HomeMy WebLinkAbout95-05301
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JAYME POTTEIGER.
Plaintiff
V.
RODNEY POTTEIGER.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-5301 CIVIL TERM
IN RE: PROTECTION FROM ABUSE
ORDER OF COURT
AND NOW. this 30th day of October. 1995. I find the
facts warrant the entry of a civil protection from abuse order.
Therefore. the following order is entered:
1. Respondent. Rodney potteiger. is ordered to
refrain from abusing. harassing, or threatening Jayme potteiger.
2. Respondent is prohibited from going to any place
where Jayme potteiger lives or works.
3. The parties shall make arrangements for the
transfer of their children for custodY purposes at a location
other than where petitioner lives.
4. This order shall remain in effect for a period of
one year. ,~
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Gerald S. Robinson. ESQuire
For Plaintiff
Michael L. Bangs. ESQuire
For Defendant
:prs
Edgar B. Bayley.
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JAYME POTTEIGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v. . 95-5301 CIVIL TERM
.
.
.
RODNEY POTTEIGER, . CIVIL ACTION - LAW
.
Defendant : PROTECTION FROM ABUSE
IN RE: CONTINUANCE
ORDER OF COURT
AND NOW, this 18th day of October, 1995, the
Temporary Protection from Abuse Order currently in effect shall
be continued in effect pending a further hearing of this matter
on Monday, October 30, 1995, at 8:45 a;p.
By the court,/
Gerald S. Robinson, Esquire
For the Plaintiff
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Michael Bangs, Esquire
For the Defendant
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LA WRt:NCE E, WELKER
PJOffIONOTAI"
CUMBERLAND COUNTY
CARLISLE. PA 17013
REASOh (HICKEO
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OCT 05 199511-
JAYME POTTinGER,
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PSNNSYLVANIA
, .
Petitioner,
vs.
NO. t/.S- .f3tJ/ ~~~
RODNEY POTTE~GER,
,
c.
Respondent.
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CIVil. ACTION - LAW
I'IlOTECTION FROM ABUSE
TEMPORARY PROTECTION ORn~1l
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AND NOW, this
9'
day of October 1995, upon presentation and
consideration of the within Petition, the following Order is entered:
1. Respondent is directed to refrain from abusing, harassing,
or threatening Petitioner and her children, physically or verbally,
wherever they may be;
2, Respondent is excluded from entering or telephoning
Petitioner's current residence or any residence in which Petitioner
may reside during the pendency of this Order;
3. Respondent is prohibited from having any contact with
Petitioner, including entering or telephoning Petitioner's place of
employment and any other places Petitioner frequents;
4, Respondent Is directed to refrain from all harassing
communication with Petitioner or her relatives.
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5. RQ~pafllieRl L:. d",ol,.6 vil;ililtl"n-rl'lhl" wlth...J:agards to the
Partie&' minor enileFsn.
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i~ 6, RcspendcRt is dil'ec~ed---~ pay &\lwrn~-[.e&&-J.-nGurred by
Pe.t1tlgRer in the amount 0 f five - hundred.,! 1500~QQ) dollaFilplus any
and- all fiHAg feell-and'-add~,L.1onal Colillit.li iRCIlFre" "'y Petlt.1olHNT
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I cf,6 7, R..".,ulld"..t ill (:lfr9cteEi to rollll<j"'Rh to-t.1l&-a1l8r~lf-f---ai+the'
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Ii '....af:lUIUI, includill<;l but not limited l6 gu..~ all'! ri f19S, tllat-ha-'lllllJUl
or that are ilt hi.. possession.
8. A ~ertified copy of this Order shall be served on the police
,
department(s) in the jurisdiction where Petitioner resides. Pursuant
to Section 6109 (a) of the Act, a certified copy of this Order shall
immediately be filed by the police department in the County Registry
of Protection Orders. Should the pollee come into contact with
Respondent, and Respondent alleges that he has not been served with
this Order, the police officer shall immediately serve the Order upon
her,
9. This Order shall be enforced by any law enforcement agency
in any county where a violation of it occurs. As provided in Section
6133 (a) of the Act, "laIn arrest for violation of an Order issued
pursuant to this chapter may be without warrant upon probable cause
whether or not the violation is committed in the presence of the
police officer."
10. Respondent is hereby notified that if he violates this
Order, he may be held in indirect criminal contempt which is
punishable by a fine up to $1,000.00 and/or by a jail sentence of up
to six (6) months. The Court may modify this Order at a contempt
hearing,
11, This Order shall remain in lull force and effect until
further Order of the Court.
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12, A hearing on
October 1995, at II:bO
this matter 1s scheduled [or the
!o'M
day of
County Courthouse, High and Hanover Streets, Carlisle, Pennsylvania,
~.m., 1n Courtroom
~ , Cumberland
,
BY THE COURT:
ffl qm 4. ~fr
J,
TRUE COpy FROM P.E
In Testimony whEreof I h- . CORD
and th I " rl! unto :ct my hand
e sea J) said Court at Carlisle, Pa
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,I JAYME POTTEIGER,
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IN TilE COURT OF COMMON PLEAS
CUM13ERLAND COUNTY, PENNSYLVANIA
pell lioner.
vs,
NO.
RODNEY POTTE~GER,
CIVIL ACTION - LAW
PROTECTION fROM ABUSE
,
Respondent.
NOTICE TO ()E~'END
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YOU HAVE BEEN SUED IN COURT. IC you wish to defend against the
claims set forth in the Collowlng pagus, you must appear at the
hearing scheduled herein. You are warned that if you fail to do 50,
the case may proceed without you and an Order may be entered against
you for the relief requested in the PetItIon. You may lose money or
property or other rights important to you.
If a copy of the TEMPORARY ORDER is attached, you must obey it
until the hearing. If you do not obey It, the police can arrest you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE A
RIGHT TO HAVE AN ATTORNEY REPRESENT YOU 1\1' TilE HEARING. 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 MAY GET LEGAL HELP.
AVISO PARA DEFENSA
USTED HA SIDO DEMANDADO EN LA CORTE. Si usted quiere defenderse
de las reelamaeiones descritas en las paginas siguientes usted debe
asistir a la vista que esta citada en esta. Usted esta siendo
advertido de que si falla en asistir a la vista el caso procedera sin
usted y una Orden puede ser expedida en contra suya para el remedio
solicitado en la Peticlon. Usted puede perder dinero 0 propiedad u
otros dereehos lmportantes para ustcd.
5i la copia de una Orden ProvIsional csta adJunta usted debe
obedecerla hasta que ia vista se llcve a cabo. Si usted no la
obedece la polieia 10 puede arrestar.
Lleve este aviso a su abogado inmediatamente. Usted tiene
derecho a tener representacion legal durante la vista. 5i usted no
tiene 105 medios economieos para paqar un abogado, dlrijase al
telefono mas cereano 0 vaya a la oficina cuya direccion apareee a
contlnuaclon. En esta dirnccion padra obtonof ayuda legal.
iI
CUMBERLAND COUNTY LAWYER REfERRAL SERVICE
COURT ADMINISTRATOR
CUMUERLANO COUNTY COllRTIIOUSE
ONE COURTIIOllS~: SQUARE
CARLISLE PENNSYLVANIA 17013
(717) 240 6200
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JAYME POTTEIGER,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Petitioner,
vs.
NO.
\
RODNEY POTTE1GER,
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
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Respondent.
PETITION FOR PROTECTION FROM ABUSE
TO THE HONORABLE JUDGES OF SAID COURT:
The Petition of JAYME POTTEIGER, by her attorney, Gerald S,
Robinson, Esquire, of Robinson & Geraldo, pursuant to the Protection
from Abuse Act, 1990, Dec. 19, Pa. Laws 1240, No. 206, 23 Pa.C.S.A
I:
Ii Section 6101 et. sea. respectfully represents as follows:
I
ii 1. Petitioner is JAYME POTTEIGER, an adult individual presently
residing at 227 Rich Valley Road, Mechanicsburg, Cumberland County,
Pennsylvania 17055.
2, Respondent is RODNEY POTTEIGER, an adult individual whose
current address is unknown.
3. Petitioner and Respondent were married on January 12, 1990,
and divorced from the bonds of matrimony December 7, 1994, by this
Honorable Court, which action was docketed at 3525 Civil 1994.
4. There were two children born to the marriage to wit: Tyler
Potteiger, born May 6. 1992, and Alex Potteiger, born December 10,
1989. Petitioner has primary physical custody pursuant to an order
of court from this Honorable Court, which action was docketed at 3525
Civil 1994.
