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HomeMy WebLinkAbout96-02626 ;' . J. COI'II'IV" V~IUI' ..,.."" ." IN '1'11I, COUIl'I' 01' COMMON PLEAS CUMUEIlI,AND COUN'I'Y, PENNSYLVANIA Rickey L. Moffitt, Plaintiff, CIVIL AC'I'ION CUS'I'ODY v. Karen L. Moffitt, Defendant. NO. f}1. .1(, i{. C(;~( u..- COMPLAINT FOR CUSTODY 1. The plaintiff is Rickey L. Moffitt, residing at 1055 Grahams Wood Rd., Newville, 17241, Cumberland County. 2. The defendant is Karen L. Moffitt, address unknown. 3. Plaintiff seeks custody of the following children: Name Present Residence Age Kjersten Moffitt 1055 Grahams Wood Rd., Newville 15 Erica Moffitt 1055 Grahams Wood Rd., Newville 14 The children were not born out of wedlock. The children are presently in the custody of Rickey L. Moffitt, who resides at 1055 Grahams Wood Rd., Newville, PA. During the past five years, the children have resided with the following persons and at the following addresses: Persons Addresses Dates Rickey L. Moffitt 1055 Grahams Wood Rd. , NeWVille From It) . ~~;i... to Present l't '.,- Karen L. Moffitt 1055 Grahams Wood Ild. , Newville From . ~..' ,J... to ~\ - ~j -:.]il> IN '1'111:: COUH'I' 01-' COMMON P(,I::AS CUMIlWII.ANlI COUN'I'Y, PI';NNSYINAN I A Hickey L. Moffitt, Plaintiff , CIVIl, AC'I'lON v. SPECIAL HEI.IEF; EMI::HGI::NCY CUSTOllY Karen L. Moffitt, Defendant. NO. (h. ,)(, h (,,-.;, "(.,- COMPLAINT FOR SPECIAL RI>LIEI'; I>MEHGENCY CUSTODY 1. The plaintiff is Hickey L. Moffitt, residing at 1055 Grahams Wood Rd., NeWVille, 17241, Cumberland County. 2. The defendant is Karen L. Moffitt, address unknown. 3. Plaintiff seeks special relief of the following children: Name Present Residence of emergency custody Kjersten Moffitt 1055 Grahams Wood Rd., Newville Erica Moffitt 1055 Grahams Wood Rd., Newville The children were not born out of wedlock. The childron are presently in the custody of Hickey L. Moffitt, who resides at 1055 Grahams Wood Rd., NeWVille, PA. During the past five years, the children have resided with the following persons and at the follow i ng addresses: Persons Addresses Datos Hickey L. Moffitt 1055 Grahamn Wood Hd., Newville From I/-~~ Age 15 14 Karen I.. Moffitt to Present 1055 Grnhamn Wood <<d., Nowvllle From ,"R~- to [I r, '/<0 * 1Z1(,~ty t, IYJd'r./t Plaintiff :IN THE COURT OF CO/oIHON PLElIS OF :CUMnERLI1ND COUNTY, PENNSYLVANIA V * /Lt(({,,t, !J1i~, It . . :CIVIL ACTION - L1Ho{ :NO.q~-Z/,17-v CIVIL :CUSTODY/VISI2~TION 19 Defendant onDEn OF COURT 1,\/)" '/.? S 'd' f J AND NOW, this (date) , upon cons~ erat~on 0 tie attached complaint, it is hereby directe the parties and their respective counsel appea~ before , the conciliator, at 3CI W. 1YJa'11 ,.'jt,u!- 17d::b on the I ~ day of TWIt ,19 ,~ at fl' 00 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~y the court, and to enter into a tempora~ order. Either party may bring the child who is the subject of this custody action to the conference, but the child/children'S attendance is not mandato~. Failure to appear at the conference may provide grounds for entry of a tempora~ or permanent order. FOR THE COURT: ~ ' Bydl!,JJflV 'i':t!