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MARYANN MURPHY
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AUG 04 1994
KllNNE1'1I NYERS, : IN TilE ColJRT OF COMMON Pl.I~AIl
"Iulnllff : ClJMllliKl.ANIl COUNTY, I'ENNIlYJ.VANIA
:
: NO.
V. t
I CIVIl. ACTION - l.AW
litiS BBBlt8, I
OufllndRnt t IN Cl/N1'OnY
IT UU1ATlOIL l'D.lLllt:lTRYu 9J'u.. CUBT9DY.. .J)RJ)r.~
'I'hll pllrtllls to lhlN /Icllon. KENNE'I'1l MYIiIHI, (hllrlllnoftur
refurred to all "I'ATIIER"), und 110 II llf.~;RS (hcl'ldnllfter referrud to
1111 "MOTl"'R"), desiring lo Rnllc/lhly Ilellle und ret!olve 1111
outlltandlng Illsues concerning cUlllody und l'urll,ll custody with
rllspllct lo the minor children Involved In lhls /Ict lone ASIIl.EY
NICOLE BEERS, born November 15, Iq91: und ZAKARY KENNETH m<:ER:l,
born December 5, 1992, herehy Ilt Ipulule Ilntl ugrce lo thu entry of
an Order of Courl uwurdlng cuslody und partlul custody of ASHLEY
and ZAKARY ut! followNI
1. PATHf.R shull huve prlmury physical and legal cUlltody of
the minor chi Idren: ASHLf.Y NICOl.E DEERS, born November IS, 1991:
und ZAKARY KENNETH !lEERS, born Ilecumbe I' S, 1992.
2. MOTHER IIhull have partial phYlllcal custody of the minor
~hlldren on the following t!chedule:
a) On allernale weekends from Friday at 4:00 p.m.
unt I I SundRY ul 7100 p.m,;.
b) During the Bummer, MOTlIER Nhall hllve lwo (2) non.
conllecut I Vll weekN of VIlCRt Ion t imll wi th lhe
dilldrllJl, 'J'hlJ/l1l weuk/l/lhllll betllkeJl In nu mOl'llthllJl
lIlIll (I) wellk IJltervlIlII. MO'I'III':1l IIhllll f!Ive l"A'I'tmR
lIut' cu uf t helle week/l hy MIIY lilt uf ellch YUill'.
3. Thu followlJlM hlllldllYIl IIhllll bu lllhlll'e<l hy the p'lrllntll,
reaardlellll of the ullulII Ilchedullll Memurllll [lilY, I'uurth uf July,
Lllbor OilY IInd 'I'hllllkllf!lvlllj,l. MO'!'tll':ll IIhllll hllve themlnul' chlldrun
from BIOO lI.m. until 2100 p.m. ellch uf thelle holldllYIl.
4. Tho 1\lIl1ter hull<lllY /lhllll be /lhllre<l by the pllrents. I'A'I'IIF.R
IIhllll have the minor chlldrcllon ElIllter SundRY until 2:00 p.RI. If
Euter flllls on MO'l'lIF.R'1l weekend, r"A'I'IIER shllll hllve the children
from 8:00 p.m. the night before Enllter. MOTIIER /lhlll I hllve the minor
chlldrcn on ElIllter SundllY from 2:00 p.m. until 8:00 p.m.
S. The Christmlls holld/1Y /lhllil be IIhllrcd by the parentll. 011
Christmas EVe, MOTHER shal\ hllve thc children from 8100 a.m. until
2:00 p.m. On Christms/l Dny, MOTIIER shill I hllve the children from
noon until 7:00 p.m.
(,. I'ATII1\R shllll hllve thc child on I'ather's Day, MOTHER IIhall
have the child on Mother'/l Day, regllrdlellll of the usual IIchedule.
The hours shlll\ be from 10:00 a.m. until 6:00 p.m.