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5, Respondent has threatened to cause bodily injury or serious
bodily injury with or without a deadly weapon, and has placed
Petitioner and her children in fear of imminent serious bodily
injury. Examples of Respondent's conduct include, but are not
limited to the following:
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a. On or about September 30, 1995, Respondent entered onto
Petitioner's rented property with his truck and bow, and proceeded to
hunt on Petitioner's land, despite posted signs stating that hunting
is prohibited. Because Respondent was being uncooperative,
Petitioner contacted the police to remove Respondent and his vehicle
from her land, Respondent was violent and angry, as he was fined for
having no insurance on his vehicle which resulted in removal of his
license plate and his truck being towed from the property. Verbal
threats were made at that time.
b, On or about September 29. 1995, during Respondent's
visitation period, Tyler was thrown into the car with such force that
he hit his head on the front door frame and he ended up face down in
the back seat.
c, Several incidents have occurred on Petitioner's rented
property which lead Petitioner's to believe that Respondent has been
on her land when she is not present. Investigation relative to these
incidents is on-going and is being conducted by the Silver Springs
Police Department.
d. Since May 1994, the Parties' d~te of separation,
Respondent has made it his business to know Petitioner's whereabouts
and actions.
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e. During the marriage Respondent had a habit of
physically, mentally, and emotionally abusing Petitioner and her
children, Specifically, Respondent slammed Petitioner's head
into the wal', slapped her several times, and punched her in the face
with such force that he broke her nose. Respondent struck Alex so
hard that his handprint was left on the child's skin.
f. Petitioner and her children are in fear of serious
bodily harm and are in need of and entitled to protection from such
abuse.
WHEREFORE, pursuant to the Protection from Abuse Act, Petitioner
prays your Honorable Court to:
1. Immediately enter a Temporary Order, pursuant to Section
6107 (b) of the Act, 23 Pa.C.S.A. 6101 et. sea.;
a). Directing Respondent to refrain from abusing,
harassing, or threatening Petitioner and her children, physically or
verbally, wherever they may be;
b). Excluding Respondent from entering or telephoning
Petitioner's current residence or any residence in which Petitioner
and the children may reside during the pendency of this Order;
c). Prohibiting Respondent from having any contact with
Petitioner, including entering or telephoning Petitioner's place of
employment and any other places Petitioner frequents;
d). Directing Respondent to refrain from all harassing
communication with Petitioner or her relatives;
e). Denying Respondent visitation rights with regards
to the Parties' minor children;
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f), Directing Respondent to pay Attorney's fees
incurred by Petitioner in the amount of five-hundred ($500.00)
dollars plus any and all filing fees and additional costs incurred by
Petitioner; l1nd
g). Directing Respondent to relinquish to the sheriff
all the weapons, including but not iimited to guns and rifles that he
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owns or that are in his possession.
2. After a hearing to be held within ten ( 10) days of the
f11ing hereof, and pursuant to Section 6107 (a) of the Act, 23 Pa.
C.S.A, Section 6101 et. sea. , enter a finai Protect! ve Order
continuing the relief set forth above for a period of one ( 1) year.
Respectfully submitted,
By (1. 4u..~d'c. -
Geraid~~ RObin~~~e
ROBINSON & GERALDO
Attorney 1.0. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, Pennsylvania 17110
(717) 232-8525
Attorney for Petitioner
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JAYME POTTEIGER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
v. 95-5301 CIVIL TERM
RODNEY POTTEIGER, . CIVIL ACTION - LAW
.
Defendant : PROTECTION FROM ABUSE
IN RE: CONTINUANCE
ORDER OF COURT
AND NOW, this lOth day of October, 1995, this
matter having been called this date on a petition seeking
a Protection from Abuse Order and Temporary Custody Order,
and Defendant having indicated he is unwilling to enter into a
consent order and requests time to consult with an attorney
involving the disposition of this matter, his request for a
continuance is granted. A hearing shall be held in Courtroom
Number 2 of the Cumberland County Courthouse at 3:30 p.m.
Wednesday, October 18, 1995.
The temporary order the Temporary Protection From
Abuse Order entered on October 5, 1995, shall remain in full
force and effect pending
Court.
Q~
Gerald S. Robinson, Esquire
For the Plaintiff
Rodney Potteiger, Pro Se
P.O. Box 164
New Kingstown, PA 17072
Probation
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JAYME POTTEIGER,
vs,
Petitioner,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Ii
!I RODNEY POTTEIGER,
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NO, ~5'.5301 ~\::P~
Respondent.
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
TEMPORARY PROTECTION ORDER
AND NOW, this :ili., day of October 1995, upon presentation and
consideration of the within Petition, the following Order is entered:
1, Respondent is directed to refrain from abusing, harassing,
or threatening Petitioner and her children, physically or verbally,
wherever they may be;
2. Respondent is excluded from entering or telephoning
Petitioner's current residence or any residence in which Petitioner
may reside during the pendency of this Order;
3. Respondent is prohibited from having any contact with
Petitioner, including entering or telephoning Petitioner's place of
employment and any other places Petitioner frequents;
4. Respondent is directed to refrain from all harassing
~" c/mmunication with Petitioner or her relatives.
,I , . 5. n-..pondent....I.s d8AJ.~ylit~tJ.gn rigRtIl
\.... '
. ( Parties' mMor t:h-Hdren.
1/ -~.---Respeftdent-k- directed""to paYAITOtfley's femr incu....t1 ~
Petitioner_~ the amount o~ five-hundred ($500T00) doiiars Plus any
yl~h rega~s to~
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an<14lJ..- fHing fees1nd additional C01ltB ll'tCUrred"-by Petitioner.
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7-...... Re&pondent. is di....eted---1:'O" ~Hnquish-t.o- the slier! ,U 'all Lhe
weapon!.t__.illkludinq-but not-lJ.mJ.l;ed togunLaflri rJ.fl_.., that Int-o~ms
to----.... .
qr .tl\~ Are in his 'l:JSedsion,'-
8, A certified copy of this Order shall be served on the police
department(s) in the jurisdiction where Petitioner resides, Pursuant
to Section 6109 (a) of the Act, a certified copy of this Order shall
immediately be filed by the pOlice department in the County Registry
of Protection Orders. Should the police come into contact with
Respondent, and Respondent alleges that he has not been served with
this Order, the police officer shall immediately serve the Order upon
her.
"
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9. This Order shall be enforced by any law enforcement agency
in any county where a violation of it occurs. As provided in Section
6133 (a) of the Act, "(a)n arrest for violation of an Order issued
pursuant to this chapter may be without warrant upon probable cause
whether or not the violation is committed in the presence of the
police officer."
10. Respondent is hereby notified that if he violates this
Order, he may be held in indirect criminal contempt which is
punishable by a fine up to $1,000.00 and/or by a jail sentence of up
to six (6) months. The Court may modify this Order at a contempt
hearing.
11. This Order shall remain in full force and effect until
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further Order of the Court.
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12. A hearing on this matter is scheduled for the I06t day of
October 1995, at J/:uu -fi...m., in Courtroom 7I , Cumberland
County Courthouse, High and Hanover Streets, Carlisle, Pennsylvania.
p
BY THE COURT:
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fa-Box "'4-
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OCT '; I:> !it! :,~ '95
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\. < !,',l
"I,' ,.
JAYME POTTEIGER,
Petitioner,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO.
RODNEY POTTEIGER,
Respondent,
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
NOTICE TO DEFEND
YOU HAVE BEEN SUED IN COURT, If you wish to defend against the
claims set forth in the following pages, you must appear at the
hearing scheduled herein. You are warned that if you fail to do so,
the case may proceed without you and an Order may be entered against
you for the relief requested in the Petition, You may lose money or
property or other rights important to you,
If a copy of the TEMPORARY ORDER is attached, you must obey it
until the hearing. If you do not obey it, the police can arrest you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, YOU HAVE A
RIGHT TO HAVE AN ATTORNEY REPRESENT YOU AT THE HEARING, 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 MAY GET LEGAL HELP.
AVISO PARA DEFENSA
USTED HA SIDO DEMANDADO EN LA CORTE, Si usted quiere defenderse
de las reclamaciones descritas en las paginas siguientes usted debe
asistir a la vista que esta citada en esta. Usted esta siendo
advertido de que si falla en asistir a la vista el caso procedera sin
usted y una Orden puede ser expedida en contra suya para el remedio
solicitado en la Peticion, Usted puede perder dinero 0 propiedad u
otros derechos importantes para usted.
Si la copia de una Orden Provisional esta adjunta usted debe
obedecerla hasta que la vista se lleve a cabo, 51 usted no la
obedece la policia 10 puede arrestar.
Lleve este aviso a su abogado inmediatamente. Usted tiene
derecho a tener representacion legal durante la vista, Si usted no
tiene los medios economicos para pagar un abogado, dirijase al
telefono mas cercano 0 vaya a la of Ie in a cuya dIreccion aparece a
continuacion. En esta direccIon podra obtener ayuda legal.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE PENNSYLVANIA 17013
(717) 240-6200
JAYME POTTEIGER,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Petitioner,
vs.
