HomeMy WebLinkAbout94-04035
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SEP 0 II 200W"-'
l.ARRY l.EE L1EBRlJM, JR..
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
SHARON E. CRAMER,
Defendant
NO, 94 - 4035 CIVIL
IN CUSTODY
COURT ORDfJ!
AND NOW, this 111\ day of September. 2000, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
cc:
I.
A hearing is scheduled in Courtroojp No.2 of the Cwnberland County Co_urthouse
on the _~'O day of '--j(~-LH~ . 2000, at I: 3d ~.M. at
which time testimony will be taken in the above case, At this hearing, the Father,
Larry Lee Liebrum. Jr" shall be the moving party WId shall proceed initially with
testimony, Counsellor the parties shalllile with the Court and opposing counsel a
memorandum selling forth the history of custody in this case, the issues currently
before the Court, a list of witnesses who will be called to testify at the hearing and a
summary of the anticipated testimony of each witness, This memorandum shall be
tiled at least three (3) days prior to the mentioned hearing date,
2,
In the event either party desires to have any type of evaluation performed in advance
of the hearing. the other party will make themselves available tor the evaluation and
ensure that the minor child is involved in the evaluation, Upon the request of the
evaluator. each party shall ensure that any significant other in their life participates
in the evaluation.
3.
Pending further Order of this Court, the following temporary custody ordel' is
entered with the understanding that this temporary order does not prejudice either
parents ability to suggest a dillerent custody order at the hearing:
A.
The parties shall share legal custody of Kayla Elizabeth Liebrum,
born June 6. 1992 with the Mother having primary physical custody
on a temporary basis and the Father enjoying periods of temporary
physical custody on alternating weekends from Friday at 5:00 p.m.
until Sunday at 5:00 p.m. Additionally, Father shall also have
periods of temporary custody at such times as agreed upon by the
parties. __
BY THE C~.,/' 'f";
r--.,< / /,
" / ~
,~-
Edgar B, Bayley
Karl E. Rominger, Esquire
Johnna J. Deily, Esquire
J. ct\Y
, .\' 'DO
G~ ()/~ ~
>
It is proposed that the parties share legal custody of the
child, with mother having primary physical custody of the
child, subject to periods of partial physical custody on an
alternating weekend basis by the father. It is also proposed
that the parties share holidays and the parties enjoy two
uninterrupted weeks of custody in the summer months.
Respectfully submitted,
SAlOIS, SHUFF, FLOWER & LINDSAY
Date /1-10-00
Johnn
Attar ey I. . #53147
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Attorney for Defendant
3
.
On this
CERTIfICATE Of SERVICE
:;J I 15' day of Y~7.-f.(:nht",-
, 20_, I
hereby certify that I served a true and correct copy of the
foregoing Pre-Trial Memorandum upon all parties of record via
United States Mail, postage prepaid, addressed as followsl
Karl Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
SAIDIS, SHUFF, FLOWER & LINDSAY
By, rY*r-1'
SAlDIS
SH\J!'t.tlDWER
& UI"luSAY
-..- ....
MW.JUP-
eo...... 'A
LARRY LEE L1EBRlIM, JR.,
Petltlontr/F.thu
v.
: IN THE COURT Of' COMMON PLUS OF
: CUMBERLANI) COlINTY, PENNSYLVANIA
: NO. 94.4035 CIVIL TERM
SHARON E. C:RAMF.R,
Respondent/Mother
: IN CUSl'OI)Y
fRETRIAL ClJSl'OI)Y....ME,MORANlnJM
.lM.CK(;ROUND
The parties have been ill dispute over the custody of their daughter, Kayla. for many years
now. Petitioner.1.arry Lee 1.il'brum. Jr.. adopts the report of Hubert X. Gilroy. Custody
Conciliation Report,
Your Petitioner feels it important to point out that in order to enforce the Custody Order
of June 1995. and to even see his child at all, he had to take Respondent to an emergency hearing
in front of the Honorable J, Wl'sley Oler. Since then. the parties have been lollowing the
provisions of that Temporary Order as the conciliator was unwilling to return the child to the
week on/week off schedule,
Your Petitioner believe.. that Rcspondent has evidenced sullicient disinterest in the
child's welfare and has so obstructed your Petitioner's visitation. that the best remedy would be
granting primary physical custody to your Petitioner, Petitioner would have no objection to
extremely liberal but pal1ial vi~itation in Respondent.
WITNESSES
I, Petitioner. Larry L1ehrum is expected to testily to his ability to care for the child. his
history with the child, and his frustrations as a rcsult of Respondent, Shanlll E. Crl1tl1cr's inability
to comply with the Custody Order.
