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FEB 1 7 199B IP
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NINA MARIS TOBSRY,
Plaintiff
IN THS COURT OF COMMON PLSAS OF
CUMBERLAND COUNTY, PSNNSYLVANIA
CIVIL ACTION - LAW
96 -~B5B CIVIL TSRM
IN CUSTODY
V.
JOSEPH HSNRY FISHER, SR.
Defendant
IN RE I TEMPORARY CUSTODY ORDER
ORDER OF COURT
AND NOW, this 20th day of February, 1998, after
hearing on the petition for contempt and motion to modify the
prior custody order, this Court orders as folloWS I
1, Mother is adjudged to be in contempt of this
Court's order of October 7, 1996, and is sentenced to spend 3
months in the Cumberland County prison, Sentence to begin on
June 15, 199B, The condition of purge is that the mother
faithfully comply with all terms of this temporary order prior
to that date,
2, The hearing on modificaticn of the Court's prior
order is continued until August 20, 199B, at 9130 a,m,
3, pending the continued hearing, the Court enters
the following temporary Order of Court:
A, The parties shall have joint legal custody of
Mindy Jo Fink, born July 10, 19B9,
B, Mother shall have primary physical custody of
said child,
C, Father shall have partial physical custody of
the child as follows 1
(i) From 3130 p,m, today until 11:00 a,m,
tomorrow morning,
(ii) From tbe first Saturday in June, 199B,
after Mindy is done with school until further order of this
Court,
D. Both parties shall keep each other informed
of a current address and phone number at which they may be
reached, In the event that the parties stay overnight at
another residence with the child, they shall let the other party
know of that address and phone number,
E, Between now and the summer period of partial
custody father shall be allowed frequent contact by phone with
his daughter. In addition, mother shall see that daughter
attempts to call father at least one evening per week,
F, If father travels to Missouri between now and
the beginning of partial physical custody in the summer, father
may visit with the child any evening after school and a~y
weekend he is in Missouri, provided he give mother at least 10
dayo notice.
G, Likewise when father has hi~ period of
part ial custody next summel', if mother comes to the Central
Pennsylvania area mother shall be allowed to visit with the
child while the father is at work for up to 7 days, provided she
give father at least 10 days notice,
H, Father shall be responsible for transporting
the child from Missouri to Cumberland County at the beginning of
the partial custody period next summer,
G, This Court shall obtain jurisdiction,
By t~_~_~ut:)'
~?S.//~-~
Edward E, Guido, J,
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PLAINTIFF'S
I EX~IBIT
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NINA MARIE TOBERY,
Plaintiff
vs.
: IN THE COURT O~' <XlMMOO PLEAS Oli'
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 96-4858 CIVIL TERM
:
: CIVIL ACTION - LAW
: CUSTODY
JOSEPH HENRY FISHER, SR.
Defendant
PRIal JUOOBI George B. IfOffe!:'
aJSlQlY CXHlILIATIOO SlMlARY RBPmT
IN AOCXlID.\NCB WITlI aJIBERLAND CXDlTlt RULE OF CIVIL PR(nlll\JRB
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:
~
Mindy Jo f'ink
DA'l'I3 OF BIRTlI
ClJRRfNl'LY IN aJS'lOO~ OF
July 10, 1989
Plaintiff/Mother
2. A Conciliation Conferenc~ was held on January 8, 1998, with the
fOllowing individuala in attendance: The Father, Joseph Henry Fishe!:', Jr.,
with his counsel, Diane M. Rupich, Esquire, and Jan Tet:pening as the
Mother's representative. The Mother resides in Missouri and was unable to
attend the Conference.
3. The Court previously entered an Order in this matter on October 7,
1996, reflecting an agreement of the parties at a Custody Conciliation
Conference. Under the Order, the Mother had legal and primary physical
custody of the Child with the Father having specified periods of pertial
physical custody. It is not disputed that, sInce entry of the prior Order,
the Mother moved with the Child to Missouri without modification of the
existing Order. The Father filed this Petition for Contempt as he has not
been able to see the child since June 1997.