NO. 't'f- ). je I Cl.l:4i -r..---
RODNEY POTTEIGER,
Respondent.
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
TO THE HONORABLE JUDGES OF SAID COURT:
The Petition of JAYME POTTEIGER, by her attorney, Gerald S.
Robinson, Esquire, of Robinson & Geraldo, pursuant to the Protection
from Abuse Act, 1990, Dec, 19, Pa, Laws 1240, No. 206, 23 Pa.C.S.A
Section 6101 et. sea. respectfully represents as follows:
1. Petitioner is JAYME POTTEIGER, an adult individual presently
residing at 227 Rich Valley Road, Mechanicsburg, Cumberland County,
Pennsylvania 17055.
2. Respondent is RODNEY POTTEIGER, an adult individual whose
current address is unknown,
3, Petitioner and Respondent were married on January 12, 1990,
and divorced from the bonds of matrimony December 7, 1994, by this
Honorable Court, which action was docketed at 3525 Civil 1994,
4. There were two children born to the marriage to wit: Tyler
Potteiger, born May 6, 1992, and Alex Potteiger, born December 10,
1989. Petitioner has primary physical custody pursuant to an order
of court from this Honorable Court, which action was docketed at 3525
Civil 1994,
I'
5. Respondent has threatened to cause bodily injury or serious
bodily injury with or without a deadly weapon, and has placed
Petitioner and her children in fear of imminent serious bodily
injury, Examples of Respondent's conduct include, but are not
limited to the following:
a, On or about September 30, 1995, Respondent entered onto
Petitioner's rented property with his truck and bow, and proceeded to
hunt on Petitioner's land, despite posted signs stating that hunting
is prohibited, Because Respondent was being uncooperative,
Petitioner contacted the police to remove Respondent and his vehicle
from her land. Respondent was violent and angry, as he was fined for
having no insurance on his vehicle which resulted in removal of his
license plate and his truck being towed from the property. Verbal
threats were made at that time.
b. On or about September 29, 1995, during Respondent's
visitation period, Tyler was thrown into the car with such force that
he hit his head on the front door frame and he ended up face down in
the back seat.
c, Several incidents have occurred on Petitioner's rented
property which lead Petitioner's to believe that Respondent has been
on her land when she is not present, Investigation relative to these
incidents is on-going and is being conducted by the Silver Springs
Police Department.
d, Since May 1994, the Parties' date of separation,
Respondent has made it his business to know Petitioner's whereabouts
and actions.
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. e. During the marriage Respondent had a habit of
physically, mentally, and emotionally abusing Petitioner and her
children. Specifically, Respondent slammed Petitioner's head
into the wall, slapped her several times, and punched her in the face
with such force that he broke her nose, Respondent struck Alex so
hard that his handprint was left on the child's skin.
f. Petitioner and her children are in fear of serious
bodily harm and are in need of and entitled to protection from such
abuse,
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WHEREFORE, pursuant to the Protection from Abuse Act, Petitioner
prays your Honorable Court to:
1. Immediately enter a Temporary Order, pursuant to Section
6107 (b) of the Act, 23 Pa.C,S.A. 6101 et, sea,;
a). Directing Respondent to refrain from abusing,
harassing, or threatening Petitioner and her children, physically or
verbally, wherever they may be;
b), Excluding Respondent from entering or telephoning
Petitioner's current residence or any residence in which Petitioner
and the children may reside during the pendency of this Order;
c). Prohibiting Respondent from having any contact with
Petitioner, including entering or telephoning Petitioner's place of
employment and any other places Petitioner frequents;
d). Directing Respondent to refrain from all harassing
communication with Petitioner or her relatives;
II
e). Denying Respondent visitation rights with regards
to the Parties' minor children;
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VERIFICATION
I verify that the statements made in the foregoing Petition for
Protection from Abuse are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
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JAYME POTTEIGER,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Petitioner,
vs.
NO. 95-5301 Civil Term
RODNEY POTTEIGER,
Respondent,
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
PROOF OF SERVICE
I, Gerald S. Robinson, Attorney for Plaintiff, do hereby certify
that on the 9th day of October 1995, a true and correct copy of the
Temporary Order and Petition for Protection from Abuse was served on
the following individual by hand-delivery at his residence. Proof of
Service is evidenced by "Exhibit One" (attached),
Rodney Potteiger
RD t1 Apt .6
Shermans Dale, PA 17090
Respectfully Submitted,
j;
BY~~
Gerald S, Robinson, Esquire
ROBINSON & GERALDO
Attorney I,D. No, 27423
4407 North Front Street
P,O, Box 5320
Harrisburg, Pennsylvania 17110-5320
(717) 232-8525
Attorney for Petitioner
JJ02l688.DOC
PRIORITY ONE ATTORNEYS' MESSENGER SERVICE
. Joa.ph F, Johnaon, Owner
. Subpoenu & Cltatlona for All Courta
, S.rvlng U.S.A. & Canada
99 S. Cameron Str.et
P,O. Box 454
Harrlaburg, PA 1710800454
(717) 257-1365
PROOF OF SERVICE
ORDER NO,
ROBINSON & GERALDO
4407 NORTH FRONT STREET
HARRISBURG, PA 17110
PROCESS TO BE SERVED BY:
TEMPORARY PROTECTION
DOCUMENTS:FROM ABUSE ORDER ON
RESPONDENT; LETTER;
WITNESS FEE:
DATE. RECEIVED
DATE REASSIGNED
CASE NO.CUMBERLAND COUNTY,
PAl 95-5301 CIVIL
JAYME POTTEIGER
PlAINTIFF
-vs-
RODNEY POTTEIGER
DEFENDANT
RODNEY Po~~f~VED:
RD #1 APT 1115
SHERMANS DALE, PA 1709('
RODNEY po~f~ BY:
RD #1 APT #5
SHERMANS DALE. PA 17090
; DATE SERVED:
TIME:
9 OCT 95
8:10 P
PROCESS SERVER'S NAKE
JOSEPH F. JOHNSON
[ t.t1lale
I J Female
, [~ustache
, [ J Beard
[ ~asses
[~e Skin
[ ] Black Skin
[ I Yellow Skin
[ ] Brown Skin
[ J Red Skin
I ] Black Hair
ri ~rown Hair
l.-f-o-t' Blonde Hair
I ] Gray Hair
[ ] Red Hair
I ] White Hair
I ] Balding
[ ] 14-20 Yrs.
I L.J.--21- 35 Yrs.
[ ] 36-50 Yrs.
[ ] 51-65 Yrs.
I ] Over 65 Yrs.
I ] Under 5'0"
[ ] 5'0" - 5'3"
I ] 5'4" . 5'8"
fl.-.t'5i9" - 6'0"
I ] Over 6'0"
[ ] Under 100 Ibs.
I ] 100-130 lbs.
I ] 131-160 Ibs.
[t.-!-'1'61-200 lbs.
[ ] Over 200 Ibs.
[ ] Military Service
Other Identifying
Features:
NON-SERVICE INFO
I ] Moved
[ ] No Longer Employed
[ ] Never in But Address
Has Been Verified
[ ] Not Known
[ ] Evading Service
[ ] No Such Address
Sworn, t,o, and sUbscribe~ b~ me
Ie) .1 cs.y of C. / -f
19 9.5-, /1
0k../ ..0.~/
Notary Public
thls
PROCESS SERVER'S REPORT
(,.,j[ r1,.'\DE L t'4TT[Mr'TS !t': ~;,[ :J'~' ~ ... ro (: ~'I~-l'" Ti", It,ll-, lC ':-~[~'l}[ HIM.
Exhibit
"ONE"
JoltpA I: "':. ;"'>(j-" being duly sworn
accorJing to law, deposes and says that he/she is
process server herein named; and that the feets
herein set forth above are true and correct to
the bes of the~r knOW~d e, information and belief.
Comai 5 on xPHO
SH~noll R, AnNHARr, Ntll3l'; PlJbtit
tM.t ":':'''~,V'':l ~\tIIP" r~rr:!JWl!d COU'tty
My CVI:,Ifi"$IO;' E~"es Nod, 1887
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~Iaintiff
v
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION LAW
: NO. S \u\ CIVIL 19CJ,S
: CUSTODYNlSITATION
. JO'iffi c.. A0'\-\e '3e\
Defendant
ORQl:R OF COURT
AND NOW, this ~ day of ex:. \doe r, upon consideration of the attached complaint,
it is hereby directed that the parties and their respective counsel appear before
~~..)..\,.rW\t'1' E:::.~theconciliator,at c~q \,.j Mll\;\c\\"wdv'f\ll }hJJ I
, on the G) day of t'-.h. 't'fIW''J.. (, 19'1], at \ \ no A, 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 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.