2. Kelly Block is Petitioner's sister and will testily to various interactions which
Petltionl~r has with Kayla, the family situation, and her observations of the relationship between
Petitioner and Respondl'nt in regards to the exchange of Kayla.
3. Steve Block is the husband of Kelly Block and the brother-in-law of Petitioner, He
will be called to verify Kelly Block's statements if necessary,
4. Arthur L1ebrum, Sr. is Petitioner's father and patemalgrandfather of Kayla I1I1d he
will testify with his interactions with the child. his son's interactions with the child and his
observations of the custlldy situationlll1d exchanges and communications amongst the parties,
5. Barbara L1ebrum is the child's patemalgrandmother and is expected to testify to the
care she provides for thl: child, the care that Petitioner. Larry Liebrum provides for the child, and
the circumstlll1ces surrounding the custody situation over the last several ycars.
6. Emily L1ebrum is the Petitioner's sistcr-in-Iaw and she will be expected to testify to
the circumstances surrounding the custody situation over the last sevcral years.
7. Sharon E. Cramer. Respondent will be called as if on cross. Respondent will be
asked why she has failed to comply with the Court Order, why a contempt procceding was
necessary, and as to whethcr or not she would be able to faithfully comply with any other Order
for visitation in the future. Additionally, Rcspondent will be questioned about her care of the
child, including an incident where she allowed the child to go several blocks and cross a busy
highway on her own, and other similar incidences, including taking the child into bars.
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SAlOIS,
SHUFF &
MASLAND
A'ITDINlYIIAT-aAW
16 W. HI'" Sir'"
CUU.II, PA
APR 1 4 199~ 'J
LARRY LEE LIEBRUM, JR,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL--ACTION
v.
SHARON E. CRAMER,
Defendant
NO. 4035 CIVIL 1994
IN CUSTODY
ORDER OF COURT
AND NOW, upon consideration of the attached petition, it
is hereby directed that the parties and their respective
counsel appear before \-\.l\yr\,/- (';\\\ll"'\\\.:>'\.\c ' the
conciliator, at ~c I.\l"'n J,un\y\ X{\c\. (0. (o.J'\-'O..l)e...,on the
day of _~c \\ 1999, at ':oS, ~)O \,\.m. for a Custody
Conciliation 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 a temporary Order. All children aged
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.
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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
FOR THE COURT,
By :l~\\\J.n\.1-.d"\~\~
\'1'i:>i)
SAlOIS.
SHUFF &
MASLAND
"...........lTIlAW
16 W. Hip Sir'"
Co""". PA
LARRY LEE LIEBRUM, JR.,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION . LAW
: NO. 4035 CIVIL 1994
IN CUSTODY
v.
SHARON E. CRAMER,
Defendant
fl1ITION POR MODIPICATION
AND NOW COMES, the Defendant, Sharon Cramer by and
through her attorneys, saidis, Shuff & Masland and respectfully
avers the following:
1. A Concilliation Conference was held on August
7,1997 based on a petition for Modification previously filed by
the Defendant, to alter the week on, week off schedule that has
been ordered by the Court on June 7, 1995; a copy of said Order
is attached hereto and made a part hereof marked Exhibit "A".
2. pursant to the Concilliation Report and subsequent
Order dated August 22, 1997, the parties were to undergo a
custody evaluation performed by an independent evaluator; an
evaluation was performed by the Stevens Center in March of 1998,
although copies were not mailed out until March of 1999.
3. The circumstances have changed whereby the shared
custody situation is no longer in effect, but in practice, the
Defendant has had primary physical custody subject to very
limited periods of partial physical custody in the Plaintiff.
WHEREFORE, the Defendant respectfully requests Your
Honorable Court to enter an order granting her primary physical
custody of said child, subject to periods of partial physical
custody in the Plaintiif as the parties may agree, or as the
Court shall order.
SAlOIS,
SHUFF &
MAS LAND
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CUSTODY EVALUATION
Re: L1ebrum V. Cramer
Page 2
Larry Llebrum (natural father)
March 17, 1995
April 18, 1995
Initial Interview
Parent Sentence Completion Test
Child Management Questionnaire
Second Interview
Life History Questionnaire
Kayla Elizabeth Llebrum
March 18, 1995
Marcil 23, 1995
Parent-Child Observation
(accompanied by father)
Parent-Child Observation
(accompanied by mother)
BACKGROUND:
Sharon and Larry dated Intermittently for a seven year period. She became
pregnant September of 1991, Larry was uninvolved during the pregnancy. He
Initially denied paternity. The child was born In June 1992 and after paternity was
confirmed In January 1993, Larry became more Involved with Kayla. The parents
lived together off and on from March 1993 through June 1994. Kayla has been at
the Carlisle Early Education Center since August of 1993.
