HomeMy WebLinkAbout94-04024
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CYNTRIA O. JONES, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PRNNEYLVANIA
I
•a. I CIVIL ACTION - LAW
i IN DIVORCR
MICHAEL A. JONES, I
Defendant t 91-1024 CIVIL TERN
ORDE$
AND NOW, this _ day of , 1996, a hearing is not
for the day of , 1996, at _,M. in Courtroom No.
Fourth Floor, Cumberland County Courthouse, Carlisle, Pennsylvania, on the
Wife's Petition for Special Relief.
BY THE COURT,
i
CYNTHIA 0, JOHNS,
Plaintiff
Va.
MICHAEL A. JONES,
Defendant
I IN TNS COURT OF COMMON PLBANE OF
I CUMBERLAND COUNTY, PSNNBYLVAMIA
I
I CIVIL ACTION - LAW
I IN DIVORCE
I
t 94-6877 CIVIL TRAM
ORDER
AND NOW, this day of 199_, after
hearing in this matter, the Petition of Plaintiff for Special Relief is
granted. Defendant is ordered and directed to make and keep current all
outstanding mortgage payments on the marital residence within fifteen (16)
days of this order. The Defendant in further ordered and directed to obtain a
psychological evaluation and to promptly initiate mental health counseling.
He is further directed to provide a copy of the evaluation and confirmation of
counseling to Plaintiff's and Defendant's counsel, as well as to this Court
within sixty (60) days of this order.
BY THE COURT,
ce Ruby D. Weeks, Esquire, Attorney for,the Plaintiff
Raymond ferrario, Esquire, Attorney for the Defendant'
CYNTHIA O. JONES, I
Plaintiff i
i
vs. I
I
MICHAEL A. JONES, 1
Defendant i
IN THE COURT OP COMMON PLEASE OP
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAN
IN DIVORCE
94-6877 CIVIL TERM
PETITION FOR SPECIAL RELIEF
COUNT I - MORTGAGE RELIEF
COMER NOW, CYNTHIA JONES, Plaintiff-Petitioner, by her attorney,- Ruby !-;J
D. Weeks,Esquire, and petitions the court as followst
1. Your Plaintiff-Petitioner is Cynthia G. Jonas, Box 100, Boilijuo 5RJ,1ngS4'
Cumberland County, Pennsylvania 17007.
2. Your Defendant-Respondent is Michael A. Jones, 1127 Black Bear Road,
Hamlin, Wayne County, Pennsylvania, 18436.
3. Since June 1995, Defendant-Respondent has refused to make mortgage
payments on the marital residence located at 1127 Black Bear Road,
Indian Rocks, Hamlin, Pennsylvania 16427.
4. On May 2, 1994, Plaintiff-Petitioner removed herself and the children
from the marital residence because of the Defendant's physical abuse
toward her.
5. At the time, Plaintiff-Petitioner wag pregnant with the parties' third
child, who wan subsequently born on October 26, 1994.
6. The Plaintiff-Petitioner Is unemployed and is a full-time caretaker for
the parties' children who are Christopher Jonee, born June 24, 1988 and
Brian Jones, born May 14, 1991 and Rachel Jonee born October 26, 1994.
7. On December 19, 1995 the Plaintiff-Petitioner was served with mortgage
foreclosure documents from LA Bank, N.A. since the Defendant-Respondent
has refused to make the aforementioned mortgage payments.
8. The marital residence in the major asset in the divorce and the
Defendant-Respondent has threatened to let it go to foreclosure unless
the wife deeds her interest to the husband.
9. The wife has no income other than the spousal and child support ¦he
receives from the husband and has no way to make the mortgage payments
current to prevent the foreclosure.
10. The marital residence is presently listed with Coldwell Banker Realtors
in Hamlin, Pa. for $62,5001 there is an outstanding mortgage of $52,
760.79 which includes interest to 11/16/95 and lets charges, to LA sank,
N.A.
COUNT II - REQUEST FOR DEFENDANT TO UNDERGO
PSYCHOLOGICAL EVALUATION AND COUNSELING
11. Paragraphs 1 through 10 are hereby incorporated by reference and made a
part hereof.
12. Following a period of partial custody with the rather-Defendant-
Respondent on November 26, 1995, the child, Christopher was returned by
the father severely bruised on his buttocks after having been
"disciplined" by the father in an apparent angry rage.
WHEREFORE, Plaintiff-Petitioner seeks to have Defendant-Respondent
directed to make current all outstanding mortgage payments to prevent the
foreclosure on the marital residence and to have him court-ordered to received
counseling and a psychological evaluation for his rages and mental health
problems.
Dates Respectfully,
/
t
Ruby D. Weeks, Esquire
Attorney for the Plaintiff-Petitioner
30 West High Street
Carlisle, Pennsylvania 17013
(717) 243-1294
COMMONWEALTH Of PENNSYLVANIA t
t n
COUNTY Or CUMBERLAND e
I, CYNTHIA 0. JONES, appeared before me, a Notary Public in and for the
Commonwealth and County aforesaid, the undersigned, being duly sworn according
to law, deposes and says that the foregoing PETITION FOR SPECIAL RELIEF are
true and correct to the best of my knowledge, information and belief and are
made subject to the penalties of 18 Pa.C.S. 54904 relating to unsworn
falsification to authorities.
CY T 0. e, - TITIONER
Sworn to and subscribed to
before me this day
of 1916-
Notary ary , P?jlic
01
rv?r r; , ; -r
IAV Crmm_;.,•?L_'? I.::'i ?Y t,,n, 1 ', X097
,
.ter ,
CYMTEIA 0. Jolms, I IN TEE COURT OF COMMON PLEAS OF
Plaintiff I CUMBXRLAND COUNTY, PENNSYLVANIA
I
Vs. I CIVIL ACTION - LAW T
CUSTODY
y _ ' I 0 2.y 6uU l
w:cuEL A. JONES, ? `•? •??
Defendant t NO. C VIL 19
/I ORDER OF COURT
AND NOM, this L day of ?' L ?-' / , 194, upon agreement of the
parties, the attached Stipulation and Agreement of Custody is made an Order of
Court.
BY THE COURT,
J.
Ruby D. Weeks, Esquire For Cynthia 0. Jones
Raymond W. Terraria, Esquire For Hichael A. Jones
AIN
.494 eGi,,
AGO P ez 6 S nn?
i
CYNTXIA O. JONNB,
Plaintiff
? .
NICOUL A. JONBS,
Defendant
1 IN THE COURT or COMMON PLEAS or
e CUNBBRLAND COUNTY, ?BNNBYLVANIA
1
1 CIVIL ACTION - LAN
1 CUBTODY
I
1 NO. CIVIL 18
This Agreement ¦nd Stipulation entered Into the day and year hereinafter
not forth, is by and between Cynthia O. Jones, natural mother, by her attorney,
Ruby D. Necks, Enquire, and Michael A. Jones, natural tether, by his attorney,
Raymond W, P H7vU'fo Esquire, who ever as follower
1. Plaintiff, is Cynthia O. Jones, natural mother and an adult sui juris, who
resides at Box 100, Boiling springs, Cumberland County, Pennsylvania,
17007.
II. Dependant is Michael A. Jones, natural lather and an adult sui furls, who
resides at 1127 Black Bear Road, Wayne County, Pennsylvania, 18436.
III. Mother and rather are the parents of two children, Christopher Jones, born
June 24, 1988 and Brian Jones, born May 14, 1991. The mother is presently
pregnant with a third child of the parties, whose birth is anticipated in
October, 1994.
IV. The parties, Cynthia 0. Jones and Michael A. Jones, agree to the following
custody terms regarding custody of Christopher Jones and Brian Jones, and
request the terms be entered as an Order of Courts
A. The parties shall have joint, shared, legal custody of the children.
8. The mother shall have actual physical custody of the children, with
partial custody awarded to the father as follower
1. The parties recognize and acknowledge that the mother is
presently pregnant with the parties' third child due to be
born on or about October 1994. once that infant is weaned,
which in anticipated to occur at approximately 9 months of
age, as with the other children of the parties, the infant
will be included in all periods of partial custody with the
father along with the other two children.
However, from the date of the child's birth to the time
the child is weaned, the father shall have day visits with the
child between the hours of 5000 a.m. and 600 p.m. twice a
month, on date mutually agreeable to the parties, only in the
immediate Boiling Springs area. The mother will provide the
father with bottles for the infant on these occasions.
2. Two weekends a month from 5c00 p.m. Friday to St00 p.m. Sunday
on the first and third weekends of the month.
3. a. In the event Labor Day, President's Day, Memorial Day,
or July 4 falls on a Friday, in conjunction with the
father's weekend as in paragraph 2 above, the father
shall have the children from 5t00 p.m. the Thursday
before the holiday until 500 p.m. Sunday.
b. In the event Labor Day, President's Day, Memorial Day,
or July 4 falls on a Monday, in conjunction with the
father's weekend as in paragraph 2 above, the father
shall have the children until BOO p.m. Monday, rather
than Sunday.
4. Starting in 1995, during the summer months of June, July and
August, the father shall have partial custody for a total of
thirty (30) days, to be taken ten consecutive days at a time
in each of those months from 5t00 p.m. on a Friday until St00
p.m. the second-following Sunday. This paragraph supersedes
the alternating weekend schedule in paragraph two above. The
father agrees to schedule these dates with the mother no
later than April 30 each year.
3
6. Commencing in 1994, and in even-numbered years thereafter,the
father shall have partial custody of the children each
Thanksgiving and each taster Sunday and one-half of whatever
school vacation is provided by the school calendar, which is
to include the holiday. In odd-numbered years, the mother
will have the Thanksgiving and Easter Sunday holidays and one-
half of the school vacation for those holidays. The parent
not having the children for the holiday shall have the
remaining one-half of the school vacation, Thanksgiving and
i
taster holidays each year.
6. a. The mother shall have the children each Christmas Day,
(the time her family celebrates this holiday) and the
father each Christmas Eva, (which is the date the
father's family celebrates this holiday) on December 23
at 9:00 a.m. until 9:00 p.m. on December 24. The
parties recognize that there may be times when the
school calendar may not permit the father to pick up the
children until school dismisses on December 23. In the
event Christmas Eve is on a Friday, the day shall be
added to the father's alternate weekend time, and the
father shall have the children from 9:00 a.m. Christmas
Eve, Friday, and he shall not have to return the
children until 9:00 p.m. on Sunday. Likewise, in the
event Christmas Eve is on a Monday following the
father's alternate weekend, then the father would return
the children at 9:00 p.m. on Monday and would have them
through Sunday night.
b. The father shall have one-half of the school Christmas
vacation, to be taken in such a way as to minimise his
4
travel. The mother shall have the children the other
one-half of the school Christmas vacation, when the
father has partial custody during the second half of the
school holiday, he shall return the children to the
mother at 2to0 p.m. on New Year's Day to allow the
children to celebrate the mother's birthday.
7, a. The father shall always have partial custody of the
children on Father's Day from 9t00 a.m. to 8t00 p.m. and
the mother on Mother's Day, even if that day would have
otherwise been a day for custody of the children with
the other parent.
b. The father shall have some period of partial custody
with each child on the child's birthday and on the
father's birthday to celebrate the occasion. Likewise,
the mother shall always have time with each child on her
birthday and on the child's birthday even if these days
were ordinarily days of the father's partial custody.
8. The parties agree that Dr. Robert Morton M.D. of Hamlin, PA
18427, will continue to be the children's pediatrician when
the children are with the father, and accordingly, he will
provide medical treatment to the children when necessary, at
the father's expense for items not covered by health
insurance.
9. The parties agree that each parent shall be entitled to have
conferences with any physician, dentist, counselor or other
health care provider, treating the children and each parent
shall be entitled to copies of reports regarding a child's
treatment.
5
10. The parties acknowledge that the child has the following
medical conditions and that each parent will ensure that the
recommended dietary, medical and environmental restrictions
and treatments are adhered to, including but not limited to,
nonexposure to animals and cigarette smoke, and that the
children will receive all prescribed dosages of medication and
treatment as directed by the physician.
a. Christopher - croup and respiratory problems
b. Brian - Suspected colitis and gastro intestinal
problems
It Is acknowledged that these health probleme often
occur at night, and the father agrees to seek prompt medical
treatment when the children are with him and such problems
occur.
11. The father shall provide the transportation to and from his
periods of partial custody. After March 31, 1995, the mother
agrees to most the father one-half way at a mutually-agreed-
upon location in Frackville, Pr, at such times an the father
is returning the children to the mother's custody.
12. The parties shall exchange infant and children's car seats,
with the mother providing these to the father me necessary
when he picks up the children. The father shall promptly
return the car seats to the mother at the time he returns the
children.
13. The father may have partial custody of the children during
such additional periods as the parties shall from time to time
agree, without the need to modify the order of Court entered
as a result of this Stipulation.
6
14. The father agrees to call at least 24-hours before appearing
for an unannounced visit and to confirm these prearranged
periods of partial custody at least twenty-four hours (24) in
advance. The wife agree¦ not to unreasonably withhold consent
for such visitation or periods of partial custody by the
father.
16. Time is of the essence regarding the father's pick-up and
return of the children for periods of the father's partial
custody. The parties agree that if the father has not picked
up the children within one hour of the set time, that period
of partial custody is forfeited by the father and the mother
and children are free to make other plans, unless the father
has notified the mother in advance of an emergency situation
which prevents his timely arrival.
16. The parties shall notify each other in a timely fashion if it
in necessary due to an emergency or unforeseen circumstance
for him or her to be delayed at any of the times set out
herein. It is intended, however, that time be of the essence,
and that the parties as strictly as possible comply with the
times set forth herein.
17. The parties will notify and consult with the other party
immediately in cases of medical emergencies that occur while
the children are in each parent's custody.
18. The father agrees to continue the children in and to transport
them to and from their regularly scheduled activities which
occur while he is in this area during his periods of partial
custody. The mother agrees to keep him timely advised of
these events.
7
19. The parties agree that the father shall be allowed reasonable
telephone time contact between himself and the children when
the children are with the mother. Likewise, when the children
are with the father, the mother shall be allowed reasonable
telephone contact with the children.
20. The parties agree that they shall obtain each other's written
consent before removing the children from Pennsylvania, and
they also agree to provide the other parent an emergency
telephone number and address in the avant they do remove the
children from Pennsylvania.
21. Neither parent shall do anything which may estrange the
children from the other parent or injure the opinion of the
children as to the other parent, or which may hamper the free
and natural development of the children's love or affection
for the other parent. Likewise, each parent shall encourage
their relatives not to belittle or disparage the other parent
to the children.
22. The parties agree that in making this Agreement, there has
boon no fraud, concealment, overreaching, coercion, or other
unfair dealing on the part of the other.
8
Any modification or waiver of any of the provisions of this
Agreement shall be effective only it made in writing and only
it executed with the same formality as this Agreement.
IN WI OE M111MR110r, the parties hereto intending to bt-Aally nd th
ter?mys hereof, set forth their hands and seals this day of ,
19
1
Rub D. Ne ke, Esquire Cyn his G. Jone
Attorney for Plaintiff P1 intiff - Ho er
10 Nest High street
Carlisle,-,PA 17013
!C
ACtorne or Defendant
suite
$cran 61fe Bldg.
536 B ruce Street
Scranton, PA 18503-1816
HichaeL A. Jone*
Defendant - rather
9
COMMONWEALTH OP PENNSYLVANIA t
I ¦s
COUNTY OP CUMBERLAND I
On this, the-2,11?day oflg?p before me, a Notary
M ael A, Jones
Public, the undersigned officer, personally appeared 0 AH9W =XJdh*s, known to
me to be the person whose name is subscribed to the within custody stipulation
and Agreement, and acknowledged that she executed the same for the purposes
therein contained.
COMMONWEALTH Of PENNSYLVANIA I
0
COUNTY OP CUMBERLAND i
On this, the day of a&i 19L , before me, a Notary
Public, the undersigned officer, personpeered HAz?xxaPj4jes
known to me to be the person whose name in subscribed to the within Custody
Stipulation and Agreement, and acknowledged that he executed the same for the
purposes therein contained.
NOTAFaAL SU1L
MARYIYN A LAPATO, NotYy Pudw
my 2gftjjjWv C4"" Cu Ex"
Met 1w 19G7
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CYNTHIA O. JONES, 1 IN THE COURT OF COMMON PLEASE OF
Plaintiff I CUMSERLAND COUNTY, PENNSYLVANIA
t
vs. t CIVIL ACTION - LAW
t IN DIVORCE
MICHAEL A. JONES, 1
Defendant 1 96-6077 CIVIL TERM
ORDER
AND NOW, this day of 199_, after
hearing in this matter, the Petition of Defendant To Transfer Venue to Wayne
County, Pennsylvania is denied.
BY THE COURT,
J,
01 Ruby D. Weeks, Require, Attorney for the Plaintiff
Raymond lerrario, Require, Attorney for the Defendant
CYNTHIA 0. JONES,
Plaintiff
vs.
MICNAEL A. JONES,
Defendant
IN THS COURT OF CONISON PLEASE OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
96-6977 CIVIL TERN
r d +• i• ,r .u
NOW COMES PLAINTIFF CYNTHIA A. JONES, through her Attorney Ruby D.
Weeks, Esquire in response to the Defendant's Petition for Change of Venue,
requesting change of venue to Wayne County, Pennsylvania.
1. A. Admitted. By way of explanation, Defendant was served the
Complaint in Wayne County, by certified mail.
B. Plaintiff, Cynthia G. Jones is a resident of Cumberland County,
currently residing at 219 Front Street, Box 100, Boiling Springs,
Cumberland County, Pennsylvania 17007, since May 2, 1994. The date of
final separation was May 2, 1994, and Plaintiff filed the Divorce
complaint In Cumberland County on December 5, 1994.
2. Admitted.
3. Admitted. By way of explanation, the date of separation was May 2,
1994, seven months prior to the filing the Divorce complaint.
4. Admitted. Although the support action originated in Cumberland County,
as required by RURESA, the action transferred to Wayne County, as this
is the county of residence of the Defendant.
5. Denied. Plaintiff properly filed divorce complain in Cumberland County,
according to 23 Pa.C.a.a. 3104(e)(5) and Pennsylvania Rules of Civil
Procedure No. 1902.2 (a)(1), as Plaintiff filed the divorce complaint
more than six months after the date of final separation
6. Denied in part. Admitted in part. Plaintiff would not allow the
parties' children to be seen by their father due to his previously being
violent and verbally abusive to the Plaintiff in front of the children,
as well as previously being physically abusive.
HEW HATTER
7. Paragraphs 1 through 6 are hereby incorporated by reference and made a
part hereof.
B. Defendant persists in using the docket number for the custody matter,
94-4024 in documents In the Divorce Action 94-6877.
WHEREFORE, Plaintiff Cynthia G. Janes respectfully requests that the Court
deny the Defendant's request to transfer venue to Wayne County.
Dstedi November 13. 1996
RUBY D. WEEKS, ESQUIRE
Attorney for Plaintiff
Cynthia G. Jones
10 West High Street
Carlisle, PA 1701.3
(717) 243-1294
MEME.U
CYNTRIA 0. JONES,
Platatiff
vs.
NICEAEL A. JONES,
Defendant
t IN THU COURT OF COMMON PLRASR OF
t CVNBNRLAWD COUNTY, FBNNBYLVANIII
t
t CIVIL ACTION - LAW
t IN DIVORCE
t
t 94-6877 CIVIL TERN
AFFIDAVIT OF SERVICE BY RAIL
PURSUANT TO PA R.C.P. 1920.4 10 111111)
COMMONWEALTH. OF PENNSYLVANIA t
t an
COUNTY OF CUMBERLAND t
I, RUBY D. WEEKS, ESQUIRE, Attorney for Cynthia G. Jones, being duly
sworn according to law, depose and say that a true and correct copy of the
PLAINTIFF'S ANSWER TO DEFENDANT'S PETITION FOR CHANGE OF VENUE, was served on
Raymond Ferrario, at Suite 528, Scranton Life Building, 538 Spruce Street,
Scranton, PA 18503-1816, by mailing the same to him by regular mail, postage
pre-paid on November 13, 1995.
Datet November 13, 1995
Ruby D. We Wks, Enquire
y? i 1?I?I Y ICI i ? lr d r Ir )?IVl1??1{A%ry f'^ rv vT41t 1' '' I 4 I 'I I - r}{:
1 1 l e I 1 ? ? I A _ ? r 1' I I 1 rl L I ?'? Ir
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of 7) MM0.1? II 4 r r rr'I.
CYNTNIA O. JONES, t IN TUN COURT OF COMMON PLEASE OF
Plaintiff i CUNSERLAWD COUNTY, PENNSYLVANIA
i
rs. i CIVIL ACTION - LAN
i IN DIVORCE
MICNAML A. JONES, i
Defendant 1 96-6577 CIVIL TENT
ORDER
AND NOW, this day of 199, after
hearing in this matter, the Petition of Defendant To Transfer Venue to Wayne
County, Pennsylvania is denied.
BY THE COURT, aGt' ?`r
01 Ruby D. Weeks, Esquire, Attorney for the Plaintiff
Raymond Farrar in, Esquire, Attorney for the Defendant
{
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CYNTRIA 0. JOHNB,
Plaintiff
Va.
NICURL A. JONES,
Defendant
1 IN THE COUNT OF CONNON PLEABE DP
1 CUMBERLAND COUNTY, PENNSYLVANIA
1
1 CIVIL ACTION - LAW
1
1 IN DIVORCN
1
1 94-4877 CIVIL TERN
PLAINTIFF's AMRNBR TO D?RNDANT's PETITION Fn comas or VEEUE
NOW COMES PLAINTIFF CYNTHIA A. JONES, through her Attorney Ruby D.
Weeks, Require in reeponse to the Defendant's Petition for change of Venue,
requesting change of venue to Wayne County, Pennsylvania. t
1. A. Admitted. By way of explanation, Defendant was served the
Complaint in Wayne County, by certified mail.
B. Plaintiff, Cynthia O. Jones in a resident of Cumberland County,
currently residing at 219 Front street, Box 100, Boiling Springs,
Cumberland County, Pennsylvania 17007, since May 2, 1994. The date of
final separation was May 2, 1994, and Plaintiff filed the Divorce
Complaint in Cumberland County on December 5, 1994.
2. Admitted.
3. Admitted. By way of explanation, the date of separation was May 2,
1994, seven months prior to the filing the Divorce complaint.
4. Admitted. Although the support action originated in Cumberland County,
as required by RURESA, the action transferred to Wayne County, as this
is the county of residence of the Defendant.
5. Denied. Plaintiff properly filed divorce complain in Cumberland County,
according to 23 Pa.C.9.a. 3104(a)(5) and Pennsylvania Rules of Civil
Procedure No. 1902.2 (a) (1), as Plaintiff filed the divorce complaint
more than six months after the date of final separation
6. Denied in part. Admitted in part. Plaintiff would not allow the
parties' children to be seen by their father due to his previously being
violent and verbally abusive to the Plaintiff in front of the children,
as well as previously being physically abusive.
NEW NATTER
7. Paragraphs 1 through 6 are hereby incorporated by reference and made a
part hereof.
a. Defendant persists in using the docket number for the custody mattero
94-4024 in documents in the Divorce Action 94-6877.
WHEREFORE, Plaintiff Cynthia 0. Jones respectfully requests that the Court
deny the Defendant's request to transfer venue to Wayne County.
i
Datedl Novamber 13. 1995
RUBY D. ASKS, ESQUIRE
Attorney for Plaintiff
Cynthia 0. Jones
10 West High Street
Carlisle, PA 17013
(717) 243-1294
I
¦,
CYNTUA a. JONES,
Plalgtl[!
Va.
NICEABL A. JONE80 Defendant
AFFIDI
PURSUANT To
COMMONWEALTH OF PENNSYLVANIA t
t IN THE COURT OF COMM ILRA8E OF
t CUMBERLAND COUNTY, PRNN8YLVAIIIA
t
t CIVIL ACTION - LAW
t IN DIVORCE
t
t 94-6977 CIVIL TERN
I
COUNTY Of CUMBERLAND Ye
t tt
I, RUBY D. WEEKS, ESQUIRE, Attorney for Cynthia 0. Jonas, being duly
sworn according to law, depose and may that a true and correct copy of the
PLAINTIFFS ANSWER TO DEFENDANT'S PETITION FOR CHANGE OP VENUE, was served on
Raymond Fsrrarlo, at Suite 528, Scranton Life Building, 538 Spruce Street,
Scranton, PA 18503-1816, by mailing the same to him by regular mail, postage
pro-paid on November 13, 1995.
Datet November 13, 1995
Ruby D. We s, Esquire
,
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CYNTHIA 0. JONES, t IN THE COURT OF COMMON PLEASE Or,
Plaintiff CUNBRRLAND COUNTY, PEMNSYLVANIA
Va. i CIVIL ACTION - LAW
i IN DIVORCE
MICHAEL A. JONES, i
Defendant i 96-6477 CIVIL TERN
ORDER
AND NOW, this day of 199, attar
hearing in this matter, the Petition of Defendant To Transfer Venue to Wayne
County, Pennsylvania is denied.
I
BY THE COURT,
15
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lei Ruby D. Wseks, Esquire, Attorney for the Plaintiff
Raymond Ferraro, Esquire, Attorney for the Defendant
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CnMEIA 0. JONES,
Plaintiff
vs.
NICRARL A. JONES,
Defendant
IN THE COURT OF COMMON PLEASE OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAN
IN DIVORCE
16-6677 CIVIL TERM
PLAINTIFF'S RMBWER TO DEPENDANT'S PETITION FOR CRANOE OP VRNOS
NOW COMES PLAINTIFF CYNTHIA A. JONES, through her Attorney Ruby D.
Weeks, Require in response to the Defendant's Petition for Change of Venue,
requesting change of venue to Wayne County, Pennsylvania.
1. A. Admitted. By way of explanation, Defendant was nerved the
Complaint in Wayne County, by certified mail.
B. Plaintiff, Cynthia G. Jones is a resident of Cumberland County,
currently residing at 219 Front Street, Box 100, Boiling Springs,
Cumberland County, Pennsylvania 17007, since May 2, 1994. The date of
final separation was May 2, 1994, and Plaintiff filed the Divorce
Complaint in Cumberland County on December 5, 1994.
2. Admitted.
3. Admitted. By way of explanation, the date of separation was May 2,
1994, seven months prior to the filing the Divorce Complaint.
4. Admitted. Although the support action originated in Cumberland County,
as required by RURESA, the action transferred to Wayne County, as this
is the county of residence of the Defendant.