~1 /,rm1( Custody onciLZator YOU SHOULD TAKE THIS PAPER TO YOUR LAr'lYER AT ONCE. IF YOU DO NOT HAVE A LAr'/YER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTJI BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE PA 17013 (717) 240-6200 RICKEY L. MOFFITI. PllIinliff IN TliE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. %,2626 CIVIL TERM KAREN L. MOFFIlT, Defellllllnt CIVIL ACTION. CUSTODY ORDER AND NOW, this I~' dllY of Muy. 191)6, the plllintlff is grunted IClIvc In proceed in formll puuperis, BY THE COURT, ,ilL r;{ %1 d Vt4,. );J ~l..'( 1./,. ( - -I" I" '. 'I ' / (~./~;l ,,', 'J' , '.1' ./ (. /1, ',.1.. . Jr.l nl.J.. ~ ", - '-0" U'rt,,,t /j (';1 1ft" ('~!)I.( I (1,: I If' I. /.J~ I, ,.- \' The mother of the children is Karen L. Moffitt, currently residing at Unknown Address. She is married. The father of the children is Rickey L. Moffitt, currently residing at 1055 Grahams Wood Rd., Newville, PA. lie is married. 4. The relationship of the plaintiff to the children is that if father. The plaintiff currently resides with the following persons: Name Relationship Kjersten Moffitt Daughter Erica Moffitt Daughter S. The relationship of the defendant to the children is that of mother. The defendant currently resides with the following per~ons: Name Relationship James Mort Unknown 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and immediate welfare of the children will be served by granting the special relief requested because the defondant willfully abandoned the children and left them in the sole care of the plaintiff. The defendant has had no contact with tho children and is presently and knowingly residing with a thirty-three year old male known to have a sexual interest in both her fifteen year old daughter as well as herself. The defcndant refuses to disclosc her addrcss to the plaintiff or to her children. 8. Each parent whoso parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. Whereforc, plaintiff requests the court to grant Special Relief; Emergency Custody of the minor children. 12 'j. :J -... ~ .... Plain~ff 'j..LI(" C \'C")~\ oj"'/firt \ \(",,-C '. . /'l\'; I' I "~;'( I~L ... ? ' , !1.,Cfr'<'/ 111 co 11',", r In tho Court of ~ommon Pl~as of Cumberland County, Pennsylvania , ~o. '1t".J (. ..I (, Civil/; .~ VI. /l!fIIN It l 1'1 ell, ,...,- PRAECIPE TO PROCEED IN FORMA PAUPERIS To tba Prothonotary: Kindly allow 12 .. (, 1'/ ( . / , n-I c' 1'1' , /7 L (plaintiff) (Defendant), to proceed in forma pauperis. Io ,attorney for the party proceeding in forma pau~eris. certify that I ,elieve the party proceeding 11 unable to pay the COlts and that I am providing free legal service to the party. The party'a aff~davit showing inability to pay the costs of litigation is attached hereto. '-1t'~ ,v /),'11;& "" for ,rlll/96 1 ! Wi )';:)[-;\..J,,,,- IN 'rilE COUHT 01' COMMON PLEIIS CUMllEIlLIIND COUN'!'Y, PBNNSYINIINIII Rickey L. Moffitt, Plaintiff, CIVIl. IIC'I'ION CUS'!'ODY V. Karen L. Moffitt, Defendant. NO . (, (, , ,,) (_ :J (, (' (",~( 'r.;., '-.. ORDER OF COURT You, Karen L. Moffitt, defendant, have been sued in court to obtain Custody, Partial custody, or Visitation of the children: Kjersten Moffitt and Erica Moffitt. You are ordered to appear in person at on ,at , _.M., for [ a conciliation or mediation conference. [ a pretrial conference. [ a hearing before the court. If you fail to appear as provided by this order, an order for custody, partial custody, or visitation may be entered against you or the court may issue a warrant for your arrest. YOU SHOULD 'I'IIKE TillS PIIPEIl TO YOUH LIIWYEIl AT ONCE. IF YOU DO DOT III1VE 11 LIIWYER OR CIINNO'I' AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CIIN GET LEGIIL HELP. PA Lawyer Reforral - Domestic Relations 1-800-692-7375 BY 'rilE COUll'!' J. Tho mother of the childron is Karon L. Moffitt, currently residing at Unknown nddress. She is lIIarried. 