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OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Slreel
Carlisle, PA 17013
(717) 240-6535
I. Robert IlIcker, II
Divo,ce Masle,
Treel .10 Colver July 1, 1996
OIflce ManagerlReporter
Jenniter L. Lehman
Attorney at Law
3540 North Progress Avenue
suite 207
Harrisburg, PA 17110
RE: christinalynn E. MCCoy-Poley vs. Daniel R. Poley
No. 96 - 1384
In Divorce
We.' Shore
697-0371 Exl. 6535
Daniel R. Poley
107 East ~eller Street
Mechanicsburg, PA 17055
Dear Ms. Lehman vs. Mr. Poley:
By order ot Court ot President Judge Harold E. Sheely
dated June 26, 1996, the full-time Master has been appointed in
the above reterenced divorce proceedings.
A divorce complaint was filed on March 14, 1996, raising
grounds tor divorce ot irretrievable breakdown of the marriage.
The complaint also raised the economic claim of equitable
distribution.
I am going to proceed on the assumption that grounds for
divorce are not an issue and that either the parties have been
separated tor a period in excess of two years or they will sign
aftidavits of consent to conclude the divorce under the
irretrievable breakdown provisions of the Domestic Relations
Code.
With respect to the economi.c claim ot equitable
distribution, I am directing Ms. Lehman as attorney for the
Plaintiff and Mr. Poley, who apparently is unrepresented by
counsel, to each file a pre-trial statement in accordance with
P.R.C.P. 1920.JJ(b) on or before Monday, July 22, 1996. Upon
receipt of the pre-trial statements I will immediately schedule
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CHRIsTINALYNN E. McCOY-POLEY,
Plaintiff
: IN THE COURT OF caoIMON PLEAS OF
: CUMBERLAND COUNT'i, PENNSYLVANIA
vs.
NO. 96-1384
CIVIL TER.'1
DANIEL R. POLEY,
Defendant
:
: IN CUSTODY
aU>I!R OE' CXXlRT
AND lUI, this S, J day of ~ ,')
of the attached Custody Conciliatlon Report, it
follows:
, 1996, upon consideration
is ordered and directed as
1. The Mother, Christinalynn E. McCoy-Poley, and the Father,
Daniel R. Poley, shall have shared legal and physical custody of Oanielle E.
poley, born June 10, 1992.
2. For a trial period of three (3) months, the parties shall
share physlcal custody of the Child on alternating blweekly periods. The
parties ehall exchange custody under this schedule on alternating Sunday
evenings at 7:30 p.m. The alternating biweekly schedule shall begin with
the Father having physical custody of the Child from April 28 through May
12, 1996.
3. The parties agree to cooperate with each other in scheduling a
period or periods of partial custody for the non-custodial parent during the
interim weekend or on a weekday evening as arranged by mutual agreement of
the parties.
4. The parties shall share or alternate custody on holidays as
arranged by mutual agreement of the parties.
5. The custodial party shall contact the other party in the event
he or she requires childcare for the Child. The custodial party shall make
arrangements with a third party to provide care only if the non-custodial
party is either unable or unwllling to assume custody of the Child during
the period for which the custodial parent requires childcare.
6. The parties and cousel shall meet the Custody Conciliator,
Dawn S. Sunday, Esquire, for a second Conference on July 30, 1996 at 8:00
a.m.
7. This Order is entered pursuant to an agreement of the parties
at a Custody Conciliation Conference. The parties may modify the terms of
this Order by mutual consent. In the absence of mutual consent, the terms
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CHRISTINALYNN E. McCOY-POLEY,
Plaintiff
: IN THE COUR'r OF CCfo1l-Ol PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-1384
CIVIL TERM
DANIEL R. POLEY,
Defendant
: IN CUSTODY
~ a!' <DR!'