4. The Father's position on custody ill as follows: Due to the
Mother's unauthorized relocation with the Child to Missouri, the Father
believes that it would be in the Child's best interest to reside primarily
with him in Pennsylvania. According to the Father, neither of the perties
has sufficient resources to pay for transportation between Pennsylvania and
Missouri to exchange custody of the Child for periods of partial custody.
The Father stated that he only recently receiVed from the Mother an address
and telephone number where the Child could be reached. However, the Father
stated that when he tried to contact the Child by telephone, the child
would not talk to him, giving him the impression that the Mother and her
husband were supervising and interfering with the contact. The Father
indicated that if the Mother were to move back to Pennsylvania with the
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I IN 'rHj;; COUR'V O~' CXWlON PLEAS OF
I CUMBERLAND COUNTY/ PENNSYLVANlA
I
I NO. 96-4858 CIVlL T~
I
I CIVIL ACTION - LAW
I IN CUSTODY
NINA MARIj;; 'roBj;;RY/
Plaintiff
JOSEPH HENRY FISHER/ SR.
Defendant
awl'.a Of' CXllRT
-
M
AND ~, this 1 ~ay of
consideration of the st~UstodY
and directed ss follows:
/ 1996, upon
it is ordered
1. The temporary Order of this COUt"t entered on August 30/ 1996 is
vscated and t"eplaced by this Order.
2. The Fathet"'s Custody Complaint filed at Docket No. 96-4938 shall
be consolidated with the custody action previously initiated by the Mother
at Pocket No. 96-4858.
3. The Mother/ Nina M. Tobery/ shall have legal custody and primary
physical custody of Mindy Jo Fink, born July 10/ 1989.
4. The Father/ Joseph Henry Fisher, St"., shall have partial physical
custody of the Child on the first and thit"d weekends of each month from
Saturday at 12:00 noon until Sunday at 6:00 p.m. In the event the Father
ia able to establish an Clrrangement with his employer whet"eby the Father
regularly doss not work on Satut"day momings on the first weekend of each
month, thia padod of weekend custody shall begin on Fdday at 7:30 p.m.
On occasions when the Fathet" is unable to exet"c1se his dght to weekend
custody under this pt"ovision due to his employment, the Fathet" shall notify
the Mother as soon as possible. The Father's first padod of weekend
custody shall occur on the second weekend in Octobet" (rather than the first
weekend as regUlarly scheduled) and shall continue thet"eafter on the first
and third weekends of each month.
5. The parties shsll shat"e or alternate custody of the Child on
holidays as follows:
A. Christmas. In altet"nating years when the matet"nal grandmother
works on Christmas, the Father shall have custody of the Child
on Christmas Day ft"om 10:00 a.m. until 7:00 p.m. In
alternating years when the matet"nal grandmother doss not work
on Christmas Day, the Fathet" shall have custody of the Child
from 10:00 a.m. until 4:00 p.m. on Chdstmas Day. The Mother
shall notify the f'ather as soon as she detCll:1I1ines whClther the
maternal grandmother will be working on Christmas Pay in 1996
so that the parties can establish the alternating christ/11lll1
schedule sccordingly. Notwithstsnding the for~Joing, the
Fsther's pariod of custody on Christmas Pay in 1996 shall
begin at 9130 a.m. rather than 10100 a.m.
B. Thanksgiving. In every year, the Mother shall have custody of
the Ch11d on 'I'hanksgiving Day until 4100 p.m. and the FsthClr
shall have custody of the Child fr~n 4100 p.m. until 8100 p.m.
C. Remaining alternating holidays. 'rhe parties shall alternate
having custody of tne child on tho following holida~'sl New
Years Pay, Easter Sunday, Memorial Pay, July 4th, and Labor
Pay. 'I'he alternating holiday schedule shall begin with the
Father having custody of the Child on New Years Pay in 1997.