'I'he father of the childrcn i8 Hickey I.. Moffitt, currently reuidinlj at 1055 GrahalllB \~ood Hd., Newville, PA, 110 is married. 4. The relationship of tho plaintiff to tho childron is that if father. 'I'he plaintiff currently rOB ides with the following pcrsons: Namo RelationBhip Kjersten Moffitt Daughter Erica Moffitt Daughter 5. The relationship of the defendant to the children is that of mother. The defendant currently resides with the following persons: Name Relationship James Mort Unknown 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. , , 10' . ~~ , I \~ ~ l \--\ r <:) , ~ , l, ~i~ i~~1 ~ ..... H ~'~'J -~ ~ ~ I ~~ .g ~ ~ ~d~, i' ~ ~ ~~ . 5i -.... ~!~ If! E8 JJ,.Ji j' ;;. !t f::ll. , -.. ~ ~~ 'l f:: ~ -i ~ ,g I~ 'l == ~ ~ .- C'>- . S J;L II "'l ~ ~ . ... ~ ~ ~ ~ I - ., ... .' - .1jl t'i RICKEY L. MOFFITr, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 96-2626 CIVIL TERM KAREN L. MOFFITT, Defendant ~OF: ~,CUSTODY AND tOol, this 1 JIj--r-1 day of consideration of the attach~ conciliat directed as follows: , 1996, upon t s ordered and 1. The Father, Rickey L. Moffitt, and the Mother, Karen L. Moffitt, shall have shared legal custody of Kjersten Moffitt, born March 28, 1981, and Erica Moffitt, born May 7, 1982. 2. The Father shall have primary physical custody of the Children. 3. The Mother shall have partial physical custody of the Children on alternating weekends, beginning June 28, 1996, from Friday at 5:00 p.m. until Sunday at 6:00 p.m. During the Mother's periods of weekend custody, the Children shall sleep overnight at the maternal grandmother's residence. In addition, the Mother shall have the option to have partial custody of the Children one time per week for special events. These periods of custody, shall not include overnight custody. The parties shall arrange these periods of custody to avoid conflicts with activities previously scheduled by the Father for the Children. 4. The parties shall insure that James Mort has no contact with the Children during her or his periods of custody. S. The Mother shall insure that Christopher Hoff shall have no contact with the Children, except when the Mother is present, and not under any circumstances during overnight periods at the maternal grandmother's house. 6. Either party may contact the Custody Conciliator to schedule an additional conciliation Conference, if necessary, at such time as the Mother obtains permanent housing. 7. This Order is entered pursuant to an agreement 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. cc: Jane Muller-Peterson, Esquire Mark C. Duffie, Esquire ~~ ()><- ~L,l (., I ;).()/ r, Ie ' ;.. 