ISSUES:
Larry expressed a number of concerns about how he believes Sharon treats
Kayla. He avers that Sharon would make Kayla sit on the potty for an hour, yells
in lieu of talking calmly to Kayla, has slapped her and uses Kayla to her advantage.
He also cited an incident where Sharon allegedly put training pants on Kayla, who
then wet them. He stated that she then smeared thf,i pants on Kayla and
re-dressed her with them. Generally, he does not like the way that Sharon treats
Kayla "...it's unreal".
Sharon's major issue relates to Larry's actual availability to be with Kayla.
She related that Kayla Is more emotionally connected to her, IS more stable when
In her custody and basically believes that Kayla's best interest would be served if
placed In her primary custody. She stated her belief that Larry loves Kayla.
Additional concerns relate to Kayla sleeping at the paternal grandparents' two
nights during Larry's custody time. Finally, she expressed a concern about her
belief that Larry may let the child sleep In the same bed with him. This creates
difficultly for her upon Kayla's return as Sharon has difficultly getting Kayla to
sleep in her own bed. Finally, Sharon related that Larry has "cllssed her out" In
the presence of the child 'several times' - usually when emotions run high. The
parents currently live five minutes apart.
CUSTODY EVALUATION
Re: L1ebrum V. Cramer
pege 3
Both parents referred to the foSSlblllty that the grandparents' Involvement
may be too much since July 0 1994. However, It was noted that both
grandmothers babysat for Kayla at certain times prior to July of 1994 and neither
natural parant raised a concern,
FINDINGS:
Results of the Information from the parents Indicate that they both have e
strong emotional attachment to Kayla, appear well differentiated from her, and are
Interested In her welfare. There Is no evidence of any enmeshment. Sharon
responded to and axplalned each of Larry's concerns, She admits to "counting to
three" In wanting her own way at times. She denied ever keeping Kayla on the
~otty chair for any extended period of time. She did, howaver, admit to
swatting" her, noting that "It was not a slap", She also admits to Involving the
maternal grandmother and finally said that her going to bars, another concern of
Larry's, occurs either when she doesn't have Kayla or Kayla sleeps at the maternal
grandmother's. Parental availability seems to be an Issue, There are no Identified
risk factors such as substance abuse,
They both have an accurate perception of the child and basically have
reasonable expectations. Although their communication styles dlffor to some
degree with Larry being more structured and directive, and Sharon being more able
to re-dlrect and allow Kayla to negotiate, both parents have appropriate
communication with the child.
However, there does seem to be some Inter-parent variables present.
Specifically, It Is my belief that there are unresolved emotional issues between the
natural parents which have largely contributed to their Inability to resolve the
parenting arrangement. There continue to be some feelings of ambivalence toward
and about each other. To that end, during the assessment process, It appeared
appropriate to refer them for marital counseling, They had one session with a
therapist. A review of Sharon's diary further suggests that there are unresolved
emotional issues between the adults,
A review of the responses in the Life History Questionnaire does not suggest
any Issues which would heavily influence either of the parents concerning their
p~rception of and relationship with Kayla. Sharon's father appilrently was an
alcoholic and she received counseling related to co-dependency issues.
FINDINGS (KAYLA):
Two Parent-Child Observations were conducted to sample family Interactions.
Although additional instruments were attempted, due to Kayla's young age, these
proved less than valid.
On the first occasion, March 18, 1995, Kayla was accompanied by her father,
Mr. Larry Llebrum. Kayla Immediately asked her father for permission to play with
the toys in the playroom, and Mr, Liebrum agreed. Kayla first obtained a toy
xylophone and began playing with this. Her father then demonstrated playing
notes up and down the scale. Kayla immediately imitated this, and did so nearly
perfectly.
CUSTODY EVALUATION
Re: Llebrum V, Cramer
Page 4
Kayla then retrieved a "Connect Four" game. Her father explained the object
and methods of play, It was obvious that Kayla did not understand this, and
during their play, she moved a lever that released all the pieces ont.o the table top.
Her father stated "That's the end of the game" and Kayla stated her desire to
replace all the pieces. Her father then explained, "You don't put them all In; It's a
game; you golta get four In a row; you go first, then I go, then you go, and then I
go". Kayla quickly understood the concept of taking turns, and they continued
playing. Her father won tl\e first game and then he an owed and assisted Kayla to
win the next. At that point, Kayla expressed a desire to play with other toys, and
her father agreed, stating "you won one; I won one; let's call it a tie".
Kayla then attempted to put the "Connect Four" game away, and experienced
difficulty returnln~ It to It's shelf. She stated "I can't get this up here". Her father
responded "What s that word?", but Kayla did not reply, Her father repeated the
question and Kayla loudly said "I can't!'. Her father then commented "We don't
use that word". Kayla eventually was able to return the game to it's location.