FOR THE COURT:
BY:.d-~(,H:I..\i\ sc\ ~.1Jli~\ l<>'l\r
Custody Conciliator (-n:,,:), ~
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 FOR BELOW TO FINS OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, FOURTH FLOOR
CARLISLE, PA 17013
(717) 240-6200
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RODNEY J. POTTEIGER,
Petitioner
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 95-5301 CIVIL TERM
: CIVIL ACTION - LAW
: CUSTODY
V.
JA YME POTTEIGER,
Respondent
PETITION TO MODIFY CUSTODY AGREEMENT
AND NOW, comes the Petitioner, Rodney J. Potteiger, by and through his
atlomey, Chartes Rector, Esquire, and files this Petition to Modify Custody Agreement,
and in support thereof, avers the following:
1. Petitioner is Rodney J. Potteiger, Father, who currently resides at Box
813, Pisgah State Road, Landisburg, Pennsylvania, 17040.
2. Respondent is Jayme Potteiger, Mother, who currently resides at 322
Locust Street, Mechanicsburg, Pennsylvania, 17055.
3. The parties hereto are the parents of Alex J. Potteiger, DOB 12/10/89 and
Tyler Reed Potteiger, DOB 05/06/91 , who currently reside at 322 Locust Street,
Mechanlcsburg Pennsylvania.
4. On November 29, 1994, the parties signed a Property Settlement
Agreement which awarded primary physical custody to Respondent and partial custody
to Petitioner. A true and correct copy of this "Agreemenr is marked Exhibit -A;
attached hereto, and made part thereof.
5. The best interests and permanent welfare of the children will be served by
a modiflcatlon of the Agreement awarding Father with primary physical custody of the
children.
I verify that the statements made herein are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904,
relating to unsworn falsification to authorities.
/-,
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RooneY J. Polte)gilr
Date: /;),'17. C) 7
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PROPBRTY SBTTLBKENT AGRBBKENT
THIS AGRBBKENT, made tbis a.q day of /IIi>o/f>o.b..., 1994, is by and between:
,:
RODNEY J. PO'l"l'EIGER, party of the first part, hereinafter referred to as "Husband"; and
iJAYKE PO'l"l'EIGER, party of the second part, hereinafter referred to as "Wife."
i'
I WITNESSETH:
I WHEREAS, the parties hereto are busband and wife, having been married on January
I
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12, 1990 and are the natural parents of two (2) minor children: Alex (DOB December 10
,1989) and Tyler (DOD Hay 6, 1992),
I
(hereinafter referred to as "cbildren"); and
WHEREAS, certain difficulties have arisen between the parties hereto which have
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il.ade them desirous of living separate and apart frOD one another and Husband has
initiated or plans to sbortly initiate an action in divorce against Wife; and
WHEREAS, the parties hereto have mutually entered into an agreement for the
:!division of their assets, the provision for the liabilities they owe, and provision for
"
I'the resolution of their mutual differences, after both parties have had full and a.ple
I opportunity to consult witb tbeir respective attorneys, and the parties now wish to
jlhaVe that agreement reduced to writing.
NOlI, THEREPOIE, tbe parties bereto, in consideration of tbe above recitals, the
, .utually .ade and to be kept promises set forth hereinafter, and for other good and
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!'valuable considerations, and intending to be legally bound and to legally bind their
,
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..heirs, successors, assigns, and personal representatives, do hereby covenant, pr~ise,
,
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and agree as follows:
'-
i EXHIBIT
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Ii 5, In consideration of the payment of $4,500,00. Wife hereby waives any and all
II
[,interest she may have or claims to have from the proceeds derived from the sale of the
,
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:,residence and any interest she may have in Husband's business which is known as R.J.
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Potteiger Construction. Wife aCknowledges that she is aware that the proceeds from the
sale of the house, except for the amounts retained by the parties. were used to pay
various debts associated with the house including debts related to the construction of
the home, and further acknowledges that she has the right to require any additional
information related to the sale of the residence or related to R.J. Potteiger
Construction, Wife hereby waives and releases any claim that she may have to the
proceeds or to Husband's business or to participate in it which may arise out of her
marriage to Husband and agrees that such proceeds and business shall remain the sole
and separate property of Husband, except as limited by Husband's responsibility to pay
any and all debts as ~re fully contained in paragraph number 6 herein.
I 6. In consideration of the receipt of the remaining balance of $1,665.04, and for
other good and valuable consideration, Husband hereby covenants and agrees to assume
and pay in full any and all debts and obligations related to the construction of the
marital residence, 112 Ridgehill Road, Hechanicsburg, Pennsylvania, and any and all
I
I!debts or liens of any type related to R.J, Potteiger Construction, Husband's business,
It
;!and further, he covenants and agrees that he will indeanify and save Wife harmless from
Ilany and all liability, expense, costs, or loss whatsoever as a relult of his non-
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I payment or non-performance of said debt obligations.
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7. HUlband covenants and agrees to transfer Ind alsign to Wife. all of his right,
title. and interest in and to the 1989 Honda; said automobile to be the sole and
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Iseparate property of Wife.
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I' 8, Wife covenants and agrees to transfer and assign to Husband, all of her right,
title, and interest in and to the 1989 Ford Truck; said truck to be the sole and
separate property of Husband.
9. The parties hereto mutually agree that they have effected a satisfactory
division of the furniture, household furnishings, appliances, and other household and
personal property between them and they mutually agree that each party shall, from and
after the date hereof, be the sole and separate owner of all such tangible personal
property presently in his or her possession, whether said property was heretofore owned
jointly or individually by the parties hereto, and this agreement shall have the effect
I
10f an assignment or receipt from each party to the other for such property as may be in
Ithe individual possessions of each of the parties hereto, the effective date of said
bill of sale to be contemporaneous with the final decree in divorce entered in the
action contemplated to be filed herein.
10. The parties acknOWledge that they are aware of the income, education, income
'IPotential, and assets and holdings of the other or have had full and ample opportunity
lito become familiar with such items, Both parties acknOWledge that they are able to
,'support and maintain themselves comfortably, without contribution from the other, upon
,
I the income and assets owned by each of them except as provided for herein. The parties
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jiherebY accept the mutual covenants and te~s of this Agreement and the benefits and
,I
..properties passed to them hereunder in lieu of any and all rights to support or alimony
,
,
I
for themself, counsel fees, and alimony pendente lite at this time and during any and
all further or future actions of divorce brought by either of the parties hereto and
4
the parties do hereby remise, release, quit claim, and relinquish forever any and all
of their said rights to support for themself, counsel fees, alimony, and alimony
pendente lite during the pendency of or as a result of any such actions, as provided by
the Divorce Code of Pennsylvania or any other applicable statute, at this time and at
any time in the future.
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11. Husband releases his inchoate intestate rights in the estate of Wife and Wife
:!releases her inchoate intestate rights in the estate of Husband, and each of the
i:parties hereto by these presents for himself or herself, his or her heirs, executors,
"
:iadministrators, or assigns, does remise, release, quit claim, and forever discharge the
other party hereto, his or her heirs, executors, administrators, or assigns, or any of
them, of any and all claims, demands, damages, actions, causes of action or suits of
law or in equity, of whatsoever kind or nature, for or because of any matter or thing
!:
:done, ~itted, or suffered to be done by such other party prior to the date hereOf;
except that this release shall in no way exonerate or discharge either party hereto
from the obligations and pr~ises made and imposed by reason of this agreement and
, shall in no way affect any cause of action in absolute divorce which either party may
"have against the other,
12. The parties hereto mutually represent to the other that neither of them has
incurred any debts in the name of the other not previously disclosed or provided for in
this agreement. Each of the parties hereby represents to the other that neither one of
,them have incurred or contracted for debts in the name of the other or for which the
other is or would be legally liable from and after the date of the parties' separation.
Both parties hereto mutually agree and promise that neither will contract or otherwise
s
incur debts in the other's or joint names without the prior permission and consent of
, the other party hereto. Both parties hereto represent and warrant to the other party
that they have not so contracted any debts unbeknownst to the other up to the time and
date of this Agreement,
13. The partiet agree that they shall. contemporaneously with the execution of
I
i this agreement, make, execute, acknowledge, and deliver unto Husband's attorney,
,
'Iconsents pursuant to Section 3301(c) of the Pennsylvania Divorce Code and any and all
,
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!iother documents reasonably necessary to conclude a divorce action, The parties agree
!I
'!that they shall take any and all action necessary to conclude a divorce pursuant to
':
"Section 3301(c) promptly after the execution of this agreement.
14, In the event that any of the provisions of this agreement are breached or
,
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:Iviolated by either of the parties,
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:: agreement by an appropriate action
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the other party shall be entitled to enforce this
in law or in equity or to take any other action to
,'which they are laWfully entitled to enforce this agreement or otherwise protect their
,: rights.