6~ RICKEY L. MOFFITT, plaintiff IN TilE COURT OF COOMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 96-2626 CIVIL TERM KAREN L. MOFFITT, Defendant IN CUSTODY CUSTODY cx:tlCILIATICtl SU1I1ARY REPORT IN AClOORIlANCE wrnl Cl.tlBERLAND <XXNlY RULE OF CIVIL PwY'R!VJRE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The relevant information pertaining to the Children who are the subjects of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Kjersten Moffitt Erica Moffitt March 28, 1981 May 7, 1982 Plaintiff/Father Plaintiff/Father 2. A Conciliation Conference was held on June 18, 1996 with the following individuals in attendance: The Father, Rickey L. Moffit, with his counsel, Mark C. Duffie, Esquire, and the Mother, Karen L. Moffitt, with her counsel, Jane Muller-Peterson, Esquire and Michelle Hamilton, Legal Services Intern. 3. The parties agree to entry of an Order in the form as x2-. jJ j- ~wnS. S~ Custody Conciliator attached. ~te t.a//9/1v . . ;Im I! :tj u ~ I ii' ~' J ~ ~ 'j j ~~ "" - t I- ~~~I E... ....- t: Ii 1, , J1 ... .... ; f, t 11 .:: c.: ,~ . ,~ II r.J "" ~~ I~ I ~ . il~~ ~ ~ J~' ij] ~ " = & ' ..~ ' '" ~ JtL It"'... ... ~I~ . ..:l . ..:l ~ ~ ~ ~ \ . ... , . .' . . ! ,.dlll)\ I .i \ ...., ~ -t .)" :1 '~ I RICKEY L. MOFFITT, Plaintiff : IN THE COUR'r OF roll'lON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 96-2626 CIVIL TERM KAREN L. ~lOFFITT, Defendant : IN CUSTODY ~cnm AND roI, this '}J} r'day consideration of the attac~ody and directed as follows: , 1996, upon n Report, it is ordered 1. The prior Order entered by this Court on June 20, 1996 is vacated. 2. The Father, Rickey L. Moffitt, and the Mother, Karen L. Moffitt, shall have shared legal custody of Kjersten Moffitt, born March 28, 1981 and Erica Moffitt, born May 7, 1982. 3. Moffitt and Moffitt. The Mother shall have primary physical custody of Erica the Father shall have primary physical custody of Kjersten 4. The parties shall alternate having custody of the Children on weekends so that the Children are together every weekend. The alternating weekend schedule shall begin with the Mother having custody of the Children from August 9 at 6:00 P.M. until the following Sunday evening at 6:00 P.M. and on alternating weekends at the same times thereafter. The Father's weekend periods of custody shall be from Friday evening at 9:00 P.M. until the following Sunday at 6:00 P.M. 5. The parties shall share or alternate custody of the Children on holidays as follows: A. Christmas - In even numbered years, the Father shall have custody of the Children from December 24 at 8:00 A.M. until 7:00 P.M. and from December 25 at 5:00 P.M. until December 26 at 7:00 P.M. In odd numbered years, the Father shall have custody of the Children from December 24 at 7:00 P.M. until December 25 at 5:00 P.M. In odd numbered years, the Mother shall have custody of the Children from December 24 at 8:00 A.M. until 7:00 P.M. and from December 25 at 5:00 P.M. until December 26 at 7:00 P.M. In even numbered years, the Mother shall have custody of the Children from December 24 at 7:00 P.M. until December 25 at 5:00 P.M. The parties shall share custody of the Children over the remainder of the Children's Christmas break as arranged by mutual agreement. B. Thanksgiving/Easter/Memorial ~y - 'rhe ~lother shall have custody of the Children on Memorial ~y in even numbered years and on Thanksgiving ~y and Easter Sunday in odd numbered years. The Father shall have custody of the Children in even numbered years on Thanksgiving ~y and Easter Sunday and on Memorial ~y in odd numbered years. C. July 4th/Labor ~y/Mother's Day/Father's ~L - In every year, the Mother shall have custody of the Chi dren on July 4th from 8:00 A.M. until 8:00 P.M., on Labor ~y and Mother's ~y. In every ~'ear, the Father shall have custody of the Children on July 4th from 8:00 P.M. until the following morning and on Father's Day. 6. Each party shall have an extended period of custody with both Children each sunrner on dates and at times to be arranged by mutual agreement of the parties. 