AND rDII, this ~ rt, day of tt. _ \_, ..... ~ , 1996, upon
consideration of the attached Custody con~t, it is ordered
and directed as follows:
1. The prior Order of this Court dated May 3, 1996 is vacated.
2. The Mother, Christinalynn E. McCoy-poley, and the Father,
Daniel R. Poley, shall have shared legal ana physical custody of Danielle
E. Poley, born June 10, 1992.
3. The parties shall share physical custody of the Child on an
alternating weekly basis, with the exchange of custody to take place each
week on Sunday evening at 7:30 P.M. The alternating weekly schedule shall
begin with the Mother having physical custody of the Child from August 4,
1996 through August 11, 1996.
4. The parties agree to cooperate with each other in scheduling
a period or periods of partial custody for the non-custodial parent each
week to be arranged by mutual agreement.
5. The parties shall alternate or share custody of the Child on
holidays as follows:
A. Thanksgiving/Easter - The parties shall share custody of
the Child on Thanksgiving Day and Easter Sunday every
year with each party having an equal period of custody
with the Child.
B. New Years Eve/New Years Day - Recognizing that New Years
Eve and New Years Day fall in separate years every
holiday season, the Mother shaU have custody of the
Child in even numbered years on New Years Eve and on New
Years Day and the Father shall have custody of the Child
in odd numbered years on New Years Eve and New Years Day.
The exchange of custody for the New Year holiday shall
occur on New Years Day morning.
C. Memorial Day/July 4th/Labor Day - The Father shaU have
custody of the Child on July 4th in even numbered years
and on Memorial Day and Labor Day in odd numbered years.
The Mother shall have custody of the Child on Memorial
Day and Labor Day in even numbered years and on July 4th
in odd numbered years. For purposes of this provision,
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CHRISTINALYNN E. McCOY-POLEY,
Plaintiff
: IN THE COURT OF CQ1/oO'l PLEAS OF
: CUMBERLAND OJUNT'{, PENNSY.tVANIA
:
vs.
: NO. 96-1384
CIVIL TERM
:
DANIEL R. POLEY,
:
Defendant
: IN CUSTODY
ClUlER OF cnJRT
..tJ.. r, l
AND N:;W, this.5 day of l.l.~<,.., ,
consideration of the attachea Custody ConCIIIilt:ro'J\ "Report,
and directed as follows:
1996, upon
it is ordered
1. The prior Order of this Court dated May 3, 1996 is vacated.
2. 'l'he Mother, Christinalynn E. McCoy-Poley, and the Father,
Daniel R. poley, shall have shared legal and physical custody of Danie1le
E. Poley, born June 10, 1992.
3. The parties shall share physical custody of the Child on an
alternatl.ng weekly basis, with the exchange of custody to take place each
week on Sunday evening at 7:30 P.M. The alternating weekly schedule shall
begin with the Mother having physical custody of the Child from August 4,
1996 through August 11, 1996.
4. The parties agree to cooperate with each other in scheduling
a period or periods of partial custody for the non-custodial parent each
week to be arranged by mutual agreement.
5. The parties shall alternate or share custody of the Child on
holidays as follows:
A. Thanksgiving/Easter - The parties shall share custody of
the Child on Thanksgiving Day and Easter Sunday every
year with each party having an equal period of custody
with the Child.
B. New Years Eve/New Years Day - Recognizing that New Years
Eve and New Years Day fall in separate years every
holiday season, the Mother shall have custody of the
Child in even nurrbered years on New Years Eve and on New
Years Day and the Father shall have custody of the Child
in odd numbered years on New Years Eve and New Years Day.
The exchange of custody for the New Year holiday shall
occur on New Years Day morning.
C. Memorial Day/July 4th/Labor Day - The Father shall have
custody of the Child on July 4th in even numbered years
and on Memorial Day and Labor Day in odd numbered years.
The Mother shall have custody of the Child on Memorial
Day and Labor Day in even numbered years and on July 4th
in odd numbered years. For purposes of this provision,
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CHRISTINALYNN E. McCOY-POLEY, . IN THE COURT OF <n1MCtl PLEAS OF
.
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 96-1384 CIVIL TERM
.
.
DANIEL R. POLEY, : CIVIL ACTION - LAW
Defendant . IN CUSTODY
.