7. Both parents aj,lree that they wi II not usc, or permit
IInyonc elsc tu UIIC, IIny IlleRlI1 substnncell twcnty-four (24) hours
prior to, /lnd throullhout, their periods of cUlltody of the minor
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MARYANN MURPHY
If
AJl G 0 ',1 199~
. ~IT, ,'.I., "~I , ^.',
no' ~lOli'H ::.1,cotH) ~'l,I' I
H"miI5IlLJj,lr" HNN~"I\NM 11ll!)
('11) 2]3 tlbl'
., ~he children were not born out of wedlock. ~he children
currently reside with the Plaintiff at 97 Bosler Avenue, Lemoyne,
Cumberland County, Pennsylvania.
&. During the lifetime of the children, they have resided at
the following addresses with the following personsl
Timl MllnBII With Wh9ID
Birth-3/92 206 Hummel Ave. Plaintiff/Defendant
Lemoyne, PA Plaintiff's father,
steplTPther, stepsister
3/92-7/19/94 97 Bosler Ave. Plaintiff/Defendan~
Lemoyne, PA
7/19/94-present 97 Bosler Ave. Plaint if f.
Lemoyne, PA
6. ~he father of the children is KBNNBTH M'lEPS.
7. ~he mother of the children is IRIS BEBRS.
6. The children currontly reside with the Plaintiff.
9. The Plaintiff has not participated as a party or witness,
or in any other capacity, in other litigation concerning tho
custody of the children in this or any other court, except as set
forth above.
10. The Defendant has not participated as a party or witness,
or in any other capacity, in other lHigation concerning the
custody of the children in this or any other court, exoept as set
forth above.
1 t. The Plaintiff has no information of a custody proceeding
concerning the children pending in a Court of this Commonwealth or
in any other Court of the United states of America,
12. The Plaintiff does not know of a person not a party It)
the proceedings who haa physical cUBtody of the children, or claims
to have custody or visitation rights with respect to the children.
13. Bach parent whose parental rights to the chi ldren has not
been terminated, and the person who has physical custody of the
children, have been named as parties to this action. There are no
other persons known to have or claim a right to custody or
visitation of the child and therefore, no further notice of the
pendency of this action and the right to intervene shall be given,
other than to the parties named herein.
14. The best interest and permanent welfare of the minl)r
children will be served by granting primary physical and legal
custOdy to the Plaintiff.
WHBRBFORB, Plaintiff requests this Honorable Court to
IN THI COURT or COMMON PLBAS or CUHBla~ COUnTY, PIN"SYLVANIA
CIVIL ACTION - LAW
KlN".TH HYBBS,
Plaintiff/Petitioner
v.
No. 94-4402 civil Term
IRIS (BBBRS) TUCKBY,
Defendant/Respondent
IN CUSTODY
ORDRR OF COURT
AND NOW, this
:J..LL day of v'Jv....w I-
, 1997, upon
uonsideration of the within Petition, IT IS HBBBBY ORDBRBD AIm
DICRIID that IRIS (BBBRS) TUCKIY, Defendant/Respondent, shall have
only supervised visits at New Passages with the minor children:
ASHLBY NICOLB, born November 15, 1991; and ZACHARY KBNNBTH, born
December 5, 1992, pending her attendance at counseling and
recommendations of the therapists regarding visitation.
It is further Ordered that HICHABL TUCKIY not be permitted to
have any contact with the minor children pending his attendance at
counseling and reoommendations of the therapists. ().!/..;J ~~
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the ohildren I s counselor for approl!imately fivlI (Ii) months, wrote
a letter to counsel for Petitioner expressing concerns about the
ongoing problems during the children's visits with Respondent and
her husband. (See letter from Dr. Hiltill dated August 19, 1997,
attached hereto, incorporated by reference herein, and marked as
Bxhibit "B".).