5. Denied. Plaintiff properly filed divorce complain in Cumberland County,
according to 23 Pa.C.s.a. 3104(e)(5) and Pennsylvania Rules of Civil
Procedure No. 1902.2 (a)(1), as Plaintiff filed the divorce complaint
more than six months after the date of final separation
6. Denied in part. Admitted in part. Plaintiff-Would not allow the
parties' children to be seen by their father due to his previously being
violent and verbally abusive to the Plaintiff in front of the children,
as well as previously being physically abusive.
NEW NATTER
7. Paragraphs 1 through 6 are hereby incorporated by reference and made a
part hereof.
0. Defendant pereiete in using the docket number for the custody matter?
94-4024 in documents in the Divorce Action 94-6077.
WHEREFORE, Plaintiff Cynthia 0. Jones respectfully requests that the Court
deny the Defendant's request to transfer venue to Wayne County.
patedi November 13. 1995
`
RUBY D. WEEKS, ESQUIRE t
Attorney for Plaintiff
Cynthia 0. Jones
10 West High Street
Carlisle, PA 17013
(717) 243-1294
i
I
CYNTNIA 0. JONBB,
Plaintiff
vs.
NICEAEL A. JONBB,
Defendant
COMMONWEALTH OF PENNSYLVANIA t
I u
COUNTY OF CUMBERLAND
I, RUBY D. WEEKS, ESQUIRE, Attorney for Cynthia O. Jones, being duly
sworn according to law, depose and ¦ay that ¦ true and correct copy of the
PLAINTIFF'S ANSWER TO DEFENDANT'S PETITION FOR CHANGE OF VENUE, was served on
Raymond Ferrario, at Suite $28, Scranton Life Building, 538 Spruce Btrest,
Scranton, PA 18503-1816, by mailing the same to him by regular mail, postage
pre-paid on November 13, 1995.
Dater November 13, 1995
.
IN TBB COURT OF COMMON FLBABB OF
I CVNRBRLAND COUNTY, FENNBYLVANIA
I CIVIL ACTION - IAW
I IN DIVORCE
1 ,
t 94-6477 CIVIL TERN
Ruby D. WaWks, Esquire
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OCT 25 1995 *
CYNTHIA 0. JONES, tIN THE COURT OF COMMON PLEAS OF
Plaintiff tCUMBERLAND COUNTY, PENNSYLVANIA
t
v :NO. 4024 - CIVIL - 1994
t
MICHAEL A. JONES, t
Defendant tCIVIL ACTION - CUSTODY
COURT ORDER
AND NOW, this day of C f, 6,L- , 1995, upon consideration of
the attached Custody Concil at on Report, it is ordered and
directed as follows:
1. The attached Custody Stipulation and agreement of the parties
is hereby incorporated as a Court Order.
2. A Hearing is scheduled in Courtroom No. 1 of the Cusberland
County Courthouse on the ,day of 199&f at
M. at which time testimony will be to en on the issue
of transportation for exchange of custody. Counsel shall
file with the Court and opposing counsel a Memorandum setting
forth rsach party's position on the transportation issue, a
list of witnesses that will be called to testify on this
issue and a summary of the anticipated testimony. This
memorandum shall be filed at least ten days prior to the
mentioned Hearing date.
BY THE COURT,
( I I----
Judge Harold E. Shee y, P.J.
cot Ruby D. Weeks, Esquire 11u.. lKa.(ut II/1/15-aA,,
Raymond W. Ferrario, Esquire
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CYNTHIA G. JONES,
Plaintiff
v
MICHAEL A. JONES,
Defendant
tIN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
tNO. 4024 - CIVIL - 1994
tCIVIL ACTION - CUSTODY
PRIOR JUDGE: JUDGE HAROLD E. SHEELY, P.J.
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
I915.3-8(b), the undersigned Custody Conciliator submits the
following report:
1. The information pertaining to the children who are the
subject of this report is as follows:
Christopher Jones, born June 24, 1988, Brian Jones, born
May 14, 1991, and Rachel Jones, born October 26, 1994.
2. A Conciliation Conference was held on October 20, 1995, with
the following individuals in attendance:
The Mother, Cynthia G. Jones, with her counsel, Ruby D.
Weeks, Esquire, and the Father, Michael A. Jones, with his
counsel Raymond W. Ferrario, Esquire.
3. The parties agreed on all the particulars of a custody
arrangement but could not agree on a transportation issue.
The parties originally lived in a town north of Scranton.
At separation, the Mother moved to the Cumberland County
area to be with her family. Father wants Mother to share
equally in the transportation. Mother is only willing to
meet halfway on Sundays and share transportation on that
day. She is unwilling to share the transportation otherwise.
A Hearing is required on the transportation issue.
4. The parties filed with the Conciliator a Custody Stipulation
that resolved all issues except the transportation. The
Conciliator recommends an Order in the form as attached.
-(fJ a Q.Sr - 6xzw K?u
-
DATE Hubert X. Gilroy, Es re
Custody Conciliate
CYNTHIA O. JONES, 1 IN THE COURT OF COMMON PLEAS OP
P1¦tStlr[ I CUMENRLAND COUNTY, PENNSYLVANIA
•s• 1 CIVIL ACTION - LAW
I CUSTODY
MICHAEL A. JON86, I
Defendant 1 NO. CIVIL' It
This Agreement and Stipulation entered into the day and year hereinafter
set forth, is by and between CYNTHIA G. JONES, natural mother, by her attorney,
Ruby D. Weeks, Esquire, and natural .',ether, by his attorney, RAYMOND N.
FERRARIO, Esquire, who aver as follower
1. Plaintiff 1s Cynthia G. Jones natural mother and an adult sul jurts, who
resides at Box 100, Boilinq Springs, Cumberland County, Pennsylvania,
17007.
II. Defendant is Michael A. Jones natural father and an adult sue jurts, who
resides ¦t 1127 Black Bear road, Wayne County, Pennsylvania, 18436.
III. Mother and father are the parents of three children, Christopher Jones,
born June 24, 1988 and Brien Jones, born May 14, 1991 and Rachel Jones,
born October 26, 1994.
IV. The parties agree to the following custody terms regarding custody of
the children and request the terms be'entered as an order of Court;
A. The parties shell have joint, shared, legal custody of the children.
8. The mother shall have actual physical custody of the children, with
partial custody awarded to the father as follower
1.Two weekends a month from 6t00 p.m. Friday to 6t00 p.m. Sunday as
on the first and third Weekends of each month. November 10th to 12th and 24th
to 26th 19951 December 8 to 10, December 26, 1995 to January 1 at 2100 p.m. 1996;
January 12 to 15 19961 January 26 to 28 1996; February 2 to 4 and 16 to 19 1996;
March 1 to 3 and 14 to 17 1996; April 5 to 7 and April 26 to 28 1996; May 10 to
12 and 24 to 26 19961 September 6 to 8 and 20 to 22 1996. It is the Intent of
the parties that each year when the father receives his national guard duty
1
schedule that the parties will arrange for the entire year the weekend schedule
taking the father'a national guard duties into consideration.
2. starting in 1996 during the mummer months of June July and August
i the father shall have partial custody for a total of thirty days to be taken tan
consecutive days at a time in each of those months from 900 a.m. on a Friday
until 6100 p.m. the second following Sunday. This paragraph supersedes the
I alternating weeks 4dr Pgiz11}g'?,ir??era above. For 1996 these dates aces
June 21 to 30 1996 July 12 to 21 6 • to 18 1996.
3. The mother is to have the entire Thanksgiving day in 1995.
Commencing in 1995 and odd numbered years thereafter, the father shall have
partial custody of the children each rhanksglving and each tooter Sunday and one-
half of whatever school vacation is provided by the school calendar, which is to
include the holiday. In the even numbered years, the mother will have the
Thanksgiving and Easter Sunday holiday" and one-half of the school vacation for
those holidays. The parent not having the children for the holiday shall have
the remaining one-half of the school vacation, Thanksgiving and Easter holidays
each year.
4.(a.) For 1995 and odd numbered year thereafter the mother shall
have the first half of the children's school holiday to include both Christmas
Eve and Christmas Days, the father shall have the second half of that school
holiday period.
I
(b.) For 1996 and even numbered year thereafter the father shall
have the first half of the children'" school holiday to include both Christmas
Eve and Christmas Days the mother shall have the second half of that school
holiday period.
6.(4.) The father shall always have partial custody of the children
on Father's Day from 9t00 a.m. to 9t00 p.m. and the mother on Mother's Day, even
if that day would have otherwise been a day for custody of the children with the
other parent.
G.
(b.) The father shall have some period of partial custody with each
child on the child's birthday ¦nd on the father's birthday to celebrate the
occasion. Likewlee, the mother shall always have time with each child on her
birthday and on the child's birthday even it thee* days were ordinarily day¦ of
the father's partial custody.
6. The portion agree that Dr. Robert Morten M.D. of Hamlin, Ph 19477,
will continue to be the children'e pediatrician when the children are with the
father, and accordingly , he will provide medical treatment to the children when
necessary, at the father's expense for items not covered by health insurance.
7.The parties agree that each parent shall be entitled to have
conferences with any physician , dentist, counselor, or other health care
provider, treating th• children, and each parent shall be entitled to copies of
reports regarding a child's treatment.
gy The father agrees to call at least 24-hours before appearing
for eni'wPu.trL
. visit and to confirm theme prearranged
periods of partial custody at least twenty-tour hours (24) in
advance. The wife agrees not to unreasonably withhold consent
for such visitation or periods of partial custody by the
tether..
g.. Time to of the essence regarding the father's pick-up and
return of the children for periods of the father's partial
custody. The parties agree that if the father has not picked
up the children within one hour, of the set time, that period
of partial custody is forfeited by the 'father and the mother
and children are free to make other plane, unless the tether
has notified the mother in advance of an emergency situation
which prevents his timely arrival.
1D ' The parties shell notify each other in a timely fashion it it
is necessary due to an emergency or unforeseen circumstance
tot him or her to be delayed at any of the times set out
ICI herein. It to Intended, however, that time be of the •seence,
and that the portion as strictly as possible comply with the
times set forth herein.
11. The parties will notify and consult with the other party
immediately in cease of medical emergencies thst`oocut while
the children are In each parent's custody.
12 The father agrees to continue the children in and to transport
them to and from their regularly scheduled activities which
occur while he is in this area during his periods of partial
custody. The mother agrees to keep him timely advised of
theme events.
f
n?. The parties acknowledge that the child has the following
medical conditions and that each parent will ensure that the
recommended dietary, medical and environmental restrictions
and treatments are adhered to, including but not limited to,
noneaposure to animals and cigarette smoke, and that the
children will receive all prescribed dosages of medication and
treatment a directed by the physician.
a. Christopher - croup and respiratory problems
b. Brian - suspected colitis and 9metro intestinal
problems
it in acknowledged that thew health problems often
occur at night, and the rather agrees to meek prompt medical
treatment when the children are with him and such problems
/? A1k{
lei. The ??/ql? 5F Iit / h?r ( hall f?i^twa pspotNtion to and from his,
periods of partial custody. After March ll, 1996, the mother
agrees to most the father one-half way at a mutually-49ree4-
upon location in rrackvllls, PA, at such times as the father
turning the children to the mother's custody.
lg. The parties shall-okeherigs intent and,childron's car seats,
with the mother providing these to the father as necessary
when he picks up the children. The father shall promptly
return the car cents to the mother-at the time he returns the
children.
1f,. The father may have partial custody of the children during
such additional periods an the parties shall from time to time
agree, without tits need to modify the order of Court entered
as a result of this Stipulation.
I
5
1'?• The portion agree that the tether shall be allowed reasonable
telephone time contact between himself and the children when
the children are with the mother. Likewlw, when the children
ere with the father, the mother shell be allowed reasonable
telephone contact with the children.
le' The portion agree that they shall obtain each other's written
consent before removing the children from Pennsylvania, and
they ale* agree to provide the other parent an emergency
telephone number' and address in the event they do remove the
children from Pennsylvania.
19. Neither parent nhall do anything which may estrange the
children from the other parent or injure the opinion of the
children as to the other parent, or which may hamper the free
and natuFal development of the children's love or aftection
for the other parent. LikewLse, each parent shall encourage
their relatLvee not to belittle or disparage the other parent
to the children.
gyp. The parties agree that in making this Agreement, there has
been no fraud, concealment, overreaching, coercion, or other
unfair dealing on the port of the other.
CJ
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IN MUSS MBBBBO?, the parties hereto intending to be legally bound by the
terms herett, met forth their hands and meals this 40th day of October, 1999.
Bu y D. • •, Bequ re c !! A oJo
Attorney for Plaintiff Pi•intiff
10 Nest High Street
4 Car 910,011A 17011
A8
Ba mrrar , B q ire HICHABL A. J
At M for Defendant At
suite 78
loran on Life Building
678 spruce street
Scranton, PA 18607-1916
f
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COMMONWEALTH Of PENNSYLVANIA t
t as
COUNTY or CUMBERLAND I
On this, the rL_//I day of ((f 1 '' /I
, 19Zll, before ma, a Notary
Public, the undersigned officer, personally appeared, MICHAEL A. JONES known to
me to be the person whose name is subscribed to the within Custody Stipulation
and Agreement, and acknowledged that she executed the same for the purposes
therein contained.
KWIYL1N A LAI'A It, Y+••.?, r ??. ?.
C r%AK CumD vWq C to 1y
1?4I 1't?13?7
COMMONWEALTH Or PENNSYLVANIA
COUNTY or CUMBERLAND n
J.tj? 1;
Notary P b c"
On this, the IL ZI) day of 19•(x, before me, a Notary
Public, the undersigned officer, personally appeared, CYNTHIA O. JONES known to
me to be the person whose name in ¦ubscribed to the within Custody Stipulation
and Agreement, and acknowledged that he executed the same for the purposes
therein contained.
NuLAWAI. M1'.AL
MAJIYLYN A. LM'AO, MMI f MOW
CetMn Currd+glWCwunl/
&Wjpb% I Q07_ 1
Notary Pub io -?
RAYMONp W..FERRAR10, mc,
• ATTORNRY•AT•LAW
Own 636. SCRANTON LIIL BUILDING
606 6r111Jct 6TNItT
SCRANTON, rtNN@VLVANIA 16000.1616
T[LR*?IONa1 171 71 660.7876
rAAI 17171 043,7090
CYNTHIA 0. JONESr I IN THE COURT OP COMMON PLEAS
Plaintiff I OF CUMBERLAND COUNTY
I PENNSYLVANIA
VS s
I CIVIL ACTION - LAN
MICHAEL A. JONESt t IN DIVORCE
Defendant s
t 94-4024 CIVIL TERN
esssssesseetesssesesseatsestresstossesseesssstsessss:stesssasssse
NOW COMES DEPENDANT MICHAEL A. JONES through his ATTORNEY
RAYMOND W. PERRARIO and requests the Court change venue of this
case to the Court of Common Pleas of Wayne County, Pennsylvania.
The following is alleged in support:
1. Defendant Michael A. Jones is a resident of Wayne County,
currently residing at Box 318, R.D. 02, Waymart, Wayne County,
Pennsylvania 18472. Defendant was served the Complaint in this
case in Wayne County.
2. The marital residence of the parties is a single family home
located at Box E9, R.R. ,fl, Lake Ariel, Wayne County,
Pennsylvania. The home is still owned by the parties and is one
of the primary marital assets of the parties.
3. Prior to separation on or about May 2, 1994, the parties
spent substantially the entire period of their marriage in Wayne
County.
1
4. The support action in this case was commenced and litigated
by the Plaintiff Cynthia G. Jones, and actively litigated by the
Plaintiff Cynthia G. Jones in Wayne County.
5. The Plaintiff unilaterally and improperly filed the divorce
and custody action in Cumberland County although until very
recently the Court of Common Pleas of Cumberland County was not
actively involved in the litigation between the parties.
Recently in August, Plaintiff requested the appointment of a
divorce master in Cumberland County. No hearings have yet to be
scheduled or conducted.
6. A custody agreement was entered between the parties due to
the fact that Plaintiff Cynthia G. Jones would not allow the
parties' children to be seen by their father, Defendant Michael
A. Jones, until said custody agreement was entered of record in
Cumberland County.
7. The primary issue to be resolved involves the economic
issues of division of the marital assets in Wayne County and
issues of alimony. Both issues will essentially involve use of
witnesses from Wayne County - including real estate appraisers
and salesmen, and persons acquainted with the vocational
background of Plaintiff in Wayne county.
6. In accordance with Pennsylvania Rule of Civil Procedure No.
1006(d), proper venue lies-not in Cumberland county but rather
properly in Wayne County. Proper venue should not be determined
merely as a result of a "race to the Courthouse".
2
9. Transferring the case to Wayne County should not impede
timely and fair disposition of the issues in this case.
WHEREFORE, Defendant Michael A. Jones respectfully requests
the Court transfer this case to Wayne County.
Dated c AUG 17 IVE MAYMOND W. FORM
RAYMOND W. FERRARIO, ESQUIRE
Attorney for Defendant
Michael A. Jones
Attorney I.D. 0 35096
Scranton Life Bldg-Ste 528
538 Spruce Street
Scranton, PA 18503
(717)963-7878
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RAYMOND W. RERRARIO, P.C.
ATTORNaY-AY•LAW
suiva ego, SCRANTON LI/E OuiLOINO
534 frnuCE STREET
SCRANTON. PENNSYLVANIA 19603.101!
TaLiMMDNa1(717) 043.70741
/Aw 17171943-79110
CYNTHIA O. JONES? t IN THE COURT OF CONKON PLEAS
Plaintiff t OF CUNEERLAND COUNTY
t PENNSYLVANIA
Va t
t CIVIL ACTION - LAN
MICHAEL A. JONSS7 t IN DIVORCE
Defendant 1
t 94-4024 CIVIL TERM
etetttetttetetteeeettetetteeetteetteteeeeteeeetttetteteetetttttet
NOW COKES DEFENDANT MICHAEL A. JONES through his ATTORNEY
RAYMOND W. FERRARIO and requests the Court change venue of this
case to the Court of Common Pleas of Wayne County, Pennsylvania.
The following is alleged in support:
i. Defendant Michael A. Jones is a resident of Wayne County,
currently residing at Box 319, R.D. #2, Waymart, Wayne County,
Pennsylvania 19472. Defendant was served the complaint in this
case in Wayne County.
2. The marital residence of the parties is a single family home
located at Box E9, R.R. 01, Lake Ariel, Wayne County,
Pennsylvania. The home is still owned by the parties and is one
of the primary marital assets of the parties.
3. Prior to separation on or about May 2, 1994, the parties
spent substantially the entire period of their marriage in Wayne
County.
1
d. The support action in this case was commenced and litigated
by the Plaintiff Cynthia G. Jones, and actively litigated by the
plaintiff Cynthia G. Jones in Wayne County.
5. The Plaintiff unilaterally and improperly filed the divorce
and custody action in Cumberland County although until very
recently .he Court of Common Pleas of Cumberland County was not
actively involved in the litigation between the parties.
Recently in August, Plaintiff requested the appointment of a
divorce master in Cumberland County. No hearings have yet to be
scheduled or conducted.
6. A custody agreement was entered between the parties due to
the fact that Plaintiff Cynthia G. Jones would not allow the
parties' children to be seen by their father, Defendant Michael
A. Jones, until said custody agreement was entered of record in
Cumberland County.
7. The primary issue to be resolved involves the economic
issues of division of the marital assets in Wayne County and
issues of alimony. Both issues will essentially involve use of
witnesses from Wayne County - including real estate appraisers
and salesmen, and persons acquainted with the vocational
background of Plaintiff in Wayne County.
8. In accordance with Pennsylvania Rule of Civil Procedure No.
1006(d), proper venue lies-not in Cumberland County but rather
properly in Wayne County. Proper venue should not be determined
merely as a result of a "race to the Courthouse"
2
90 Transferring the case to Wayne County should not impede
timely and fair disposition of the issues in this case.
METRE/ORE, Defendant Michael A. Jones respectfully requests
the Court transfer this case to Wayne County.
Dated: 'AU9 17 1995 /Z _
.'
PAkRO_N!V,A. F RRARIO, ESQU RE
Attor y for Defendant
Mich el A. Jones
Attorney I.D. 0 35096
Scranton Life Bldg-Ste 528
538 Spruce Street
Scranton, PA 18503
(717)963-7878
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RUBY 1). WEEKS,ESQUIRIi w_ _ rnv.xl•.
I CMrI?77IIATTIIFwrrmN IA A rxLG TEN WEST HIGH STREET Nr xr xrnoul 1111 Will It A WON nn
ANU COEEE[T UPY Of MR OAIOINAI. CARLISLL', PA • 17013 xrswin)f nr un rnrnutu
FILED IN 70D ACTION (717) 243-129?? I9 1 ,I Y,)1' PAY) W)m
CYNTHIA 0. JONES I
Plaintiff t
t
Vs. t
t
MICHAEL A. JONES t
Defendant
IN THE COURT OF COMMON PLHAH OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
CUST4 97 - Civil Tt r,»
Nosy.
NO. CIVIL 19`i
ORDER Or COURT
AND NOW, this ii± day of ) , I ?? , 19.?(J, upon consideration
of the attached Complaint, it is hereby directed that the parties and their
respective counsel appear before I1,61j Z, 6, the conciliator, at
on the '93(((
t
day of
at <4i A .m., for a Pre-Hearing Custody Conference. At such conference, an
effort will be made to resolve the issues in dispute; or if this cannot be
accomplished, to define and narrow the issues to be heard by the Court, and to
enter into a temporary Order. All children age five or older may also be present
at the conference. Failure to appear at the conference may provide grounds for
entry of a temporary or permanent Order.
Un it suc time the parties meek with the conciliat th parties are
dirac that the c ody of the children not to be changed the
moth in or to inta he statue qu .
FOR THE COURT.,
By:
Custody Conc Setor r/
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU I NOT AVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
Jut 22 I al
nnu r: )uliir
trill.
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CYMMIA 0. JONES, 1 IN THE COURT OF Comm FLEAS OF
plaintiff CUMURLAND COUNTY? PENNSYLVANIA
Vs. CIVIL ACTION - LAN
1 CUSTODY
NICUM A. JONES, t
Defendant t NO. CIVIL 199,
ORDER OF COURT
YOU, MICHAEL A. JONES, have been sued in Court to obtain custody, partial
custody or visitation of the children, Christopher M. Jones, born 6/24/88 and
Brian N. Jones, born 5/14/91.
You are ordered to appear in person at Courtroom No. , Cumberland
County Courthouse, Carlisle, Pennsylvania, on , the
of , 19_, at _.M. for a hearing. Until such
hearing, custody of the children shall be and remain with the natural mother,
Cynthia 0. Jones.
If you fail to appear as provided by this Order, an Order for custody,
partial custody or visitation may be entered against you or the Court may issue
a warrant for your arrest.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
Talephonet (717) 240-6200
BY THE COURT,
CYNTHIA 0. JONES, t IN THE COURT OF COMMON PLEAS OF
Plaintiff t CUMBERLAND COUNTY, PENNSYLVANIA
t
•s, t CIVIL ACTION - LAN
t CUSTODY
MICHAEL A. JONES, I
Defendant t NO. CIVIL 19,;",
COMPLAINT FOR JOINT AND SHARED CUSTODY
TO THE HONORABLE, TOE JUDGES OP SAID COURTt
1. The Plaintiff is, CYNTHIA G. JONES, hereafter referred to as the natural
mother, residing at Box 100, Boiling Springs, Cumberland County, PA,
17007.
2. The Defendant is MICHAEL A. JONES, hereafter referred to as the natural
father, residing at R.R.01, Box E9, Lake Ariel, PA 18436, .
3. Plaintiff seeks legal custody of the following childrent
a. KAW Present Residence 842 Date of Birth
I, Christopher M. Jones Box 100
Boiling Springs, PA 17007 6 6/24/88
Brian N. Jones Box 100
Boiling Springs, PA 17007 3 5/14/91
b. The children are presently in the custody of the natural mother, who
resides at Box 100, Boiling Springs, Cumberland County, PA 17007
1
C. The children have resided with the following persons and at the
following addressee for the past 5 years:
parson! Address Dates
Mother 6 Father 1127 Black Bear Rd. Birth to 5/94
Indian Rocks
Hamlin, PA.
Mother P.O. Box 100 5/94 to present
Boiling Springs, PA. 17007
3. Plaintiff has not participated as a party or witness, or in any other
capacity, in any other litigation concerning the custody of the children
j in this or another court.
4. Plaintiff has no information of a custody proceeding concerning the
children pending in a Court of this Commonwealth.
5. Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the children or claims to have custody or visitation
rights with respect to the children.
6. Each parent whose parental, rights to the children has not been terminated
and the person who has physical custody of the children has been named as
parties to thin action. There are no other persons who are known to have
or claim a right to custody or visitation of the children, so none will be
given notice of the pendency of this action and the right to intervene.
7. Pursuant to the child custody law 23 Pa.C.S.A. 55301 gj, seg., the mother
requests thin court to grant an award of legal custody to her.
B. The mother requests primary physical custody of the children in that she
is in a better position to provide consistent and stable care for the
children and she is the parent more likely to assure that the children
have a relationship with both parents.
9. The best interests and permanent welfare of the children and their
physical, spiritual, emotional and moral well-being will be served by
granting the relief requested of legal and physical custody with the
mother.
10. Plaintiff-mother prays for an Order awarding legal and primary physical
custody of the minor children, , Christopher M. Jones was born 6/24/88 and
Brian N. Jones was born 5/14/91 to the Plaintiff-mother, with partial
custody awarded to Defendant-father as this Court determines is in the
best interests of the children.
WHEREFORE, Plaintiff-mother prays for an Order awarding legal and primary
custody of the minor children, Christophor M. Jones and Brian N. Jones to the
mother, with partial custody to the Defendant-father as this Court determines is
in the best interests of the children.
Respect;lly submit/teed,, L "
Dates Ct\(?(JCQ[?lJ--
Ruby D. week , Esquire
Attorney for laintiff
10 West High Street
COWMONM MT1 OF PENNSYLVANIA ,
an
COUNTY OF CUMBERLAND ,
Personally appeared before me, A Notary Public in and for the Commonwealth
and county aforesaid, the under-signed, being duly sworn according to law,
deposes and mays that the facts set forth in the foregoing Complaint are true and
correct.