PRICR JUDGE: J. Wesley Oler
aJS'1'COY CXH:ILIATICN SlMlARY RBPCRT
IN ACXXIUlANCB WI'l'H aJIBERLAND <X:.UlrY RULE OF CIVIL PflCo.""'lRE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME
BIRTIlIlATE
alRRBN'l'Ly IN ammy (R
Danielle E. Poley
June 10, 1992
Plaintiff/Defendant
2. The initial Conciliation Conference was held in this matter on
April 23, 1996, which resulted in an Agreement between the parties
establishing a shared custody arrangement. Due to the Mother's change in
residence and the fact that the Child will begin school next Fall, the
Mother filed this petition for Modification and a second Conference was held
on January 8, 1997, '.lith the following individuals in attendance: The
Mother, Chrlstinalynn E. McCoy (formerly McCoy-Poley), who is no longer
represented by counsel in this matter, and the Father, Daniel R. Poley, with
his counsel, Keith o. Brenneman, Esquire.
3. The parties were able to agree that one party would serve as the
primary custodian of the Child during the school year with the other party
serving as primary custodian during the swnner school break. The parties,
to their credit, were also able to negotiate a partial custody arrangement
for the noncustodial parent as well as a holiday schedule. The only issue
left unresolved at the Conference was which party would have primary custody
of the Child during the school year. The parties agreed to submit their
dispute on this one issue to a professional custody evaluator and agreed to
be bound by the evaluator's determination. The parties will advise the
Conciliator of the evaluator's determination upon receipt. The Conciliator
wiU then submit a substitute order clarifying which party will serve as
primary custodian during the school year and during the swnner school break.
4. The parties agreed to entry of
DATE . Ja../I-U..(j I if, /9'17
an Order in the form as attached.
(~LviL-ddtL-~l~*'
Dawn S. Sunday, Esqu1r
Custody Conciliator
CHRISTINALYNN E. McCOY-POLEY, : IN THE COURT OF CCfolMCtl PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. : NO. 96-1384 CIVIL TERM
DANIEL R. POLEY, CIVIL ACTION - LAW
Defendant : IN CUSTODY
CROeR 06' cnJRT
AND !Oil, this ~ day of J' 217u V~ ' 1997, upon
consideration of the attached Custody ConcIT'Iation Reporl:, it is ordered and
directed as follows:
1. The prior order of this Court dated August 5, 1996 is vacated
and replaced by this order.
2. The Mother, Christinalynn E. McCoy (formerly McCoy-Poley), and
the Father, Daniel R. Poley, shall have shared legal custody of Danielle E.
Poley, born June 10, 1992.
3. Until one week before cOlTlllencement of the 1997-1998 school
year, when the Child begins kindergarten, the parties shall continue to
share physical custody of the Child on an alternating weekly basis, with the
exchange of custody to take place on Sunday evenings at 7:30 p.m. The
parties shall cooperate with eachother in scheduling a period or periods of
partial custody for the noncustodial parent each week to be arranged by
mutual agreement.
4. The parties shall submit themselves, the Child and any other
family members or significant others deemed necessary by the evaluator, to a
custody evaluation to be performed by a professional chosen by the parties
and counsel. The parties shall select the evaluator within twenty (20) days
of the date of the Custody Conciliation Conference. The purpose of the
evaluation is to obtain a professional determination as to which party would
best serve as the primary custodian of the Child during the school year.
For purposes of the evaluation, it shall be assumed that the remainder of
the custody arrangements are established as set Corth in this Order. The
Father shall be responsible to contribute toward the cost of the evaluation
in an amount up to one-half of the total cost. The Mother shall be
responsible for payment of the remaining cost.
5. The follOWing custody arrangements shall become effective one
week prior to conmencement of the 1997-1998 school year:
A. Custody of the Child shall be transferred to the party who
has primary custody dur!.ng the school year.
B. The Ol<Irty who has primary custody of the Child during the
school year shall have custody of the Child one weekend in
each four wEll/kund cycle. -nlQ noncustodial party shall
have partial custody of the Chlld from ~'riday after school
untii Sunday tlvanin'J on three weekends in every four
weekend cycle.