6. Following this letter, Dr. Hiltill called counsel to inform
her that she had contacted Children and Youth to investigation a
recent allegation by Ashley that Michael Tuckey, Respondent' B
husband, struck the child with a board. Dr. Hiltz strongly
recommended that Respondent have only supervised visits with the
minor children, and the Mr. Tuckey have no contact with them at
all, pending counseling sessions and parenting classes for the
Tuckeys. Dr. Hiltz further agreed to work with the Tuckeys I
therapist in attempting to resolve the problems which occur during
the children's visits with Respondent.
9. Petitioner received a letter from Children and Youth
dated August 20, 1997 stating that an investigation is underway.
(See letter from Children and Youth dated August 20, 1997, attached
hereto, incorporated by reference herein, and marked as Exhibit
"C".) .
10. Petitioner placed the children in counseling because of
the ongoing problems associated with visitation. These problems
remain unresolved. When Petitioner has attempted to discuss his
concerns with Respondent, he is told that the Tuckeys will continue
to be uncooperative. The following are some examples of
Petitioner's concerns:
a, Petitioner believe. that there are nine (9) plople
living in Respondent t s home and that the childun do not have
adequate sleeping quarters;
b. Ashley has returned from visits with Respondent with
flea bites;
c. Ashley has returned from visits with Respondent with
ringworm/
d. Both children are returned from visits dirty, and
wearing soiled clothing;
e. Zachary told Petitioner th~t Hr. Tuckey lets him
smoke cigarettes and drink beer;
f. Ashley is frequently sick to her stomach when she
returns from visits with Respondent. The child tells Petitioner
that she is allowed to eat all the candy she wants;
g. Ashley has had vaginal irritation from not being
bathed when she visits with Respondent;
h. Both children have reported seeing Respondent
shoplifting when they are in stores with her;
i. Zachary's language is inappropriate, and his
behavior is aggressive when he returns from visits with Respondent;
j . Hr. Tuckey uses foul language to, and in the
presence of, the minor children, and he encourages them to do the
sama.
k. Both children report that Hr. Tuckey encourages tham
to physically fight with each other;
1. ZaChary lost five (5) pounds when he returned from
a week-long visit with Respondent this summar/
m. The children told Petitioner that they have to go to
"Jam..' house" if they need to go to the bathroom during the night,
and that they have to go to "Aunt Bonni.'s house" to take a bath
when they visit with Respondent I
n. Hr. TUckey repeatedly teases and taunts the minor
children.
11. Petitioner believes that Respondent is unable or
unwilling to adequately care for the minor chil.dun, and that their
visits with Respondent and Hr. Tuckey are detrimental to Ashley and
Zachary, both physically and emotionally.
12. Petitioner is agreeable with Dr. Hiltz' recommendation
that Respondent and Mr. Tuckey attend counseling sessions and that
Dr. Hiltz cooperate with their thurapist to resolve the visitation
problems. In the interim, Petitioner is willing to ensure that the
minor children are taken to New Passages for supervised visits
requested by Respondent, and that Respondent has reasonable
telephone aCCOBS to Ashley and Zachary.
WHBRBFORB, Petitioner prays this Honorable Court to enter
an Order directing that Respondent have only supervised visits at
New Passages with the minor children; that Michael Tuckey have no
contact with the minor children; and that Respondent and Hr. Tuckey
attend cQunseling and follow the recommendations of"the
ItINNBTII NYHIlS l II Ifl TillS COURT O/' COMMON PI,MS ' , ,
, , " III ant Ir f " CUMBBRLAND COUNTY, PBNNBYI,V^N I ^
J
I NO.
v. I
J CIVil. ACTION ~ L^W
III & BBBRS, J
Defendant I IN CUSTODY
STIPULATION POR BNfRY or CUSTODY ORDB&
'rhe parties to this action, KENNETII MYERS, (hereinafter
I
referred to all "PATIIIlR'~), nnd IRIS DEERS (hereinafter referred to
all "MOTIIER"), desiring to amlcnbly Ilettle nnd resolve 1111
outstanding IllIlues concerning cUlltody and partial custody with
respect to the minor children Involved In thill actlonl ^SIII.BY
NICOLE DlmRS, born November IS, 19911 and ZAKARY KENNETH BEERS,
born December S, 1992. hercby stipUlate nnd agree to the entry of
an Order of Court awarding custody nnd partial custody of ASIILEY
and tAKARY 66 folloW61
I. "ATHIlR shall hnve prlmnry phYlllcal and legal custody of
the minor children: ASIILEY NICOLE DEERS. born November IS, 19911
and ZAKARY KENNETII DEERS, born December 5. 1992.