Kayla then obtained a toy shark, She showed it to her father and asked him why
it had teeth. Her father explained that sharks eat little fish and Kayla seemed to
become apprehensive. She asked her father to put the shark away. A few
minutes later, after reading a few children's books to Kayla, her father again
obtained the toy shark and pretended to bite her with It. Kayla said "Ouch" each
time he did so, and altel' a couple times, she again seemed anxious and moved
away from her father, Mr, L1ebrum stated "Come here, Honey", to which Kayla
answered "No". Her father replied "Yes" and Kayla complied. Mr. L1ebrum then
explained to Kayla that the toy shark was not real.
Kayla then got crayons from the toy shelves. Her father assisted her In
drawing a person, by placing his hand over hers. He then helped Kayla to trace
the outline of a toy, and they spent several minutes coloring the picture.
Kayla and her father spent several minutes playing with a wooden marble toy.
KClyla divided the marbles between herself and her father, Several times during
this activity, Kayla Imitated various statements her father would make (e.g, "Here
it cornesl"). On several occasions, Mr, Llebrum tried to get Kayla to name the
colors of the marbles or to count them. He usually needed to use two or three
prompts before she would do so. At one point, after several minutes of playing
with this toy, Kayla seemsd to become bored and began to whine. Her father told
her to "Stop the whining", and Kayla did comply. A few seconds later, however,
Kayla stated to her father "You scared me". She then said something that was not
intelligible to the observer. Her falher quickly asked "What did you say"? Kayla
replieo "Nothing". Her father asked her the same question three more times and
Kayla responded "nothing" each time. Finally, her father stated "No more balls
(marbles) will go down till you tell me what you said". Kayla again stated
something that was not understood by the observer, but her father replied "Okay, I
thought you said something else". They then returned to the marble toy for the
remainder of the observation.
A second Parent-Child observation was conducted on March 23, 1995, with
Kayla and her mother, Ms. Sharon Cramer, Kayla and her mother entered the
playroom, and Kayla immediately obtained the crayons. She again attempted to
trace the outline of a toy, as she had done the previous observation. After about
two or three minutes of coloring, however, Kayla stated "I don't like this crayons"
CUSTODY EVALUATION
Ae: Llebrum V, Cramer
Page 5
and began to return them to their location on the toy shelf, She experienced
difficulty and stated "I can't get It". Her mother quietly Instructed Kayla to use
two hands and stated "I'll bet you can get It". Kayla was successful, and her
mothar praised her "See, you can do It".
Kayla then obtained the checkers and the "Connect Four" game. However,
she then quickly noticed the marble toy and said "I don't want to play with these",
referring to the "Connect Four" game, She began to return the checkers and the
game to the toy shelf when she noticed the toy shark, She backed away from the
shelf, stating "Shark Is going to get me". Kayla asked her mother to put the toys
away. Her mother took: the chflckers from her, stating "I'll put these away and
you put this (Connect Four game) away". Kayla complied.
Kayla moved to the marble toy and began playing. After a few minutes, her
motller attempted to direct Kayla's attentfon to a t'JY from the Disney movie
"Aladdln". Kayla looked at this a few seconds, then returned to the marbles for a
few more minutes. She then asked for a puzzle, although the ones available were
obviously too difficult. Her mother stated "They're klnda big for you, don't you
think?" but Kayla Insisted. Her mother aided Kayla In assembling the puzzle by
handing her one piece at a titTle and plwslcally asslstlnQ her in placln~ It In the
correct location. After a few minutes, Kayla stated "I don t want to do it'.
She then wanted to play the game "Hangman". Her mother explained that to
play the game, Kayla had to know the letters of the alphabet. Kayla quickly
recited the alphabet, but Incorrectly, She Insisted on playing the game. Her
mother attempted to use the letters In the game to help Kayla to speir her name.
However, Kayla quickly said "I'm done with these". Mom directed her to put the
game away, Kayla replied "I can't". Her mother said "You hand them to me and
I'll put them away." Kayla complied,
Kayla explored various toys In the playroom including playing cards, a toy
doctor's kit, a xylophone, blocks, hats, and finally, the crayons and the marble
toy. In each case, her Involvement with the toy lasted less than two or three
minutes. At one point, her mother remarked, "Nothing is keeping your attention
tonight, is there?"
As the evaluation was concluding, Kayla then became more Interested in
remaining. She protested vigorously to her mother, exhibiting a mild temper
tantrum. Her mother explained the need to leave and gathered Kayla's coat and
opened the door. Kayla reach'ld for h'3r mother, who picked her Lip and carried her
from the office.
Generally, during both observations, Kayla seemed to be quite bonded to both
parents. She was in general inquisitive, playful, and outgoing with both parents.
