periods oftime: The
child has lived with the Mother until January 28,2005, when she was removed from the Mother's
residence by Cumberland County Children & Youth Services, and placed with Father, Ronald L.
Tritt, and she has resided there up to and including the present.
4. The relationship ofthe Defendant to the child is that of Father. He is divorced and
living separately. The Defendant currently resides with the following:
Name
Relationship
Ambyr Tritt Daughter
5. The relationship of the Plaintiff to the child is that of Mother. She is married and
living separately. The Plaintiff currently resides with the following:
Name Relationship
Bruce E. Killinger, Jr.
Tristan Killinger
Husband
Stepson
6. The best interest and permanent welfare of the child will be served by granting
custody to Defendant because of physical and emotional abuse on the part of the stepfather, Bruce
E. Killinger, Jr.
7. Defendant does not know of any person not a party to these proceedings who claims
to have custody or visitation rights with respect to the child.
WHEREFORE, Defendant requests your Honorable Court to set a time and place for a
hearing at which Defendant requests the Court to grant him the Custody Order. Pending said
hearing, Defendant requests temporary custody.
MARTS ON DEARDORFF WILLIAMS & OTTO
By ''1~Q t,~~
Thomas J. Willi s, EsqUire
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiffs
Date: March 24, 2005
VERIFICA nON
The foregoing Complaint in Custody is based upon information which has been gathered by
my counsel in the preparation of the lawsuit. The language of the document is that of counsel and
not my own. I have read the document and to the extent that it is based upon infomlation which I
have given to my counsel, it is true and correct to the best of my knowledge, information and belief.
To the extent that the content of the document is that of counsel, I have relied upon counsel in
making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
avernlents, I may be subject to criminal penalties.
~j L SL:::U'---
Ro nald L. T ri tt
CERTIFICATE OF SERVICE
I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby
certify that a copy of the foregoing Complaint for Custody was served this date by depositing same
in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Robert L. O'Brien, Esquire
O'BRIEN, BARIC & SCHERER
19 West South Street
Carlisle, PA 17013
MARTSON DEARDORFF WILLIAMS & OTTO
- I' . ' ,j
(By /{(CL '.
'T 'cia D. Eckenroad
--- Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Dated: March 24, 2005
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JEANNE M. KILLINGER FIK/A JEANNE M.
TRITT
IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
CUMBERLAND COUNTY, PENNSYL VAN A
V.
94-3767 CIVIL ACTION LAW
RONALD L. TRITT
IN CUSTODY
DEFENDANT
ORDER OF COlJRT
AND NOW,
Wednesday, March 30, 2005
, upon consideration oft~ attached Complaint,
it is herehy directed that parties and their respective counsel appear before Hnhert X, GiI oy, Esq.
at 4th Floor, Cumherland County Courthouse, Carlisle on Friday, April 15,20 5
, the conciliator,
at 8:30 AM
for a Pre-Hearing Custody Conference. At such conference. an effort will be made to resol e the issu s in dispute: or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, an to enter il to a temporary
order. All children age five or older may also be present at the conference. Failure to appe r at the C1 nference may
provide grounds for entry of a tcmporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection f~om Abus orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing
FOR THE COURT.
By:_~I__...,." .,!!.!!.bert X. Gilrov, Esq,
Custody Conciliator
,
t-~
I
,
The Court of Common Pleas of Cumberland County is required by law to COI'PIY with the Americans
with Oisabilites Act of 1990. For information about aceessible facilities and reasonabl accomm dations
available to disabled individuals having business before the court, please contact our 0 lice. All rrangements
must be made at least 72 hours prior to any hearing or business before the court. Y ou ~ust atten the schcduled
conference or hearing. :
YOU SHOULD TAKE THIS PAPER TO YOUR A HORNEY AT ONCE.IIF YOU 0 NOT
HA VE AN A HORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPIIONE TIlE OFFI E SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249,3 I 66
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F\F1LES\DA TAFILEIGeneraIICu1TemI8 174.] .orderltde
Created: 06119/0202:29:50 p~
'Revised 031HI0511:4929AM
81741
.
,
\
,.
JEANNE M. KILLINGER f/k/a
JEANNE M. TRITT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 94-3767
CIVIL TERM
RONALD L. TRITT,
Defendant
IN CUSTODY
STIPULATION
AND NOW, this 24th day of March, 2005, the parties hereto stipulate that the following Order
shall be entered with regard to their daughter, Ambyr Tritt, born November 13, 1988.
R ( (0) 1 J I) (. "f
--d I\I,,;L I " ..'NC~
Jeanner. Killinger f/k/it Jeann M. Tritt, Mother
~i!~
Ronald L. Tritt, Father
~~~
Robert O'Brien, Esquire
Attorney for Mother
4.dt--.
ORDER
AND NOW, this
. ,
:layoJ
,2005, upon consideration of the foregoing Stipulation,
it is Ordered and Decreed that custody of AmbyrTritt, born November 13,1988, shall be as follows:
I. Primary custody of Ambyr Tritt, shall by with father, Ronald L. Tritt.
2. Mother, Jeanne M. Killinger, f/k/a Jeanne M. Tritt, shall have temporary custody at
such times the parties may agree.
3. The Order of April21, 2003, is hereby rescinded in its entirety and replaced with the
above.
BY THE COURT,
, J.
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Revised 03/~4i05114929AM
8174,]
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-
JEANNE M. KILLINGER f/k/a
JEANNE M. TRITT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 94-3767
CIVIL TERM
RONALD L. TRITT,
Defendant
IN CUSTODY
STIPULATION
AND NOW, this 24th day of March, 2005, the parties hereto stipulate that the following Order
shall be entered with regard to their daughter, Ambyr Tritt, born November 13, 1988.
J~;~~i;~ng-~; ~A~L~f~. Tritt, Mother
)
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Robert O'Brien, Esquire
Attorney for Mother
~ t $7Jr
Ronald L. Tritt, Father
ORDER
AND NOW, thi~]cta;o; 11/~5, upon consideration ofthe foregoing Stipulation,
it is Ordered and Decreed that custody of Ambyr Tritt, born November 13, 1988, shall be as follows:
"
I. Primary custody of Ambyr Tritt, shall by with father, Ronald L. Tritt.
2. Mother, Jeanne M. Killinger, f/k/a Jeanne M. Tritt, shall have temporary custody at
such times the parties may agree.
above. 3. The Order of April 21 ,2003, is hereby rescinded in its entire~~:7/ith the
BY HiE COUR {I
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Plaintiff
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RECEIVED MAY 02 ZOO5 ,j"^/
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
'N-1fl.j
NO. 399-4 J"'"
IN CUSTODY
ONALD L. TRITT,
Defendant
COURT ORDER
AND NOW, this 1.. t day Of~, 2005, The Conciliator being advised that the
parties have reached an agreement, 'he Conciliator relinquishes jurisdiction.
tJ;,.
rt X. Gilroy, Esquire
ustody Conciliator
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