Periods of holiday custody under this paragraph shall be from
10100 a.m. until 6100 p.n1. on the day of the holiday.
P. Mother's Pay/Father's Pay. Tho Mother shall have custody of
the child every year on Mother's Pay from 10100 a.m. until
6100 p.m. and the Father shall have custody of the Child every
year on Father's Pay from 10100 a.m. until 6100 p.m.
E. Halloween. In even numbered years the Father shall have
custody of the Child for the Halloween parade (until 9100 p.m
or until the parade has ended) and the Mother shall have
custody of the Child for trick-or-treat night. In odd
numbered years, the Mother shall have custody of the Child
for the Halloween parade and the Father shall have custody of
the Child for trick-or-treat night.
6. The Fsther shall have custody of the Child for one week each
sUlllller upon providing thirty (30) daya notice to the Mother and upon
providing the address and telephone number where the Child can be
contacted. The Child shall be permitted to have telephone contact with the
Mother during the one week period of vacation.
7. The Father shall not remove the Child from the Comnonwealth of
Pennsylvania during his periodS of custody unless the Father first provides
a telephone number and address to the Mother indicating where the Child can
be contacted.
8. The Mother shall notify the Father of any significant medical,
educational, or social developments concerning the Child and shall make the
Child's school report cards availabll;! to the Father. The Father may
contact the Child's physicians, counselors and tl;!achers to obtain
information concerning the Child as appropriate.
9. The Father shall provide transp:lrtation for exchanges of custody
under this Order.
10. 1'his Order is entered pursuant to an Agreement of the parties at a
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shall notify the Father aa soon as she determines whether the
maternal grandmother will be working on Christmas Day in 1996
sO that the parties can eatablish the alternating Christmas
achedule accordin91y. Notwithstanding the foregoing, the
Fsther's period of custody on christmas Day in 1996 shall
begin at 9130 a.m. rather than 10100 a.m.
B. Thankagiving. In every year, the Mother ahsll hsve custody of
theCliIld on Thankogiving Day until 4100 p.m. and the Father
shall have custody of the Child from 4100 p.m. until 8100 p.m.
C.
Remaining alternating holidays. The parties shall alternate
having custody of the Child on the following holidays I New
Years Day, Easter Sunday, Memorial Day, July 4th, and Labor
Day. The alternating holiday Ilchedule shall begin with the
Father having custody of the Child on New Years Day in 1997.
Per10da of holiday CIUItody under this paragraph ahall be from
10100 a.m. until 6:00 p.m. on the day of the holiday.
Mother's Day/Father's Dey. The Mother shall have custody of
the Child every year on Mother's Day from 10100 a.m. until
6100 p.m. and the Father shall have custody of the Child every
year on Father's Day from 10:00 a.m. until 6100 p.m.
Halloween. In even numbered years the Father shall have
custody of the Child for the Halloween parade (until 9100 p.m
or until the parade has ended) and the Mother shall have
custody of the Child for trick-or-treat night. In odd
numbered years, the Mother shall have custody of the Child
for the Halloween parade and the Father shall have custody of
the Child for trick-or-treat night.
D.
E.
6. The Father shall have custody of the Child for one week each
sumner upon providing thirty (30) days notice to t,he Mother and upon
providing the address and telephone number where the Child can be
contacted. The Child shall be permitted to have telephone contact with the
Mother during the one week period of vacation.
7. The Father ahall not remove the Child from the Ca1monwealth of
Pennsylvania during his periods of custody unless the Father first provides
a telephone number and address to the Mother indicating where the Child can
be contacted.
8. The Mother shall notify the Fsther of any significant medical,
educational, or social developments concerning the Child and shall make the
Child's school report cards available to the Father. The Father may
contact the Child's physicians, counselors and teachers to obtain
information concerning the Child as appropriate.
9. The Father shall provide transportation for exchanges of custody
under this Order.
