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Home My WebLink About07-0193 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduling conference or hearing. IMSTI M. MURTORFF, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2007 - / 9 3 CIVIL TERM JEREMY S. MURTORFF, Defendant IN CUSTODY COMPLAINT FOR CUSTODY AND NOW comes the Plaintiff, Kristi M. Murtorff, by her attorneys, Irwin & McKnight, and presents the following Complaint for Custody. 1. The Plaintiff, Kristi M. Murtorff, is an adult individual with an address of 600 "G" North Baltimore Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2. The Defendant, Jeremy S. Murtorff, is an adult individual with an address of 215 West Pine Street, c/o Justin Kennedy, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. Currently the Defendant is incarcerated in the Cumberland County Prison, 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of one (1) child, namely, Michael S. Murtorff, born October 3, 2005. 4. The Plaintiff desires that the parties have shared legal custody of the minor child, Michael S. Murtorff. 5. The Plaintiff desires primary physical custody of the minor child, Michael S. Murtorff, with periods of supervised visitation to Defendant as the parties can agree. 6. The best interests and permanent welfare of the minor child requires that the Court grant the Plaintiff's request as set forth above. WHEREFORE, the Plaintiff, Kristi M. Murtorff, respectfully requests that she be awarded primary physical custody and shared legal custody of Michael S. Murtorff, as provided herein, with periods of supervised visitation to Defendant as provided herein. Respectfully submitted, IRWIN & By: e"K Marcus c 'ght, I, Esquire Atto y for Plaintiff 60 est Pomfret Street Car ' le, Pennsylvania 170 -3222 (717) -2353 Supreme Co o. 25476 Date: January 9, 2007 VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unworn falsification to authorities. aAAzA7-v KRISTI M. MURTORFF Date: January 9, 2007 t7 Aa 00 ? .-- ,. FT KRISTI M. MURTORFF IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 07-193 CIVIL ACTION LAW JEREMY S. MURTORFF IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, January 18, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, February 09, 2007 at 1:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ John . Man an r. EST Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . r? o-?Svic1 ?.,'- ?(qj•? fob/•/ C ? cZ d 6 ! NU LOOZ Abl`v1Cl'Nl]' icc d 3HI ?o JUN 112007 KRISTI M. MURTORFF IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 07-193 Civil Term JEREMY S. MURTORFF Defendant : ACTION IN CUSTODY COURT ORDER AND NOW, this N - day of June, 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. The Father, Jeremy S. Murtorff and Mother, Kristi M. Murtorff, shall enjoy shared legal custody of Michael S. Murtorff, born October 3, 2005. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. The Mother, Kristi M. Murtorff, shall enjoy primary physical custody of Michael S. Murtorff. 3. The Father, Jeremy S. Murtorff, shall enjoy periods of supervised partial physical visitation with Michael S. Murtorff Tuesday mornings from 9:00 am until 12:00 pm and every other Saturday from 1:00 pm until 4:00 pm. Said visits are to be supervised by Denzel Murtorff or some other mutually-agreed to supervisor. 4. The Mother shall provide transportation of Michael S. Murtorff for the visitation with the Father. 5. Holidays with Michael S. Murtorff shall be mutually agreed to by the parties. 6. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 7. The parties shall refrain from making derogatory comments about the other party in the presence of the Michael S. Murtorff, and to the extent possible, shall prevent third parties from making such comments in the presence of the Child. it WAiiin f• 8. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. A status update Conciliation Conference is tentatively scheduled for July 25, 2007 at 2:00 PM. Cc: Marcus A. McKnight, III, Esquire Karl Rominger, Esquire "O John J. Mangan, Esquire KRISTI M. MURTORFF Plaintiff V. JEREMY S. MURTORFF Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07-193 Civil Term ACTION IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Michael S. Murtorff, born October 3, 2005, currently in the primary physical custody of Plaintiff Mother. 2. A Conciliation Conference was held on February 9, 2007 with the following individuals in attendance: The Father, Jeremy S. Murtorff with his counsel, Karl Rominger, Esquire The Mother, Kristi M. Murtorff, with her counsel, Marcus A. McKnight, III, Esquire. 3. The parties agreed to the entry of an Order in Date: June 11, 2007 form as attached. a KRISTI M. MURTORFF Plaintiff V. JEREMY S. MURTORFF Defendant Prior Judge: Kevin A. Hess, J. SEP 0 420U7rr IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07-193 Civil Term ACTION IN CUSTODY COURT ORDER AND NOW, this a' day of September, 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that: 1. The Father, Jeremy. S. Murtorff and Mother, Kristi M. Murtorff, shall enjoy shared legal custody of Michael S. Murtorff, born October 3, 2005. The parties shall have an equal right to make all major non-emergency decisions affecting the Child's' general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. The Mother, Kristi M. Murtorff, shall enjoy primary physical custody of Michael S. Murtorff. 