Sworn to and subscribed to
before me this i9lt- da
of
Srl
1 C . ` 4,__. Mrc?an ?YBdOron? 1f, t
Notary Public
C-
CYNTHIA O. JONE6, i IN THB COURT OP COMMON FLEAS OF
Plaintiff i CUMBERLAND COUNTY, PENN6YLVANIA
1
vs, t CIVIL ACTION - LAN
i IN DIVORCE
HICHA6L A. JONE6,
Defendant 1 94-4074 CIVIL TERN
O RDE $
AND NOW, this
day of 1996, a hearing is met
_
for the day of , 1996, at _ _.M. in Courtroom No. _,
fourth Floor, Cumberland County Cour tho use, Carlisle, Pennsylvania, on the
Wife's Petition for Special Relief.
BY THE COURT,
CYNTHIA 0. JOHNS,
plaintiff i
i
rs. e
1
HICNASL A. JONES, 1
Defendant i
ORDER
IN THE COURT OF COMMON PLEASE OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAN
IN DIVORCE
16-6677 CIVIL TERM
AND NOW, this day of 199,, after
hearing in this matter, the Petition of Plaintiff for Special Relief is
granted. Defendant in ordered and directed to make and keep current ¦ll
outstanding mortgage payments on the marital residence within fifteen (16)
days of this order. The Defendant is further ordered and directed to obtain a
psychological evaluation and to promptly initiate mental health counseling.
He is further directed to provide a copy of the evaluation and confirmation of
counseling to Plaintiff's and Defendant's counsel, a¦ well as to this Court
within sixty (60) days of this order.
BY THE COURT,
cl Ruby D. Weeks, Esquire, Attorney for.the Plaintiff
Raymond ¦errario, Esquire, Attorney for the Defendant
CYNTHIA O. JONES, t IN THE COURT Or COMMON PLEASE Or
Plaintiff t CUMBERLAND COUNTY, PENNSYLVANIA
t
va. t CIVIL ACTION - LAW 0 n
t IN DIVORCE i.: ' •?
MICHAEL A. JONES, t
Defendant t 94-6677 CIVIL TERi
i
PETITION FOR SPECIAL RELIE?
COUNT I - NORTOAOE RELIS? _"?rtr
COMES NOW, CYNTHIA JONES, Plaintiff-Petitioner, by her attarpsy-, Ru4i
D. Wesks,Esquire, and petitions the court as follower
1. Your Plaintiff-Petitioner is Cynthia G. Jones, Box 100, Boiling spring,
Cumberland County, Pennsylvania 17007.
2. Your Defendant-Reepondent in Michael A. Jones, 1127 Black Beer Road,
Hamlin, Wayne County, Pennsylvania, 18436.
3. Since June 1995, Defendant-Reepondent has refused to make mortgage
payments on the marital residence located at 1127 Black Bear Road,
Indian Rocks, Hamlin, Pennsylvania 18427.
4. on May 2, 1994, PlaLntiff-Petitioner removed herself and the children
from the marital residence because of the Defendant's physical abuse
toward her.
5. At the time, Plaintiff-Petitioner was pregnant with the parties' third
child, who was subsequently born on October 26, 1994.
6. The Plaintiff-Petitioner is unemployed and is a full-time caretaker for
the parties' children who are Christopher Jones, born June 24, 1988 and
Brian Jones, born May 14, 1991 and Rachel Jones born October 26, 1994.
7. On December 19, 1995 the Plaintiff-Petitioner wag served with mortgage
foreclosure documents from LA Bank, N.A. since the Defendant-Respondent
has refused to make the aforementioned mortgage payments.
8. The marital residence in the major asset in the divorce and the
Defendant-Respondent has threatened to let it go to foreclosure unless
the wife deeds her interest to the husband.
9. The wife has no income other than the spousal and child support she
receives from the husband and has no way to make the mortgage payments
current to prevent the foreclosure.
10. The marital residence is presently listed with Coldwell Banker Realtors
in Hamlin, Pa. for 662,5001 there is an outstanding mortgage of 452,
760.79 which includes Interest to 11/16/95 and late charges, to LA Bank,
N. A.
COUNT II - REQUEST FOR DEPENDANT TO UNDERGO
PSYCHOLOGICAL EVALUATION AND COUNSELING
11. Paragraphs 1 through 10 are hereby incorporated by reference and made a
part hereof.
12. Following a period of partial custody with the rather-Defendant-
Respondent on November 26, 1995, the child, Christopher was returned by
the father severely bruised on his buttocks after having been
"disciplined" by the father in an apparent angry rage.
WHEREFORE, Plaintiff-Petitioner seeks to have Defendant-Respondent
directed to make current all outstanding mortgage payments to prevent the
foreclosure on the marital residence and to have him court-ordered to received
counseling and a psychological evaluation for his rages and mental health
i problems.
Date, 1' vZ' 4 , Respectfully,
/ ,.1 ?l 1"
Ruby D. Weeks,' Esquire
Attorney for the Plaintiff-Petitioner
10 Went High Street
Carlisle, Pennsylvania 17013
(717) 243-1294
r
COMMONWEALTH or PENNSYLVANIA f
COUNTY OF CUMBERLAND t n
I, CYNTHIA G. JONES, appeared before me, a Notary Public, in and for the
Commonwealth and County aforesaid, the undersigned, being duly sworn according
to law, deposes and says that the foregoing PETITION FOR SPECIAL RELIEF are
true and correct to the beet of my knowledge, information and belief and are
made subject to the penalties of IS Pa.C.S. $4904 relating to unsworn
falsification to authorities.
CYNTHIA 0. J S,I TIF - TITIONER
Sworn to and subscribed to
before1 me this _4ZaLl dayJ'
ARYI• r L 1
G ,' I'd R , `n• f u?•Pt
vd.IT, r. ??I :rd ?. 1 ?';r
i Cmnni i •, h_, i,,; _.r Y fame 1 ', 1U97
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I nprtvv nur rm• wmlIN IS n I xrt. TEN WEST HIGH STREET urxtxv nnntuu to wu:nwxr)rnn _
AND(OxYfCrruvv01, rill-nxxdNni CAPLISLEv PA 17013 xrsinwvo- wnu, reruraru r'; ?•
HIMrIN rllq nCIION (717) 243-1294 wp OjN IWt Nrv,Sx Dnvxrxom R...' ,
CYNTHIA 0. JOWNG, 1 IN TUN COURT OF COMMON FLEAS OF
Plaintiff 1 CUMBERLAND COUNTY, PSMNSYLVANIA
t
vs. t CIVIL ACTION - LAN
t IN DIVORCE
NICHAHL A. JONES, t
Defendant 1 94-0026 CIVIL TNRN
ORDER
AND NOW, this day of , 1996, a hearing it Get
for the day of , 1996, at _.M. in Courtroom No. _,
Fourth Floor, Cumberland county courthouse, Carlisle, Pennsylvania, on the
Wife's Petition for Special Relief.
BY THE COURT,
i
1
CYNTHIA 0. JOURB, I IN THE COURT OF COMMON FLEABE OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
vs. I CIVIL ACTION - LAW
IN DIVORCE
MICHAEL A. JONES,
Defendant t 94-6877 CIVIL TERM
ORDER
AND NOW, this day of _199_, after
hearing in this matter, the Petition of Plaintiff for Special Relief in
granted. Defendant is ordered and directed to make and keep current all
outstanding mortgage payments on the marital residence within fifteen (15)
days of this order. The Defendant In further ordered and directed to obtain a
psychological evaluation and to promptly initiate mental health counseling.
He is further directed to provide a copy of the evaluation and confirmation of
counseling to Plaintiff's and Defendant's counsel, as well as to this Court
within sixty (60) days of this Order.
BY THE COURT,
cc Ruby D. Weeks, Esquire, Attorney for the Plaintiff
Raymond Ferrario, Esquire, Attorney for the Defendant
NL
CYNTHIA 0. JONES, I
Plaintiff r
t
vs. t
t
MICHAEL A. JONES, t
Defendant t
IN THE COURT OF COMMON PLEASE OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
94-6677 CIVIL TERM
PETITION FOR SPECIAL RELIEF
COUNT I - MORTGAGE RELIEF
COMES NOW, CYNTHIA JONES, Plaintiff-Petitioner, by her attorney, Ruby
D. Weeks,Esquirs, and petitions the court as followst
1
2.
3.
4.
5
6
7.
8
Your Plaintiff-Petitioner Is Cynthia G. Jones, Box 100, Bolling Springs,
Cumberland County, Pennsylvania 17007.
Your Defendant-Respondent is Michael A. Jones, 1127 Black Bear Road,
Hamlin, Wayne County, Pennsylvania, 18436.
Since June 1995, Defendant-Respondent has refused to make mortgage
payments on the marital residence located at 1127 Black Bear Road,
Indian Rocks, Hamlin, Pennsylvania 18427.
On May 2, 1994, Plaintiff-Petitioner removed herself and the children
from the marital residence because of the Defendant's physical abuse
toward her.
At the time, Plaintiff-Petitioner was pregnant with the parties' third
child, who was subsequently born on October 26, 1994.
The Plaintiff-Petitioner is unemployed and is a full-time caretaker for
the parties' children who are Christopher Jones, born June 24, 1988 and
Brian Jones, born May 14, 1991 and Rachel Jones born October 26, 1994.
On December 19, 1995 the Plaintiff-Petitioner was served with mortgage
foreclosure documents from LA Bank, N.A. since the Defendant-Respondent
has refused to make the aforementioned mortgage payments.
The marital residence in the major asset in the divorce and the
Defendant-Respondent has threatened to let it go to foreclosure unless
the wife deeds her interest to the husband.
9. The wife has no income other than the spousal and child support she
receives from the husband and has no way to make the mortgage payments
current to prevent the foreclosure.
10. The marital residence is presently listed with Coldwell Banker Realtors
in Hamlin, Pa. for $62,5001 there is an outstanding mortgage of $52,
760.79 which Includes interest to 11/16/95 and late charges, to LA Bank,
N. A.
COUNT 11 - REQUEST FOR DEFENDANT TO UNDERGO
PSYCHOLOGICAL EVALUATION AND COUNSELING
11. Paragraphs 1 through 10 are hereby incorporated by reference and made a
part hereof.
12. Following a period of partial custody with the Father-Defendant-
Respondent on November 26, 1995, the child, Christopher was returned by
the father severely bruised on his buttocks after having been
"disciplined" by the father in an apparent angry rage.
WHEREFORE, Plaintiff-Petit loner seeks to have Defendant-Respondent
directed to make current all outstanding mortgage payments to prevent the
foreclosure on the marital residence and to have him court-ordered to received
counseling and a psychological evaluation for his rages and mental health
problems.
Dates Respectfully,
o?.?1?:lti
Ruby D. Weeks, Esquire
Attorney for the Plaintiff-Petitioner
10 West Nigh Street
Carlisle, Pennsylvania 17013
(717) 243-1294
COMMONWEALTH OF PENNSYLVANIA I
I as
COUNTY OF CUMBERLAND I
I, CYNTHIA 6. JONES, appeared before me, a Notary Public in and for the
Commonwealth and County aforesaid, the undersigned, being duly sworn according
to law, depose¦ and says that the foregoing PETITION FOR SPECIAL RELIEF are
true and correct to the beet of my knowledge, information and belief and are
made subject to the penalties of 18 Pa.C,S. $4904 relating to unsworn
falsification to authorities.
/6;?-
CYNTHIA G. J S, AI T FF- TITIONER
Sworn to and subscribed to
before me this 7.i e( day -?
r MAFYI
o ary , "qlLc
,
RAYMOND W. FIERRARIO, P.C.
ATTOITNLY•AT•LAW
SUITE 529. SCRANTON LIFE BUILDING
535 SPRUCE STREET•
SCRANTON. PENNSYLVANIA 16503. BIB
TBLtM1oNaI (717) 048-7674 U1, I J u I-JUJ f
TAM: 17 1 71 043-7060
CYNTHIA O. JONEBE t IN TEE COURT OF COMMON PLEBE
Plaintiff t OF CWIEERLAND COUNTY
I PENNBYLVANIA
Ve t
t CIVIL ACTION - LAN
NICEAEL A. JONEB0 I IN DIVORCE
Defendant t
1 94-4024 CIVIL TERN
ertrrrrtreeeerrrrrrerrrrerrreeereirrrrrrrrtetrereeetrtteeerreetrr
RULE RETURNAEjIZ
AND NOW THIS jjad day of AldV102,614 , 1995,
Plaintiff Cynthia G. Jones is hereby Ruled to Show Cause, if any
she may have, why venue in the above matter should not be
transferred to the Court of Common Pleas of Wayne County.
RULE RETURNABLE on the/3" day of AZO M mAke ,
1995. Hearing, if necessary, to be held on the jAd day of
- UAAWAZ./7 , , at at Courtroom 01,
_
4/ tA_ Floor of the Cumberland County Courthouse, Carlisle,
Pennsylvania.
BY TH CO[JRT:
1 (? - - ,, /(- - - C k 1- J.
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CY"RIA O. JONRNe I IN TRR COURT OF COMMON PLEAD
Plaintiff I OF CUMEERLAND COUNTY
I PENNBYLVANIA
VS t
t CIVIL ACTION - LAN
MICRAIL A. JOKE/o I IN DIVORCE
Defendant t
t 94-4024 CIVIL TERM
titttitittttltittttttttttttititttitttttitittttittttttittttttltttt
PETITION POR CHANGE OP VENUR
NOW CONES DEPENDANT MICRARL A. JONES through his ATTORNEY
RAYMOND N. PERRARIO and requests the Court change venue of this
case to the Court of Common Pleas of Wayne County, Pennsylvania.
the following is alleged in support:
1. Defendant Michael A. Jones is a resident of Wayne County,
currently residing at Box 318, R.D. J2, Waymart, Wayne County,
Pennsylvania 18472. Defendant was served the Complaint in this
case in Wayne County.
2. The marital residence of the parties is a single family home
located at Box E9, R.R. 010 Lake Ariel, Wayne County,
Pennsylvania. The home is still owned by the parties and is one
of the primary marital assets of the parties.
3. Prior to separation on or about May 2, 1994, the parties
spent substantially the entire period of their marriage in Wayne
County.
4. The support action in this case was commenced and litigated
by the Plaintiff Cynthia G. Jones, and actively litigated by the
Plaintiff Cynthia G. Jones in Wayne County.
6. The Plaintiff unilaterally and improperly filed the divorce
and custody action in Cumberland County although until very
recently the Court of Common Pleas of Cumberland County was not
actively involved in the litigation between the parties.
Recently in August, Plaintiff requested the appointment of a
divorce master in Cumberland County. No hearings have yet to be
scheduled or conducted.
6. A custody agreement was entered between the parties due to
the fact that Plaintiff Cynthia G. Jones would not allow the
parties' children to be seen by their father, Defendant Michael
A. Jones, until said custody agreement was entered of record in
Cumberland County.
7. The primary issue to be resolved involves the economic
issues of division of the marital assets in Wayne County and
issues of alimony. Both issues will essentially involve use of
witnesses from Wayne County - including real estate appraisers
and salesmen, and persons acquainted with the vocational
background of Plaintiff in Wayne County.
9. Venue best lies-not in Cumberland County but rather properly
in Wayne County. Proper venue should not be determined merely as
a result of a "race to the Courthouse".
90 Transferring the case to Wayne County should not impede
timely and fair disposition of the issues in this case.
WNEREFOREp Defendant Michael A. Jones respectfully requests
the Court transfer this case to Wayne County.
i
Dated: RAYMOND,, W. FE?RRA I0, ESQUIRE
Attorney for Defendant
Michael A. Jones
Attorney I.D. / 35096
Scranton Life Bldg-Suite 528
538 Spruce Street
Scranton, PA 18503
(717)963-7878
WO,4k.
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CYNTHIA 0. JONES, rZN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
r
v MO. 4024 - CIVIL - 1994
MICHAEL A. JONES, :CIVIL ACTION - CUSTODY
COURT ORDER
fit
AND NOW, this r day of ? , 1994, the Conciliator
being advised tat the parti s ave reached an agreement, the
Conciliator relinquishes jurisdiction.
Hubert X. Gi roy, squ re
Custody Concilia or
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SHERIFF'S RETURN
COMMONWEALTH OF PENNSYLVANIA In the Court of Common Pleas of
COUNTY OF CUMBERLAND Cumberland County, Pennsylvnaia
Cynthia G. Jones No. 94-4024 Civil Term
VS
Michael A. Jones
R. THOMAS KLINE, Sheriff, who being duly sworn according to law,
says, that he made diligent search and inquiry for the within named
defendant, to wit: Michael A. Jones
but was unable to locate him in his bailiwick. He therefore
deputized the sheriff of Wayne County, Pennsylvania,
to serve the within Order of Court and Complaint For Joint
and Shared Custody
On August 15, 1994
the attached return from Wayne
this office was in receipt of
County, Pennsylvania.
Sheriff's Costs: So answers:
Docketing 14.00
Out of County 5.00 !
Surcharge 2.00
Wayne County g 25.00 R. THOMAS KLINE, Sheriff
Sworn and subscribed to beforepme batty 8-15-94
this k day of dt ?4 L_
19 (i4-, A D q
?,,JL . J h1tA e
Prothonotary V
c-
In The Court rr C=rnmon Flees c:T Cus.::.::t -%=nd ; , P nrsyhvartic:
Cynthia G. Jonon
'i S.
Michael A. Jnnon
lo. _'14-±024 Civil Tenn a
tiow July 25, 1994
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Snect:I at CL._..erlsed Cauap, N.
A ndavit of Se.-ace
low August ± 94 -_ 12:20 O' 'eel P ?rL ,^- ed
_G wits' Order/ ComplaLrt
lroa Michael A. Jones, lxxrsonally _? -
it _ Ilis Work Place - Loveshaw Corp. , South Canaan, Po:
by ancn; to Him, personally _
I
znd ^, mown to
h
c•ov of __ a r-al -_ Qxsicr/ Q=l int _
So ar_swc-",
Stanley Itudrmicz, Deputy Sheriff
scr._z of Wayne County. ?a.
William M.Illuff
ccSTs
Swan and rtcsc:eed mere
_: •::. day of __
SEXV-IC S
!o_ Jf - 1GE
A.MMAVIT
?1w1.,.? ?• TWAplaintiff
V
t
(.y/?t h " Defendant
tIN THE COURT OF COMMON PLEAS OF
tCUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION - LAW
:NO. ` 1+LJv3L) CIVIL 19
:CUSTODY/VISITATION
ORDER OF COURT
AND NOW, this upon consideration of the
attached complaint, it is hereby directed that the par?les and
their respective counsel appear before I4uLr t t 61 f . Y N ?y ,
the conciliator, at Lt" (?.m .T- U.4? bw?•?
on the ?day of , 19 , at Al-
M. . fo a Prehearing 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. Either
party may bring the child who is the subject of this custody
action to the conference, but the child/children's attendance is
not mandatory. Failure to appear at the conference may provide
grounds for entry of a temporary or permanent order.
FOR THE COURT:
Custody Co ciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO , ? TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, FOURTH FLOOR
CARLISLE PA 17013
(717)240-6200
,
duc 7!? 2 N4 PM '95
ru,? , ? ?r.N,;afir
zr,
I
RAYMOND W, RERRARIO, P.C.
ATTQ11 ISY-AT•LAW
SUIT[ 828, SCRANTON LIf[ 11UILOIN6
876 6?NUC6 BTBBBT
SCRANTON, P[NNBVLVANIA 16807.1816
'RLBM MIts 17171663-7674
?Ax, 17 1 71 663-7640
AUO 1 /, Iggi " . O
MICHAEL A. JONES,, I IM THE COURT OF COMMON PLEAS
Petitioner I OF CUMBIRLAND COUNTY
1 PENNSYLVANIA
Vs 1
/ CIVIL ACTION - LAW
CYNTHIA O. JONESO t CUSTODY
Respondent 1
1 94-4024 CIVIL TERM
911/1/9111 1119111 i//19111111111111:1 M 99:111: 11 t1111111111111111
Respondent Cynthia A. Jones is hereby ruled to show cause,
if any she may have, why the special Relief sought by Petitioner
Michael A. Jones should not be
RULE RETURNABLE the
1995. Hearing to be conducted
, 1995, at
of the Cumberland County Court
granted.
_ day of
1
on Vhe
M.
,?oute, Carlisle,
_ day of ,
at Room
Pennsylvania.
MICHAEL A. JONES, I IN THE COURT OF COMMON PLEAS
Petitioner t OF CUMBERLAND COUNTY
t PENNSYLVANIA
vs t
t CIVIL ACTION - LAW
CYNTHIA O. JONES, t CUSTODY
Respondent s
t 94-4024 CIVIL TERM
tettttstatssstis18:tts:ttsstat:istssastest1ttts:sasttsesttttetett
NOW CONES PETITIONER MICHAEL A. JONES, through his ATTORNEY
RAYMOND N. PERRARIO, and requests the Court grant Special Relief
in custody. The following is alleged in support:
1. Petitioner (P) is Michael A. Jones, who is an adult and
competent individual residing at Box 318, R.D. #2, Waymart, Wayne
County, Pennsylvania 18472.
2. Respondent (R) is Cynthia G. Jones, who is an adult and
competent individual residing at Box 100, 219 Front Street,
Boiling Springs, Cumberland County, Pennsylvania 17007.
3. The parties have joint physical custody of 3 minor children
namely Christopher Jones, born 6/24/88, age 7; Brian Jones, born
5/14/91, age 4; and Rachel Jones, born 10/25/94, age 10 months.
4. An agreement of the parties was ratified by Judge Harold E.
Sheely on 8/4/94.
1
5. The children primarily reside with their mother Cynthia G.
Jones in the residence of her parents, Leo and Audette Gelinas.
Also residing at the residence and working at the residence is
Michael Gelinas, brother of the Respondent Cynthia G. Jones.
6. Michael Gelinas has been involved in at least one previous
occasion where he has improperly assaulted a young boy and is
believed to be a pedophile.
7. This information was obtained by Petitioner Michael A. Jones
in November 1994 and promptly conveyed through counsel to
Respondent Cynthia G. Jones so that adequate protective measures
would be taken to assure that Michael Gelinas does not have the
opportunity to be alone, unsupervised with the minor children.
8. the Respondent gave vague, general assurances that the
children would not be left alone unsupervised with the minor
children of the parties.
9. Since said confrontations in November-December 1994, the
Petitioner Michael A. Jones believes that the children have been
left alone in the charge of Michael Gelinas and that Respondent
Cynthia G. Jones has not implemented any safeguards to assure the
safety of the parties, minor children.
Petitioner Michael A. Jones respectfully requests
the Court grant the following special relief in the best interest
of the children:
2
1. That primary physical custody be changed to be with Michael
A. Jones until Respondent Cynthia G. Jones is able too
(a) present proof to the Court of a new residence away from
the home and work place of Michael Gelinas or that Michael
Gelinas no longer is employed, nor resides or regularly
visits the home or building where the partieso minor
children primarily reside; and
(b) that the Court grant such other relief as it deems just
in the best interests of the children and the parties.
Dated: I7
RAYMON . FERRARIO, ESQUI
Attor for Petitioner
Micha 1 A. Jones
Attorney I.D. / 35096
Scranton Life Bldg-Ste 528
538 Spruce Street
Scranton, PA 18503
(717) 963-7878
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CYNTHIA G. JONES,
Plaintiff
V.
MICHAEL A. JONES,
Defendant
t IN THE COURT OF COMMON PLEAS OF
t CUMBERLAND COUNTY, PENNSYLVANIA
t ?
t NO. 94-4024 CIVIL TERM
t
t NO. 94-6677 CIVIL TERM
t
t CIVIL ACTION - LAW
l ORDER
AND NOW, this •1 r day of MARCH, 1996, Michael Jones'
petition to transfer venue of this action to Wayne County is
DENIED. Cynthia Jones' petition for special relief is likewise
DENIED. However, Michael Jones is ordered and directed to resume
mortgage payments on the marital real estate immediately and to
continue payment each and every month until the property is sold.
Finally, with regard to the custody transfer issue, it is ordered
and directed that from the beginning of Daylight Savings Time in
the Spring to the end of Daylight Savings Time in the Fall, the
parties shall meet halfway to exchange the children when they are
returning from their father's care. At all other times, Michael
Jones is responsible for transportation. Also, Cynthia Jones is
ordered and directed to work with Michael Jones in order to
facilitate a satisfactory arrangement for picking up the children
on Fridays in the event that Michael Jones cannot take time off
from work.
Ruby D. Weeks, Esq.
For the Plaintiff
Raymond W. Ferrario, Esq.
For the Defendant
By the Court,
-c<.4 T
c
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Harold E. Sheely, P.J.
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CYNTHIA O. JONES, t
Plaintiff t
t
V. t
t
MICHAEL A. JONES, :
Defendant t
t
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-4024 CIVIL TERM
CIVIL ACTION - LAW
NO. 94-6677 CIVIL TERM
Before the court are two petitions: the petition of Cynthia
Jones (Wife)for special relief and the petition of Michael Jones
(Husband) to transfer venue in this case to Wayne County. We are
also called upon to settle a custody dispute about transportation
that could not be agreed upon in front of the custody
conciliator. We held a hearing on January 3, 1996, from which we
made the following findings of fact.
FINDINGS QF FACT
1. Husband is an adult male, 33, who resides at Box 318,
Rte. 2960 Waymart, Wayne County.
2. Wife is an adult female, 30, who resides at 219 Front
Street, Boiling Springs, Cumberland County.
3. The parties married on April 19, 1986, and separated on
May 2, 1994.
4. They are the parents of three children: Christopher, 71
Brian, 41 and Rachel, 1.
5. The major assets of the parties are the funds
contributed by Husband to his retirement plans during the
marriage and the jointly owned marital residence located at 1127
Black Bear Road, Hamlin, Wayne County.
NO. 94-4024 CIVIL TORN
6. Husband is employed by a subsidiary of the Illinois Tool
Works in Wayne County, earning approximately $32,000 per year
gross.
7. He is also an officer in the Pennsylvania National
Guard, from which he earns approximately $9,000 per year gross.
8. Wife is not employed, although she is a college graduate
and certified teacher.
9. Husband pays $287 per week in child and spousal support.
10. Under the current custody order, Wife has primary
custody of the children, and Husband has them for two weekends
per month.
11. It is, at minimum, a three hour trip from Husband's
residence to Wife's residence.
12. At the beginning of the current custody arrangement,
Husband would make the six-plus hour round trip to pick up and
drop off the children on his weekends.
13. Lately, the parties have been meeting halfway to
exchange the children on Sunday of Husband's weekends.
14. Wife does not own a car and must depend on her parents
for transportation.
15. On Fridays of his weekends with the children, Husband
must leave work early in order to pick up the children on time,
and he has indicated that he may not be able to continue to do
eo.
2
NO. 94-4024 CIVIL TERM
16. Wife is afraid to be alone with Husband because he has
been verbally abusive and physically threatening to her in the
past.