She seemed to remain with one toy or activity longer with her father than her
mother, but this may have been attributable to her previous familiarity with many
of the toys. Both parents seemed to use similar methods of instruction with Kayla,
and for the most part, were quite attentive to her statements, wishes and needs.
If there was any difference in parenting methods, it might be generally described
that her father seemed to provide somewhat more instruction and structure, while
her mother ~eemed to provide more praise and affection. Kayla obviously would
seem to require both in order to thrive.
.
..
J AN 17 1995dlk.
LARRY LBB LIEB/WH, JR.,
Plaintiff
I IN THE COURT OF COMMON PLEAS OF
ICUMBBRLAND COUNTY, PENNSYLVANIA
I
INO. 4035 - CIVIL - 1994
I
I
ICIVIL ACTION - CUSTODY
v
SHARON E. CRAMER,
Defendant
COURT ORDER
AND NOW, this ~ day of ~"lll\~ll~ , 1995, upon
consideration of the attached CustodY Conc~liis'tion Report, it is
ordered and directed as follows:
1, A Hearing is scheduled in Courtroom NO.2 of the Cumberland
County Courthouse on the ~ day of (Lu~Q , 1995,
at P, 'I', A H. at which time testimony WTIl be taken in the
above case. At this Hearing, the Father Larry Lee Liebrum,
Jr., 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
their position on custody and also setting forth a list of
witnesses that will testify at the Hearing along with a
summary of the anticipated testimony of each witness.
This memorandum shall be filed at least ten days prior to
the Hearing date.
2. In the event either party desires to have any type of
psychological or any other evaluation done in preparation for
this Hearing, and that party is willing to pay the cost of
said evaluation, it is directed that the opposing party shall
make themselves available for an evaluation and shall also
make the child avai.lable for any type of evaluation. In the
event both parties through the,ir counsel reach an agreement to
have this type of an evaluation done, such evaluation shall
then be deemed to be an independent evaluation with the parties
sharing the costs of the evaluation.
3. Pending further Order of this Cour
of October 17, 1994 shal.l>remain i
prior Order
eel
Carol J. Lindsay, Esquire). .
James J. Kayer, Esquire J lt~.. -,:.i"'....(...fk
! ~
.
v
IIN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
INO. 4035 - CIVIL - 1994
I
I
ICIVIL ACTION - CUSTODY
LARRY LEE LIEBRUM, JR.,
Plaintiff
SHARON E. CRAMER,
Defendant
PRIOR JUDGEI JUDGE KEVIN A, HESS
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report I
1. The pertinent information pertaining to the child who is the
subject of this litigation is as followsl
Kayla Elizabeth Liebrum, born June 6, 1992,
2. A Conciliation Conference was held on January 12, 1995, with
the following individuals in attendance:
The Father, Larry Lee Liebrum, Jr" with his counsel, Carol
J. Lindsay, Esquire, and the Mother, Sharon E. Cramer, with
her counsel, James J. Kayer, Esquire.
3. The parties separated in July of 19.94. They were before the
Custody Conciliator in September of 1994 at which time a
temporary agreement was reached whereby the parties would
share physical custody of the minor child on a week on/week
off basis. At the time of the agreement in September, another
Custody Conciliation Conference was scheduled for January to
review the custody agreement at that time.
4. After a number of months of the alternating week custody
arrangement, both parents are dissatisfied with this
arrangement. Both parents feel that they should have primary
physical custody of the minor child. Both parties raise
various concerns relating to the lack of parenting skills of
the other party and other miscellaneous concerns. It is clear
that an agreement cannot be reached and that a Hearing is
required.
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in this mailer for April 20. 199~. As the psychological evaluation that was being performed by
Guidance Associates had not been completed in time for that hearing, the parties stipulated that the
hearing be continued. TIlls Coun has scheduled the hearing to occur on June I, 199~.
Prior to the panies' living together. they had their disagreements regarding the child. During the
mother's pregnwlcy. the father denied patemity of the child. He continued to do so even after the child
was oom. The mother, as pan of her action for child suppon. requested that blood tests be perfonned
confinning patemity. The tests did, indeed. confinn that Mr. Liebrum was the father. He has since
withdrawn his challenge as to patemity.
It is the mother's contention that the primary motivation behind the father's interest in the child
and his pursuit of custody i:; 11I1 allempt by him to manipulate the relationship between father and mother.