3. The Father, Jeremy S. Murtorff, shall enjoy periods of supervised partial physical custody with Michael S. Murtorff liberally as the parties may mutually agree. The parties shall give each other one week's advance notice of available custody periods for Father. Said partial custody is to be supervised in a mutually agreed upon environment. 4. The Mother shall provide transportation of Michael S. Murtorff for the visitation with the Father. 5. Holidays with Michael S. Murtorff shall be mutually agreed to by the parties. 6. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. 7. The parties shall refrain from making derogatory comments about the other party in the presence of the Michael S. Murtorff, and to the extent possible, shall prevent third"parties from making such comments in the presence of the Child. 99:111-4 S- d3S LOOZ AUVIU NL'H,HiOdd n,HI JO r 8. This Order is entered pursuant to a Custody Conciliation Conference status update. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Cc: us A. McKnight; III, Esquire 400 it Romin$er, Esquire VX6 J. Mangan, Esquire y BY E Cjoi J. i -IV KRISTI M. MURTORFF Plaintiff v. JEREMY S. MURTORFF Defendant Prior Judge: Kevin A. Hess, J. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 07-193 Civil Term ACTION IN CUSTODY CONCELIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the :undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Michael S. Murtorff, born October 3, 2005, currently in the primary physical custody of Plaintiff Mother. 2. A Conciliation Conference status update was held July 25, 2007 with the following individuals in attendance: The Father, Jeremy S. Murtorff with his counsel, Karl Rominger, Esquire The Mother, :Kristi M. Murtorff, with her counsel, Marcus A. McKnight, III, Esquire.' 3. The parties agreed to the entry of an Order in the form as attached. Date: September 4, 2007 John gan, E re iqp Cusdy onciliato C=a -q 711! KRISTI M. MURTORFF, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 2007-193 CIVIL TERM JEREMY S. MURTORFF, The Honorable Kevin A. Hess, P.J. Defendant IN CUSTODY PETITION TO MODIFY CUSTODY 1. Petitioner is Jeremy S. Murtorff, who resides at 431 North Bridge Street, Apt. 25, New Cumberland, Pennsylvania 17070. 2. Respondent is Kristi M. Murtorff, who resides at 42 Lonesome Lane, Newville, Pennsylvania, 17241. 3. On September 5, 2007, the Honorable Kevin A. Hess entered an Order of Court, attached hereto as Exhibit "A". 4. Since the entry of said Order, there has been a significant change in circumstances in that: a. Mother's current husband, J. Dean Hockenberry intentionally threw a paddle at the child which struck the child in the head leaving a mark on the child's forehead on November 13, 2010. b. Father has filed a report with the Pennsylvania State Police and the same has an incident number of H02-1885766. ,S?0 06 P°-4-W, 76.1 gy'r ,5-1315' C. Father has filed a report with Cumberland County Children & Youth Service on. 5. The best interest of the child will be served by the Court in modifying said Order. WHEREFORE, petitioner prays this Court to grant the modification of the existing Custody Order to grant Petitioner primary physical custody of the child. Respectfully submitted, ROMINGER & ASSOCIATES Date: November 16, 2010 Karl E ominger, Esquire 155 outh Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Jeremy S. Murtorff VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. cons. Stat. § 4904 relating to unworn falsification to authorities. Jeremy S. Murtorff, Plaintiff KRISTI M. MURTORFF, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 2007-193 CIVIL TERM JEREMY S. MURTORFF, The Honorable Kevin A. Hess, P.J. Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, certify that I this date served a copy of the within Petition to Modify Custody upon the following by depositing the same in the United States Mail, postage pre- paid, first class, addressed as follows: Marcus A. McKnight, Esquire 60 West Pomfret Street West Pomfret Professional Building Carlisle, Pennsylvania 17013 Respectfully submitted, ROMINGER & ASSOCIATES Date: November 16, 2010 Karl E. R)Ohinger, Esquire 155 Sodffi Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Jeremy S. Murtorff 0 SEP 4 42am r KRISTI M. MURTORFF : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 07-193 Civil Term JEREMY S. MURTORFF Defendant : ACTION IN CUSTODY Prior Judge: Kevin A. Hess, J. AND NOW,,this r day of Septembw, 2007, upon cx uiciastion of the ettach?e 1 Custody Conciliation Report, it is ordered and directed that: 1. Ila Father, kr my.S. Mudorff and Mather, Kristi M.1vfifflort shall aayoy shared legal custody of Mcba l S. Mtutorf? born October 3,2W5. The parties steel twe a ff eqW d& to make all magor non-icy decisions affibeft the Child's postal wel-b ft ins uding, but not limited to, all decisions regarft his hesM education and religion. 2. Thz Molnar, KrW M. MurtwM shall enjoy primary physical custody of Michael S. Murtorff. 3. The-Father, *emy S. M shall enjoy periods of supervised partial physical moody withMichael S. Mtutaffliberslly as to parties may tm*BUY agree. 