17. The mortgage balance on the house is in dispute, but in
any event is in excess of 450,000.
18. The parties have attempted to sell the house, to no
avail, and could not come to an agreement in order to facilitate
rental of the house.
19. Mortgage foreclosure proceedings have been instituted
by the mortgage holder, L.A. Hank.
20. On November 26, 1995, Husband disciplined Christopher
by spanking him through his clothes.
21. A photo taken the day after the spanking indicated
severe bruising on Christopher's buttocks.
First, we will address Husband's petition to transfer venue
of this action to Wayne County. Husband contends that this
action should be transferred to Wayne County because, among other
things, the parties' jointly owned real estate is located there
and all witnesses related to his employment and earnings are
located there or in that area. Wife responds that this action
has been properly filed here and should not be moved.
We note initially that Pa.R.C.P. 1006 states:
(e) Improper venue shall be raised by
preliminary objection and if not no raised
shall be waived...
3
NO. 94-4024 CIVIL TERM
In this case, Judge Bayley of this court previously dismissed a
preliminary objection based on venue. Thus, the venue issue has
been decided, and a later petition to transfer venue should not
be considered. However, even if we were to consider the
petition, it is clear to us that venue in Wayne County is as
inconvenient for the Wife as venue in Cumberland County is for
the Husband. Furthermore, the testimony adduced at the hearing
contained no information that would compel us to assail Judge
Bayley's decision. The petition to transfer venue is therefore
denied.
Next, we shall consider the custody/transportation issue.
As it stands now, Husband has a round trip in excess of six hours
when picking up the children. The trip time is cut in half on
the Sunday trip to return the children when the aforementioned
exchange is made halfway. Husband desires to use the halfway
meeting point on both trips. However, Wife has indicated that
the halfway exchange on Sundays is not feasible for her because
her father will no longer accompany her and she refuses to meet
Husband alone.
The hearing testimony indicated that the halfway exchange is
made at a Mc Donald's restaurant at the Frackville exit of
Interstate 81: a decidedly public place. Wife, however, fears
abuse if she meets Husband alone. Husband states that since his
employer has changed, he cannot leave in time to pick up the
children in Boiling Springs at 600 P.M. on Fridays. Therefore,
4
NO. 94-4024 CIVIL TERM
Husband avers, the halfway meeting point is not only convenient,
but necessary.
Both Husband and Wife are credible witnesses. However,
since they could not agree on this issue, we are forced to forge
a compromise for them. We find that the halfway meeting point in
Frackville is a good system. However, we are equally cognizant
of Wife's fears. Therefore, we will fashion an order directing
that the halfway meeting point shall be utilized, on the Sunday
return trip only, from the beginning of Daylight Savings Time in
the Spring until the end of Daylight Savings Time in the Fall.
Thus the exchange during that part of the year will be made in
daylight in a public place. We are also fully aware of Husband's
difficulties with work and his long round trip. We therefore
order and direct that Wife shall give him as much leeway as
possible in arranging times to pick up and drop off the children.
Additionally, we note that we would be willing to consider a
change in the above arrangement to require a halfway meeting on
both trips if it is shown that Wife has obtained her own
automobile.
Finally, we will address Wife's petition for special relief.
The petition contains two counts, one for mortgage relief and one
to compel Husband into psychological counseling. Regarding the
mortgage payments, the evidence at the hearing indicated that the
mortgage has not been paid in about six months and that
foreclosure proceedings had been instituted by the mortgage
5
NO. 94-4024 CIVIL TERM
holder. Because neither party was sure about the exact amounts
at issue, Husband's counsel represented to the court that he
would obtain up-to-date information about the foreclosure
proceedings. He has provided the court with that information in
a letter dated January 17, 1996. The letter stated that the
mortgage on the jointly owned real estate has been in default
since July 1, 1995. As of January, the principal, interest and
late charges due amounted to $2,851.80. The mortgage balance is
approximately $54,000. The present attorney fees for the
foreclosure proceeding are approximately $500 plus an additional
$200 for filing costs and service fees.
The holder of the mortgage, L.A. Bank, has assigned the
mortgage to Freddie Mac. The assignment, according to Gary
Lavelle, Assistant Vice President of Assets for the bank, and
Paul Horger, counsel for the bank, has greatly limited any
discretion that the bank would have had in dealing with this
foreclosure. Lavelle and Horger indicated that, in order to
satisfy Freddie Mac, the arrearage would have to be paid current
within three or four months. Lavelle also stated that it is
unlikely that Freddie Mac would accept a rental arrangement,
because that would neither pay the current debt nor take the
property out of foreclosure. Furthermore, Lavelle and Horger
both stated that an arrangement whereby the property is sold
would be infinitely preferable to any rental scheme.
On January 24, 1996, the court received a response letter
6
I A.L.
NO. 94-4024 CIVIL TERM
from wife's counsel. The letter states that the principal
payment due as of January 22, 1996, is $50,776.30, and that
interest and late fees amount to $2,971.33. Wife agrees that the
attorney fees for the foreclosure are $500, but disputes the
costs associated with foreclosure. Upon speaking with Horger and
Lavelle, Wife's counsel learned that any rental scheme, to be
acceptable to Freddie Mac, would require a rent payment of $1100
and is therefore not feasible. The letter from Wife's counsel
also indicates that Wife has re-listed the property with Century
21 Real Estate for $60,000, which she wishes to reduce to
$59,000.
In her petition, Wife avers that her only income is the
support she receives from her husband, and that she has no way to
make current the mortgage payments. She desires an order from
the court directing the husband to make current the mortgage
payments in order to prevent foreclosure. Husband represents
that he does not have the funds in reserve to allow him to make
the payments.
Before we resolve wife's petition, we must note that it is
not our custom to conduct the business of this court through
letters from counsel. If counsel had come to the hearing
prepared to examine the real estate issue, we would not have to
proceed in a manner that puts a severe strain on the court's
time.
7
NO. 94-4024 CIVIL TERM
We will not order Husband to make current the mortgage
payments at this time, because he cannot. We will, however,
order and direct that Husband resume the mortgage payments
immediately and continue paying until the property is sold. The
second count of Wife's petition for special relief seeks to
compel Husband into psychological counseling because of the
spanking incident on November 260 1995. The evidence, including
a photograph of Christopher's buttocks after the spanking, showed
that the spanking was excessively severe. We cautioned Husband
at the hearing, and reiterate here, that any abuse will not be
tolerated, and will be dealt with swiftly and severely. However,
since the testimony reflected only one incident, we will not
direct psychological counseling at this time.
ORDER
AND NOW, this day of MARCH, 1996, Michael Jones'
petition to transfer venue of this action to Wayne County is
DENIED. Cynthia Jones' petition for special relief is GRANTED in
part and DENIED in part. Michael Jones is ordered and directed
to resume mortgage payments on the marital real estate
immediately and to continue payment each and every month until
the property is sold. Finally, with regard to the custody
transfer issue, it is ordered and directed that from the
beginning of Daylight Savings Time in the Spring to the end of
Daylight Savings Time in the Fall, the parties shall meet halfway
8
r
NO. 94-4024 CIVIL TERM
to exchange the children when they are returning from their
father's care. At all other times, Michael Jones is responsible
for transportation. Also, Cynthia Jones is ordered and directed
to work with Michael Jones in order to facilitate a satisfactory
arrangement for picking up the children on Fridays in the event
that Michael Jones cannot take time off from work.
By the Court,
/a/ Harold E. Sheely
Harold E. Sheely, P.J.'
Ruby D. Weeks, Esquire
For the Plaintiff
Raymond W. Ferrario, Esquire
For the Defendant
told
9
9
RAYMOND W. FERRARIO. P.C.
ATTORNCY•ATTLAW
SUITE 520. S'?F A.NTON UPE SUILDINO
539 SPRUCE STREET
SCRANTON. PENNSYLVANIA 1 9803 1 9 14
T9LEPHON61 17 1 71 843.7678
PAM, 17171063.7990
• I
CYNTHIA O. JONES, I IN THE COURT OF COMMON PLEAS
Plaintiff I OF CUMBERLAND COUNTY,
t PENNSYLVANIA
VB s
t CIVIL ACTION - LAN
MICHAEL A. JONE80 t IN DIVORCE
Defendant e
t 94-4024 CIVIL TERM
$IIIII19ItsitsIsIs:1191111tsssltl198111Itsis$IifItlists :IIIstlist
PRE-TRIAL STATEMENT IN ACCORDANCE WITH
PENNSYLVANIA RULE OF CIVIL PROCEDURE NO. 1920.33ib)
I
AND NOW COMES DEFENDANT MICHAEL A. JONES, through his
ATTORNEY RAYMOND N. PERRARIO, and submits the following Pre-tT)rial
Statement in accordance with Pennsylvania Rule of Civil Procedure
1920.33(b):
1. List of Assets: See Inventory and Appraisement and
attached documents.
2. May call experts pertaining to the value of the Pension and
as to the valuation of the marital residence. Defendant is in
the process of obtaining those documents.
3. Witnesses: May call Michael A. Jones, realtor, pension
evaluator. Michael A. Jones reserves the right to call such
other witnesses as he deems appropriate in the course of
preparation for trial.
4. Exhibits have been attached. Michael A. Jones reserves the
right to attach updated pay-off notices from various creditors
and banking institutions as to the respective liabilities of
payments of the parties. Michael A. Jones also reserves the
right to add such additional information as appropriate for the
updated valuations of the Loveshaw Employment Benefits and any
additional information provided by the Pennsylvania Army National
Guard pertaining to the valuation of the pension.
5. Incomes The Income and Expense Statement of Michael A.
Jones is attached hereto and incorporated herein.
6. See Income and Expense Statement attached hereto.
7. A copy of the Pension and all related to said Pension are
attached hereto and incorporated herein. Michael A. Jones
reserves the right to add such Pension valuations as may become
necessary.
8. Counsel fees: Michael A. Jones reserves the right to attach
documentation pertaining to counsel fees should that issue become
relevant and should the Master specifically request that
information.
9. In evaluating the Inventory and Appraisement of Cynthia G.
Jones, Michael A. Jones believes the following valuations to be
disputed: (to be completed after Michael Jones' review of
Inventory and Appraisement of Cynthia G. Jones)
10. In addition to those marital debts specifically listed on
the Inventory and Appraisement, Michael A. Jones reserves the
right to supplement with the evidence of payments toward the
marital debts and of the mortgage since the date of separation.
(Mike is to include to us a list of all of his payments of
marital debts since separation)
11. Proposed resolution of economic issues is as follows:
Michael A. Jones proposes, without pre udice to his position
at time of hearing that the division of marital assets will be as
follows:
(a) Cynthia G. Jones would receive sole right, title
and ownership of the marital home, subject to all
liens, mortgages and obligations outstanding against
the property including mortgages and taxes.
(b) Cynthia G. Jones would also receive the 1990
Subaru Legacy as per her lease, and would assume all
responsibility for said lease.
(c) Milico Life Insurance Policies would inure to that
person whose life is insured. All responsibility would
go to that person for any future maintenance of said
policy.
(d) Michael A. Jones would have all right, 'title and
ownership of the 1988 GL Subaru station wagon, together
with all liens and encumbrances against said vehicle.
(e) Michael A. Joneu would have all right, title and
ownership of his 401K and any and all other employee
benefits that have been accrued by him.
(f) Michael A. Jones would retain Bole right, title
and ownership of his National Guard Pension, if and
when said Pension exists.
(g) The personal household assets have already been
divided between the parties.
(h) No alimony would be paid.
(i) Due to the fact that the marital bank accounts
have already been withdrawn,' the proceeds of those
accounts would remain with that person who currently
has possession of those proceeds or accounts.,
Dated:
RA M N W. FERRA IO, ESQUIRE
Attor ey for Michael A. Jones
Scra on Life Bldg-Suite 528
538 Spruce Street
Scranton, PA 18503
REt CYNTHIA G. JONES V8 M{CNAEL A. JONES
JONES' MARITAL ASSETS
as of 10/2QjLj
House & Mortgage, etc. -0-
National Guard Pension
Travellers
Loveshaw 11,550.65 as of 10/95
Prudential Employee 18 mths x 4.3 x 18
Contribution
Marital Debt as Of 5/20/94
(12 Creditors)
-9-
2,653.90
8,083.85
10,000.00
1,393.20
(10,816.77)
Nat Marital Estate 40,920.00
Ef
%
RETIREMENT OUESTIONHAIRB
The Lovashaw Corp.
ATTHI Benefits Administrator
Route 296, Box 83
Southcanasn, PA
1. Participant's Namoe MICHAEL A. JONES
' 2. Saxe HALE
3. Date of Marriages 4/19/86
4. Date of Dirthe 2/28/62
8. Date of Separatlone 6/2/94
6. Date of Hirst f 1, pIfr `/
7. Spouee'o Date of Birthr
8. Deltas of Plan Participations
9. Total No, of years oervlce credited to amployea in plan on 4/19/86 i
I 6_/2/94 including all military aervice credit and sick leave
eredite
10. Military service credit for retlrement purposaset Z.f.
' 11. Length of Military service and dotage
12. Amount of nick leave credit for retirement purposess -& n
13. A. Have any voluntar contaibutlone been made by participant to
retirement plan? . dNtr If so, when and how much?
B. Does participant have option to pick up of military time?
What will be the coot? _ Nd
Indicate how calculatede
f
14. Is any deposit due or ar any paid to receive retirement credit for prior
military service? _ IUrI? If so, indicate how much was recilv¦d and
dates of receipt.
15. Normal Retirement Dates rd op f 44,
16. What are the ratir?m nt plan optio ¦ apd at wba44 age Ore these available
to Participant? w e1C ( U[A'3 1 /1 ce.? 17..
17. Benefit to be valued jllf of -4[1!/86 6/2/!4 and date of hire
and at presents 1 ? `
.18. Vested Accrued Bonet as of 4/19/86. 5/2/94 and at pnsente -'•?
. e6
µ ?
MEMORANDUM FOR: Yvonne Perri
FROM: Mike Jones
DATE: 25 August 1998
SUBJECT: Retirement Questionnaire
Yvonne,
Please find enclosed a retirement questionnaire that is regjira to be
completed by the Loveahaw Benefits Administrator.
My wife and I are currently going thru divorce proceedings and this
document is required.
Please complete and return the copy to me so that I may forward to my
attorney.
If you have questions, please feel free to discuss with me.
Thank You
Regards,
Mike
L.OVESHAW
an MY Company
Little David Products Division
Route 296 Box 63 South Cenoan, PA 18459 717.937.4921 FAX: 717.937.3229
October 17, 1996
Ruby D. Weeks, Esq.
Ten West High Street
Carlisle, PA 17013
Dear Attorney Weeks,
Enclosed you will find the completed Retirement questionnaire
forwarded to me concerning one of our employees, Mike Jones. I found
the questionnaire confusing, but I have tried to supplied the answers
with the help of the information I have in Mike's file.
My answer to most of the questions is "Not Applicable" due to the fact
that The Loveshaw Corporation does not ofrer a retirement or pension
plan other than an employee/employer participation in 401K.
I understand that Mike Jones has already furnished or is in the
process of furnishing information regarding his 401K and the amount
of earnings credited to him. If there is other information you
require concerning the 401K or any item on the questionnaire, do not
hesitate to contact me at 800-962-2633 extension 3006.
Sincerely,
Yvonne Perri
Human Resources
cc: Mike Jones
Raymond W. Ferrario, Esq.
?r9dM
l,ut"n r" F%••y•
RE1 Policy No. 009PF07090
Insured, Illohael A. Jones
Door Mr. ,lonca:
Although we sinnorely rogrut that you find It necuusary or advisable to
terminate the shove numbered polloy, our chock i'or 41,749.30 irl IL11
eottlument of alI clalam In ounl11eduoted ction lrlth thle polloy la analosud. A
surrender ohargo of 4360.06 was as apocifled in your Pcltoy,
Even though this poliny has heel terminated, wa would 111<u to tnke this
opportunity to Lhank you I'or yawl, pact bualness and to offer Our durvlocs
for your oontinued goodw1 , 11 slid pRtvouaRQ.
11' we may be of Rny furthar sasl^,tanna, plaaau let ws know.
$incuruly, ?LLn
'?u. Kcal./.?
r1 AT L'urlua
Cuntomur Survloc 11aprea0ntrwtlva
0.1°1111,`1111 YLfC
rOR TUU 411000 LIPa.
LAMAa T.IPR 11I511RANIOR 1:OMPAIM
r, O. nOx 110, IAC\3017, M! .39305
009PE07090
VOUCHER 110. 0-131223
SEP. 13, 1994
AMOUNT
"""'S1,749.30"
INSURED/C LAIMAIITMINIOR
01SCAND POLICY
187699 OII,OM MNMIN
IAtL11EPOLICY 0107899
?j IIIEHn DEPOSIT .00
III BALANCE .00
IItT PROCLI:IIS 1,749.30
.r.
In1.I v; n0
an ecu Dux eI L L.M4r 91110110 0ROWN hflr, a14F.19 ODA PA1L,6Br
111.V Na s4 Lax a9VItl 11,11, ol'or1 •,aLO
11 ?c`l1Y ar Itte6ll-? 66
'
THIS SOLID 1:11O OLI WHIM 1906
I 5
Hiuhael Allan Jones
nr 11 nox 139
Lake Ariei PA 10436
IAIAR Irllt 1111111AHw:9 WHI'Alq
F,e. 1011 110 Joetoon, w/ 39205
Yhonol 00o) 2111112
Ur?/
September 1110 1994
In1
?• I. to 01
,(WE LOVESH W COIIPORATION
0/0 PMFS
P,O, UOX 16040 a New nln6wIck, N.) 00008
?7 r
I,RIILIIIILII?,LIL IILIIII?ILIL??I,I,IL„IHIIIdLI
NICHACL A JON 11
P.O. BOX 405
IIANWIN PA 111: •Olbl
TIouiNNG PBnIOD 10/01104 TO 12/01/04
ACCOUNT NO, 17064.4000 I
111 AN NUMOEN. 4490
LOCADON 0011011110111
P1100PNNAI. nEV C01EnY1 SIEIN
,
l ELEI'NuIIE NUMNL'n 16001 364-1236
INVESTMENT AL OCATION
FUND SALARY MATCII PROFIT CLOWN0
SYMBOL DEFERRAL BHARINO PnICI
GOVT MM OVMF 20% 20% 20'r. 1.00
UTILITY A PUTA 05% 06% 26% 6.27
EQUITY A PEUA 2014 20% 20% 1944
OIA OUAR 26% 20% C6% 1100
UYILITY 6 PUTS 04: 0% 01: 0.20
EQUITY B PEQB 0:4 0% 014 1014
TOTAL 100% 100% 100%
VESTED PERCINTAO 100% 100% 0%
YOUR TOTAL PO
I TFOLIO VALUE: $8,900.OB
YOUN TOTAL TED VALUSi $0,089.06
THE INTEI EST RAIE APPLICABLE 10 1090 CONIHIOUTIONS, AND ALL. PRE 1000
CONTRISI IONS, TO 1HE OLIAHANTEED INTEREST ACCOUIII WILL BE 5.00%. THIS
RATE I6 I FECIIVE FROM JANUARY I , 1005 THR00011 OLCEA1BEli 31, 1006. '
FOR 40114 ACCOUNT INFOnAlAT16N, TnY THE NEW VOICE nESPONnF 9VS1EM • VHSI
VMS 19 A AILABLE 24 HOJn9 A VAY AND IS CONVENIENT 6 EASY 10 USE. CALL
1.000.07 0727 6 FOLLOW THE STEP•BY-STEP INS1811CTION9.
ON SELL11 0 YOUR CLASS B On CLASS C SHAHES, YOU MAY PAY A SALES CHAnOE.
FOR THE 1HAR0E AND OTHER FEES, SEE THE PnOSPEC'TOS,
PMFS CLIENT SERVICE TEAM DESIGNATED TO SERVICE YOL)n COMPANY'S PLAN
CAN 6E nEACHEO AT 11110 TOL1. FnEE NOMI)ER;
1.600.040.4015
FROA1 8.00A.M. 'TO 0.00P,M, EA0IEIIN TIME, MONDAY THROUGH FRIDAY.
I ? (
I
Lira IIIII III IIII II I III Iia
,NJ .gill. ,n11M1:, ,
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11
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VIDORSENENTIEXTFINXIM AUTHORIZATION
to LISTING AORL14NLNT
RELLER I fl. (. 1
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ADDREss I 81 / 4/.') I
DATE1,
RXI Propgrr.y Addr•eu111 T-..1 _Y,) Ill'rk'?,
Llnting INCEP'rIou Dato1 "'-'-
current EXPIHATION DLItv1 ?._....
ORION2AL Lint Priaal n
CURRENT Lint Pricvl ,y-
..._-?i_Lrt:fal
It 10 hereby agraod 0110 unrlrzrWtood that the wUOV1v-ralwrrltdW
IIatinv ohnII b0 further nnelorood/a)lt'uudvd en IollowaI
1, EXpir•atlun dato aha.ll be LX-1-L•-NDED toe
2. CURRENT Lint 1"r7ov w111411 bu DECNkASED Lu i ?)yroo
or INCREASED to
J. Other changeu/notations (PLIliASE SPECI°Y) I
All other termer 0nd Conditionu a1d stated in original Contract
for Solo/EXOhanya of Raul Entato Agreement (i.e. Liating
?ggrga enG) shall remain in full for-cc arui wffvaL,
ColdwR11 Danker Commonwealth,
S?;LLER) RE AL'I'UNS r
(Lrs'ritiC3 'Ai)ENT)
- ??
(GELLER)
An Indppendlnlly ()wuPil 11111 Opd4ded )Irouxt ,11 Coldu,!II 11 mo 111vv,Ipn Gdl A141AII"i luf ?? nH®
TOBVIIANNA AUNIV ill-Alm
FEDETAL CT11"Iff UNION
101110AIlhA ANI11 0IP0T
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FfB11 ur,I l,'1, 1,r1A x111;11:1 AL'Ulll YU11O 1ILLC114UmS TAANUIENS
ACCOUNT NO. 19077 PA41 1
SOCIAL 6ECUNITY NO. 177.64-6669
STATEMENT PERIOD
FROM 10'01.64 TO 17.71.94
DATE OtSCR10TAON . „AN010". 1A?.IVK71 DATE DESCRIPTION AMOUNT 6Ak"q.
10-01 PREVIOUS DALANC! 6178 17'JI NF.V 6ALANCL 0.77
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ALVIUEL JCACCOUNT N0, 4044 PAGE 1
R14 1 UO)! ON CAROL EJDIIEI SUCIAL INMINITY No. 174-41-4444
Ii 1
LAKE ARIIL IM 14420-0401 STATEMENT PEAIOO
It IO-01-04 TO 12-31.01
------------?m?
-oATR , PISSITPTION.... _ AI DfIT 0AI.ANGl DATE D16CNIPTION AMOUNT 4ALANCI
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TIC PLAN 111IMBERI 12777 TIFITHF AN iCO I,1D '(heTraveleri'''
LLOCATION 001 IT PL iOR EMP.CWers
AS OF 12/31/1994
MICHAEL p, 10IIE5
RR N1 BOX E9
LAKE ARM
VA 111436
50C.SEC,1101 178.54-4839
ACTIVITY FOR lilt: PERIOD 09/30/94 TO 12/31/94
?F1FLaxe? Accnlurs E2XEp ..---_-----
PRIO IIOALANPE 5,346.98
EIIII BALANCE 01.3
5,4440.33
3
COMFAILY A"GLI d
PRIOR BALANCE 21586.50
EE 11 11BALANCE 49.02
2,635.52
I
SUMMARY OF ACCOUNT SINCE INCCI''TIOII TIIRII 12/31/1994
snUr
tee CorrtR"BUT10N3 nualanu.umm CARNIN05 CURWIT BALANCr
COMPANY ASK 3,205.43
1,565.41 0.00
6:00 21242.90
0'/0
1
11 5,448,33
TOTAL AL
T
4,770.84
0.011 1
.
3,313.01 2,635.52
81083.85
RE 107 AFTER-TAX CONTRIBIITIlN13 4 -- O _06 ?POST_116 AFTER-TAX CONTRIOIIIIONS 4 3403.43
QUESTIONS HOARDING YOUR Af.CO1NlT SIIOIILD BE DIRECTED TO WHIR FLAN ADMINISTRATOR.
TRAIISAMOUS AFTCR 12/31/1994 1111.1- BE 011 YOUR NEXT STAI'milit.
19
III At IOU
All
IOI,RY. r6 ±
CONMACT ron SALE on EXCI IANGE OF REAL. ESTATE
RESIDENTIAL LISTING FORM
APPIIOV1a FOR UbE BY PANIICIPANTS OF 7119
C,REATCR 68)IANTON h+lll.TblIB 16ERVICL•
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- m 0Unaloalallah of ynrlr accoVlenro of the farm, 111 this wauln0ld All, of yullt pl'JIb11111) lids. 10 offet it), sale, also to obdeswor to fell my
pro ally florulnslist du'I1nbn11, to aJ.urlllt lily aGilla 111 uncn m111nof as yvO AA) Jybnl AOlia,hl aerul I... l0 Ynllll In 11110 bs1,All Yllonl 01 ydllf
Org4waidinn in lie wool illy ow a a of built 1041.IPur04y 41v 0a11l14f Yld 1'111 f-r U01 WJ V1 /Ay munlhe(rom 11, basis of ibis fhalnn ant file
bYrlullvy It4nl And sidbrn-l) to uull ins pI tI1.1r1y hUlunl,11101 JY4?.r111YJ lur Inn Ill .1. uW tV•. H Ina Ill-ll9 hI1 VHnall ar out lonh.