7. The party receiving custody at an exchange of custody under this Order shall provide transportation. 8. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent or hamper the free and natural development of the Children's love and respect for the other parent. 9. Each parent shall immediately notify the other of any medical emergencies arising while the Children are in that parent's custody. 10. The parties agree that James Mort, Ricky Shoemaker and Roger Moffitt shall have no contact with the Children except in the presence of one of the parties. ll. This Order is entered pursuant to an agreement 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 TilE COURT, cc: Mark C. Duffie, Esquire Joan Carey, Esquire n .., n . .). -II ."f h .., (i,II .,'j TJ , r" ; "J ; 1 :6 l ; . . ~ "'J '.., .' J-- "1 .,' -- j jll .. ,J :.'1 ~lJ UJ .... t~ , '" 'f' I ~ P ~~ j ~' t ~., I . , \, r , I , r ~J I I f. :' ! i(:.',;,l~ . ?' { , 1; j; I! , : J i; . ,- \ 1 c, I' 1+ 1 " I:, , I :' , .!> , , . I ",. \ ~" " "-~"> , ~ .f ! . , . , " . KARFN I . MnH I TT , P 1 n i nt Iff III THF COURT OF CnMI.lotl PIFAS OF rllMAFRI A1H) rnl HHY, PErms','\ VAN I A V. tlO. 'ltr -~h' ).1.' C I V II TF RM Rlr-KFY I. MOFFITT. nt' fendilnl 1~IISTnnY r;ON5F1fL ~G.REFME!H This A\l'HIlIll'''lt is ,'ntH",,1 on 11';<, ,_.\~'~\ rlny of \\\L\rcb, 199A, hy I hH (11uinl Iff 1 1\1I,..n I. Moff it t, IInd tl", dHfAnrlant. Rid"y I. Moffitt. Till' ptnint iff h 'tl(1r""f!ntfHj hy Jonn Carey, of L"\Jlll Sl'rViCH5, Inc..; th" def."ldunt i'l .mr..presen!>lCl but i5 awerH of his right tn Ilf'VH fin u"",nHY, 1. Tht! dHf"/1I1flnt find Ih" plflint iff flg"P.lJ to tl", Hntry of an Order providing for thH following ~"stody schArlulH for their child,..~n: Kjarsten Moffitt, nOA 3/2A/Al, anrl Fricll Moffitt, nOB 5/7 /82. a. Tlltl mother al1d fAther shall hflve sllf.rerl legal custody nf thA ..hild,'el1. h. The moth.'!!' shall hnvl-! primAry physicill r.ustorly of thl-! ..hi ldrHIl. c. TllF! fntlll'!!' ShAll hnvH pa,llAl clIslody of the ..hlldren fit lim,'" olnd plllet.s 119'''Hd 'Ipon hHtwAAII the motllllr IInd f all"'1 , ?, Tllt~ part y rt-ll-:toiiving (lj...111lIy Ht ;11l J-I)l.f,hitllU'" 11f clIstody IJltdnr this nrdt~r '~hrll1 Plt)V111" tlflll~:;'llllltdtil'J1I. 3. TI,,' f"ll"., "h..ll ;"',11'" th.ll Rll~Jt" 1', I.h,ffltt hav" 110 Lnnt.-tLt with tht" childl'''l wllf'" lh,~y it"" "I IIi'" l.tJ,~tllCly, and the c.hildl,~n mil)' dl~( lilll' tl) '.II) wit" tll..i, r,tlIH" if nlllJHI E. Moffitt KARFN I,. MOFF I TT 1 PIll I n I i ( ( IN THF r,OIJRT OF C:OMMON PLFAS OF C:lJMRFRI AlJn r,OllfHY, PFNNSYL VAlH A v, r~o. '1A- ('IVII TFAM RTC:KFY I. MrlFFITT. 0.. (''II''nlll C:IISTOOY rEIl.IJ 0.r.Lf08..