The mother believes that as she has been the primary caretaker of the child throughout the child's life.
until the altemating custody schedule was imposed upon her by the father's unilateral seizing of the child
nearly one year ago, that the child will continue to thrive in an environment where she is primarily with
the mother. The mother is concemed regarding the relative lack of maturity of the father based upon
a number of incidents that have occurred between the panies. She believes that these incidents are
indicative of the character of the father and believes that they could lead to the type of "flaws of
judgment" that could endanger the child when with her father in a time of crisis. The father exposes
the child to a steady stream of verbal abuse and expletives directed at the mother (in the child's
presence), during nearly every conversation that the parties have. This conduct is not limited to
telephone conversations between the panies, it has also occurred when they meet face-to-face. The
mother is concemed that if this type of verbal abuse and denigration occurs in her presence, then she
questions what types of abuse and denigration occur throughout the rest of the time that the father has
the child.
II. WITNESSES
It is anticipateclthat the Defendant shall call the following people to testify at the hearing:
I. Stanley E. Schneider. ED.D.,R.C.E. - Dr. Schneider is completing a custody evaluation at the
request of the mother and it is anticipated that the panies shall either stipulate as to his repon or.
alternatively, that one or both panies may call Dr. Schneider as a witness. As the report has not been
completed at the time of this writing. it is impossible to detennine whether such a stipulation is possible.
2. Sandra Hawkins - A personal friend of the mother who has known the mother for
approximately five (5) years. Mrs. Hawkins is to testify as to her observations of the mother-daughter
relationship, as well as Ms. Cramer's experiences with children prior to Kayla's binh.
3: Pamela Dickson - Ms. Dickson is a friend of the mother and is the mother of a five year old
boy who plays with Kayla. It is anticipated that Ms. Dickson will testify as to her observations of the
parent-child relationship.
4. Jody Shields - Ms. Shields is a cousin of the mother who has ~itnessed incidents between
the mother and father in the past, the most recent incident having occurred on or about May 12. 1995.
5. Amy or Pat of the Carlisle Early Education Center - Mother's counsel is without the last
names of these individuals at the time of this writing. These individuals are the teacher and teacher's
assistant for Kayla at her day-care facility. It is anticipated that one of them will testify as to their
observations of the parent-child relationship regarding oolh parents, observations regarding the difficulties
that the plllties have had in dealing with each other regarding custody transfer, as well as the child's
progress in school since the alternating weekly custody schedule has been in place.
6. Grace McKee - Mother of the Defendant, has personal knowledge regarding many of the
incidents that have occurred between mother and father since the binh of Kayla. Mrs. McKee will also
testify as to her observations of the mother-daughter relationship.
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing Defendant's Pre-Trial Memorandum
wa., served on the following person(s) by First Class mail, postage prepaid by forwarding a
true and correct copy unto:
Carol J. LlndSllY, Esquire
Flower, Morllenthlll, Flower & Lindsay
II East Hlllh Street
Carlisle, PA 17013
Dated:
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The mother of the child Is Sharon E. Cramer, currently residing at 293 Plaza Drive, Boiling
Springs, Pennsylvania.
She Is single.
The father of the child Is Larry Lee Llebrum, Jr., currently residing at 922 Forest Court,
Carlisle, Pennsylvania.
He Is married.
4. The relationship of the Plaintiff to the child Is that of father. The Plaintiff currently
resides with the following people:
NAME RELATIONSHIP
Kayla Elizabeth Llebrum father/child
5. The relationship of the Defendant to the child Is that of mother.
The Defendant currently resides with the following person: her paramour
6. Plaintiff has not participated as a party or witness, or In any other capacity In other
litigation concerning the custody of the child In this or another jurisdiction.
7. The Plaintiff has no Information of a custody proceeding concerning the child pending
In a court of the Commonwealth.
8. The Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the child or claims to have custody or visitation rights with respect to the child.
9. The best Interest and permanent welfare of the child will be served by granting the
relief requested because:
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Plaintiff
:IN '1'HB COUR'l' OF COMMON PLEAS OF
:CUMBERLAND COUN'l'Y, PENNSYLVANIA
:
:CIVIL AC'l'ION - LAW
;NO. 1.11, ,.".~ CIVIL
:CUSTODY/VISr'l'A'l'ION
19Q'i
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* ~hC\ron E, ((''-1(,'\\'i
Defondant
ORDER OF' COURT
AND NOW, this (date) ~; {;\,'/<ll, upon consideration of the
attaohed complaint, it .is hereby directed that the arties a~d
their respective counsel appear before t~ C' - - '/.., ,
the oonciliator, at i ,'\ ...., (,\. .~' (, ,')\)e r'~
on the \C) day of \.j\'::::,l. , 19"1 , at I(j " "Cl
A. M., for a Prehearing Custo8y Conference. At suoh conference,
an effort will be made to resolve the issues in dispute; or if
this oannot be aocomplished, to define and narrow the issues to be
heard ~y the oourt, and to enter into a temporary order. Either
party may bring the child who is the subjeot of this custody
aotion to the conference, but the ohild/ohildren's attendanoe is
not mandatory. Failure to appear at the oonference 'may provide
grounds for entry of a temp~rary or permanent order.