C. The party who does not h,wu primary custody of the Child
durinrJ the school yeilr shaU hilVII primary physical custody
of thll Chiid durin'! the UU/llllllr from the beginning of the
sUl1lllllr schooi break untU one week before corrmencement of
the next schooi year. The party WhCl has primary custody
of thll ChUd durinrJ thll sunlner shall also have custody on
one weekend durin'J each four weekend cycle. The
noncustodial parent shall have partilll custody of the
Child durinfj the sUl1lllllr from ~'riday evening through Sunday
evenin<J on threo weekend" dudnrJ esch four weekend cycle.
D. 'rh. party who is the noncustodial parent during the summer
school break Shllli have a one week period of uninterrupted
custody with the Child upon providing thirty (30) days
notico to the other party.
E. The Mother and t'ather shall cooperate in rescheduling
weeJtend periods of custody for the Mother for any weekends
missed due to the Mother's military reserve duty.
F. The party who is the noncustodial parent during the school
year shall have partial custody of the Child (with the
exception of FAster Sunday stated in paragraph 6A) during
the Child's spring break from school every year.
G. The parties agree that it is their intention to alternate
custody of the Child by agreement on school holidays which
are not otherwise addressed in this Order.
6. The parties shall alternate or share custody of the Child on
holidays as follows I
A. ~iyi/1l1/Eaat.r - The parties shall share custody of
the Chiid on Thanksgiving Day and Easter Sunday every year
with each party having an equal period of custody with the
Child.
8. Olrisl:llBs - The Christmas holiday shall be divided into
5e<Jment A and Segment B, with Se<Jment A beginning at 10:00
a.m. on Christmas Eve and ending on Christmas Day at 1:00
p.m., snd Se<Jlllent B beginning on Christmas Day at 1:00
p.m. and ending on December 26 at a time to be arranged by
agreement of the parties. Segment B shall also include a
two hour period of custody between 4:00 p.m. and 9:00 p.m.
on Christmas Eve. The Father shall have custody of the
Chiid in 00d numbered years during Segment A and in even
Ol.lllt>ered years during Segment B. The Mother shall have
custody of the Child in even numbered years during Segment
A and in odd numbered years during Segment B.
C. Nav Years Eve/New Years Day - The party who has custody
of the Child during Sagment B over the Christmas holiday
shall have custody of the Child in the fOllowing week from
New Years Eve through New Years Day at times to be
arranged by agreement of the parties.
D. MlIIIIodal Day/July 4th/Labor Day - The Father shall have
custody of the Child on July 4th in even nurrbered years
and on Memorial Day and Labor Day in odd numbered years.
The Mother shall have custody of the Child on Memorial Day
and Labor Day in even nurrtlered years and on July 4th in
odd nurrtlered years.
E. Mother's Day/Father's Day The Father shall have
custody of the Child in every year on Father's Day and the
Mother shall have custody of the Child in every year on
Mother's day.
F. Child's Birthday - Each party shall have a reasonable
period of custody with the Child on the Child's birthday
in every year.
7. If either party intends to remove the Child from his or her
residence for a period of a weekend or longer, that party shall provide
reasonable advance notice and a telephone nurrtler where the Child can be
reached by the noncustodial party.
8. The custodial party shall contact the other party in the event
he or she requires childcare for the Child for an overnight period or
longer. The custodial party shall make arrangements with a third party to
provide care under those circumstances only if the noncustodial party is
either unable or unwilling to assume custody of the Child during the period
in which the custodial parent requires childcare.
9. This Order is entered pursuant to an Agreament of the parties
at a Custody Conciliation Conference. The parties may modify the provisions
of this Order by mutual agreement. In the absence of mutual agreement, the
terms of this Order shall control.
BY THE CXXJRT,
J.
, ,
cc:
Keith o. Brenneman, Esquire - Counsel
Christinalynn E. McCoy, Pro Se
for Father _ c.~~. '/~3/97
..d.t'.