2. MOTHER shall have partial physical custody of the minor
children on the following schedule:
a) On alternate wllOkends from Prlday at 4:00 p,m.
until Sunday at 7:00 p.m. I
b) During the summer. MOTHER shall have two (2) nO/l"
consecutive weeks of vacation time with the
, ,
children. "huo wllCks IIhall bo taken In no mora thRn
,
CHII (1) week Intervals. MOTlIBR IIhall give f^'I'llIilt
notice of thelle weeks by May lilt of oaeh yoar.
3. Tho following holldnYII ahnll be IIhared by the parentll,
reaardlus oC the unal schedulel Memorial Day, Fourth oC July,
Labor Day and Thanksgiving. MOTIIER shall have the minor children
Crom 8:00 a.m. until 2:00 p.m. each oC thelle holidays.
.
4. The Euter hol iday shall be shared by the paconLII. 1'N"flIIR
shall have the minor children on Eallter Sunday until 2:00 p.m. If
Baster fallll on MOTHER's wonkllnd, "ATIIER IIhall have the children
Crom 8:00 p.m. the night bofore Easter. MOTHER IIhall have the minor
children on Easter Sunday from 2:00 p.m. until 8:00 p.m.
S. The Chrlstmall holiday shllll be shared by the parents. 0"
Chrllltmllll Eve, MOTHER shllll have the children Crom 8:00 a.m. until
2:00 p.m. On Chrllltmas I)oy, MOTHER IIhal' have the children Crom
noon until 7:00 p.m.
6. PATHER shall have the child on Father's Day, MOTHER shall
have the child on Mother'lI Day, regnrdlesll of the usual schedule.
The hours shall be Crom 10:00 a.m. until 6:00 p.m.
7. Both pll1'ents agree that thoy will not use, or permit
anyone else to use, any Illegal substances twenty-Cour (24) hours
prior to, and throughout, their periods of custody 'of the minor
,\L I S
Wi.
PSYCHIATRIC, PSYCHOLOGICAL
IJIlI
mERAPEUTIC SERVICES, PC
SUlln L. Thomal.y, MD
JAw..nCl L. von RISO, MD
Mlrty H. B..nn.r, MS
Debrl A. Doubrlvl, MS
Miry Ilnl Fox, MSW
Iq..lc. M. Hart, MA
Nicol.. M. HllIz, PhO
Lynn O. I.ooml., MUd,
111I 1\. M'l'IIhall, MS
Alan C. Wenrich, OMln.
..A.....................~
l\ugustl9, 1997
Mary Ann Murphy
2201 N. 2nd Street
Harrisburg, PA 17110
Dear Ma. Murphy:
I am writing to you l'egarding Ashley and Zachary Myers. Mr. and Mrs. Myers brought
Ashley and Zachary to this office due 10 aevel'al concern..
As you are aware, Ashley and Zachary are Ken Myers biological children. They mide
with him andJena Myers, their .tepmother. They also are on a visitation schedule with
Iris Tuc~y, their ~iological.mother and Mike Tuckey, their .tepfather.
. -'11'1. " . "
Mr. and Mr.. Mye'rs haye bee/1 concerned about the possibility of poor quality of care
and Inappropriate adult behavior In the. presence of the children. For in.tance,they
report that Ashley Rnd Zachary come home from visitations either dirty, .ick or
infected. Ashley hM returned from severnl vl.its with a red, sore vaginal area. Poor
hygiene can often lead 10 such irritations. At present, thl. seems 10 be the most likely
reason for her discomfort.