I,
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"party s
:,
In the event that such action is cOllllllenced by one of the parties and the other
found to have breached or violated any of the teras and provisions of this
'i
':agreement. the party having so violated or breached the agreement, shall be responsible
I:
, for and shall promptly pay upon demand the reasonable attorney's fees incurred by tbe
other party to enforce their rights hereunder.
15, This Agreement shall be interpreted and construed in accordance with the lavs
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::of the COMOnwealth of Pennsylvania,
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16, If for any reason whatsoever any part of this Agreement shall be declared
void or invalid. only such part shall be deemed void and in all other respects this
6
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'Agreement shall remain valid and fully enforceable,
17. The waiver ot any term, condition, clause, or provision of this Agreement
,
'shall in no way be deemed or considered a waiver of any other term, condition, clause
I
or provision of this Agreement.
IN WITNESS VHBRBOP, the parties hereto have set their hands and seals the day and
year first above written.
~
ROD . P BIG
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COHHONWEALTH OF PENNSYLVANIA )
( SS.:
COUNTY OF CUHBERLAND )
I On this, the294 day o;Y)bJln't.bir ' 19<Y/-. before me, the undersigned
liofficer, personally appeared RODNEY J. POTTEIGER known to me (or satisfactorily proven)
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,. to be the person whose name is subscribed to the wi thin instrument, and aCknowledged
that said perSOD executed same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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WENDY S, BLAIR. Notary Pcblic
lemoyne Boro. Cl:mbi!r1and CO'Jnty. Pa.
~ Commission Expire. ~y 6. 1995
"
,
ii' COHHONWIlALTH OF PIlNNSYLVANIA )
I ( SS.:
, 'COUNTY OF CUHBIlRLAND )
II on this, thZ~day of~{JYlJYli9tr , 19~ before me, the undersigned
'I orr
I.
::officer, personally appeared JAYHB POTTBIGER known to me (or satisfactorily proven) to
j:
iibe the person whose name is subscribed to the within instrWlent, and acknowledged that
"
::said person executed same for the purposes therein contained.
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IN WITNESS WHBlEOP, I hereunto set my hand and official seal.
/J.1A/J )" J J/11 <--r
~~~on Expires:
NOTtR:Al SEAL
WENDY S, 3lAI~, Nolary Pcb';c
bmoyna B~r~ r..".,L'r' . (
.. \,I, -....,?.. ..!n" o:..nty, Pa.
My Comr.i.:':il.:n b:,:;a:~ Aiay ~. 1995
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RODNEY J. POTTEIGER,
Petitioner
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: ~~O. 95-5301 CIVIL TERM
: CIVIL ACTION - LAW
: CUSTODY
V.
JAYME POTTEIGER,
Respondent
PETITION FOR SPECIAL RELIEF TO PREVENT
RESPONDENT'S DEPARTURE FROM CUMBERLAND
COUNTY WITH THE PARTIES' MINOR CHILDREN
AND NOW comes the Petitioner, Rodney J. Potteiger, by and through his
attorney, Charles Rector, Esquire, and files this Petition for Special Relief, and In support
thereof, avers the following:
1. Petitioner, Rodney J. Potteiger, is an adult individual residing at Box 813,
Plsghah State Road, Landisburg, Pennsylvania, 17040.
2. Respondent, Jayme Potteiger, is an adult Individual residing at 322
Locust Street, Mechanlcsburg, Pennsylvania, 17055.
3. The parties are the parents of Alex J. Potteiger (DOB 12/10/89) and Tyler
Reed Potteiger (DOB 05/06/91) currently residing with Respondent.
4. On or about October 25, 1997, Petitioner learned that Respondent
Intends to relocate with the children to Uniontown, Fayette County, Pennsylvania, on or
about November 4,1997.
5. On October 28,1997, Petitioner filed a Petition to Modify the parties'
current Custody Agreement and is seeking primary physical custody of the children (See
Exhibit "A" attached).
6. A Custody ConcUiation has been scheduled for November 11, 1997,
before Dawn Sunday, Esquire.
7. Petitioner believes If Respondent leaves Cumberland County with the
children that she will not retum for the scheduled Conciliation,
8. The best interests of the children will not be served by Respondent's
departure from Cumberland County and the Mechanicsburg School District in mld-
semester.
9. Until the Conciliation is held, the parties' children should not be removed
from Cumberland County.
WHEREFORE, Petitioner seeks a temporary Order of Court preventing
Respondent's removal of the parties' minor children from Cumberland County,
Pennsylvania pending conciliation and further order of this Court.
RESPECTFULLY S BMITTED,
------
Date:~
rles Re r, quire
1104 Femwood Avenue, Ste, 203
Camp Hill, PA 17011
(717) 761-8101
Attorney for Petitioner
I verify that the statements made herein are true and correct. I understand that
false statements herein are made subject to the penalUes of 18 Pa.C.S. SecUon 4904.
relaUng to unswom falslficaUon to authoriUes.
/;" ~" ,;~~,~)
~o<!ney J. polttlTger
/. 0 /Ja a -
Date: /t:> -,7 , . I /
. R06t"\~'i..)' ~\ \c'~ e r
, 'Plaintiff
V
· jQ,,\N'\~ fb-\-\e\3~\
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION LAW
: NO. S~()\ CIVIL 19Q5
: CUSTODYNlSITATION
QBDER OF COURT
AND NOW, this ~ day of Oc-\c'nel, upon consideration of the attached complaint,
it is hereby directed that the parties and their respective counsel appear before
{))~ ~\ .~~~ ao...:.....t!1econciliator, at ~q \,.j. Hci \:\ \ 'A, I t-\t-c hrr'\lr S b-rj )
S!8..- ' on the ~ ~ay of .lli 'f'J1\~L 19~, at 1\' ()() A. 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 the court, and to enter into a temporary order. All children age five or older may also
he present at the conference. Failure to appear at the conference may provide grounds
for entry of a temporary or permanent order.
FOR THE COURT:
By: \~
Custody Conciliator C~:)
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 FOR BELOW TO FINS OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, FOURTH FLOOR
CARLISLE, PA 17013
(717) 240-6200
TRUE coPy FROM REOOR~
, 11" I hef8 urCO .UWW
Inl~jlllftY.... at ca-, PI.
aneS tbi"" of said ~~.~ 19 '9 i
thl' 12fr~ ~ ';:;4:'
~ EXHIBIT
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RODNEY J. POlTElGER,
Petitioner
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
JA YME POTTEIGER,
Respondent
.
: NO. 95-5301 CIVIL TERM
: CIVIL ACTION - LAW
: CUSTODY
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PETITION TO MODIFY CUSTODY AGREEMENT
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AND NOW, comes the Petitioner, Rodney J. Potteiger, by and through his
attomey, Charles Rector, Esquire, and files this Petition to Modify Custody Agreement,
and in support thereof, avers the following:
1. Petitioner is Rodney J. Potteiger, Father, who currently resides at Box
813, Pisgah State Road, Landisburg, Pennsylvania, 17040.
2. Respondent is Jayme Potteiger, Mother. who currently resides at 322
Locust Street, Mechanicsburg, Pennsylvania, 17055.
3. The parties hereto are the parents of Alex J. Pottelger, DOB 12/10189 and
Tyler Reed Potteiger, DOB 05106/91 , who currently reside at 322 Locust Street,
Mechanicsburg Pennsylvania.
4. On November 29, 1994, the parties signed a Property Settlement
Agreement which awarded primary physical custody to Respondent and parllal custody
to Petitioner. A true and correct copy of this "Agreement" is marked Exhibit "A,"
atteched hereto, and made part thereof.
5, The best interests and permanent welfare of the children will be served by
a modiftcation of the Agreement awarding Father with primary physlcal custody of the
children.
6. Modification of the Custody Agreement Is necassary and appropriate
under the circumstances because:
a. Mother has relocated no less than six (6) times durlng the last two (2)
years causing disruption and Instability to the minor children.
b. Mother has failed to maintain consistent full-time employment since 1994
and has worked for no less than six (6) different employers during that
period, all of which contributes to the instability of the minor children's
home environment.
c. Petitioner leamed on or about October 25, 1997, that Respondent will
relocate herself and the minor children to 11 Falrview Street, Unlontown,
Pennsylvania, on or about November 4, 1997, and In so doing, Intends to
remove the children In mid-semester from their respective schools
disrupting their education.
d. Petitioner was neither consulted nor approves of Respondenfs relocation
outside of Cumberland County.
e. Petitioner has been advised by their minor children's teachers in the
Mechanlcsburg School District that the children have missed an Inordinate
amount of ciass durlng the 1996-1997 school year.
WHEREFORE, Petitioner respectfully requests that this Honorable Court modify
the parties' Settlement Agreement and award Father prlmary physical custody of the
minor children.
, ulre
1104 Fe Avenue, Ste. 203
Camp Hili, PA 17011
(717) 761-8101
Attorney for Petitioner
Date: /t~;4f
I verify that the statements made herein are true and correct I understand that
false statements herein are made SUbject to the penalties of 18 Pa.C.S. Section 4904,
relating to unsworn falsification to authorities.