~Q!l! Elf ~n0.N Tht> plllillf i rr. Kill..1l I, Mo((il I, rl'llf,,~,'"ltl" hy .IORIl Cllr.lY o( leonl S,',vl,-,tl", 11le,. sliltHS Ih.. (nlll)win!j: 1 . TIll' pI il I n I i ( (, K /lItHl I , Mn ( ( ill. I' tl sid.l S lit 34 I Illl n V III e SlrH"', P.O. Rr)) 5(l1, York HilVHIl, York C:olJnly, Ptl/1/1sylvallia 17:170. 2 . T h tl rI" ( 0;11 rI all I. A I r: k 0; Y I . ' Mo rr ill 1 r A s i rI tl S II I 1 n 5 5 GIllhAm" Woon AOllrl, Nt!wvilltl. r,lJmht!rllllld r,olJllly. Pt!11rlsylvi'l/1ia 17;>4 I. 3. The Pllrl i.>s III tl IhH pllr..ll! S o( KilHSlfl/1 Moffilt, naB ,1/?1l/1l1, Illld F.riell Mnrrll I, nOR r;/7/A':'. 4. Thl" clwll e/1IHrurl n r:uslnrly Ordl'" 0/1 AUOlJsI (lOI h, 1996. A cnpy n( 1 hH 0,..1,,1' i" III I nr.h'lfl. 5, ThH C'18lody Ord..r shnuld he modi(IHd I"H;lllj~H: fl. Th<lmi/1nr child, FljcllMn((11I h,lS llv..d wilh the mnltwr sinc" Ilpp'o,lmntnly AIJ\Jusl of 1'196, ann tht! millOI' child, Kj"",I"1l MfJ((ill, hilS lived with tho rnnthp.- ...illLfl npprllxillliltoly ,1IJIlP of 1'197. h. Th" fnll,,,, h"., llil" p,I.'1 iill clhlnrly o( 1 hn chi ldre/1 at f fmtt dnd plilf;P'l aurtlpd Ilplll1 Iltd Wt-;lf:..n 1 h~ Inot '\t~r find f" I I"" . G. TIl.. pltrIIP', dljt I~'" th..t I hH 0, ot...., lu.J vilcatpd illHJ fl1nl fif' '" ~\ r tJ! RICKEY [.. MOFFITT, Plaintiff IN TIlE CXXlRT OF lXX1/'lCtl PLEAS OF CUMBERLAND cx:umc, PDlNSYLVANIA vs. NO. 96-2626 CIVIL TERM KAREN L. MOFFITT, Defendant IN CUS'roDY moER OI!' <DIRT AND lUf, this .:O-ll'-day of ;)" /UJ AT, 1996, upon consideration of the attached Custody Concil~rt, it is ordered and directed aa follows: 1. The prior Order entered by this Court on June 20, 1996 is vacated. 2. The Father, Rickey L. Moffitt, and the Mother, Karen L. Moffitt, shall have shared legal custody of Kjerllten Moffitt, born March 28, 1981 and Erica Moffitt, born May 7, 1982. 3. Moffitt and Moffitt. The Mother shall have primary physical custody of Erica the Father shall have primary physical custody of Kjersten 4. 'ltIe parties shall alternate having custody of the Olildren on weekends 80 that the Olildren are together every weekend. i11e alternating veekend schedule shall begin with the Mother having custody of the Olildren fran August 9 at 6:00 P.M. until the following Sunday evening at 6:00 P.M. and on alternating weekends at the same times thereafter. The Father's weekend periods of custody shall be fran Friday evaning at 9:00 P.M. until the following sunday at 6:00 P.M. 5. 'ltIe parties shall share or alternate custody of the Olildren on holidays aa follows: A. Olrlstrnaa - In even nunbered years, the Father shall have custody of the Olildren fran Decl!llber 24 at 8:00 A.M. until 7:00 P.M. and from Decl!llber 25 at 5:00 P.M. until Decl!llber 26 at 7:00 P.M. In odd nunbered years, the Father shall have custody of the Olildren from Decl!llber 24 at 7:00 P.M. until Decerrber 25 at 5:00 P.M. In odd nunbered years, the Mother shall have custody of the Olildren fran Decerrber 24 at 8:00 A.M. until 7:00 P.M. and from Decl!llber 25 at 5:00 p.M. until Decerrber 26 at 7:00 P.M. In even nunbered years, the Mother shall have custody of the Children fran Decerrber 24 at 7:00 P.M. until December 25 at 5:00 P.M. The parties shall share custody of the Children over the remainder of the Children's ChristmaB break 8B arranged by mutual agreement. B. i11anksgiving/Easter/Memorial ~y - The Mother shall have custody OI the Children on Memorial ~y in even nWlbered .~ .Jo . ~"q 0- ......... ~ 1 ~ t:"