ITUIII HER AtiI1rDIIpUtI ltIIi GL)ll:illlF.IlAil(III HEHI IN LILNIIi1HLll ail VA1 VYIUA QUAIM1441ON Qa YLlIG4N14 IUt
fHEUHUnS 8ALIC P111114,W1 IL I Nth 400I t 5ALh ti AIAC.E 4y) GU Ill alt 011111 All 'l UUHER I'In50fv All lulu f 1 Iri1.110( IN PAY 4LHAL1UWIN THU I CIVAS IILIIe IH e1, rLll 1,111i Ili 111k16 oil lIr ON ANY OTI hill l Lllelh AOCI VI'AIA I, 10 HIE
bJCh compullsallon /hall alto be wn if till pfnpu Hy -4 Sold, GJnrlt y0, "r u11wlV,les tlwillarllJ within a VIJIYnIIYII 00110401 r .•'•. (.11?
nlya allul (hA Isfmhnlllon of Ihl$ AuMU1Hy till lily y.IMflwl 111.110,1) to an) of la % till onom ag Gal MAI had Iludilllallunl Pilot 10 final IAf mllpllon,
plundln 1 have 4r.stved nobcl tit widlno of Such nogOl.4 a el f, Incllnllny Ina ARm.4 nl p14AImah V1 PlI chalYq. Ldo1 t of upon bpnlnpmn al 1010
Atootronl of any uylunllon it 0It0I.l Wwavar, 1 ob All not Vy ow jaivid lo Pei, allot aon,p U.I 111-nn it t vYbaLllllllly Y4rslmanl Is sol/fan into win
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And upon Ins paymu11l of Inc Plachlau moony. 1111114 to ..weulty mnl Jtlbn/ IJ 111111111111.411111' 1 wallynly dead ill aonvuyanCa lu Ina /UJ
propurly, IIIU to 114 lrss wild cleat of All 111110 a-.J an,unl Dl In Gtn, 11.11 IuOyu Ci 1010t 101111NnIn1 be Sill 011J
I have bean YJvum1 01 my duly 0, disclose mat Allbl d111C1i ... I Boo Jllhuu allJ 1n4w OI rJ Qropslly 1144014 I.CYp1 as follows.
Otto
I Igrlny 0uthorlua Out. In lecLUl mYUllal prnp61(y NIa1la apuclllad aLOVa 611J e4rlu to InJu-Holly licit and molly nlb10m111ga1M1 lbblllly.
Inchiding cotjnc011o and allurney lobs, caooa l by lily fallwil to diet Ilea occurYiuly Alto C-J1.,Plylul) anynlau0sl landlhunullh6propany Illalmay
alleayl, Ill dlelrWilly.
t)VIA0 the li tm at this uglumnant 1 ni Udh6114e yot. In Accuid 1 Jup.illl to lie AppINJ Bon the puransl0 pfice, and to p(spale lot lily
sl4Nlure, v binding noollm,t Jr op11u1JI agronnionl lot the sale of IAA Saw p14Vur I'/ In my Wolf
Ins agent is ho'll'y sulnuntad 14 place a 'ilu 3010' Sign upon Ilia laid I1t111pit
Owner Is halsfiy ndtll14J and 111111Yf11111114 Intl .11 Ptyt.1111is all a. cYUnl OI I'le Ilsl19e010A at 411 be rvislnlu In SIGN. faf 1110 06114111 of Ilia
pe'llvs In this Iran14,11011 b. awan4nCS wish Ihu Rol kuluu Lw.,,awl; I Bow 0 ill. .:a...luonV: .,fill of ?unnsyiril.
11,14 sdul,my shall till Omdlnll I,poll and tnn.n to VIII Derr, Ill ill Inv hall, 1111l and IilnlnlelrelJrl YIIJ Ieelgnl 01111. rAlpecllvs Pslll.l
YIAtb.
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19. When did participant vest in plan? ???14 A krt yo / /L_( ?tr?LrrutiPa (/?„
20. Are any employer cZ7t_s2 utiona included in (18)? If no, indicate amounts
21. What is the amount of any employer contributions as of 5/2/`94 .
and at present? !, ,/ & C, j)
22. (a) The value of employee contributions plus interest as of AI/I?
and at presents -TT---
(b) Please list amploygpa annual contributions to plan from date of hire
to the prevents
23. List tctal annual earnings for 1996
to the presents
24. Indicate the service factor used in the retirement formula, compute ion,
and set out formula used to calculate monthly annuitys
25. When benefits commence to the participant, indicate requirements for
eligibility to retires
A. What will be the monthly amount of the net annuity under the various
optiora to employse(liat for asch option)?
7 0 h .,,,.1 .sue'
b. What form would this be paid in under the various options available?
(i.e., for empee's lifetime, continued to spousal list for each
option)I N?
s
C
d
Amount of survivor annuity availables _,_
Amount of lump-sum death benefits available and to whom payables _
I
i
,
?I
e.
yes No
No
Are there any limitations as to
include? It so list
f./ Who is currently designated ae beneficiary of any benefits due,atter
death of participant under plan?
L L YL U
s
y.
how to accomplish or what to ,
26. What is the present value as of 6(2,/94 and at present of
participant's retirement account considering employee's military service
credit, nick leave credit, and both the employees' contributions as well
as those of the employer and the interest rate such funds earn?
27. If there were any previous plan(e) since 1995 to which employee
belonged, please indicate information as to each of those planr an
requested above and indicate what disposition was made of employee's funds
in such plan(s) at termLnation.
-10 Ow c« .• e-
-2D. Does participant take advantage of a savings or thrift plan? If so, how
much does employee contribute? Please detail amounts of contributions,
withdrawals, interest accumulated including time from
4/19/86 to present, and dates made, as well as the interest rate of
such earnings.
29. Dues participate hold any share's of stock through an employee stock
option/purchase plan? If so, give details of plan and employee's annual
purchase, sale, transfer, exercise of option from 4/19/66 to the present.
Please list value of stock and amount of stock for each transaction listed
and annual dividends since A.
30. Does employee participate in a 401K plan? If so, 'detail employee's
annual contributions since 4 19 86 and interest
accumulated thereon to date annually.
CO X
. J. . J f T 'l f TI ? _ T
31, Please itemize and give details of any other employee benefits
available to employee from 4/19186 to the present time
giving value amount. Where appropriate, indicate value and dates of
acquisition and/or transfer or terminnt of benefit.
' r? t f
r , ?,
TT r I I r 1
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PLEASE ATTACH A COPY Or THE FOLLOWINGS
NAME OF PLAN(S)
ADDRESS OF PLAN ACHINISTRATOR(S)
SUhMARY PLAN DESCRIPTION(S)
CURRENT BENEFIT STATEMENT AND FOR 19 56 TO DATE.
Date requeetedS 7126195
Dated NeadedS As noon an cosoihle
ATTORNEY REQUESTING#
Date Requesting 7-a&'%'S"
RETURNED BYt ?f vv
Date Returned
i
I
RUBY D. WEEKS, ESQUIRE
TEN WEST HIGH STREET
CARLISLE, PA 17013
(717) 243-1.294
d9 n
TVs Loveshaa Corp.
hi'TN Benefits Administrator
Routs 296, Box 83
Southcanann, PA
COMPANY NAMES /-010J/taJ ) rf!cr0 k(fn
PERSON COMPLETING FORMS YLt Q.9[e pt-d fr
C . • +
STREETS U .+rt rtw l
r,
CITY, STATE, 21Pt _
DATE SIONEDS (tll l'2/ --
Enclosuret Employee consent form.
NA Kt
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r e n!. i A
Ij' lid,
t tAttt t f?t'1 r t.; ?,a t••. f 1? .. r;.
A?r. r np,1) • nl!{?,?!ry rY.t'" { ?: {' rY.?1 .n? ..
Prudential Mutual Fund Services THe CORPORATION j.,
` • ) / 1 . f„
P0160KISOIONEW16RUNOWICX,NJ00400 ?(? ?n .?• 4011K) PLAN
STATEMENT AS 0I
JUN! 24,Y091 .I ivn,?.•I
MICHAEL A. JONES ACCOUNT NUMBER
P.O. 50X 465 170-E4-4037
HAMLIN, PA 10427 LOCATION 04494
CURRENT VALUE AND ACTIVITY
EMPLOYEE ALLOCATIONS
GOVT SEC. TRUST-M.M.
GUARANTEED INTEREST ACCT
EMPLOYER ALLOCATIONS
GOVT SEC. TRUST-".M.
GUARANTIED INTEREST ACCT
ACTIVITY
PBGVM
OPENING SAL 1457.41
BASIC PRE-TAM 46.47
IMF MATCHING 24.25
INVEST RESULT
REINVEST DIVI 7.17
TOTAL VALUE 6637.30
VESTED PORTIO 1537.30
(PBGVM) 20% UTILITY FUND
(CIA) 26X
1PBCVM) 20% UTILITY FUND
(CIA) 25%
IPBUTF) 36X EQUITY FUND
t?SIQF) lox
PRICE 06/26 01.00
PBUTF POF.QF CIA TOTAL
4621.26 1513.62 6674.06 12,366.67
64.61 46,47 60.69 242.34
42.44 24.25 30.30 121.24
(22.26) 5.66 12,06 (4.36)
10.04 .00 .00 17.21
4936.31 1592.39 6677.01 62,743.01
0936.31 1692.39 1677.01 62,743.01
(PBUTF) 35X EQUITY FUND
(?OSQF) lox
015.65 011.75 41.00
CURRENT TRANSACTIONS
FUND
GOVT SEC. TRUST-M.M.
UTILITY FUND
DATE TRANSACTION
04/12 EMPLOYEE PRE-TAX CONTRIB
04/12 EMPLOYER MATCH CONTRIS
04/25 DIVIDEND
05/16 EMPLOYEE PRE-TAX CONTRIB
05113 EMPLOYER MATCH CONTRIS
05/24 DIVIDEND
06/13 EMPLOYEE PRE-TAR CONTRIB
66/13 EMPLOYER MATCH CONTRIS
06/25 DIVIDEND
04/12 EMPLOYEE PRE-TAX CONTRIS
04/12 EMPLOYER MATCH CON711I16
05/15 EMPLOYER ?RI-TAX CON7RIS
05/10 EMPLOYER MATCH CONTRID
06/13 EMPLOYEE PRI-TAX CONTRIB
06/13 EMPLOYER MATCH CONTRI¦
04/26 DIVIDEND
DOLLAR AMT PRICE
417.31 01.00
40.66 01.00
12.31 41.00
013.05 41.00
06.93 01.00
62.32 01.00
417.31 01.00
40.66 41.44
02.34 01.00
430.29 426.15
015.16 416.15
024.23 415.97
412.12 415.97
430.29 415.96
010.16 015.96
410.04 415.77
SHARES TOTAL SHARES
17.310 474.720
0.660 403.340
2.310 400.690
13.464 499.940
6.730 506.476
2.520 504.990
17.314 126.304
4.660 534.960
2.344 537.300
1.476 53.414
.939 53.955
1.517 55.476
.709 $6.229
1.094 ".127
.954 169.077
.637 59.714
EQUITY FUND 04/12 EMPLOYER PRE-TAM CONTRIO 017.31 011.71
1.474 42.696
1111011011111 11111 1111111141
MICHAEL A JONES
P-0. BOX 465
HAMLIN PA 18427-0465
Account Nunltlert 178-54-4839
Plan Numbert 4496
Location, OOOO0OIX)I
CURRENT VALUE AND ACTIVITY _
EMPLOYEE ALLOCATIONS
DOW MM GVMF 20.0% UTILITY 6 PUTS 35.0% EQUITY 6 PEQa 20.0%
GIA GIA 25.0%
EMPLOYER ALLOCATIONS
GOVT MN GVMF 20.0% UTILITY B PUTS 35.0% EQUITY B P[Q8 20.0%
GIA GIA 25.0%
ACTIVITY
GVMF PUTS PEQB GIA TOTAL
OPENING SAL $915.86 $1,787.43 $1,015.54 $1,186.25 $4,900.08
SALARY REDUCTION $46.80 $81.90 $46.80 $58.50 $234.00
WITCHING $23.40 $40.95 $23.40 $29.25 $117.00
REINVEST DIV $6.84 $49.88 $56.85 $.00 $113.57
INVEST RESULTS 4.57- 1.42 20.44 17,29
TOTAL VALUE $992,90 $1,950.59 $1,144.01 $1,294.44 $5,381.94
VESTED PORTION $992.90 $1,950.59 $1,144.01 $1,294.44 $5,381,94
PRICE 12/31 $1.00 $17.91 $12.08 $1.00
CURRENT TRANSACTIONS
FUND CONFIRM TRADE TRANSACTION DOLLAR ANT PRICE SHARES TOTAL SHARES
DATE DATE
- GOVT MM 10120 10120 SALARY REDUCTION $14.40 $1.00 14.400 930.260
10120 10120 MATCHING $7.20 $1.00 71200 937.460
10/23 10123 DIVIDEND REINVEST $2.03 $1.00 2.030 939.490
11117 11/17 WITCHING $9.00 $1.00 9.000 946.490
11117 11/17 SALARY REDUCTION 118.00 $1.00 18.000 966.490
11/25 11125 DIVIDEND REINVEST $2.33 $1.00 2,330 968.820
12/17 12/17 MATCHING $7.20 $1.00 7.200 976.020
12117 12117 SALARY REDUCTION $14,40 $1.00 14.400 990.420
12/24 12/24 DIVIDEND REINVEST $2.24 $1.00 2.240 992.660
12/30 12/30 DIVIDEND REINVEST S.24 $1.00 .240 992.900
UTILITY 5 10120 10/20 SALARY REDUCTION $25.20 $17.93 1.405 100.705
10120 10120 MATCHING $12.60 $17.93 .703 101.408
11/17 11/17 MATCHING $15.75 $17.82 .884 102.292
11117 11/17 SALARY REDUCTION $31.50 117.82 1.768 104.060
12117 12117 MATCHING $12.60 $18.20 1692 104.752
12/17 12117 SALARY REDUCTION $25.20 $18.20 1.385 106.137
12/29 12122 DIVIDEND REINVEST $18.04 $17.98 1.003 107.140
12/29 12122 LT CAP GAIN REINVESTMENT $31.84 $17.96 1.771 108.911
EQUITY 6 10120 10120 SALARY REDUCTION $14.40 $11.92 1.208 65.276
10120 10/20 HATCHING $7.20 $11.92 .604 SS.aaO
11117 11117 MATCHING $9.00 $12.05 .747 86.627
11117 11/17 SALARY REDACTION $18.00 $12.05 1.494 56.121
12117 12117 MATCHING $7.20 $11.89 .606 64.727
12117 12117 SALARY REDUCTION $14,40 111.69 1.211 69.930
??II
SUNNI
PRHS -54100. 12 8 733 1007 1 (1000 Ili 00 1 1455 PP40(1001 PP440121412401414 nnnn(1nnnnnnnn(10(1 n0n1
i
7t
l
THE LOVESHAW CORPORATION
% PMFB
P.O. Box 15040 • Now Brunswick, NJ 08906
1,11 1111, II III IIIIIIII1111III u,IIIII nl,IndlJ
MICHAEL A JONES
P.O. BOX 465
HAMLIN PA 10427.0465
INVESTMENT ALLOCATION
REPORTING PERIOD 10/01/83 TO 12131/63
ACCOUNT NO: 178.64.4538
PLAN NUMBER: 4496
LOCATION: 000000001
PRUDENTIAL REP: CHERYL STEIN
TELEPHONE NUMBER. (800) 354.1235
FUND SALARY MATCH PROFIT CLOSING
SYMBOL DEFERRAL SHARING PRICE
GOVT MM GVMF 20% 20% 20% 1.00
UTILITY B PUTS 35% 35% 35% 8.89
EQUITY B PEOB 20% 20% 20% 13.80
GIA GIA 25% 25% 25% 1.00
TOTAL 100% 100% 100%
VESTED PERCENTAGE 100% 100% 0%
YOUR TOTAL PORTFOLIO VALUE: $7,534,58
YOUR TOTAL VESTED VALUE: $7,534.58
THE INTEREST RATE APPLICABLE TO 1994 CONTRIBUTIONS, AND ALL PRE-1904
CONTRIBUTIONS, TO THE GUARANTEED INTEREST ACCOUNT WILL BE 5.25%. THIS
RATE IS EFFECTIVE FROM JANUARY I, 1994 THROUGH DECEMBER 31, 1994.
8
THE PMFS CLIENT SERVICE TEAM DESIGNATED TO SERVICE YOUR COMPANY'S PLAN
CAN BE REACHED AT THIS TOLL FREE NUMBER:
1.800.848.4015
FROM B:OOA.M. TO 6:OOP.M. EASTERN TIME, MONDAY THROUGH FRIDAY.
I?INIpN?IN?I?IIN
IW MIIC, I,W IIYI \ YW?I, Y„MI MIIW, N.,O„I,YYIYII ,pO,INgWpppNY1
"THE'LOVESHAW CORPORATION
o% PMFB
P.O. Box 16040 • Now Brunswick, NJ 06006
1111 II111IIII1111illllllll 110110 111111110 11611 III 11 Iloilo 11111
MICHAEL A JONES
P.O. BOX 465
HAMLIN PA 164270465
i
INVESTMENT ALLOCATION
FUND SALARY MATCH PROFIT
SYMBOL DEFERRAL SHARING
GOVT MM GVMF 204 204 20%
UTILITY B PUTS 35% 35% 364
EOUITY B PEGS 204 20% 204
GIA OIA 264 264 25%
TOTAL 100% 100% 1004
VESTED PERCENTAGE 1004 100% 04
YOUR TOTAL PORTFOLIO VALUE: $7,735.56
YOUR TOTAL VESTED VALUE: $7,735.56
de ptW V
X ? Utiujt td Services (9
REPORTING PERIOD 01/01/64 TO 03/31/94
ACCOUNT NO: 176.644639
PLAN NUMBER: 4409
LOCATION: 000000001
PRUDENTIAL REP: CHERYL STEIN
TELEPHONE NUMBER: ISM) 354.1239
CLOSING
PRICE
1.00
9.11
13.39
1.00
$
THE PMFS CLIENT SERVICE TEAM DESIGNATED TO SERVICE YOUR COMPANYS PLAN
CAN BE REACHED AT THIS TOLL FREE NUMBER:
1-000-946-4015
FROM 8:00A.M. TO 6:00P.M. EASTERN TIME, MONDAY THROUGH FRIDAY.
.M .1,1\h i\\?Y\YI \ M\\IM Wf1\I M.IY1\?n.w\\I\\1YrYM 1
1 '
THE LOVESHAW CORPORATION
WO PMFB
P.O. Box 16040 • Nov Brunswick, NJ OC906
111111111111111111011116111 1111 111111111 VIII 1
MICHAEL A JONES
P.O. BOX 4E3
HAMLIN PA 16427.0466
i4nl3s?.
ol typ11
REPORTING PERIOD 04/01104 TO 06/30/04
ACCOUNT NO: 176644839
PLAN NUMBER: 4488
LOCATION: 000000001
PRUDENTIAL REP: CHERYL STEIN
TELEPHONE DUMBER: (800) 354.1236
INVESTMENT ALLOCATION
FUND SALARY MATC H PROFIT CLOSING
SYMBOL DEFERRAL SHARING PRICE
OOVr MM GVMF 20% 2075 20% 1.00
UTILITY A PUTA 35% 35% 35% 8.79
EQUITY A PEUA 20% 20% 20% 13.48
GIA GUAR 25% 26% 26% 1.00
.. UTILITY B PUTS 0% 075 0% 8.76
EQUITY B PEGS 01: 0% 0% 13.44
TOTAL 100% 100% 100%
VESTED PERCENTAGE 10075 100% 075
YOUR TOTAL PORTFOLIO VALUE: $8,042.92
YOUR TOTAL VESTED VALUE: $8,042.92
8
THE PMFS CLIENT SERVICE TEAM DESIGNATED TO SERVICE YOUR COMPANY'S PLAN
CAN BE REACHED AT THIS TOLL FREE NUMBER:
1800-848-4015
FROM 8:00A.M. TO 6:00P.M. EASTERN TIME, MONDAY THROUGH FRIDAY.
IM111111
I14.MI0 1y 081 I MWY ?IfW wIIMi IIIMI?IIINIYI, AIMIblerMI
CR. NO. 1:,x777 001
LOVeSHAgEMO?ORRATION TheTravelenT
EMPLOYEE SAVINGS AND INVESTMENT PLAN
JONES MICHAEL A STATEMENT OF ACCOUNT AS OF 03/31/67
IDENTIFICATION NUMBER 178-54-4839
LOCATION CODE QQ1
pp TRANSACTIONS FOR PERIOD 12/31/86 -NRU -03131/87
/87 TFIRU 02/87 141.77
riARNI BUOIQNESBFORC
GS
T VALUE 141.77
*.* **EMPLOYppERRryS RR
I CCONTO f9XIT?ITHRUT/87 56.71
CBRRENNNF VALUE
56.71
I
i
I
OROYER BASIC 1161:?7
1y ??
1 8.4788 15 .4
R CONTRIBUT
AFTER ws I J 4f Or WILL APPEAR ON YOUR NEXT
V
L.
IOR. NO. 12777
THE EMPLOYEE SAVINGS AND
INVESTMNENT LAM FOR EMPLOYEES
THE LID ESHAG CORP.
TheTravelers'r
JONES t MICHAEL A STATEMENT OF ACCOUNT AS OF 09/30/3957
' IDENTIFICATION NUMBER AN
1 54_4839
LOCATION CODE TFIANSACTIQNS FOR PERIOU 06/3D/1987 TNRU 119/30/1987
BASIC
r,PRIOR VALUE
o CONTRIBUTIONS
? N THORAWALS
n, ADJUSTMENTS/TRANSFERS
i EARNINGS
CURRENT VALUE
SUPPLEMENTAL
i PRIOR VALUE
',CONTRIBUTIONS
ADJUSTMFNTS/TRANSFERS
EARNINGS
CURRENT VALUE
?.c
COMPANY
PRIOR VALUE
CONTRIBUTIONS
WITHDRAWALS
ADJUSTMENTS/TRANSFERS
FORFEITURES
EARNINGS
CURRENT VALUE
FIXED
414.90
26502n
:n
li.l
69..2
.DO
':000
.08
65.96
06.08
ODD
won
.t2on
277:31
SUMMARY OF ACCOUNT FROM INCEPTION'THRU 09/30/3987
.c.
CONTRIBUTIONS EARNINGS DISTRIBUTIONS CURRENT VALUE
BAPPLEMENTAL 675:0 17:OU 00p0p 693 0
MPANY 270.20 7.11 :8S -7a 51
TOTAL 4
Q
a
n
TRANSACTIONS
WILL APPEAR ON YOUR NEXT
TIC PLAN NUMBERt 12777 T EH EMPLOYEENSA?VINGSAND T}1eTtAVllets'J
LOCATION 001 INVESTMENT PLAN FOR EMPLOYEES
AS OF 03/31/1994
MICHAEL A. JONES SOC.SEC.NOi 178-54.4839
RR 41 BOX E9
LAKE ARIEL PA 18436
ACTIVITY FOR THE PERIOD 12/31/93 TO 03/31/94
EMPLOYEE ACCOUNTS FIXED
PRIER BALANCE 5,085.86
EARNINGS 88.60
END BALANCE 5,174.66
COMPANY ACCOUNTS
PRIOR BALANCE 2,460.19
EARNINGS 42.95
END BALANCE 2,503.14
r I m
SUMMARY OF ACCOUNT SINCE INCEPTION THRU 03/31/1994
¢QU$C CONTRIBUTIONS DI STRIBUTIONS EARNINGS CU RRENT BALANCE
BASIC 3,205.43 0.00 1,969.23 5,174.66
COMPANY 1,565.41 0.00 937.73 2,503.14
TOTAL 4,770.84 0.00 2,906.96 7,677.80
PRE187 AFTER-TAX CONTRIBUTIONS 0.00 POST186 AFTER-TAX CONTRIBUTIONS 0 3,205.43
QUESTIONS REGARDING YOUR ACCOUNT SHOULD BE DIRECTED TO YOUR PLAN ADMINISTRATOR.
TRANSACTIONS AFTER 03/31/1994 WILL BE ON YOUR NEXT STATEMENT.
PLAN NUMBERt 12777
TION 001
MICHAEL A. JONES
RR 01 BOX E9
LAKE ARIEL
THE LOVESHAW CORP,
THE EMPLOYEE SAVINGS AND
INVESTMENT PLAN FOR EMPLOYEES
AS OF 03/31/1994
PA 18436
TheTravelers'SOC.SEC.NOt 178-54-4839
0
EMPLOYEE ACCOUNTS
PRIOR BALANCE
EARNINGS
END BALANCE
COMPAN ACCOUNTS
PRIOR BALANCE
EARNINGS
END BALANCE
FIXED
5,005.86
88.00
5,174.66
2,460.19
42.95
2,503.14
BASIC 3,205.43 0.00 1,969.23
COMPANY 1,565.41 0.00 937.73
TOTAL 4,770.84 0.00 2,906.96
PRE087 AFTER-TAX CONTRIBUTIONS 9 0.00 POST186 AFTER-TAX
5,174.66
2,503.14
7,677.80
QUESTIONS REGARDING YOUR ACCOUNT SHOULD BE DIRECTED TO YOUR PLAN ADMINISTRATOR.
TRANSACTIONS AFTER 03/31/1994 WILL BE ON YOUR NEXT STATEMENT.
con SA O. JONES, I
Plaintiff I
i
•. 1
NICEARL A. JONSS,
Defendant I
To the Prothonotarys
in TER COURT OP CONN01K PLRAS OF
CUMERRLRND COUNTY, PENNSYLVANIA
CIVIL ACTION -- LAM
IN CUSTODY
094-4024 CIVIL TERM
Please discontinue this custody matter filed with this Court regarding
Cynthia O. Jonas. Mr. Jones has agreed to allow Christopher Jones to accompany
his maternal grandparents to Florida for his birthday. There is no need to
continue with a Conciliation or a Court hearing.
Dater March 24, 1997 ?-
Ruby D. Weeks, Att rney for the Plaintiff
cot Hubert Gilroy
Raymond Ferrario
Cynthia G. Jones
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• Mi(, .hae° A ..JcnCa
Plaintiff
Defendant
•w
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION - LAW
:No. CIVIL 19?:)?J
:CUSTODY/ VISITATION
ORDER OF COURT
AND NOW, this (date) upon consideration of the
attached complaint, it is hereby directed that the parties and
their respective counsel appear before 11(' C Ch/. T
the conciliator, at 4M rl,? r(; r,?m cc' C'm (k.tflbc•r1 rVA (c `
on the 1P" day of t`}?? -?_1 , at
?, M., for a Prehearing 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. Either
party may bring the child who is the subject of this custody
action to the conference, but the child/children's attendance is
not mandatory. Failure to appear at the conference may provide
grounds for entry of a temporary or permanent order.
FOR THE COURT:
Custody Conc ator U
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, FOURTH FLOOR
CARLISLE PA 17013
(717)240-6200
`"I, f . i " ra'.
. ? ??. /? . •y.•
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RUBY D,WTMMS
Attornoy At Lew
10 West M-P 9trcar MAR 1 3 Igy7d-
C.arlhile, P! 1701:
I
MAL
CYMT/IA 0. JONES,
Plaintiff
•s.
MICRARL A. JONES,
Defendant
IN THE COURT OF COMMON PLEAS OP
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
CUSTODY
/94-4024 CIVIL TERM
1 .