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R J. Potte A
Date: //). {)7.97
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PROPERTY SB'l'TLIlHRN'I' AGRBIlKBN'I'
THIS AGRBJlMJlNT, made this a.'1 day of IVt>y'l\o.b.., 1994, is by and between:
RODNBY J. POTTEIGER, party of the first part, hereinafter referred to as "Husband"; and
JAYKB POTTEIGER, party of the second part, hereinafter referred to as "Wife."
VITNB8SBTII :
IHElBAS, the parties hereto are husband and wife, having been married on January
12, 1990 and are the natural parents of two (2) minor children: Alex (DOS December 10
1989) and Tyler (DOS Hay 6, 1992), (hereinafter referred to as "children"); and
IHElBAS, certain difficulties have arisen between the parties hereto which have
initiated or plans to shortly initiate an action in divorce against Wife; and
IIIIBlBAS, the parties hereto have mutually entered into an agreellent for the
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division of their assets, the provision for the liabilities they owe, and provision for
the resolution of their mutual differences, after both parties have had full and ..pIe
opportunity to consult with their respective attorneys, and the parties now wish to
have that agreement reduced to writing.
II 110I, 'l'IDlRBPOIB, the parties hereto, in consideration of the above recitals, the
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:lIUtually made and to be kept promises set forth hereinafter, and for other good and
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'valuable considerations, and intending to be legally bound and to legally bind their
Ilheirs, successors, assigns, and personal representatives, do hereby covenant, promise,
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I and agree IS follows:
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EXHIBIT
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. 1. The parties shall share legal custody ot the minor children and Wite will have
primary physical custody with periods of partial custody and visitation with Father as
iagreed upon by the parties.
2, Support has been determined through a separate action filed by Wife against
Husband with the DQlestic Relations Office. The payment of support, will continue to be
controlled by that Order and is not part of this agreement.
3. The parties acknowledge that they oVDed or had an interest in property known
as llJ Ridgehill Road, Kechanicsburg, Pennsylvania 17055. The parties further
acknowledge that that property was sold on October 7, 1994 and that both parties
participated in the sale of the property. Further, the parties acknowledge that there
was a total of $12,165.04 that was paid to the Sellers which represented the total
equity in the hoae after payment of all liens against it or other expenses related to
the construction of the hoae. Bach party retained $3,000.00 froa the sale of the hoae
which was retained at the settlement on the property. The re.aining $6,165.04 was
retained by Husband's attorney and will be divided in accordance with the re.aining
teras of this agreement.
4. Husband agrees that Wife should retain $4,500.00 from the proceeds of the lale
of the residence lilted in paragraph number 3 above. Husband will retain the re.aining
balance of the proceeds. HUlband authorizes his attorney to releale those funds to
Vife'l attorney. Vife'l attorney il authorized to releale'tholefundl without further
notice to HUlband or hil attorney provided that Vife has fully executed thil agre..ent
I and further hal taken all other Itepl necellary to conclude the divorce al conte.plated
herein.
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,5. In consideration of the par-ent of $4,500,00, Wife hereby waives any and all
linterest she .ay have or claims to have from the proceeds derived from the sale of the
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Ilresidence and any interest she may have in Husband's business which is known as i.J.
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;:Utle,
Potteiger Construction. Wife aCknowledges that she is aware that the proceeds froa the
sale of the house, except for the amounts retained by the parties, were used to pay
various debts associated with the house inClUding debts related to the construction of
the hoae, and further acknowledges that she has the right to require any additional
infor.ation related to the sale of the residence or related to i.J. Potteiger
COnstruction. Wife hereby waives and releases any claim that she .ay have to the
proceeds or to Husband's business or to participate in it which may arise out of her
aarriage to Husband and agrees that such proceeds and business shall remain the sole
and separate property of Husband, except as li.ited by Husband's responsibility to pay
any and all debts as more fUlly contained in paragraph nuaber 6 herein.
6. In consideration of the receipt of the re.aining balance of $1,665.04, and for
other good and valuable consideration, Husband hereby covenants and agrees to assu.e
and pay in full Iny and all debts and obligations related to the construction of the
.arital residence, 112 iidgehill ioad, Mechanicsburg, Pennsylvania, and any and all
debts or liens of any type related to i.J. Potteiger COnstruction, Husband's business,
Ind further, he covenants and agrees that he will inde.uify Ind save Vife har.less fro.
Ilny Ind all liability, expense, costs, or loss whatsoever as I result of his non-
pl,..nt or non-perfo~nce of said debt obligations.
7. Husband covenants and agrees to transfer Ind assi90 to Vife, all of his right,
Ind interest in and to the 1989 Honda; Slid automobile to be the sole Ind
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separate property of Wife.
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8. Wife covenants and agrees to transfer and assign to Husband, all of her right,
iititle, and interest in and to the 1989 Ford Truck; said truck to be the sole and
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separate property of Husband.
9. The parties hereto mutually agree that they have effected a satisfactory
division of the furniture, household furnishings, appliances, and other household and
personal property between them and they mutually agree that each party shall, trom and
after the date hereof, be the sole and separate owner of all such tangible personal
property presently in his or her possession, whether said property was heretotore owned
IjOintlY or individually by the parties hereto, and this agree.ent shall have the ettect
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of an assignment or receipt from each party to the other tor such property as may be in
the individual possessions of each ot the parties hereto, the effective date ot said
bill ot sale to be conte.poraneous with the' tinal decree in divorce entered in the
action contemplated to be tiled herein.
10. The parties acknOWledge that they are aware of the income, education, in~e
potential, and assets and holdings ot the other or have had full and ample opportunity
to become tamiliar with such ite.s. Both parties acknowledge that they are able to
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support and maintain themselves comtortably, without contribution trom the other, upon
,
Ithe incoae Ind assets owned by each of the. except as provided for herein. The parties
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IherebY Iccept the mutual covenants and teras of this Agreement Ind the benefits Ind
..properties pissed to them hereunder in lieu of any and III rights to support or Ilimony
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for themself, coUDsel fees, and alimony pendente lite at this time and during any and
III further or future Ictions of divorce brought by either of the plrties hereto and
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the 'parties do hereby remise, release, quit claim, and relinquish forever any and all
of their said rights to support for themself, counsel fees, alimony, and alimony
pendente lite during the pendency of or as a result of any such actions, as provided by
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::the Divorce Code of Pennsylvania or any other applicable statute, at this time and at
:any time in the future.
ii 11. Husband releases his inchoate intestate rights in the estate of Wife and Wife
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!ireleases her inchoate intestate rights in the estate of Husband, and each of the
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IIparties hereto by these presents for himself or herself, his or her heirs, executors,
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liad.inistrators, or assigns, does remise, release, quit claim, and forever discharge the
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'.other party hereto, his or her heirs, executors, ad.inistrators, or assigns, or any of
':them, of any and all claims, demands, damages, actions, causes of action or suits of
:'
rlav or in equity, of vhatsoever kind or nature, for or because of any matter or thing
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Iidone, omitted, or suffered to be done by such other party prior to the date hereof;
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; except that this release shall in no yay exonerate or discharge either party hereto
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';from the obligations and promises made and imposed by rea~on of this agreement and
;shall in no yay affect any cause of action in absolute divorce vhich either party may
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',have against the other.
12. The parties hereto mutually represent to the other that neither of them has
incurred any debts in the name of the other not previously disclosed or provided for in
: this agreement. Bach of the parties hereby represents to the other that neither one of
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'. them have iDcurred or contracted for debts in the Due of the other or for vhich the
other is or would be legally liable from and after the date of the parties' separation.
loth parties hereto mutually agree and promise that neither viII contract or othervise
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-'incur debts in the other's or joint names without the prior permission and consent of
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.the other party hereto. Both parties hereto represent and warrant to the other party
.that they have not so contracted any debts unbeknownst to the other up to the time and
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ildate of this Agreement.
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!i 13. The parties agree that they shall, contemporaneously with the execution of
this agreement, make, execute, acknowledge, and deliver unto Husband's attorney,
consents pursuant to Section 330l(c) of the Pennsylvania Divorce Code aDd any and all
lother documents reasonably ne~essary to conclude a divorce action. The parties agree
,that they shall take any and all action necessary to conclude a divorce pursuant to
I Section 330l(c) promptly after the executioD of this agreement.
"
'I 14. In the event that any of the provisions of this agreement are breached or
'violated by either of the parties, the other party shall be entitled to enforce this
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ljagreeaent by an appropriate action in law or in equity or to take any other action to
;:Which they are laWfully entitled to enforce this agreement or otherwise protect their
p
iirights. In the event that such action is coaaenced by one of the parties and the other
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, party is found to have breached or violated any of the teras and provisions of this
ii.......... the ..,., h..i.. 00 vi.'.... ., h,""he' the ..,....... ..." he '"'....!hl.