11w-patties smell. give each other one wash's advance notice of ? custody periods, for Father: Said partial custody is to be supervised in a mutwdly agreed upon raivirat: 4. The Mother provide transportation of Michael S. Muctorfffor the visitation with the Father. 5. Holidays with Michael S. Murtorff gaff be mutually agreed to by the patties. 6. In:the.eveat of a.m &cal emergency, the custodial party shall notify the other parties as soon as prect cable aver the emergency is handled. 7. The panties doff raft= firm making daugartory cotes about the other party in the prNea x of the Michael S. Murtarff, and to die extent posa'ble, shell pmvent third'parties from malting such comments in the presence of the Child. 0. me stow a COY C006US'6on confere tvy nnvw c7a per is ? y to. t o rov °f ? *AU contd. In the *90 W.X °f A.M,cx Cc* V4, BxN ?% j - -MOWS&, A KRISTI M. MURTORFF Plaintiff V. JEREMY'S. MURTORFF Defendant Prior Judge: Kevin A. Hess, J. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 07-193 Civil Term : ACTION IN CUSTODY 1N ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(B), the undersigned Custody Conciliator submits the following report: l . 'The pertinent ufamnition pertaining to the child who is the subject of this lid is as follows: KwUdl S. Murtor$ born October 3, 2005, cum* in the primary physical cuApdy of Plaintiff Modw. . 2. A Coon Conference status update was bold July 25, 2007 with the following .individuals in attendance: The Father, Jeremy S. Murtuff with his counsel, Karl Rominger, Esquire The Modter, Knsti M. Muutoa with her coumael, Mamas A. McKnight, III, Esquire. 3. Tbe parties agreed to the entry of an Order in the form as attedwd. Date: September 4, 2007, John onc' b KRISTI M. MURTORFF IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA C) C-) ' c ? 0 -n -4 V. 2007-193 CIVIL ACTION LAW xc ror C) JEREMY S. MURTORFF (A IN CUSTODY DEFENDANT A C-) = Z"' ORDER OF COURT cr? AND NOW, Thursday, November 18, 2010 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, December 21, 2010 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custodv orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Oft . Mangan, r. Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street ?Q L - Carlisle, Pennsylvania 17013 k°Telephone (717) 249-3166 ?""rds A t CF THE LE-OFFIE RJ H0f rjTARy QiQ DEC 13 Pm G: 01 CUMBERLAND COUNTY PENNS) YLVAN1 KRISTI M. MURTORFF, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 2007-193 CIVIL TERM JEREMY S. MURTORFF, The Honorable Kevin A. Hess, P.J. Defendant IN CUSTODY STIPULATION AGREEMENT AS TQ CUSTODY The plaintiff, Kristi M. Murtorff, hereinafter referenced) as "Mother," and Defendant, Jeremy S. Murtorff, hereinafter referenced as "Father," hereby Agree to the entry of the following terms in a Court Order defining custody and partial custody rights and responsibilities in relation to the parties' minor children, Michael S. Murtorff, bom October 3, 2005, hereinafter referenced as "Child": The parties hereto agree that the blest interest and continuing welfare of the Child would be best served with the custody arrangement as follows: a. Father shall have sole legal and physical custody of Child. 2. 3. 4. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. Both parties agree that the terms of this agreement have been fully explained to them by their respective counsel or that both parties have had the', opportunity to have legal counsel review and fully explain the terms of this agreer$ient. Father is represented by Karl E. Rominger, Esquire, of Rominger & Associates. 5. The parties hereto agree that this agreement shall be recorded and incorporated into an Order enforceable by the Court. 6. Consented to: Date Kristi M. Murtorff, Plaintiff Date Date 'alol, D Da Witness f?r Kristi M. Murtorff Defendant Esquire COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND S?: On this, the day of 0kce-mbkf- , 201 , before me a notary public, the undersigned officer, personally appeared ' ti M. Murtorff, own to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. C0MMjl*j1ggpdFkYLA1'J4unto set my han 4ffici4al. Notarial seal Tarrmie L. Peters, Notary Pubic car isle Boro, Curnb"W County My Commission E)phes Sept. 8, 2011 NMember, Pennsylvania Association of Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . SS: On this, the /Owl day o Z?140W j6eV'- , 2010, before me a notary public, the undersigned officer, personally appeared Jeremy S. Murtorff, own to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. In witness whereof, I hereunto set tray hand and official OF PENNSYLVANIA Notarial Seal Tam ar L. Peters, No? Wisle Boro, Cunt.: ;awSy M ,y C wrmIssion Ewa x'!1I Notary Pu c -- wr _? , i"srmsylvanla Assmo on or +i&wq i 1JLL . W Jl j KRISTI M. MURTORFF, Plaintiff V. JEREMY S. MURTORFF, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007-193 CIVIL TERM The Honorable Kevin A. Hess, P.J. IN CUSTODY ORDER OF COURT AND NOW, this Wday of 2010, based on the Stipulation of the parties, the Court hereby Orders as follows: 1. Defendant, Jeremy S. Murtorff shall have sole legal and physical custody of the minor child, Michael S. Murtorff, born October 3, 2005. Distribution: c o -'' w Karl E. Romin g er Esquire M o ;z m ° r*'F 155 South Hanover Street 7i, r '_ C`' ? Carlisle, Pennsylvania 17013 -c > ul o 0 o z -? 5-6 Kristi M. Murtorff, pro se a 42 Lonesome Lane D''' Newville, Pennsylvania 17241 a I Irl( ) 9