AND NOW, 'his LV day of t-AC)( (_ ` 19,
attached petition requesting authorization for CH
upon consideration of the
JONES to accompany his
grandparents to Disney World for a birthday gift, t is hereby directed that CHRISTOPHER
JONES, and the parties and Owir respectiv counsel appear before l 3_1? l J Xib
?, the conciliator, at? 1 on the .)day of _
r ( 1 19LLI-, at for a Pre-Nearing Custody Conference. At such
conference, an effort will be ma to resolve the issues in dispute] or if this cannot
be accomplished, to define Z11 narrow the issues to be heard by the court, and to enter
into a temporary order.. children age five or older may also be present at the
conference. Failure 6 appear at the conference may provide grounds for entry of a
temporary or pexman9 t order.
FOR THE COURT,
Sys
Custody Conciliator
The Court of Common Pleas of Cumberland County is required b law to comply with
the Americans with Disabilities Act of 1990. For information about accessible
facilities and reasonable accommodations available to disabled i ividuals having
business before the court, please contact our office. All arrangements ust be made at
least 72 hours prior to any hearing or business before the court. You m t attend the
scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER
OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
Office of the Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
Telephone: (717) 240-6200
CYNTEIA O. JOKE/,
Plaintiff
vs.
NICEAEL A. JONES,
Defendant
in TEE COURT OF Comm !LEAS or
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAN
CUSTODY
NO. 094-4014 CIVIL TERM
YOU, MICHAEL A. JONES, Defendant, have been sued in Court to allow your
child CHRISTOPHER JONES, 8, June 24, 1988 to accompany his maternal grandparents
on a trip to Disney World in Orlando, Florida as a birthday gift from them.
You are ordered to appear in person at courtroom No. , Cumberland
County Courthouse, Carlisle, Pennsylvania, on , the
of , 19_, at _.M. for a hearing. Until such
hearing, the current order of custody of the children shall be and remain in
effect.
If you fail to appear as provided by this Order, an Order for custody,
partial custody or visitation may be entered against you or the Court may issue
a warrant for your arrest.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND
OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
Telephoner (717) 240-6200
BY THE COURT,
J.
CYMTEIA O. JONES, 1
9lsletl!! 1
1
vs. 1
1
MICMAMI. A. JONES, 1
De[eadast 1
IM TEE COURT or Comm lLMAE OI
CVMEERLAND COUNTY, P MMEYLVAMIA
CIVIL ACTION - LAM
CUSTODY
09{-{044 CIVIL TERM
AND NOW, this day of _, 1997, it is ordered and directed
that CHRISTOPHER JOHEB is hereby allowed to accompany his maternal grandparents,
Leo and Kitty Oelinas, to Orlando, Florida, from April B, 1997 to April 18, 1997,
to attend Disney World, as a birthday gift.
BY THE COURT,
eel Ruby D. Weeks, esquire, for mother
Raymond ferrario, Esquire, for father
v.
CYNTEIA G. ions,
Plaintiff i
i
•s. t
t
NICEAEL A. JONES,
Defendant i
in Tam COURT OP COMM MPLEAS OF
CUNEERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAN
CUSTODY
NO. 094-4024 CIVIL TERN
TO TER EONORARLE, THE JUDGES OF SAID COURTS
1. The Plaintiff is, CYNTHIA 0. JONES, hereafter referred to as the natural
mother, residing at Box 100, Boiling springs, Cumberland County,
Pennsylvania, 17007.
2. The Defendant is MICHAEL A. JONES, hereafter referred to an the natural
father, residing at Box 318, R.D./2, Waymart, Wayne County, Pennsylvania
18472.
3. The attached order of custody which is made a part hereof as though fully
set forth herein is presently in effect between the parties.
4. The child is presently in the custody of the natural mother, who resides at
Box 100, Boiling Springs, PA 17007.
5. Plaintiff has not participated as a party or witness, or in another
capacity, in other litigation concerning the custody of the CHRISTOPHER
JONES in this or another Court since the attached custody order was issued
by this Court.
6. Plaintiff has no information of a custody proceeding concerning the
children pending in a Court of this Commonwealth.
7. Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the children or claims to have custody or visitation
rights with respect to the children.
8. Each parent whose parental rights to the children has not been terminated
and the person who has physical custody of the children has been named as
parties to this action. There are no other persons who are known to have
or claim a right to custody or visitation of the children, so none will be
given notice of the pendency of this action and the right to intervene.
9. Pursuant to the Custody Act, the mother requests this Court to grant her
request to allow CHRISTOPHER JONES to accompany his maternal grandparents
on a trip to Disney World in Orlando Florida, planned for April 8, 1997 to
April 15, 1997 as a birthday gift for the child. Never dreaming that the
father would object to the trip, the grandparents have already purchased
airline tickets and expended a considerable amount of money for this. In
addition, the child in already aware of the plans and is very much look"g
forward to the trip. The father is unreasonably withholding his consent,
giving no valid reason for his refusal.
10. The mother requests this Court to authorize the child's accompanying his
maternal grandparents from April 8, 1997 to April 15, 1997 to Disney World
in Orlando, Florida.
11. The best interests and permanent welfare of tho child and his physical,
spiritual, emotional and moral well-being will be served by granting the
relief requested.
12. Plaintiff mother prays for an Order authorizing CHRISTOPHER JONES to
accompany his maternal grandparents from April 8, 1997 to April 15, 1997 to
Disney World in Orlando, Florida.
WEEREFORE, Plaintiff mother prays for an Order authorizing CHRISTOPHER JONES
to accompany his maternal grandparents from April 8, 1997 to April 15, 1997 0
Disnew World in Orlando, Florida.
Respectfully submitted,
?) Z
Ruby D. W eks, Esquire
Attorney for Plaintiff
10 West High Street
Carlisle, Pennsylvania 17013
(717) 243-1294
ccl Raymond Ferrario, Esquire
COMNIMNRJILTN Of PNNK5nVANIA i
i as
COUNTY OF CUMRLRMD
Personally appeared before me, A Notary Public in and for the Commonwealth
and County aforesaid, the under-signed, being duly sworn according to law, deposes
and says that the facts not forth in the foregoing Complaint are true and correct.
$worn to and subscribed to
before me this, 1 l t'14 day
of `J,Pl s!A , 1901/.
1(/, g)el
Notary P lic '/
NOTARIAL SEAL
BNIRLEr P• CLEVEI-OF_R, NOTARY PUBLIC
MY CommosslonnExpiressMa cn 5, 2000
t
RECEIVED NOV 0 5 1995
V OCT 2 51095
(i
CYNTHIA G. JONES, :IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
t
v :NO. 4024 - CIVIL - 1994
t
MICHAEL A. JONES, t l
Defendant :CIVIL ACTION - CUSTODY'
COURT ORDER
AND NOW, this. day of , 1995, upon'consideration of ?.
the attached Custody Conciliation Report, It Is ordered and
directed as follows:
1. The attached Custody Stipulation and agreement of the parties
is hereby incorporated as a Court order.
2. A Hearing is scheduled in Courtroom N 1 of the Cumbesrland
County Courthouse on the _d,?k day of ? 199?,CAat
q:OQ A.M. at which time testimony wit be to en on the Issue
of transportation for exchange of custody. Counsel shall
file with the Court and opposing counsel a Memorandum setting
forth each party's position on the transportation Issue, a
list of witnesses that will be callerd to testify on this
issue and a summary of the anticipated testimony. This
memorandum shall be filed at least ten days prior to the
mentioned Hearing date.
BY THE COURT,
le - Sh*OIY, P-
Judge Harold E-
cc: Ruby D. Weeks, Esquire
Raymond W. Ferrario, Esquire
t?.ntw ccnu?e2?s,e.,' _
In Testlal6riY wDKlof; t hell unwed y hand
and the *,of UId Court st Cerbi. ps.
Y' 1
1 r ry' ? K ?1 R(Rca7'--7-
11:' / fit.
L.: 1
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CAI
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li
CYNTHIA G. JONES,
Plaintiff
v
MICHAEL A. JONES,
Defendant
tIN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:
tNO. 4024 - CIVIL - 1994
r
:CIVIL ACTION - CUSTODY
PRIOR JUDGE: JUDGE HAROLD E. SHEELY, P.J.
I .M
1
CONCILIATION CONFERENCE SUbAlARY RE'PQRT n,aG'P`"
IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report:
1. The information pertaining to the children who are the
subject of this report is as follows:
Christopher Jones, born June 24, 1988, Brian Jones, born
May 14, 1991, and Rachel Jones, born October 26, 1994.
2. A Conciliation Conference was held on October 20,.1995, with
the following individuals in attendancet
The Mother, Cynthia G. Jones, with her counsel, Ruby D.
Weeks, Esquire, and the Father, Michael A. Jones, with his
counsel Raymond W. Ferrario, Esquire.
3. The parties agreed on all the particulars of a custody
arrangement but could not agree on a transportation issue.
The parties originally lived in a town north of Scranton..
At separation, the Mother moved to the Cumberland County
area to be with her family. Father wants Mother to share,
equally in the transportation. Mother is only willing'to
meet halfway on Sundays and share transportation on that
day. She is unwilling to share the transportation otherwise.'
A Hearing is required on the transportation Issue.
4. The parties filed with the Conciliator a Custody stipulation
that resolved all issues except the transportation. The
Conciliator recommends an Order in the form as attached.
ivy; Y Q6,-- 6xljw?-tvi' /,/
DATE Hubert X. G rcy, Es Ire ,
Custody Conciliato
1 ?I.u
I
CrNTefA O. JONES, IN Tai COVRT or COMNOM FLeA/ or w '
rlalatifL CVKBBRLRND COUNTY, PUN6YLVANIA
ve• CIVIL ACTION - LAN -
t
CUSTODY'
MICeAEL A. JONES,
Defendant NO. CIVIL 19
This Agreement and stipulation entered into the day and year hereinafter
not forth, is by and between CYNTHIA Q. JOMYB, natural mother, by hie Iattorlley,''
?!
?'V
Ruby D. Weeks, Esquire, and natural father, by his attorney, RAYMOND N.
fZRRARiO, Esquire, who aver as follow n .
1. Plaintiff is Cynthia G. 'Jones natural mother 'and an adult sul curie, who
resides at Box 100, Boiling springs, Cumberland County, Penneylvanlap`
17007.
II. Defendant is Michael A. Jones natural Lather and an adult sul curls, who
resides at 1127 Black Bear road, Wayne County, Pennsylvania, 14436@
III. Mother and father are the parents of three children, Christopher Jonee,'
born June 24, 1988 and Brian Jones, born May 14, 1991 and Rachel Jonee,,
born October 26, 1994.
IV. The parties agree to the following custody terms regarding custody of
the children and request the terms be'lentered a an order of Courts
A. The parties shall have joint, shared, legal custody of the children.
0. The mother shall have act0al physical custody of the children, with
partial custody awarded to the father as followms
I.Two weekends a month from 600 p.m. Friday to 6100 p.m* Sunday as
on the first and third 1eekends of each month. November 10th to 12th and 24th
to 26th 19951 December 8 to 100 December 26, 1995 to January 1 at 200 p.m. 19961
January 12 to 15 19961 January 26 to 28 1996; rebruaey 2 to 4 and 16'to 19 19961
March 1 to 1 and 14 to 17 19961 April 5 to 7 and April 26 to 26 19961 May 10 to
12 and 24 to 26 19961 September 6 to 6 and 20 to 22 1996. It is the intent of
the parties that each year when the father receives his national guard duty
1
_ a
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i
t
schedule that the parties will arrange for the entire year the weekend schedule
taking the father'e national guard duties into consideration.
2. Starting in 1996 during the summer months of June July and August
the tether shall have partial custody for a total of thirty days to be taken ton
consecutive days at a time in each of thou months from. 9100 a.m. on a Friday
until 6100 p.m. the second following Sunday. This paragraph supsrsedoo the
alternating weaken s m u era above. For 1996 these data area
June 21 to 10 19961 July 17 to 2&S3j
_ypuat to 16 1996.
„
fi e, `• tl
1. The mother in to have the entire Thanksgiving day in' 199116
Commencing in 1995 and odd numbered years thereatter, the father shall have
partial custody of the children each Thanksgiving and each taster Sunday and one-
halt of whatever school vacation is provided by the school calendar, which into„ -
includo the holiday. In the even numbered years, the mother will have the
Thanksgiving and Canter Sunday holidays and one-half, of the school vacation Nor
those holidays. The parent not having the children for the holiday shall haw*
the remaining one-half of the school vacation, Thanksgiving and Raster holidays
each year.
4.)a.) For 1995 and odd numbered year thareafter the mother shell
have the first halt of the children's school holiday to include both Chriettas
Eve and Christmas Dayl, the father shall have the second half of that school
holiday period.
(b.) for 1996 and even numbered year thereafter the lather shall -o-
have the first half of the children's school holiday to include both Christmas
Eve and Christmas Day1 the mother shall haye the second hall of that school
holiday period.
5.1a.) The father shall always have partial custody of the children
on Father's Day from 900 ¦.m. to St00 p.m. and the inother on Mother's Day, even
it that day would have otherwise been a day for custody of the children with the
other parent.
2.
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(b.) The father shall have name period of partial custody with each
child on the child's birthday and on the fatherom birthday to salebrate th
e
occasion. Likewise, the mother shall always have time with each child on her
birthday and on the child's birthday even if theme days were ordinarily days of
the father's partial custody.
6. The parties agree that Dr. Robert Morten M.D. of Mewling IPA 164370
will continue to be the children's pediatrician when the children are with the
father, and accordingly , he will provide medical treatment to the children W"?
Nl
necessary, at the father's expense for items not covered by health lnsuranos.'
7.The parties agree that each parent shall be entitled to have ,
conferences with any physician , dentist, counselor, or other health case
provider, treating the children, and each parent shall be entitled to copies of
reports regarding a child's treatment.
i
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?ri
2•, The father agrees to call at lust 24-hour before appearing
for an?Irat.. visit and to confirm theme prearranged
periods of partial custody at least twenty-four hours (241 In
advance. The wife agrees not to unreasonably withhold ..resent'-'
for ouch visitation or perlode of partial I custody by. the
^.ather.,
q. Time is of the essence regarding the, father's plok-upend
return of the children for period* of the father's partial'.,
custody. The parties agree that if the Lather has aet,plck Of i#,Pj
up the children within one hour. of the set t?mep that period
of partial custody is forfeited by the 0fether and the mother "
and children are free to make other plane, unless the father
has notified the mother in advance of an emergency a?tuatloa
whLch prevents his timely arrival.
10 • The parties shell notLfy.each other in a timely fashion if lt'
to necaeeary due to an emergency or unforeseen circumstance '
for him or her to be delayed at any of the times eet out
horein. It le intended, however, that time be of the essences
and that the partle¦ an strLctlla as possible comply with the
times not forth,hereLn.
I1. The parties will notify and consult with the other party
immediately in cases of medical emergencies thatloccur while
the children are in each parent's culody.
12. The father agrees to continue the children in and to treneport' ? "
them to and from their regularly scheduled activities which
occur while he is In this area during his periods of partial
custody. Tito mother agrees to keep his timely advised of
these events.
!/ ,
Lt. The parties acknowledge that the child has the following {
medical conditions and that each parent will ensure that the
recommended dlet•ry, medical and environmental restrietlons
and tre•tment• are adhered to, including but not limited to,
. y
nonerpoeur• to animals and cigarette smoke, and that the
children will receive all prescribed dosages of msdloation and
treatment as directed by the physician.
a. Christopher - Croup and respiratory problems „
b. Brian - Suspected aolitle end gaetro intestinal
problems
It is acknowledged that these health problems often
occur at night, and Lite tether agr•ee'to week pecmpt medical
treatment when the
a
re with him and. such problems
children
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tf` .4 ArK{ -ww
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coil iUrAprr 11Wa•-
w
YT
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l •4 . The • h
r shell l
l • t • tr
ispa
tlon to.one from hl -
periods ok partial custody. After March ]l, 1ff{,;the mother
4grse¦ to most the tether one-half way at a mutually-agr}ad-
upon location in Frackville, 'IPA. at such times as the lather
turning the chLldren to the mother's custody.
lg. The parties •halr ix@hingi-1nZint'and'ohLldtin'a ear seats,
with the mother providing these to the father as necessary
when he picks up the children. The father shall promptly
return the car seats to the mother' at the time he ratarne the
i children. I , 11 -
lR. The father may have partial custody of the 'children during
'
such additional periods as the parties shall tram time to time
agree, without the need to modify the Order of Court'antered
as a result of this Stipulation.
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The parties agree that the tether shall be allowed rresaeneble r rl rn rl
rr
telephone time contact between himself and the children when "'1 S!
the children Ore with the mother. L.LkewLse, when the children
are with the father, the mother shell be allowed reasonable
telephone contact with the children.
The parties agree that they shall obtain each others written
consent before removing the children from Iennsylvanler and
they 0100, agree to provide the other parent an emergency
telephone number'and address In the event they do remove the
children from Pennsylvania.
Neither parent shall do anything which" may ''estrange the
r?r ' 4 t
children from the ocher parent or injure the opinion of the
children as to the other parent, or which may hamper the free
and natupal development of the children's love or affection
for the other parent. Likewise, each parent shall encourage -
their relatives not to belittle or disparage the other parent
to the children. t
The portion agree that in making this Agreement, there has
been no fraud, concealment, overreaching, coercion, or other
unfair dealing on the part of the other.
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IN WITHE88 WHEREOF, the parties hereto intending to be legally bound by the
terms hereof,{ not forth their hands and seals this 70th day of October, 1995.
Ru y D. Weeks, Esquirs - C 11 A c. JO
Attorney for Plaintiff Plaintiff
10 West High street
Carllsle,iPA 17011 1 .
AttornAaf for Defendant
suite 78
reran on Life Building
618 spruce street
ecranton, PA 18601-1816
i
V
COMMONWEALTH OF PENNSYLVANIA i
COUNTY OF CUMBERLAND ss i'
On this, the . n ?/( day of
Public, the undersigned officer -?-r l9G,Zr befpre'e1eP • Np
Y Personally appeared, MICHANL A,'Joan$ know
me to be the person whose name is subscribed to the within Custody Ntlyulal
and Agreement, and acknowledged that she executed the same I„
therein contained. foe the'purpe
MAfIr1rN A LAD' W, Na.?, pr;;.. / ?fig ,
1997
NotarY• P 4 e
i
COMMONWEALTH OF PENNSYLVANIA t
COUNTY Or CUMBERLAND ee
t
On this, the .' ' ' ) day of Public, the undersigned officer, -?i_I 19 tore me* •:Npta
personally appeared, CYNTHIA O, JOHNS
me to be the person whose name in subscribed to the. within Custody itlpula L
and Agreement, and aekngwledged that he executed the same for the purppa,
therein contained.
......-• NOW 1, `l .. `.
l -Al
MAIIYLrN A t4j` ?l, A?Aer P?ANp I /
f:i1kV0. CumMWy C,auny ?. 17 t 17
Notary Pub to
i ^,
MAY 7 1 too7bv
CYNTHSA 0. JONES, tIN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
I
V :CIVIL ACTION - LAW
I
MICHAEL A. JONES, :NO. 94-4024 CIVIL TERM
Defendant tiN CUSTODY
COURT ORDER
??11 ?y
AND NOW, this a day of May, 1997, the Conciliator being
advised that the parties have reached an agreement, the Conciliator
relinquishes jurisdiction.
nu"V&l A. WAAL X o
Custody Concili or
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MICHAEL A. JONES I IN'1'I11i c'OURT OF COMMON PLEAS Oh
PLAINTIFF t CLIMI)FRLANDC01 IM Y. PENNSYLVANIA
V. t
CYNTHIA JONES t 94_4014 & CIVIL ACTION LAW V/
DEFENDANT q,j_ LA-77
t
t IN CIISTODY
91MIEWOF-C-0-U i :
AND NOW. Frlday, April 20, 2001_ - ___ _.. . upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear hefbre Hubert X. Gilroy, Esq. the conciliator,
at 4th Floor. Cumberland County Courthouse. Carlisleon Frida?Dlay 11.2001 at 8t30 a.m.
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to he 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 TI IL: UOIIIt 1'.
By: _. /s/ -----HubivZLX. GilroJ1..EFf/?.
-- Custody Conciliator
The Court of Common Pleas ol'C'umberlaod 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 befirre 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'I'll IS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT' AFFORD ONE. GO'I'O OR T'ELENIONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERFi YOU CAN (it; f LEGAL It 11, .
Cumberland County liar Association
2 Liberty Avenue
Carlisle. Pennsylvania 17013
'telephone (717) 249-3166
Plely
o l APR 2 ? PH 12, 19
CUMBEriNSYLVMA
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FRANK 3. RUGGIERO, ESQ.
Attorney for PLAINTIFF, MICHAEL A. JONES
Identiftabon No. 79850
Law OMlaat
P O Box 178
108 North Main Strad
Taylor, Ponn"Wenle 18517
Phonet(570)562-2728
APR 1i nom
MICHAEL A. JONES
RR 2 Box 2430
Waymart, PA 18472
Plaintiff
VS.
CYNTHIA JONES
109 Andrew Court
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
IN CUSTODY
AND NOW, this day of
consideration of the attached Complaint,
respective counsel appear before
Conciliator, at
the day of , 2001, at
a.m./p.m. for a Prehearing 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.
Either party may bring the children who are the subject of this Custody Action to the
Conference, but the children's attendance is not mandatory. Failure to appear at the
Conference may provide grounds for entry of a Temporary or Permanent Order.
BY THE COURT:
BY:
Custody Conciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, FOURTH FLOOR
CARLISLE, PA 17013
(717) 240-6200
_ , 2001, upon
it is hereby directed that the parties and their
the
on
FRANK I RUGGIERO, ESQ.
Attomey for PLAINTIFF, MICHAEL A. )ONES
Identlfb bon No. 79850
Lew Of low;
P 0 sort 176
109 North Main Street
Taylor, hnneylvenle 16517
Phonet(570)562.2728
MICHAEL A. JONES
RR 2 Box 2430
Waymart, PA 18472
Plaintiff
vs.
CYNTHIA JONES
109 Andrew Court
Carlisle, PA 17013
Defendant
IN THE COURT OF COMMON PLEA5
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
IN CUSTODY
AND NOW, comes the Plaintiff, Michael A. Jones, by and through his attorney,
Frank J. Ruggiero, Esquire, and hereby avers as follows:
1. The Plaintiff Is Michael A. Jones, an adult and competent individual
currently residing at RR 2 Box 2430, Waymart, PA 18472.
2. The Defendant Is Cynthia Jones, an adult and competent individual
currently residing at 109 Andrew Court, Carlisle, PA 17013.
3. On or about October 20, 1995, the parties entered into a Custody
Arrangement whereby father was to provide the transportation to and from his periods
of partial custody until March 25, 1995, when mother would meet half way to a
mutually agreed upon location in Frackville, Pennsylvania upon the return trip. (See
attached Exhibit "A".)
4. On or about October 20, 1995, the parties entered Into a Custody
Arrangement whereby father, starting In 1996 during the summer months of June, July
and August the father shall have partial custody for a total of thirty days to be taken
ten consecutive days at a time In each of these months from 9:00 a.m. on a Friday until
6:00 p.m. the second following Sunday. This paragraph supersedes the alternating
weekend schedule in paragraph one above. For the 1996, these dates are June 21 to
June 30, 1996, July 12 to July 21, 1996, and August 9 to August 18, 1996. (See
attached Exhibit "A".)
5. On or about March 25, 1996, this Honorable Court entered an Order
directing that from the beginning of Daylight Savings Time in the Spring to the end of
Daylight Savings Time in the Fall, the parties shall meet halfway to exchange the
children when they are returning from their father's care. At all other time, Michael
Jones Is responsible for transporation. Also, Cynthia Jones is order and directed to
work with Michael Jones in order to facilitate a satisfactory arrangement for picking up
the children on Fridays in the event that Michael cannot take time off work. (See
Attached Exhibit "B".)
6. The Plaintiff has partial custody of the following children:
Name Present Residence Age
Christopher Jones 109 Andrew Court. Carlisle, PA 17013 1_
Brian Jones 109 Andrew Court. Carlisle, PA 17013 _9
Rachel Jones 109 Andrew Court. Carlisle, PA 17013 6
7. The children were not born out of wedlock.
8. The children are presently In the custody of Cynthia Jones who currently
resides at 109 Andrew Court, Carlisle, PA 17013.
9. During the past five (5) years, the children have resided with the following
persons at the following addresses.
Persons reside with Addresses Dates
CVnthla Jones _ 109 Andres Court. Carlisle, PA 17013 1225:219M
10. The mother of the children Is Cynthia Jones, who currently resides at 109
Andrew Court, Carlisle, PA 17013. She is single.
11. The father of the children is Michael A. Jones, who currently resides at RR
2 Box 2430, Waymart, PA 18472. He is single.
12. The relationship of Plaintiff to the subject children is that of Natural
Mother. The Plaintiff currently resides with following persons:
Name
Relationship
Alan Jones _ Parents
Carol Jones Parents
13. The relationship of Defendant to the subject children is that of Natural
Father. The Defendant currently resides with following persons:
Name
Relationship
Christopher Jones Son
Brian Jones Son
Rachel Jones Daughter
14. Plaintiff has participated as a party or witness, or in another capacity, In
other litigation concerning the custody of the subject minor children in this or another
Court.
15. Plaintiff has no Information of a custody proceeding concerning the
subject minor children pending In a court of this Commonwealth.
16. Plaintiff does not know of a person not a party to the proceedings who
has physical custody of the subject minor children or claims to have custody or
visitation rights with respect to the children.
17. The best Interest and permanent welfare of the child will be served by
granting the relief requested by the Plaintiff because the relief requested will be In the
best Interests and permanent welfare of the children.
WHEREFORE, the Plaintiff, Michael A. Jones, respectfully requests that this
Honorable Court grant his Petition for Modification of the Custody Agreement dated
October 25, 1995, and subsequent Order of Court dated March 26, 1996.
RESPECTFULLY SUBMITTED,
Fr k J. gglero, Esquire
Attorney for Plaintiff, Michael A. Jones
FRANK J. RUGGIER09 ESQ.
Attorney I'or PLAINTIFF. MICIIAHI. A. JONES
Wndacation No. 79850
Lew Omcest
P O Boa 176
109 North Maio Street
Taylor, Peonsylvaolo 16517
Phooet (570) 562.2726
MICHAEL A. JONES
RR 2 Box 2430
Waymart, PA 18472
Plaintiff
VS.
CYNTHIA JONES
109 Andrew Court
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
IN CUSTODY
NO.
VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct to the
best of my knowledge, information and belief. 1 understand that false statements herein are
made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unswom falsification to
authorities.
Date: /G A4,4,tei-l 14701 n '
Michael ,one laintiff
s
CYNTHIA 0. JONES, I IN TSE COURT UP COMMON FLEAS OF
Plaintiff I CVMBSRLAND COUNTY, FENNBMVANIA
I
•s• I CIVIL ACTION - I.AW
I CUSTODY
NICBAEL A. JONES, I
Defendant I HI). CIVIL !9
,{VSTODY STIPULATION AND AOPIrME
This Agreement and Stipulation entered into the day and year hereinafter
met forth, la by and between CYNTHIA G. JONES, natural mother, by her attorney,
Ruby D. Weeks, Enquire, ¦nd naturc.l father, by his attorney, RAYMOND W.
FERRARIO, Esquirn, who aver as follcwal
1.? Plaintiff is Cynthia G. Jones natural mother and ¦n adult ¦ui furls, who
resides at Box 1CO, Bolling nprlrgs, cumberland County, Pnnnsylvania,
17007.
Defendant is Michael A. Jones natural father and an adult sul curls, who
resides at 1127 Black Bear road, Wayne County, Pennsylvania, 18436.
Mother and father are the parents of throe children, Chrlstcpher Jones,
born Jute 24, 1988 and Brian Jones, born May 14, 1991 and Rachel Jones,
born October 26, 1994,
j IV. The parties agree to the following custody terms regarding custody of
the children and request the terms be'unter`cd ax-Ln Ordir it Courtr
! "• A. The parties shall have joint, shared, legal custody of tho children..
^ :,r B. The mother shall have actual physical custody of the children, With
A; partial custody awarded to the father as follower
r l.Two weekends a month from 6rOO p.m. Friday to Sr00 p.m. Sunday sa
on the first and third weekends of each month. November 10th to 12th and 24th
;.to 26th 1995/ December 4 to 10, December 26, 1995 to January 1 at 2r00 p.m. 1996/
.'January 12 to 19 19961 January 26 to 28 1996/ February 2 to 4 and 13 to 19 19930
March 1 to 3 and 14 to 17 19961 April 5 to 7 and April 24 to 23 19941 May 10 to
12 and 24 to 26 19961 September 6 to 6 and 20 to 22 1996. It Is the Intent of
the parties that each year when the father receives his national guard duty
EXHIBIT
?, ,
schedule that the parties will arrange for the entire year th,) weekend schedule
tnking thrn father's national guard duties Into conslderatl,on.
2. Starting in 1996 during the summer months of June July and August
I the father shall have partial custody for a total of thirty days to be talon tan
cuasecutive days at a time in each of those months from 9r00 a.m. on a Friday
until 6t00 p.m. the second follo'.+Ing Sunday. This paragraph oupereados the
ti alternating weekend ¦chedYlantiaiu!n pa • raph..o above, F,N.ornS1996 these dates area
??e,,.
June 21 to 70 19981 July 12 to 21 19 to is 1996.
1. The mother is to have the entire Thanksgiving day in 1995.
Commencing in 1995 and odd numbered years thereafter, the father shall have
i ?• partial custody of the children each Thanksgiving and each raster Sunday and one-
' ? half of whatever school vacation is provided by the school calendar, which is to
:includn tho holiday. In the oven numbered years, the mother will have the
1i
Thanksgiving and Easter Sunday holidays and one-half of the school vacation for
those holidays. The parent not having the children for the holiday shall have
the remaining cite-halt of the school vacation, Thanksgiving and Easter holidays
i.
each year.
4.(a.) For 1995 and odd numbered year thereafter the mother shall
have the first half of the children's nchool holiday to include both Christmas
r- Eve and Christmas Day; the father shall have the second half_ of that school
"•, holiday period.
(b.) For 1996 and even numbered year thereafter- the father shall
:J.""';have the first half of the children's school holiday to include both Christmas
Eve and Christmas Day; the mother shall have the second half of that school
" holiday period.
r'. 5.(a.) The 'father shall always have partial custody of the children
•'r . 1 .
on Father's Day from 900 a.m. to Soo p.m. and the mother cn Mother's Day, even
if that day would have otherwise been a day for custody of the children with the
other parent.
2.
( (b.) The father at.all have come period of partial custody with each
child on the child's bir%.hday ¦nd ca the father's birthday to celebrate the
oenaelon. Likewise, the mcther shall always have tlrta with each child on Aar
I birthday and on the child's birthday even U these days were ordinarily days of
tl the father's partial custody.
6. The parties agree that Dr. Robert Morten M.D. of Hamlin, Ph 1$427,
will continue to be the children's
?r*.. pediatrician when the children are with the
father, and accordingly , he will provide madlcal treatment to the children when
necessary, at the father's expono• for items not covered by health insurance.
•' ( 7.The parties agree that each parent shall be entitled to have
conferences with any physician , dentist, counselor,, or other health care
provider, treating the children, and each parent shall be entitled to copies of
reports regarding a child's treatment, t`
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0.0 The tathmr agrees to call at least 24-hours before appearing
.v ad?•!.,• q J-
for an'q;,r..- .. viuit and to confirm these prearranged
porLodn of partial custody at least twenty-lour hours (24) In
advance. The wife agrees not to unretaonably withhold consent
foc such visitation or perlcds of partial custody by the
father.
_ g.. Time is of the eusenc• rugarding the lather's pick-up and
return of the chlldrun for periods of the lather's partial
custody. The parties agree that it the father has not picked
ct;r ?•??` a " up the children within one hour. of thu eet'time, that period
of partial custody is forfuited by the 'father and the mother
"•?'' .y and children are free to makw other plans, unless the father
has notified the mother in advance of ¦n emergency situation
winch prevents his timely arrival.
'1o'• The partlas shall notlfy.each other in a timely fashion If It
in necessary due to an emergency or unforeseen circumstance
•• for him or her to be delayed at any of the times mot out
herein. It in intended, however, that time be of the a n ante,
and that the parties as etrlctly as possible comply with the
times ewt forth-herein.
Tti- a P4rti3s will notify and consult with the other party
Immediately in cases of medical eiiirgenclii Ehit{ocaii whlli
tp the children are in each parent's custody.
1 2 ?he lather agrees to continue tha children In a
d to
• n
transport
i
_ •' than to and from their regularly scheduled activities which -
•.?
occur while he to in this area during his perloda of partial
custody. The mother agrees to keep him timely advised of
I + ,? ?. +•, A . %Y', , lheie events. •
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1+3• The partiso acknowledge that the child has thu following
medical conditions and that each parent will ensure that the
recomeen4ed dietary, medical end environmental restrictions
and treatments are adhered to, Including but not limited to,
nonexposure to animals and cigarette smoke, snd that the
children will receive all prescrlbed dosages of medication and
i treatment ¦¦ directed by the physician.
a. Christopher - Croup and respiratory problems
b. Orion - suspected colitis and gestro intestinal
;;_ problems
_
...
;'•?;, St In acknowledged that chess health problems often
?•'/'r,ccur at night, and the lat;,er agrees to seek prompt medical
'treatment when the children ere with him and such problems
' riur._i,lllt Ct. «fYliiFtY-?y•Z0.4.i?
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1d?. 'The talker ll p ovldo t s transportation to a from
sha
p'perlods of partial custody, hlter March 31, 1995, the mother
l agree to meet the lather one-hall way ¦t ¦ mutually-agreed-
upon location in Frackville, Ph, at such times as the father
•..................................................... i_n',returning the children to the m9ther'e_custody..•
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; 15, The par as shall exchange n an an children's car vats,
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with the mother providlnq,tAese to the lather as necessary
4
c when he picks up the children. The lather shell promptly
,r
•. ?rsturn the car Data to the mother. at the time he returns the
children. 5
16 The lather may have partial custody of the children during .,
such additional period@ ¦e the parties shall froe tlei to time .,H
agree, without the need to modify the order of =urk entered
as s result of this stipulation.
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:.,_ ........_ ................... ... ,....., . ......,.... ......... .. ......,....
1:7• The parties rgree that the father shall be allowed reasonable
telephone time contact between himself and the children when
the children Are with the mother. tLkauf.. ..w_- .._
are with thli father, the mother shall be allowed reasonable..
telephone -contact with%he children.
?; 18• The parties agree that they shall obtain each other's written
convent before removing the children from Fennaylvacla, and
L fr c+r y? , they also agree to provide the' other parent an emergency .'
?? ''s 'tolaphons number' and address In the event they do remove the
children from Penn aylvanLa
fly ",q Neither parent shall do anything which may estrange the
try ,,
{ children from the other parent or injurs the opinicn o! tho
_ children as to tho other parent, or which may hamper the free
ham. J
"' - - :and natural development of the chLldren'e•inve ov Affection
for the othur parent. Likewise, each parent athall encourage
their rarlatLves not to belittle or disparage the other parent
f{h to the children.'
rj
Yp TAe' parties agree that In making tA
. + _
• Lw in agreement, there has
U r b9an no fraud 4
.? ..;v.?l ? _. , ,• concealment, overreaching, .coercion, or.other `.. unfair dealing ? .
py tiia on the part of the other •„ x :.
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I se
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ZW WITM BN WaEALor, the ps{ties hereto intending to be 1c9411y bound by the
t:
"arms hereof,, sett forth their hands and seals this 40th day of Cctobsr, 1995.
Ruby 0. Ndo s, Bequira
.''• Attorney fir Plalntlft CYNT I\ 6. JOliES G/%•?:„..'
30 West High Streat PlalntlL[
L Carllsl 7 PA 17017 ',? `?
1y?,?,?. Y lf'. '.r• ? ? / ?' L... ', •r 'N t'>v -Lhl .' ^F i'L'?i>•,y
ln7
erlo,.isqu re MICHAEL A. N a 4ti:
s Attor y for Dotondent
Suite 648 Defendant
Scranton Lita Building -
- . 538. Spruce Streat . ,;:
;'Scranton, 'PA " 18503-1818 '? - z-
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MAR " 8 M
i
CYNTHIA G. JONES, t IN THE COURT OF COMMON PLEAS OF
Plaintiff t CUMBERLAND COUNTY, PENNSYLVANIA
t
V. t NO. 94-4024 CIVIL TERM
t
MICHAEL A. JONES, t NO. 94-6877 CIVIL TERM
Defendant t
t CIVIL ACTION - LAW
IN R t PETITION FOR SPECIAL RELIEF AND PETITION TO TRANSFER VENUE
BEFORE SHEELY P J
ORDER
AND NOW, this Z :! day of MARCH, 1996, Michael Jones,
petition to transfer venue of this action to Wayne County is
DENIED. Cynthia Jones' petition for special relief in likewise
DENIED. However, Michael Jones is ordered and directed to resume
mortgage payments on the marital real estate immediately and to
continue payment each and every month until the property is sold.
Finally, with regard to the custody transfer issue, it is ordered
and directed that from the beginning of Daylight Savings Time in
the Spring to the end of Daylight Savings Time in the Fall, the
parties shall meet halfway to exchange the children when they are
returning from their father's care. At all other tidies, Michael
Jones is responsible for transportation. Also, Cynthia Jones is
ordered and directed to work with Michael Jones in order to
facilitate a satisfactory arrangement for picking up the children
on Fridays in the event that Michael Jones cannot take time off
from work.
By the Court,
Ruby D. Weeks, Esq.
For the Plaintiff
Raymond W. Ferrario, Esq.
For the Defendant i' arold E. Shealy, P.J.
r. •It ? i.l? L.., .I 11• ...I
:old ,, •, : i .., EXHIBIT
1113
I
CYNTHIA G. POaintiff t
t
V. t
t
MICHAEL A. JONES, t
Defendant t
t
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-4024 CIVIL TERM
CIVIL ACTION - LAW
NO. 94-6877 CIVIL TERM
IN REt PETITION FOR ¢PECIAL RELIEF AND PETTTTON TO TRANSFER VENUE
Before the court are two petitionst the petition of Cynthia
Jones (Wife)for special relief and the petition of Michael Jones
(Husband) to transfer venue in this case to Wayne County. We are
also called upon to settle a custody dispute about transportation
that could not be agreed upon in front of the custody
conciliator. We held a hearing on January 3, 1996, from which we
made the following findings of fact.
FIND ACS OF FACT
1. Husband is an adult male, 330 who resides at Box 318,
Rte. 296, Waymart, Wayne County.
2. Wife is an adult female, 30, who resides at 219 Front
Street, Boiling Springs, Cumberland County.
3. The parties married on April 19, 1986, and separated on
May 2, 1994.
4. They are the parents of three children: Christopher, 71
Brian, 4; and Rachel, 1.
5. The major assets of the parties are the funds
contributed by Husband to his retirement plane during the
marriage and the jointly owned marital residence located at 1127
Black Bear Road, Hamlin, Wayne County.
NO. 94-4024 CIVIL TERM
6. Husband is employed by a subsidiary of the Illinois Tool
Works in Wayne County, earning approximately $32,000 per year
gross.
7. He is also an officer in the Pennsylvania National
Guard, from which he earns approximately $9,000 per year gross.
8. Wife is not employed, although she is a college graduate
and certified teacher.
9. Husband pays $287 per week in child and spousal support.
10. Under the current custody order, Wife has primary
custody of the children, and Husband has them for two weekends
'i
per month.
11. It is, at minimum, a three hour trip from Husband's
residence to Wife's residence.
12. At the beginning of the current custody arrangement,
Husband would make the six-plus hour round trip to pick up and
drop off the children on his weekends.
13. Lately, the parties have been meeting halfway to
exchange the children on Sunday of Husband's weekends.
14. Wife does not own a car and must depend on her parents
for transportation.
15. On Fridays of his weekends with the children, Husband
f must leave work early in order to pick up the children on time,
I and he has indicated that he may not be able to continue to do
6o.
2
I ". SAL ,
NO. 94-4024 CIVIL TERM
16. Wife is afraid to be alone with Husband because he has
been verbally abusive and physically threatening to her in the
past.
17. The mortgage balance on the house is in dispute, but in
any event is in excess of $50,000.
18. The parties have attempted to sell the house, to no
avail, and could not come to an agreement in order to facilitate
rental of the house.
19. Mortgage foreclosure proceedings have been instituted
by the mortgage holder, T.A. Bank.
20. on November 26, 1995, Husband disciplined Christopher
by spanking him through his clothes.
21. A photo taken the day after the spanking indicated
severe bruising on Christopher's buttocks.
DISCUSSION
First, we will address Husband's petition to transfer venue
of this action to Wayne County. Husband contends that this
action should be transferred to Wayne County because, among other
things, the parties' jointly owned real estate is located there
and all witnesses related to his employment and earnings are
located there or in that area. Wife responds that this action
has been properly filed here and should not be moved.
We note initially that Pa.R.C.P. 1006 states:
(e) Improper venue shall be raised by
preliminary objection and if not so raised
shall be waived...
3
NO. 94-4024 CIVIL TERM
In this case, Judge Bayley of this court previously dismissed a
preliminary objection based on venue. Thus, the venue issue has
been decided, and a later petition to transfer venue should not
be considered. However, even if we were to consider the
petition, it is clear to us that venue in Wayne County is as
inconvenient for the Wife as venue in Cumberland County is for
the Husband. Furthermore, the testimony adduced at the hearing
contained no information that would compel us to assail Judge
Bayley's decision. The petition to transfer venue is therefore
denied.
Next, we shall consider the custody/transportation issue.
As it stands now, Husband has a round trip in excess of six hours
when picking up the children. The trip time is cut in half on
the Sunday trip to return the children when the aforementioned
exchange is made halfway. Husband desires to use the halfway
meeting point on both tripe. However, Wife has indicated that
the halfway exchange on Sundays is not feasible for her because
her father will no longer accompany her and she refuses to meet
Husband alone.
The hearing testimony indicated that the halfway exchange is
made at a McDonald's restaurant at the Frackville exit of
Interstate 81: a decidedly public place. Wife, however, fears
abuse if she meets Husband alone. Husband states that since his
employer has changed, he cannot leave in time to pick up the
children in Boiling Springs at 6:00 P.M. on Fridays. Therefore,
4
NO. 94-4024 CIVIL TERM
Husband avers, the halfway meeting point is not only convenient,
but necessary.
Both Husband and Wife are credible witnesses. However,
since they could not agree on this issue, we are forced to forge
a compromise for them. We find that the halfway meeting point in
Frackville is a good system. However, we are equally cognizant
of Wife's fears. Therefore, we will fashion an order directing
that the halfway meeting point shall be utilized, on the Sunday
return trip only, from the beginning of Daylight Savings Time in
the Spring until the end of Daylight Savings Time in the Fall.
Thus the exchange during that part of the year will be made in
daylight in a public place. We are also fully aware of Husband's
difficulties with work and his long round trip. We therefore
order and direct that Wife shall give him as much leeway as
possible in arranging times to pick up and drop off the children.
Additionally, we note that we would be willing to consider a
change in the above arrangement to require a halfway meeting on
both trips if it is shown that Wife has obtained her own
automobile.
Finally, we will address Wife's petition for special relief.
The petition contains two counts, one for mortgage relief and one
to compel Husband into psychological counseling. Regarding the
mortgage payments, the evidence at the hearing indicated that the
mortgage has not been paid in about six months and that
foreclosure proceedings had been instituted by the mortgage
5
NO. 94-4024 CIVIL TERM
holder. Because neither party was sure about the exact amounts
at issue, Husband's counsel represented to the court that he
would obtain up-to-date information about the foreclosure
proceedings. He has provided the court with that information in
a letter dated January 17, 1996. The letter stated that the
mortgage on the jointly owned real estate has been in default
since July 1, 1995. As of January, the principal, interest and
late charges due amounted to $2,851.80. The mortgage balance is
approximately $54,000. The present attorney fees for the
foreclosure proceeding are approximately $500 plus an additional
$200 for filing costs and service fees.
The holder of the mortgage, L.A. Bank, has assigned the
mortgage to Freddie Mac. The assignment, according to Gary
Lavelle, Assistant Vice President of Assets for the bank, and
Paul Horger, counsel for the bank, has greatly limited any
discretion that the bank would have had in dealing with this
foreclosure. Lavelle and Borger indicated that, in order to
satisfy Freddie Mac, the arrearage would have to be paid current
within three or four months. Lavelle also stated that it is
unlikely that Freddie Mac would accept a rental arrangement,
because that would neither pay the current debt nor take the
property out of foreclosure. Furthermore, Lavelle and Borger
both stated that an arrangement whereby the property is sold
would be infinitely preferable to any rental scheme.
On January 24, 1996, the court received a response letter
6
NO. 94-4024 CIVIL TERM
from Wife's counsel. The letter states that the principal
payment due as of January 22, 1996, is $50,776.30, and that
interest and late fees amount to $2,071.33. Wife agrees that the
attorney fees for the foreclosure are $500, but disputes the
costa associated with foreclosure. Upon speaking with Borger and
Lavelle, Wife's counsel learned that any rental scheme, to be
acceptable to Freddie Mac, would require a rent payment of $1100
and is therefore not feasible. The letter from Wife's counsel
also indicates that Wife has re-listed the property with Century
21 Real Estate for $60,000, which she wishes to reduce to
$59,000.
In her petition, Wife avers that her only income is the
support she receives from her husband, and that she
make current the mortgage payments. She desires an
the court directing the husband to make current the
payments in order to prevent foreclosure. Husband
that he does not have the funds in reserve to allow
the payments.
has no way to
order from
mortgage
represents
him to make
Before we resolve wife's petition, we must note that it in
not our custom to conduct the business of this court through
letters from counsel. If counsel had come to the hearing
prepared to examine the real estate issue, we would not have to
proceed in a manner that puts a severe strain on the court's
time.
7
NO, 94-4024 CIVIL TERM
We will not order Husband to make current the mortgage
payments at this time, because he cannot. We will, however,
order and direct that Husband resume the mortgage payments
immediately and continue paying until the property is sold. The
second count of Wife's petition for special relief seeks to
compel Husband into psychological counseling because of the
spanking incident on November 26, 1995. The evidence, including
a photograph of Christopher's buttocks after the spanking, showed
that the spanking was excessively severe. We cautioned Husband
at the hearing, and reiterate here, that any abuse will not be
tolerated, and will be dealt with swiftly and severely. However,
since the testimony reflected only one incident, we will not
direct psychological counseling at this time.
ORDER
AND NOW, this -,52Jl-tA day of MARCH, 1996, Michael Jones'
petition to transfer venue of this action to Wayne County is
DENIED. Cynthia Jones' petition for special relief is GRANTED in
part and DENIED in part. Michael Jones is ordered and directed
to resume mortgage payments on the marital real estate
immediately and to continue payment each and every month until
the property is sold. Finally, with regard to the custody
transfer issue, it is ordered and directed that from the
beginning of Daylight Savings Time in the Spring to the end of
Daylight Savings Time in the Fall, the parties shall meet halfway
8
NO. 94-4024 CIVIL TERM
to exchange the children when they are returning from their
father's care. At all other times, Michael Jones is responsible
for transportation. Also, Cynthia Jones is ordered and directed
to work with Michael Jones in order to facilitate a satisfactory
arrangement for picking up the children on Fridays in the event
that Michael Jones cannot take time off from work.
By the Court,
/a/ Harold Be Sheely
Harold E. Sheely, P.J.
Ruby D. Weeks, Esquire
For the Plaintiff
Raymond W. Ferrario, Esquire
For the Defendant
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MICIIAEL A..IONES, IN THE. COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNT'V,PENNSVLVANIA
V CIVIL ACTION - LAW
CVNTIllA.IONES, : NO.94-4024 CIVIL.
Defendant IN CUSTODV
COURTORDER
AND NOW, this ?'J44 day of July. 2001, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as tifllows:
A hearing is scheduled in Chun oont No. `!of the Cumberland County
Courthouse on the _11day of ld ui.rsiL><__ . 2001 at /; 3o e.M. at
which time testimony will he taken in the above case. At this hearing, the Father.
Michael A. Jones, shall be the moving party and shall proceed initially with
testimony. Counsel firr the parties shall file with the court and opposing counsel a
memorandum setting forth the history of custody in this case, a summary of each
parties position on the issues betbre the court, a list of witnesses who will he called
to testifv and a summary of the anticipated testimony of each witness. The issues
the court will address at this hearing are as follows:
A. Father's request to modify the prior order with respect to transportation for
exchange of custody.
B. Setting a location tier the parties to meet firr exchange of custody.
C. Determining whether Father is entitled to make-up time with any of the
children as a result of Mother's actions during the summer of 2001.
1). Setting a summer visitation schedule for Father firr 2002.
2. Pending further Order of this Court. the following custody Order shall be in effect
for the remainder of the summer:
A. Father shall have custody of the three minor children tram Sunday. July 8.
2001 at Noon until July 26. 2001 at 7:00 p.m. Father shall then resume
custody with the minor children on August 5, 2001 at Noon until August 9,
2001 at 7:00 p.m. when Father shall return Christopher to the Mother.
Father shall keep the other two minor children in his custody until August
26.'_001 at Noun.
B. Pending further order of this court. the parties shall exchange custody of the
minor children at the times set firth above with the location to be at the
McDonald's restaurant at the St. Claim exit off Interstate 81.
BY THE COURT.
cc: Ruby D. Weeks, Esquire
Frank J. Ruggiero, Esquire
960 Scranton-Carbondale Highway
Archbald. PA 18403
MICHAEL A. JONES,
Plaintiff
CVNTtIIA JONES,
Defendant
Prior.ludge:
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.94-41114 CIVIL
IN CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE. WTfll 'flII: CUMBERLAND COUNTY CIVIL RULE OI' PROCEDURE
1913.3-8(b), the undersigned Custody Conciliator submits the titllowing report:
I. The pertinent information pertaining to the children who are the subject of this litigation is
as follows:
Christopher Jones. born June 24. 1988: Brian Jones, bom May 14, 1991: and Rachel Jones.
bom October 26. 1994.
The Conciliator conducted numerous telephone conference calls with the attorneys for both
parties. There was a great deal of confusion as to when the Father would exercise custody
with the minor children during this summer. A temporary resolution was reached with
respect to some issues on custody. but a number of issues remain unresolved. A hearing is
necessary, and the Conciliator recommends the entry of the attached order to schedule a
hearing and also continn what the parties have agreed to with respect to the remainder of
this summer.
DATE
?14 (IQ
Hubert X.
Custody Si
Esquire
MICHAEL JONES, : IN THE COURT 01: COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. 94.4024 CIVIL.
CIVIL ACTION - LAW
CYNTHIA JONES,
Defendant
OR F,
AND NOW, this 30• day of July, 2001, hearing in the above captioned matter set
for September 7, 2001, is continued to Wednesday, October 3, 2001, at 1.30 p.m. in Courtroom
Number 4, Cumberland County Courthouse, Carlisle. PA.
Ruby Weeks, Esquire
For the Plaintiff
Frank Ruggiero, Esquire
109 N. Main Street
P. O. Box 178
Taylor, PA 18517-0178
For the Defendant
BY THE COURT,
--:?6 Vvy./
Kevin Hess, J.
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FRANK ]. RUGGIERO, ESQ.
AltwW for PkhW, Michael 7orow
[dawketim Ho, 79850
Low Onkmat
660 6aant n-Cnbonda a Highway
ArditK Pannaylvanle 16101
Phorm:(670)876-6001
Nov 2001
MICHAEL JONES
Plalntiff
Vs.
CYNTHIA JONES
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
IN CUSTODY
ORDER
AND NOW this 6+' day of A)gv.- ?
20010 It Is hereby ORDERED and DECREED that the attached Stipulation is hereby
adopted and made an Order of Court.
BY THE COURT:
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FRANK 3. RUGGIERO, ESQ.
Aft" for PMW f, Mldied 30M
wwakaum No. 79850
Law onimi
960 So Inn-Cii6a1b Highway
ArchbaK Pwm"ware 16403
Pharr (570) 876.6901
MICHAEL JONES
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
VS.
CIVIL ACTION - LAW
IN CUSTODY
CYNTHIA JONES
SSIIPULATION
AND NOW this Q 6 t day of _ & M?A-k
2001, upon Stipulation and Agreement of counsel for the Plaintiff, Michael Jones, and
counsel for the Defendant, Cynthia Jones, It Is hereby Stipulated and Agreed as follows:
1) That the parties are agreeable to continuing all outstanding matters for a
period of six (6) months and holding same In abeyance In the hopes of amicably
resolving existing Issues between the parties;
2) That the parties agree that they will share all transportation concerning
pick up and drop off of the minor children which will occur at the McDonald's at the
Frackville Exit off Interstate 81. The only exception to the above being the pick up and
drop off occurring in Hershey, PA when the Plaintiff, Mr. Jones, Is visiting his son,
Christopher, at the Milton Hershey School;
3) The parties agree that the Defendant, Ms. Jones, will continue working
with the Plaintiff, Mr. Jones, concerning his periods of partial custody due to his status
as a Major In the Pennsylvania Army National Guard and his Drill Schedule which Is
subject to change without notice;
4) That the parties will begin working on Summer Vacation Schedules for
Summer 2002 and exchanging same within forty five (45) days from date of this
Stipulation In the hopes of amicably resolving existing issues between the parties;
5) That the parties agree that they will keep each other appraised of all
major decisions concerning the minor children and each party agrees to provide
notification to the other concerning change In schedules, vacations, etc.