FOR THE COURT:
By:Jlll..C\<'/Jl} Y . ~J1;.QJlr:"u.-<! t",'1-'
Custody Concil~tor (:rrg)
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCB. IF YOU DO NOT
HAVE: A LAffl'BR OR CANNO'l' AFFORD ONE, GO TO OR TELEPHONE 'l'HB OFFICE
SB'1' FORTH BELOW TO FIND OUT WHERE YOU CAN GB'1' LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, FOURTH FLOOR
CARLISLE PA 17013
(717)240-6200
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LARRY LEE L1EBRUM, JR..
Petitionllr/Futhcr
: IN TIlE COURT OF COMMON PI.EAS OF
: CUMBERI.AND COUNTY, PENNSYLVANIA
v.
: NO. 94-4035 ('lVII, TERM
SHARON E. CRAMER,
Rllspondent/Mothcr
: 1r'J CUSTODY
ORIlER OF COURT
AND NOW, ______~_______..__' 20 _ ____, upon ~()nsidenltion of the auached Petition to Modify
Custody, it is hereby directed that the parties and their rcspcctive counsel appear belore
. the conciliator. al
oa the __,~__ day of ___,_____~__' 21100_, at ___ o'clock.
_.m., for a Pre-lIearinll Custody Conference. At such ~oaferel1ce, an eftilrt will be made to resolve the
issues ir. dispute; or if this cannot be accomplished. to defiae and narrow the issues to be heard by the
Court, and to enter into a temporary order. All children aile five or older may also be present at the
conference. Failure to appear atlhe confercnce may provide grounds lilr entry of a temporary or
permanent order,
FOR TIlE COURT:
By:
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with
Disabilities Act of 1990, For inti>rrnation about accessible lacilities and reasonable accommodations
available to disabled individuals havinll business before the court, please contact our otlice, All
arranllements must be made at least 72 hours prior to any hcaring or business before the court. You must
aUend the scheduled ~onference or hearinll.
YOU SHOUl.D TAKE nlls PAPER TO YOUR LAWYER AI' ONCE. IF YOU DO
NOT HAVE A l.A WYER OR CANNOT MHlRD ONE, GO TO OR TEl.EPHONE
TIlE OFFICE SET FORTI I BEl.OW TO FIND OUT WHERE YOU CAN GET l.EGAL
HEl.P,
Otlice of the Court Administrator
Cumberland County Court Ilouse, Founh Floor
Carlisle, PA 170lJ
(717) 240-6200
LARRY LEE L1EBRUM, JR.,
PLAINTIFF/FATHER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
SHARON E, CRAMER,
DEFENDANT/MOTHER
94-4035 CIVIL TERM
IN CUSTODY
ORDER QE..COURT
AND NOW, this -'Il-- day of June, 1995, following a hearing on the merits,
IT IS ORDERED:
(1) The custody order of October 17, 1994, Is vacated and replaced with this
order,
(2) Sharon E, Cramer and Larry Lee L1ebrum, Jr" shall have shared legal
custody of Kayla Elizabeth Llebrum, born June 6, 1992.
(3) The mother and father shall have shared physical custody of Kayla on a
week-to-week basis.
(4) The parents shall share physical custody on all holidays. At Christmas, the
father shall have physical custody on Christmas Eve through noon Christmas Day and
the mother shall have physical custody for the remainder of Christmas Day.
(5) The father and mother shall cooperate in securing day care for Kayla that
will not require Kayla to attend when the father is off work during the weekly periods
he has physical custody and can be with her.
EXHIBIT A.l
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6. There is currently in el1i.:ctll Coun Order dllted June 7, 1995. <Exhibit Al entered to the llbove
docket number IInd II Petition tor Moditicllllon to the swne number with hellring dIIte scheduled tor
September 12. 2000 <Exhibit BI,
7. Petitioner docs not know of II person not II pliny to the proceedings who hIlS physiclIl custody
of the child or c1l1ims to hllvc physiclIl custody or visitation rights with respect to the child,
8, The best interests IInd pennwlelll wellare of the child will be scrved by grllntin8the relief
requested bcclluse:
(II) Petitioner is the naturaltather of the child:
(b) Petitioner has established a rcllltionship with the child;
(c) Petitioner desires to continue exercising pllrentlll duties IInd enjoys the love IInd
affection of the child:
(d) The child sh()uld be pennilled to enjoy the lovc, IIffection. IIIld emotioool suppon
which can be provided by their nlltural father,
9. Each pllrcnt whose pllrental rights to the child have not b.'Cn tenninllted and the pcrson who
has physical custody of the child hllvc Ix:en nllmed liS panics to this IIclion. No other persons arc known
to have or claim a right to custody or visitation of thc child to be given notice of the pcndency of this
action IInd thc right to intervene.
