Before the hearing, Judge Ruest requested that we each submit witness lists and exhibits. Having these meant that there would be fewer surprises and allowed my attorney to prepare better Rita’s arguments. My witnesses included my father, the psychologist who did the psychiatric evaluation, and my psychiatrist.My exhibits included a proposed parenting plan, the psychological assessment, and the photographs of my forehead and wrist showing no injury or scars. The complete filing, minus documents already presented, is shown in the image gallery.
Custody Pre-Hearing Statement filed by Eric Mockensturm in a Pennsylvania civil action.
The image shows a scanned legal document titled 'CUSTODY PRE-HEARING STATEMENT' for a civil case between Rita Mockenstrum (Plaintiff) and Eric Mockensturm (Defendant). It includes sections on the parenting plan, list of persons over age 18 living in residence, and witness details with names, addresses, and relationships to children.
Legal document excerpt listing expert witnesses and court exhibits.
The image shows a printed legal form section titled 'Expert Witnesses' and 'Exhibits'. It lists two experts: Dr. Yvonne Reedy (Psychologist) and Dr. John DeCarle (Psychiatrist), with their addresses and relationship to children noted as None. Below, Exhibit A is the Father’s Proposed Parenting Plan; Exhibit B is a Psychological Evaluation by Dr. Reedy; Exhibit C includes photographs of the Defendant’s Forehead and Wrist. The document is signed by Rosadele Kauffman, Esquire, Attorney for Defendant, with contact details provided.
Father’s proposed parenting plan for three children in a Pennsylvania court case.
The image shows a scanned legal document titled 'FATHER'S PROPOSED PARENTING PLAN' filed in the Court of Common Pleas of Centre County, Pennsylvania. It lists three children—Caleb (14), Amanda (11), and Amelia (5)—all living with their mother at 247 McBath St. The document outlines joint decision-making for diet, religion, medical care, mental health care, discipline, school choice, study choice, and school activities.
Document detailing custody arrangements and decision-making protocols.
The image shows a typed legal-style document with sections on Sports Activities, Decision-Making Process, and Physical Custody including primary residence addresses and a weekly schedule. The text specifies that the mother is the primary residence holder and outlines visitation times for father and children.
Document excerpt detailing exchange procedures and late arrival policies for school-related activities.
The image shows a scanned or printed page from a formal document, likely part of a relocation exhibit dated May 28, 2013. Sections C (Exchanges) and D (Late arrivals/No-shows) outline protocols for dropping off and picking up children at Corl Street Elementary School, including contact procedures if one parent is absent.
Document outlining holiday visitation schedules and summer vacation arrangements.
The image displays a printed document titled 'Special Considerations (Holidays/Summer)' with a table listing holidays and alternating parent responsibilities. Below is a section on Summer Vacation Plans specifying two weeks of uninterrupted time, followed by Section V detailing school activities for three children: Caleb, Amanda, and Amelia.
Excerpt from a parenting schedule agreement outlining procedures for changes, communication, and disputes.
The image displays a printed legal or family law document with Roman numeral sections VI through VIII. Section VI covers temporary changes to the parenting schedule, Section VII details parent-to-parent and parent-to-child contact methods, and Section VIII addresses proposed changes, disputes, or alleged breaches via mediation and court action.
Legal document excerpt regarding child custody and housing relocation plans.
The image shows a printed legal document section labeled 'IX. Other', discussing changes in children's living arrangements due to housing constraints. It includes typed text about Father moving to an efficiency apartment and proposing weekend time at his grandfather’s house until the marital residence is refinanced or sold, followed by blank signature lines for Date, Eric Mockensturm (Father), and Witness.
The proposed parenting plan was pretty standard, I think.It said that Rita and I should make all decisions jointly, that holidays would alternate from year to year, and I would have the kids at the following times:
Sunday:Alternating until 7:00 p.m. Monday:4:00 p.m. until 7:00 p.m. Wednesday:4:00 p.m. until 7:00 p.m. Friday:4:00 p.m. until 7:00 p.m.; Overnight on alternating weekends Saturday:All day and overnight on alternating weekends
Overnights would start after I was able to find a more spacious place to live.Before Rita got the PFA order, the agreement–but not a court order–was the same as this but with my weekends at the McBath Street house. With the PFA, this agreement was no longer possible, so I proposed having my weekend custodial time at my father’s house–about 90 miles away–until I could find a more spacious place.