6) It Is further agreed by and between the parties that all other provisions of
the March 25, 1996, Court Order shall remain In full force and effect until further Order
of Court
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Frank . Rugg e , Esquire
Ruby D. VMeks, Esquire
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CYNTHIA 0. JOlmo, I IN THE COURT OF COMMON PLEAS 0 AUG l) 2002
Plaintiff I CUMESRLAND COUNTY, PENNSYLVANIA
I
va, I CIVIL ACTION • LAM
I CUSTODY
MICHAEL A. JONES, I
Defendant I 094.4014 CIVIL TERM
ORDER OE COURT'
AND NOW, this day of Ofil"w , 20_, upon agreement of the parties, the attached
Custody Stipulation and Agreement is made an Order of Court.
/4uby D. Weeks, Esquire For Plaintiff
Frank J. Ruggiero, Esquire For Defendant
BY THE COURT,
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CYNTHIA 0. JOHNS,
Plaintiff
Va.
NICHAIL A. JONRS,
Defendant
i IN THR COURT OF CONKON PLUAS OF
CUNBRRLAND COUNTY, PRNNSYLVANIA
i CIVIL ACTION - LAW
i CUSTODY
s 094-4024 CIVIL TRRH
{CUSTODY STIPULATION
AND NOW, this r!' _ day ot'June, 2002, upon stipulation and agreement of the
parties, and of counsel, Frank Ruggerio, Esquire for the Plaintift7father, Michael A. Jones and
Ruby D, Weeks, Esquire for the Defendant/Mothcr, Cynthia G. Jones it is hereby stipulated and
agreed as follows:
I, a. The Plaintiff is Cynthia G. Jones, Mother residing at 109 Andrew Court, Carlisle,
Cumberland County, Pennsylvania.
b. 'The Defendant is Michael A. Jones, Father residing at 9 Falls Lane, Blakely,
Wayne County, Pennsylvania, 18447.
The parties are agreeable to a modification of custody stipulation order dated
October 26, 2002 and the stipulation order dated October 20, 1994 for the custody
of two of their children, Rachel age seven and Brian age eleven.
The parties agree that custody arrangements for Christopher who is at the Milton
Hershey School shall continue as they are at present with Christopher in the
Mother's primary physical custody and periods of partial custody with the father.
4. The parties shall each continue to have joint-shared legal custody of all three
children. Primary physical of Rachel shall be with the mother and temporary
primary physical custody of Brian shall be with the father for one year. However
during the period of time father is on temporary active
duty with the military, Brian will be in the custody of
paternal grandparents, Allan and Carol Jones at their
residence. The children during this time will continue
with the visitation as setforth herein. 4*4115v.
,%*,
S, Effective June 15, 2002 Brian shall spend two weekends per month from 6:00
p,m, Friday to 6:00 p.m. Sunday with the father and two weekends per month 6:00
p.m, Friday to 6:00 p.m. Sunday with the mother. Once per month each parent
shall have both children at the same time for a weekend period.
lf*W, .0 ZK Meat '
6. Each parent shall have ter(duys durin6Acuch summeAvith cacH'child, Rachel and
Brian, separately,
7. Neither child is required to spend the time outlined in paragraphs five and six with
the non-custodial parent, should the child not wish to do so. However, each
parent agrees to make their best efforts to encourage and persuade the children to
comply with the terms of this agreement.
8. The father agrees ?o assume responsibility for obtaining any necessary counseling
services for Brian and for continuing his orthodontic care in Cumberland County.
9. The parties agree that they shall share all transportation concerning pick-up and
drop-off of the minor children which will occur at the McDonald's at the
Frackville Exit off Interstate 81. The only exception to the above being the pick-
up and drop-off occurring in Hershey, PA, when the Defendant, Mr. Jones, is
visiting his son, Christopher, at the Milton Hershey School.
10, The parties agree that they will keep each other appraised of all major decisions
concerning the minor children and each party agrees to provide notification to the
other concerning change in schedules, vacations, etc, and that custody periods
shall be arranged between the parties and confirmed at least one week in advance.
I La. Commencing in 2002 and odd-numbered years thereafter, the father shall have
partial custody of the children each Thanksgiving, each Easter Sunday, and one-
half of whatever school vacation is provided by the school calendar, which is to
include the holiday, In the even-numbered years, the mother will have the
Thanksgiving and Easter Sunday holidays and one-half of the school vacation for
those holidays. The parent not having the children for the holiday shall have the
remaining one-half of the school vacation, Thanksgiving and Easter holidays each
year.
b. On odd-numbered years the mother shall have the first half of the children's
school holiday to include both Christmas Eve and Christmas Day; the father shall
have the second half of that school holiday period.
C. On even-numbered years the father shall have the first half of the children's
school holiday to include both Christmas Eve and Christmas Day; the mother
shall have the second half of that school holiday period,
d. The father shall always have partial custody of the children on Father's Day from
9:00 a,m. to 8:00 p.m. and the mother on Mother's Day, even if that day would
have otherwise been a day for custody of the children with the other parent.
e. The father shall have some period of partial custody with each child on the child's
birthday and on the father's birthday to celebrate the occasion. Likewise, the
mother shall always have time with each child on her birthday and on the child's
birthday even if these days were ordinarily days of the father's partial custody.
12. The parties agree that each parent shall be entitled to have conferences with any
physician, dentist, counselor, or other health care provider, treating the children,
and each parent shall be entitled to copies of reports regarding a child's treatment.
4
13. The parties shall notify each other in a timely fashion if it is necessary due to an
emergency or unforeseen circumstance for him or her to be delayed at any of the
times set out herein. It is intended, however, that time be of the essence, and that
the parties as strictly as possible comply with the times set forth therein.
14. The parties will notify and consult with the other party immediately in cases of
medical emergencies that occur while the children are in each parent's custody.
15, The parties acknowledge that the child has the following medical conditions and
that each parent will ensure that the recommended dietary, medical and
environmental restrictions and treatments arc adhered to, including but not limited
to, nonexposurc to animals and cigarette smoke, and that the children will receive
all prescribed dosages of medication and treatment as directed by the physician.
a. Rachel - Severe allergies to smoke, cats and has allergen induced asthma
and migraines.
b. Brian - Suspected colitis and gastro intestinal problems
16. The parties may have such other periods of partial custody of the children during
such additional periods as the parties shall from time to time agree, without the
need to modify the Order of Court entered as a result of this stipulation.
17. The parties agree that each party shall be allowed reasonable telephone contact
with the children when the children are with the other parent.
18. Neither parent shall do anything which may estrange the children from the other
parent or injure the opinion of the children as to the other parent, or which may
hamper the free and natural development of the children's love or affection for the
other parent. Likewise, each parent shall encourage their relatives not to belittle
or disparage the other parent to the children,
19. The panics agree that in the making this Agreement, there has been no fraud,
concealment, overreaching, coercion, or their unfair dealing on the part of the
other.
IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms
hereof, set forth their hands and seals this _ day of
2002.
L
Ruby D. Weeks, Esquire
Attorney for Plaintiff
10 West High Street
Carlisle, PA 17013
Frank k`RuggiL1fKo, Esquire
Attorney for Defendant
960 Scranton-Carbondale Hwy
Archbald, PA 18403
J
ynthia G. J s
Plaintiff-mot er
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF CUMBERLAND
ss
On this, the -L,n day of 2002, before me, a
Notary Public, the undersigned otOcer, personally appeared CYNTHIA G. JONES, known to me to
be the person whose name is subscribed to the within Custody Stipulation and Agreement, and
acknowledged that she executed the same for the purposes therein contained,
4 Y1 to 62J
E777 Notary Public
COMMONWEALTH OF PENNSYLVANIA :
ss
COUNTY OF CUMBERLAND
On this, the day of 2002, before me,' a
Notary Public, the undersigned officer, rsonally appeared MICHAEL A. JONES, known to me to
be the person whose name is subscribed to the within Custody Stipulation and Agreement, and
acknowledged that she executed the same for the purposes therein contained.
( &Uzz ?r51(?l.il
Notary Public
NOIARIAL SEAL
Lj AEN L. PICCOTTI, NOIARY PMIC
OR DORO LACKAWANNA COUNTY
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CYNTHIA G. JONES, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
MICHAEL A. JONES, No. 944024 CIVIL TERM
Defendant/Petitioner IN CUSTODY
PETITION TO MODIFY CUSTODY
1. Petitioner is Michael A. Jones, who resides at 105 Sixth Street, Blakely, Pennsylvania 18447.
2. Respondent is Cynthia G. Jones who resides at 41 Camelot Drive, Carlisle, Cumberland
County, Pennsylvania 17013.
3. On August 8, 2002, the Honorable Kevin A. Hess entered an Order of Court pursuant to the
Stipulation signed by the parties. (Attached as Exhibit "A")
4. Since the entry of said Order, there has been a significant change in circumstances in that:
a. One of the children has behavioral issues and has been in trouble with the local
authorities and has been committed to Phil Haven for substance abuse and uncontrollable
behavior since being in Mothers care.
b. The mother has demonstrated that she is not stable enough to raise the children.
c. The Petitioner is best able to undertake and perform the primary parental responsibilities
for the child.
c. Petitioner is best able to provide a stable household for the child.
5. The best interest of the child will be served by the Court in modifying said Order.
6. As this is a request to modify a current Custody Order it is assumed the opposing counsel
Ruby D. Weeks, Esquire is opposed to this modification request.
WHEREFORE, Plaintiff prays this Court to grant the modification of the Custody Stipulation
and Court Order of August 8, 2002 as follows: Petitioner is granted primary physical custody of
Brian N. Jones and Rachel E. Jones with Mother having periods of partial physical custody.
Respectfully submitted,
Rominger & Associates
Date: January 28, 2008
1 E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Defendant/Petitioner
CYNTHIA G. JONES, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
MICHAEL A. JONES, No. 94-4024 CIVIL TERM
Defendant/Petitioner IN CUSTODY
VERIFICATION
I verify that the statements made in this complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to
unworn falsification to authorities.
R f'• 11 ?_
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CU!`GE?ri ;;? „r ???1Uf11Y
PENMjYLVWA
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Plaintiff ,
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HICKUL A. JOK16, t
Defendant ,
IN TUX COUNT OF COMMON PLXAS OF
CUMIRLAND COUNTYI PsKKSYLVANIA
CIVIL ACTION - LAM
CVMDY
094-4024 CIVIL T=Ntt
QS'rODY S'rIPULA110N
AND NOW, this day of'Junc, 2002, upon stipulation and agreement of the
parties, and of counsel, Drank Ruggerio. Esquire for the Plaintiff/father, Michael A. Jones and
Ruby D. Weeks, Esquire for the Dcfendant/Mother, Cynthia G. Jones it is hereby stipulated and
agreed as follows;
1. a. The Plaintiff is Cynthia G. Jones, Mother residing at 109 Andrew Court, Carlisle,
Cumberland County, Pennsylvania.
b. The Defendant is Michael A. Jones, Father residing at 9 Falls Lane, Blakely,
Wayne County, Pennsylvania, 18447.
2. The parties are agreeable to a modification of custody stipulation order dated
October 26, 2002 and the stipulation order dated October 20, 1995 for the custody
of two of their children, Rachel age seven and Brian age eleven.
I The parties agree that custody arrangements for Christopher who is at the Milton
Hershey School shall continue as they are at present with Christopher in the
Mother's primary physical custody and periods of partial custody with the father.
4. The parties shall each continue to have joint-shared legal custody of all three
children. Primary physical of Rachel shall be with the mother and temporary
primary physical custody of Brian shall be with the father for one year. However
during the period of time father is on temporary active
duty with the military, Brian will be in the custody of
paternal grandparents, Allan and Carol Jones at their
residence. The children during this time will continue
with the visitation as setforth herein. 4rAr5r?
2
AM
S. Effective June 15,2002 Brian shall spend two weekends per month from 6:00
p.m. Friday to 6:00 p.m. Sunday with the father and two weekends per month 6:00
p.m. Friday to 6:00 p.m. Sunday with the mother. Once per month each parent
shall have both children at the some time for a weekend period.
couft turinleach W k'''?
6. Each parent shall have tchuys summc&ith cacN'chiid. Rachel and
Brian, separately.
7. Neither child is required to spend the time outlined in paragraphs five and six with
the non-custodial parent, should the child not wish to do so. However, each
parent agrees to make their best efforts to encourage and persuade the children to
comply with the terms of this agreement.
8. The father agrees to assume responsibility for obtaining any necessary counseling
services for Brian and for continuing his orthodontic care in Cumberland County.
9. The parties agree that they shall share all transportation concerning pick-up and
drop-off of the minor children which will occur at the McDonald's at the
Frackville Exit off Interstate 81. The only exception to the above being the pick-
up and drop-off occurring in Hershey, PA, when the Defendant, Mr. Jones, is
visiting his son, Christopher, at the Milton Hershey School.
10. The parties agree that they will keep each other appraised of all major decisions
concerning the minor children and each party agrees to provide notification to the
other concerning change in schedules, vacations, etc. and that custody periods
shall be arranged between the parties and confirmed at least one week in advance.
1 La. Commencing in 2002 and odd-numbered years thereafter, the father shall have
partial custody of the children each Thanksgiving, each Easter Sunday, and one-
half of whatever school vacation is provided by the school calendar, which is to
include the holiday. In the even-numbered years, the mother will have the
Thanksgiving and Easter Sunday holidays and one-half of the school vacation for
those holidays. The parent not having the children for the holiday shall have the
remaining one-half of the school vacation, Thanksgiving and Easter holidays each
year.
b. On odd-numbered years the mother shall have the first half of the children's
school holiday to include both Christmas Eve and Christmas Day; the father shall
have the second half of that school holiday period.
C. On even-numbered years the father shall have the first half of the children's
school holiday to include both Christmas Eve and Christmas Day; the mother
shall have the second half of that school holiday period.
d. The father shall always have partial custody of the children on Father's Day from
9:00 a.m. to 8:00 p.m. and the mother on Mother's Day, even if that day would
have otherwise been a day for custody of the children with the other parent.
e. The father shall have some period of partial custody with each child on the child's
birthday and on the father's birthday to celebrate the occasion. Likewise, the
mother shall always have time with each child on her birthday and on the child's
birthday even if these days were ordinarily days of the father's partial custody.
12. The parties agree that each parent shall be entitled to have conferences with any
physician, dentist, counselor, or other health care provider, treating the children,
and each parent shall be entitled to copies of reports regarding a child's treatment.
4
13. The parties shall notify each other in a timely fashion if it is necessary due to an
emergency or unforeseen circumstance for hint or her to be delayed at any of the
times set out herein. It is intended, however, that time be of the essence, and that
the parties as strictly as possible comply with the times set forth therein.
14. The parties will notify and consult with the other party immediately in cases of
medical emergencies that occur while the children are in each parent's custody.
15. The parties acknowledge that the child has the following medical conditions and
that each parent will ensure that the recommended dietary, medical and
environmental restrictions and treatments arc adhered to, including but not limited
to, nonexposure to animals and cigarette smoke, and that the children will receive
all prescribed dosages of medication and treatment as directed by the physician.
a. Rachel - Severe allergies to smoke, cats and has allergen induced asthma
and migraines.
b. Brian - Suspected colitis and gastro intestinal problems
16. The parties may have such other periods of partial custody of the children during
such additional periods as the parties shall from time to time agree, without the
need to modify the Order of Court entered as a result of this stipulation.
17. The parties agree that each party shall be allowed reasonable telephone contact
with the children when the children are with the other parent.
18. Neither parent shall do anything which may estrange the children from the other
parent or injure the opinion of the children as to the other parent, or which may
5
hamper the free and natural development of the children's love or affection for the
other parent. Likewise, each parent shall encourage their relatives not to belittle
or disparage the other parent to the children.
19. The parties agree that in the making this Agreement, there has been no fraud,
concealment, overreaching, coercion, or their unfair dealing on the part of the
other.
IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms
hereof, set forth their hands and seals this day of
2002.
Ruby D. Weeks, Esquire
Attorney for Plaintiff
10 West High Street
Carlisle, PA 17013
Frank . uggi , Esquire
Attorney for Defendant
960 Scranton-Carbondale Hwy
Archbald, PA 18403
411, /oz
ynthia G. J s
Plaintiff-mot er
Michael . J
Defendan 4a *,
6
COMMONWEALTH OF PENNSYLVANIA :
: sa
COUNTY OF CUMBERLAND
On this, the 11 ev day of 11;1 , 2002, before me, a
Notary Public, the undersigned officer, personally appeared CYNTHIA G. JONES, known to me to
be the person whose name is subscribed to the within Custody Stipulation and Agreement, and
acknowledged that she executed the some for the purposes therein contained,
w t (?vw_ A JT 17 o?IJZ caj
OMA. i cow-"
Notary Public
COMMONWEALTH OF PENNSYLVANIA :
ss
COUNTY OF CUMBERLAND
On this, the GITday of A , 2002, before me,' a
Notary Public, the undersigned officer, rsonally appeared MICHAEL A. JONES, known to me to
be the person whose name is subscribed to the within Custody Stipulation and Agreement, and
acknowledged that she executed the same for the purposes therein contained.
AZA
Notary Public
MOTARU1l 3EAl
KAHNLNCCORT I.NOtARrPAS
TAYLOR IORO. tACNAWAINA COIMItY
W COMMISSION EIM3 DEC. 1
7
CYNTHIA G. JONES, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
MICHAEL A. JONES, No. 94-4024 CIVIL TERM
Defendant/Petitioner IN CUSTODY
CERTIFICATE OF SERVICE
I, Karl E. Rominger, Esquire, attorney for Plaintiff, Walter Hockley, do hereby certify that I
this day served a copy of the Petition to Modify Custody upon the following by First Class Mail
delivery at Carlisle, Pennsylvania, addressed as follows:
Ruby D. Weeks, Esquire
P.O. Box 397
Carlisle, PA 17013
Date: January 28, 2008
Respectfully submitted,
Rominger & Associates
Kaff E. Rominger, Esquire
15 5 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Defendant/Petitioner
TO.
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CYNTHIA G. JONES IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
MICHAEL A. JONES
DEFENDANT
1994-4024 CIVIL ACTION LAW
. IN CUSTODY
ORDER OF COURT
AND NOW, Wednesday, January 30, 2008 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, March 06, 2008 at 8:30 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 Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Hubert X. Gilroy, 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
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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CYNTHIA G. JONES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 1994-4024
CIVIL ACTION - LAW
MICHAEL A. JONES,
Defendant : IN CUSTODY
PRACEIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Kindly enter the appearance of Andrew H. Shaw, Esquire as counsel of record for the Plaintiff.
Date:
BY:
Sup. Ct. ID No. 87371
200 S. Spring Garden St.
Suite 11
Carlisle, PA 17013
717-243-7135
CERTIFICATE OF SERVICE
I, Andrew H. Shaw, Esquire, do hereby certify that a true and correct copy of the
following document, Praecipe To Enter Appearance, was served this date on the below
named, by placing same in the United States mail, first-class, postage prepaid thereon,
addressed as follows:
Karl E. Rominger, Esquire
Rominger & Associates
155 South Hanover Street
Carlisle, PA 17013
Attorney for Defendant
Date: ; ???-- Qk
co
CYNTHIA G. JONES IN THE COURT OF COMMON PLEAS
Plaintiff/Respondent OF CUMBERLAND COUNTY
PENNSYLVANIA
V.
MICHAEL A. JONES CIVIL ACTION - LAW
Defendant/Petitioner No. 94-4024 Civil Term
IN CUSTODY
PRAECIPE
To the Prothonotary of Cumberland County
Please withdraw my appearance in the above matter.
C
Ruby D. Weeks, Esquire
P.O. Box 397
Carlisle, Pa. 17013
Ph. 243-1294
I agree to the above withdrawal.
ynthia A. Jo
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CYNTHIA G. JONES,
Plaintiff
v
APR 0 S 200BXY71
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
MICHAEL A. JONES, NO. 1994-4024
Defendant IN CUSTODY
COURT ORDER
AND NOW, this day of April, 2008, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
1.
2.
3
4.
The terms of the existing Custody Order dated August 8, 2002, shall remain in effect subject
to the modifications set forth below.
The parties shall make arrangements through their counsel to have both minor children
involved in counseling. Relative to Rachel, the intent of the counseling shall be to determine
what issues, if any, Rachel has relative to visiting with her father. It is anticipated that the
counselor will include the mother and father in the counseling sessions and it is the
anticipated goal of the counseling sessions to have Rachel start exercising a meaningful
relationship with her father.
With respect to counseling involving Brian, the focus of that counseling shall be generally to
determine Brian's desires on the current custody situation and what preference, if any, he
may have with respect to a potential modification of primary custody. Again, both mother
and father may be involved in those counseling sessions as determined by the counselor.
The counselor has the ability to share the results of the counseling sessions with both parents
and their attorneys as the sharing of such information is deemed appropriate by the
counselor.
5. Cost of the counseling sessions, that are not paid for by applicable insurance of both parents,
shall be shared equally between the parties.
FUD-OffirCE
THE PR(Ti-?LNOTARY
APR 14 AM 11: 16
PEENNS",TVAN
6. Father shall continue to have custody arrangements as he has enjoyed in the past.
7. Legal counsel for the parties may contact the Conciliator directly to schedule another
custody conciliation conference which just may be a telephone conference between the
attorneys and the Conciliator. At that time and in the event the process is not moving
forward, either party may ask that a hearing be set before a Judge.
BY THE COURT,
Judge Kkvin A. Hess
cc: VKarl E. Rominger, Esquire
/Andrew H. Shaw, Esquire
0-4T tizz MatU-
'Sl/l'6`0
CYNTHIA G. JONES,
Plaintiff
v
MICHAEL A. JONES,
Defendant
Prior Judge: Kevin A. Hess
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1994-4024
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 children who are the subject of this litigation
is as follows:
Rachel E. Jones, born October 26, 1994, and Brian N. Jones, born May 14, 1991.
2. A Conciliation Conference was held on April 4, 2008, with the following individuals in
attendance:
The mother, Cynthia G. Jones, with her counsel, Andrew H. Shaw, Esquire, and the father,
Michael A. Jones, with his counsel, Karl E. Rominger, Esquire.
3. The parties agree to the entry of an Order in the form as attached.
Date: (-tl J 8 -? / Hubert X. GVi?iiator
Esquire
Custody Con
AUG o i zooeC?,
CYNTHIA G. JONES, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v CIVIL ACTION - LAW
MICHAEL A. JONES, NO. 1994-4024
Defendant IN CUSTODY
COURT ORDER
AND NOW, this f-4 day of 2008, upon consideration of the attached
Custody Conciliation Report, it is ordered d directed as follows:
1. A hearing is scheduled in Court Room No. 4 of the Cumberland County Courthouse on the
6W day of -00?k-4 , 2008 at 3U?a .m. At this hearing, the father shall be the
moving party and shall proceed initially with testimony. Counsel for the parties shall file
with the Court and opposing counsel a memorandum setting forth the history of custody in
this case, the issues currently before the Court, a summary of each parties position on these
issues, a list of witnesses who will be called to testify on behalf of each party and a summary
of the anticipated testimony of each witness. This memorandum shall be filed at least five
days prior to the mentioned hearing date.
2. Pending further Order of this Court, this Court's prior Order of April 14, 2008 shall
remain in effect.
3. In the event legal counsel for the parties believe another Custody Conciliation would be
helpful prior to the hearing, counsel for the parties may contact the Custody Conciliator
directly to schedule such a conciliation.
BY THE
cc: ar. . Rominger, Esquire '
drew H. Shaw, Es
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CYNTHIA G. JONES,
Plaintiff
v
MICHAEL A. JONES,
Defendant
Prior Judge: Kevin A. Hess
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1994-4024
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 Conciliator conducted a telephone conference with legal counsel for the parties. It
was determined that the father wanted to proceed with scheduling a hearing in this case
because of problems the parties were having agreeing upon a counselor and other matters
set forth in the April 14, 2008 Order.
2. The Conciliator recommends and Order in the form as attached.
Date: 1,1,g
4bX., , dilroy, Esquire
Custody'Conciliator
CYNTHIA G. JONES, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V
CIVIL ACTION - LAW
MICHAEL A. JONES, NO. 1994-4024 CIVIL TERM
Defendant IN CUSTODY
IN RE: PETITION FOR CUSTODY
ORDER OF COURT
AND NOW, this 16th day of October, 2008, in accordance
with the agreement of the parties as announced in open court and
in their presence, it is ordered and directed that the previous
custody orders in this matter are modified as follows:
1) The father shall have visitation one weekend per
month. The parties shall share transportation and exchange the
children in Frackville, Pennsylvania.
2) During the mother's periods of custody the father
shall have reasonable telephone contact with the children.
3) The minor child, Rachel, is to continue counseling
with Franco Associates with the specific goal of resuming
visitation with the father. Once visitation is recommended by
the counselor and resumed, the father shall arrange for and
provide family counseling sessions during his one weekend a month
for himself and Rachel. Further, should Rachel's counselor not
believe that reunification is in the best interests of the child
or can be accomplished in a reasonable time frame, said counselor
is instructed to notify mother of the same so that father can be
made aware and alternative provisions can be considered by the
parties.
4) Holiday visitation for the Christmas holiday shall
be accomplished by splitting the school vacation for the minor
children in half, with one parent to receive the first half of
the school break and the other parent to receive the second half
¦ .
JONES V. JONES - NO. 1994-4024
of the school break. The intention being that one party will
receive Christmas and one party will receive New Year's
alternating each year. The father will receive the second half
of the school break this year, and mother shall receive it in
each alternating year thereafter.
5) Joint legal custody in both parties is reaffirmed
herein. All counselors and medical practitioners are instructed
to share information about the minor child's counseling and
treatment equally with both parents.
All other terms and conditions of prior orders not
inconsistent herewith shall remain in full force and effect.
By the Court,
drew H. Shaw, Esquire
For the Plaintiff
,; rl E. Rominger, Esquire
For the Defendant
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