PETITION FOR EMERGENCY RELIEF - REOUEST FOR ORDER
FOR TEMPORARV PRIM&.RV PHYSICAL CUSTODY
10. Parllgraphs one ( I) through (9) lire hereby incorporated by rcfcrence 115 though fully Ict
fonh,
LARRY LEE L1EBRUM, JR.,
PLAINTIFF/FATHER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
94-4035 CIVIL TERM
SHARON E. CRAMER,
DEFENDANT/MOTHER
IN CUSTODY
ORDER OF COURT
AND NOW, this ..' / f.- day of June, 1995, following a hearing on the merits,
IT IS ORDERED:
(1) The custody order of October 17, 1994, Is vacated and replaced with this
order.
(2) Sharon E. Cramer and Larry Lee L1ebrum, Jr., shall have shared legal
custody of Kayla Elizabeth L1ebrum, born June 6, 1992.
(3) The mother and father shall have shared physical custody of Kayla on a
week-to-week basis.
(4) The parents shall share physical custody on all holidays. At Christmas, the
father shall have physical custody on Christmas Eve through noon Christmas Day and
the mother shall have physical custody for the remainder of Christmas Day.
(5) The father and mother shall cooperate in securing day care for Kayla that
will not require Kayla to attend when the father is off work during the weekly periods
he has physical custody and can be with her.
EXHIBIT A.1
CEf,JTIFICATE OF SERVICE
I, Karl E. Romlnaer, Esquire, attorney for Larry L. Liebrum. Jr., Petitioner, do hereby
Johnna J. Deily, Esquire
26 West High Street
Carlisle, PA 17013
certifY that I this day served a copy of the P,tltlo,,/or Em,I'1l'''cy R,lIqupon the followlnlJ by
depositing same In the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania,
addressed as follows:
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Karl E, Romlnser, Esquire
Attorney for Petitioner
Dated: August I, 2000
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LARRY LEE LIEBRUM, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V,
SHARON E, CRAMER,
Defendant
94~4035 CIVIL TERM
ORDER OF COURT
AND NOW, this 4th day of August, 2000, upon
consideration of the Petition for Emergency Relief filed on be~alf
of the Plaintiff, Larry Lee Leibrum, Jr., and pursuant to an
agreement reached in open court in which the Plaintiff was
represented by Karl E. Rominger, Esquire, and the Defendant was
represented by Johnna J. Deily, Esquire, it is ordered and
directed that the Plaintiff shall enjoy periods of partial
physical custody until such time as the custody conciliation
hearing can be held on September 1, 2000 as follows:
1, From 8:00 a.m. August 10, 2000, through 7:30 a.m,
on August 17, 2000, at which time the Plaintiff must deliver the
child to the Park and Ride in Newville by 7:40 a.m. to attend
Brownie camp.
2, From immediately after Brownie camp on August 20,
2000, until August 23, 2000, at 2:00 p.m., upon the condition that
Plaintiff takes the child to her regularly scheduled dental
appointment on August 22, 2000.
3, The weekend of August 31, 2000, from Friday at
5:00 p.m. until Sunday evening at 7:00 p.m.
4, The parties agree that they shall make themselves
available should the child wish to have phone visits when she is
with her non-custodial parent.
LARRY LEE L1EBRUM, JR.,
PLAINTIFF
V.
SHARON E. CRAMER,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94-4035 CIVIL
AND NOW, this
ORDER OF COURT
~
day of December, 2000, following a hearing on
the merits, IT IS ORDERED:
(1) All prior custody orders are vacated and replaced with this order.
(2) The mother, Sharon E. Cramer, shall have primary physical custody of
Kayla Elizabeth Llabrum, born June 6, 1992,
(3) The father, Larry Lee Llebrum, Jr., shall have temporary physical custody
of Kayla as follows:
(a) Every other weekend from Friday at 5:00 p,m. until Sunday at 5:00
p.m.
(b) During any week he is off work and during any week he works a third
shift, on Wednesdays from after school until 8:00 p.m.
(c) From 9:00 a.m. until 8:00 p.m, on any of the following holidays which
he Is not working: Presidents Day, Memorial Day, July 4th, Labor Day and
Thanksgiving. He will provide the mother with two weeks notice of any
holiday that he will have Kayla,
(d) Each Christmas Day from 3:00 p,m, until 9:00 p,m. (The mother shall
have Kayla each Christmas Eve through 3:00 p.m, Christmas Day),
(e) Every December 29th at 9:00 a.m. through January 1"t at 8:00 p,m,;
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