. for and shall promptly pay upon demand the reasonable attorney's fees incurrod by the
:'other party to enforce their rights hereunder.
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I 15. This Agreeaent shall be interpreted and construed in accordance with the laws
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I.of the Coaaonwealth of Pennsylvania.
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16. If for any reason whatsoever any part of this Agreeaent shall be declared
void or invalid, only such part shall be deeaed void and in all other respects this
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liA9re~ment shall remain valid and fully enforceable.
I 17. The waiver ot any term, condition, clause, or provision of this Agreement
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'Ishall in no way be deemed or considered a waiver of any other term, condition, clause
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or provision of this Agreement.
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1M WITNESS VHBlBOP, the parties hereto have set their hands and seals the day and
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,: COHHOHWBALTH OF PIlHHSYLVAHIA )
( SS.:
COt/HTY OF CUKBIlRLAHD )
:: On this, the~ day o;Y)bJ.tntbtr ,19rl, before me, the undersigned
jOfficer, personally appeared RODNEY J. POTTBIGIlR known to me (or satisfactorily proven)
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!:to be the person whose name is subscribed to the within instrument, and acknowledged
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that said person executed same for the purposes therein contained.
1M WITNESS WHBRBOF, I hereunto set my hand and official seal.
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,I' cotIIOHIIBALTH or PBHHSYLVAHIA )(
S8.:
COtIHTY or cmmBRLAHD )
On this, thz..~day o;t}lJYlml9tt , 194 before ae, the nndersigned
:jofficer, personally appeared JAYKB POTTBIGER known to me (or satisfactorily proven) to
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Ilbe the person whose name is subscribed to the within instrument, and aCknowledged that
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Ilsaid person executed same for the purposes therein contained.
'11M WITNESS VHBlBOr, I hereunto set my hand and official seal.
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My eoa.is lon Expires:
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WINDY s. BLAIR, NOllry Poblic
lImqynl Bo,o, Combl,llnd County, Po.
NIt Commission Expl,lS Mly 6. 1995
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NOT~R:Al SEAL
WENDY 5, BLAIR, Nellry Public
lImoynl 8?,~, Cumbo".nd County, Po.
NIt CommISSion f.x;li,u MAy 6, 1995
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RODNEY J. POl'l'EIGER, . IN THE COURT OF CCX'lMOO PLEAS OF
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Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
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vs. . NO. 95-5301 CIVIL TERM
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JAYME POTTEIGER, . CIVIL ACTION - LAW
.
Defendant : CUSTODY/VISITATION
amtlR (J1' <nJRT
AND 1Of, this ~ day of O~
consideration of the attached CUstody Conciliation Report,
and directed as follows:
, 1997, upon
it is ordered
1. 'Dle prior Order of this Court dated October 30, 1997, is
vacated and replaced by this Order.
2. 'Dle Father, Rodney J. Potteiger, and the Mother, Jayme
Potteiger, shall have shared legal custody of Alex J. Potteiger, born
Oecentler 10, 1989, and Tyler Reed Potteiger, born May 6, 1991.
3. 'Dle Father shall be entitled to obtain the Children's school
records directly from the school in which they are enrolled.
4. 'Dle Mother shall have primary physical custody of the
Children.
5. 'Dle Father shall have partial physical custody of the
Children on alternating weekends, beginning Saturday, NovenDer 22, 1997
from Saturday at 10:00 a.m. through SUnday at 4:00 p.m.
6. The Father shall have partial physical custody of the
Children for one week each sumner upon providing advance notice to the
Mother by May 30.
7. 'Dle parties shall alternate having custody of the Children
over the Christmas holiday from Christmas Eve at 10:00 a.m. through
Christmas Day at 4:00 p.m. 'Dle Father shall have custody of the Children
over the Christmas holiday in even nurti:lered years and the Mother shall have
custody of the Children over the Christmas holiday in odd nUll'bered years.
8. 'Dle Father shall have custody of the Children at such other
times as the parties arrange by IIl.ltual agreement.
9. 'Dle Mother shall provide transportation for exchanges of
custody to and from the Father's residence.
10. The Mother shall provide the Father with her current addreae
and telephone nUll'ber, the Children's daycare phone nuntler, and ongoing
infotmatioo concerning the Children's progress in school, including achool
attendance and other school records.
11. This Order is entered pursuant to an agreement by the partiN
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at a custody Conciliation Conference. The
provisions of this order by mutual agreement.
agreement, the terms of this order shall control.
parties may modify the
In the absence of mutual
ee:
Edgar B. Baylely
Charles Rector, Esquire - Counsel for Father .J ~
Gerald Robinson, Esquire - Counsel for Mother ~il'l1 _
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RODNEY J. PC1l'l'EIGER, : IN THE COURT OF <::cxoIMOO PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
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vs. : NO. 95-5301 CIVIL TERM
.
.
JA~ PC1l'l'EIGER, . CIVIL ACTION - LAW
.
Defendant . CUSTODY/VISITATION
.
PRIeR JtIDGB: Edgar B. Bayley
ammy cx:NCILIATICfi lUMARY REPCRl'
IN ACXXIUW<<:B wrm ClIIBERLAND CXUl.lY ROLE OF CIVIL m:>"J<J I\JRE
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DM.'E OF BIRTB
aIOOl:NTLY IN ammy OF
Alex J. Potteiger
Tyler Reed Potteiger
December 10, 1989
May 6, 1991
Defendant/Mother
Defendant/Mother
2. A Conciliation Conference was held on November 11, 1997, with
the following individuals in attendance: The Father, Rodney J. Potteiger,
with his counsel, Charles Rector, Esquire, and the Mother, Jayme Potteiger,
who appeared at the Conference without counsel, but who is represented by
Gerald Robinson, Esquire.
attached.
3. The parties agreed to entry of an Order in the form as
A...lfuc>....n bvJ cJJ-: I ~9 7
Date .
(a,,~.~~
Dawn S. Sunday, Esqu
CUstody Conciliation
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RODNEY J. POTTEIGER.
Petitioner
v,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO, 95-5301 CIVIL TERM
JAYME POTTEIGER,
Respondent
: CIVIL ACTION - LAW
: CUSTODY
ORDER OF COURT
AND NOW, this -D- day of ~Ii\b:( ,1998, in consideration of the
attached petition, it is hereby directed that the parties and their respective counsel
appear before a custody conciliator at ~ '\rJ, ~I (\\.',\., I ~~\ ( )h. ~
'tetrc... \'r\.. f\~'> .5, ~on the ..ad day oU'e(~N"'\r-.e: r
1998, at \', Cf) ~,m. for a pre-h aring custody conference. At such conference. an
effort will be made to resolve the issues in dispute; 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 this conference may provide grounds for entry of a
temporary or permanent order.
By the Court:
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
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RODNEY J, POTTEIGER,
Petitioner
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO, 95-5301 CIVIL TERM
: CIVIL ACTION - LAW
: CUSTODY
V.
JAYME POTTEIGER,
Respondent
,
PETITION TO MODIFY CUSTODY ORDER
AND NOW, comes the Petitioner, Rodney J. Potteiger, by and through his
attomey, Charles Rector, Esquire, and files this Petition to Modify Custody Order, and in
support thereof, avers the following:
1. Petitioner is Rodney J. Potteiger, Father, who currently resides at RD#1,
Box 813, Pisgah State Road. Landisburg, Perry County, Pennsylvania, 17040.
2. Respondent is Jayme Potteiger, Mother, who currently resides at 212
Holly Drive, Camp Hill, Cumberland County, Pennsylvania, 17011.
3, The parties hereto are the parents of Alex J, Potteiger, DOB 12/10/89
and Tyler Reed Potteiger, DOB 05/06/91, who currently reside at 212 Holly Drive, Camp
Hill, Cumberland County, Pennsylvania,
4. On December 8, 1997, an Order was issued which granted primary
physical custody to Respondent and partial custody to Petitioner. A true ~nd correct
copy of said Order is marked as Exhibit "A," attached hereto, and made part thereof.
5. The best interests and permanent welfare of the children will be served
by awarding Father primary physical custody of the children,
6, Modification of the Custody Order is necessary and appropriatE! under the
circumstances because:
a. DefendanVMother has relocated on multiple occasions In the recent past
to the detriment of the children and will likely be forced to relocate in the
near future,
b. Defendant is currently working from 7:00 p.m, to 7:00 a.m. and the
children are consistently left with third parties during that period of time.
c. The Defendant has, on numerous occasions, disparaged Petitioner In the
presence of Petitioner and his wife and the children, and has otherwise
characterized Petitioner as "worthless," etc. and further has told the
children that Petitioner does not care about them,
d. Tyler is currently suffering academically and both the children are
experiencing emotional problems at school as a result of the current
custodial situation,
e. Tyler has Indicated to Petitioner and his wife on numerous occasions that
he would like to reside with them permanently.