In addition to ba.lc heaithcare, there have been concern. regarding emotional
mistreatment of the children. For example, evidence would .uggcst that the children
are victim 10 8&8resalve, obscene language and gesturing occurring nol only in their
preaence, bul also directed Ioward them.. 11 hM also been reported thallhey are
encouraged 10 engage In phy.ical combat with one another.
I have intervieWed Mr. and Mrs. Myers, and have had aeveral sessions wilh Ashley and
Zachary. Ashley and Zachary have described some of Iheac incidence. and have
experienced behaviornl and emotional reactions consistent with the alleged abuse. For
example, Zachary USC5 obscene expressions when he talka about his stepfather and calls
him offensive names" Prior to week long visitations, Zachary become. enuretic. His
behavlorl ~ollowing visllAtlons, is often unu.uallY.8&8re33ive and. may lnclude:aexual
connotat ons. Ashley, who is older and able to express feelings verbally, describes
~eeling angry, afraid, and sad over, occurrences during visits.. .
3300 North Third Street · Harrisburg, PA 17110
Tel. 717.234-3839 Fax 717.234-6247
Fed Id. 25-1767562
"""',\/0
~otinl '~er&iu. for Cl!ltm~reu nub 'IDUlIy
~lIup"ll1 QInul1tv
"JOIIpII.:lloo&lMr,,,..,...W.
S<<II/Slr/lm
110... K. Plalarcll
'1I<IIO",."fHII
25 SooltlllMi_
llonllbut,.l'IIwrlwllllllI7101'2021
rlloplloMl (117) 25'.2170
'Ill (117) 217-1'14
Commlllloncn
Sally s: Klein, Chlllrman
RuueU L. Shearrer
AIIlbony M. Pelnl~cl
J...... Eo HlbkI.. M.P.A.
Mllllnls/m/or
IIU\lUlt ~O, 1997
H~. Kenneth Hye~1
458 Woodwa~d D~lve
IUen, I'A
17319
1111 ~'hl,y Hy,n
Dea~ H~. Kenneth Hye~ll
We a~e \llvlng you thll lette~ 10 that you wlll have lmportant lnfo~matlon
ln w~lHng U yo II are a Iubject of the ~eport.
A repo~t of uUlpected child abuae o~ aerious ne\llect about the above
mentioned chlld hal been made to ou~ Agency and the Pennlylvanla Depa~tmlnt Of
Public Welfa~e. Unde~ the Child Protection Se~vlces Law, our Agency mUlt t~y
to find out if the ~eport of suspected abuse or neglect is cor~ect. Allo by law,
we must report certain types of injurie. and share info~maHon with the pollce.
The purpose of the Child Protection Service. Law is to I 1) encourage more
complete repo~ting of lu.pect.d abuse, ~) to eltablilh a county chlld p~otection
se~vice division capable of investigating such reports in a timely and profesalonal
manner, 3) to provide p~otection for children from further abuse, 4) to provide
~ehalliHtaHon services for children snd parents, and 5) to preserve and stabUile
famlly life wherever appropriate. All Agency"services, self-help group .ervices,
and multi-dilciplinary team reviews-are available to children and famillal
recelving child p~otective services from this "gency.
You, as the parent and/or the alleged abuser of the child, have the right to
receive, upon your written request, a copy of the report. InformaHon that would
identlfy the reporter or anyone who cooperated in the investigation will be
deleted, al the law requires.
lifter inveltigation, if the report is not substantiated (termed "Unfounded" by
law), then the report and all other information related to the report are expun\led
(deltroyed) within 120 days. If tho report i. substantiated (termed "Indicated" o~
"Founded" by law), then it is kept on fUe untU the chUd(rln) ~..ch.. hil/her
23~d birthday, and in certain cases, tho name of a perpetrator ls retainsd
indefinitely.
Exhibit "e"