WHEREFORE. Petitioner respectfully requests that this Honorable Court modify
its' previous Order and grant Father primary physical custody of the minor children.
RESPECTFULLY SUBMITTED,
{JflAJ~4
Charles Rector, Esquire
1104 Femwood Avenue, Ste. 203
Camp Hill, PA 17011
(717) 761-8101
Attorney for Petitioner
Date: -11l J J. }",
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11/11/1999 11:49 717-799-2191
RJ f'OTTEI(ER C(lNSTR
PAGE B1
I verify thai the ataternenll mlIde htftln .... lNe Ind oonct. I undntancl tIlIt
fllae IlItemlntl hnln ....I11Id. aubjlct to the PlI\IIlIeI of 18 Pa.C,S, SIcIIon .1104.
reIIItIng 10 lI1twom flllllIcIIlIon to authorltles,
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RODNEY J. POl'l'EIGER, . IN THE axJRT OF CXXolMOO PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
:
vs. NO. 95-5301 CIVIL TERM
JAYME POl'l'EIGER, : CIVIL ACTION - LAW
Defendant : CUSTODY/VISITATION
QUlER OF allRT
AND lOf, this 'ifff...- day of ,../)'n~, 1997, upon
consideration of the attached CUstody Concirtillon Report, it is ordered
and directed as follows:
1. The prior Order of this Court dated October 30, 1997, is
vacated and replaced by this Order.
2. The Father, Rodney J. Potteiger, and the Mother, Jayroe
Potteiger, shall have shared legal custody of Alex J. Potteiger, born
December 10, 1989, and Tyler Reed Potteiger, born May 6, 1991.
3. The Father shall be entitled to obtain the Children's school
records directly from the school in which they are enrolled.
4. The Mother shall have primary physical custody of the
Children.
5. The Father shall have partial physical custody of the
Children on alternating weekends, beginning Saturday, Noventler 22, 1997
frem Saturday at 10:00 a.m. through Sunday at 4:00 p.m.
6. The Father shall have partial physical custody of the
Children for one week each sUll1llE!r upon providing advance notice to the
Mother by May 30.
7. The parties shall alternate having custody of the Children
over the Christmas holiday frem Christmas Eve at 10:00 a.m. through
Christmas Day at 4:00 p.m. The Father shall have custody of the Children
over the Christmas holiday in even nl.lJl'bered years and the Mother shall have
custody of the Children over the Christmas holiday in odd nUllbered years.
8. The Father shall have custody of the Children at such other
times as the parties arrange by mutual agreement.
9. The Mother shall provide transportation for exchanges of
custody to and frem the Father's residence.
10. The Mother shall provide the Father with her current address
and telephone nl.lJl'ber, the Children's daycare phone number, and onqoing
information concerning the Children's progress in school, including school
attendance and other school records.
11. This OI:'der is entered pursuant to an agreement by the partif l:.\~'l';r
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at a CUstody Conciliation Conference. 'Ihe parties may modify the
provisions of this Order by Im.Itual agreement. In the absence of Im.Itual
agreement, the terms of this order shall control.
BY THE COORT,
n~~11-i1~ J.
ee: Charles Rector, Esquire - Counsel for Father
Gerald Robinson, Esquire - Counsel for Mother
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TRUE COf1V FROM "~n -~'
In Testimo!1Y wlltrtlOt, I heft unto set fffI han '
and the saal of said Cou a1 Carlisle, Pi,
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RODNEY J. POITEIGER, . IN THE CXXJRT OF ()loJloIOO PLEAS OF
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Petitioner . CUMBERLAND CCXlNTY, PENNSYLVANIA
.
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vs. . NO. 95-5301 CIVIL TERM
.
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.
JAYME POITEIGER, . CIVIL ACTION - LAW
.
Respondent . IN CUSTODY
.
aIDER OFaxm
AND tOf, this ij
consideratioo of the attached
ana directed as follows:
day of ( ...#~
Custody Conciliation Report,
, 1998, upon
it is ordered
1.
continue
parties.
ibe prior Order of this Court dated Decerri>er 8, 1997 shall
in effect pending further Order of Court or agreement of the
2. ibe parties shall subnit themselves, their minor Children ana any
other third parties deemed necessary by the evaluator to a custody
evaluation to be performed by a professional selected by agreement of the
parties and counsel. ibe purpose of the evaluation shall be to obtain an
independent report ana recomnendation concerning custody arrangements which
would serve the best interests of the Children. ibe parties shall equally
share the costs of the evaluation.
3. After conpletioo of the custody evaluation and report, in the
event the parties are not at that time able to reach an agreement as to the
outstanding custody issues, counsel for either party may contact the
Conciliator to schedule an additional Conference.
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BY THE CXXJRT,
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Edgar B. Bayley, I
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ee:
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Charles Rector, Esquire - Counsel for Father _ c.~ ~<\. J",(? ,
Gerald Robinson, Esquire - Counsel for Mother
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RODNEY J. Pal'l'EIGER,
Petitioner
: IN THE CXlURT OF <:xlMMOO PLEAS OF
: CUMBERLAND CCXlNTl!, PENNSYLVANIA
.
.
vs.
: NO. 95-5301 CIVIL TERM
.
.
JAYME Pal'l'EIGER,
Respondent
: CIVIL ACTION - LAW
: IN cusrooy
PRICR JUDGE: Bdgar B. Bayley
cn9'lmlC CXH:ILIATION SlMIARlr RBRRr
IN AOCXRlAtC!: WIT8 <DmBRLAND CXlIflY RDLE CP CIVIL ~ "" 4.tiB
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
lWIB
DATB CP BDmI
aRUlNTLY IN Ca.'"J.UJi CP
Alex J. Potteiger
Tyler Reed Potteiger
llecenber 10, 1990
May 6, 1992
Mother
Mother
2. A Calciliation Conference was held on llecentler 22, 1998, with the
following individuals in attendance: The Father, Rodney J. Potteiger, with
his counsel, Charles Rector, Esquire and the Mother, Jayroe Potteiger, with
her counsel, Gerald Robinson, Esquire.
3. 'It1e parties agreed to entry of an Order in the form as attached.
/2.eU-n.../y.-, c.2~ 179P
Date
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DIi S. sunday, Esquire
CUstody Conciliator
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CERTIFIED TRUE
AND CORRECT COPY
(717) 232-8525
r,o 80x 5320, Ii....".u";, r'~'''''''''iI' ,]\ 10,5320
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RODNEY J. POTTEIGER,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Petitioner,
v.
NO. 95-5301 CIVIL TERM
.
.
JAYME POTTEIGER,
Respondent.
CIVIL ACTION--LAW IN CUSTODY
ANSWER TO A PETITION TO MODIFY CUSTODY
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
RESPONDENT, JAYME POTTEIGER, by and through her attorney, GERALD
S. ROBINSON, files this Answer and respectfully represents the
following:
I. Admitted.
2. Denied. The Respondent's address is 17 Glenwood Road, Lot
14, Dillsburg, PA 17019.
3. Admitted.
4. Admitted.
5. Denied.
children will be
physical custody
The best interests and permanent welfare of the
served by leaving the minor children in the primary
of Respondent.
6. Denied. The Modification of the Custody Order is not
necessary nor appropriate because;
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a. Respondent relocated to Pittsburgh to improve financial
status and does not intend to relocate in the near future, however
will relocate approximately two (2) miles in the summer when
construction of the house she will occupy is finished;
b. While Respondent is at work, Respondent has arranged for
adequate care for the children, the care is usually with the
Petitioner's father and stepmother;
c. Respondent does not disparage Petitioner nor tell the
children that Petitioner does not care about them. On the contrary,
although Respondent relocated a long distance from Petitioner,
Respondent traveled to Petitioner's location on alternate weekends
with the children to allow Petitioner to spend time with the children
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pursuant to an order issued on December 8, 1997, which granted
primary physical custody to Respondent and partial custody to
Petitioner;
d. The current custodial condition does not affect Tyler's
academic performance nor are the children experiencing emotional
problems at school as a result of the current custodial condition; and
e. Neither admitted nor denied. The Respondent is without
sufficient knowledge or information to form a belief as to the truth
of the averment in Paragraph 6e of the Petition to Modify Custody.
WHEREFORE, your Respondent respectfully prays your Honorable
Court to deny modification of the Custody.
Respectfully submitted,
ROBINSON & GERALDO
Ge'~-!'~i~
4407 North Front Street
P.O. Box 5320
Harrisburg, Pennsylvania 17110
I.D. No. 27423
(717) 232-8525
Attorney for Respondent
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VERIFICATION
I verify that the statements made in this Answer to Petition to
Modify Custody are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904, relating to unsworn falsifIcation to authorities.
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