10. This Order is entered pursuant to an Agreement of the parties at a
6, In early August, 1996, Ihe mother agreed to the lather havinll the child trom
August B, 1996, until August 17, 1996, The father told the mother he intended to be married
durinll that period and wanted lhe child to be In his weddinll ceremony, On or about August 17
or IB, 1996, when lhe mother spoke to her daughter, Jennifer Michelle Klnll, who was also
stayinllat the respondent's home with Mindy, the parties' daughter, Jenniter told her mother that
the father had postponed his wedding date and wanled 10 keep Mindy another week, The mother
spoke to the father on the telephone and told him lhat she did not agree to Ihe child staying with
him an additional week because school was going 10 be slarting soon. The falher told her he did
not intend to relum the child to her and would hide the child from her,
7, Since her last telephone conversation with the child on or about August 20, 1996,
the mother has tried to telephone the child at lhe father's home several times, but has been
unsuccessful, In addition, the mother has gone 10 the father's home on at least one occassion
when no one has answered the door although it appeared that the father's then fiancee, now wife,
Katherine Brenner Fisher, was at home. The lather has not allowed the child to contact the
mother,
B, On or about August 22, 1996. the mother again wenl to the lather's home to try to
retrieve the child because she was registered to begin firslgrade at Hamilton Elementary School
in Carlisle, where the child had attended kindergarten, on Monday, August 26. 1996, Katherine
Brenner answered Ihe door, but refused to allow the mother to speak with her daughter, Mindy,
who was standing behind Ms. Brenner, Ms, Brenner. told the mother to leave and shut the door,
The mother conlal;led the Hampden Township Police Department who tried to telephone Ms.
Brenner. but there was no answer. The police also telephoned the father at his place of work.
Valk ManufllclurlnH, bul was lold Ihal he had lell work early, Laler Ihat day_ Ihe tat her
telephoned Ihe mol her al her home and Ihrealened to llIe harmmenl and olher criminal charHes
against her If she tried 10 contacl or retrieve Ihe child aHain al his home, AI Ihat time the tal her
also informed Ihe mol her Ihal he had registered the child to allend school al SportlnH WII
Elementary School In Mechanlcsburg
9, On or about August 28, 1996, Ihe mol her, who confirmed Ihrough the IlChoollhat
the child was registered 10 all end schoollhcre, went to the Sporting Hill Elementary School to
retrieve her daughter. The school prindpal advised the mother that he needed to contacl the
lather and telephoned the father at his work. The principal also contacted Ihe Hampden
Township Police Department who sent an ollicer to the school. The school allowed the child,
who had not seen her mother since Augusl 8, 1996. to see her, When the father arrived, he
demanded that the child, who was hugging her mother, come to him, The father grabbed the child
by the ann Bnd pulled her when she did nol voluntarily go to him, The principal asked the father
not to pull on the child. but the father persisted, and the mother let go at' her to avoid the child
being harmed. The father directed the school nolto release the child to the mother, The police
officer advised the molher to pursue the mailer through the courts.
10, The mol her seeks primary physical and legal custody of the child pending a
conciliation conference being scheduled in Ihe mailer lor reasons including the tollowing:
a) The mother has been the primary caretaker of the child and the provider of
the child's physical and emotional needs since the child's birth,
NINA MARIE TODERY
Plalnlill'
IN THE COURT OF COMMON I)LEAS OF
CUMBERLAND COUNTY. I)ENNSYLVANIA
v,
NO. 96- '1'65<6
CIVIL CIVIL TERM
JOSEPH HENRY FISIIER, SR,
Delimdant
CUSTODY
ORIH:R (W COlIRT
AND NOW, IhlsC(/h day of')f fl~ n' hi , 1996, upon consideration of the
allached complaint. It Is hereby directed that the parties and their respeclive counsel appear before
_____'n~n'_. _._ , on the. 'Ot )l( .. day of()c-)~'~-?~.~___. 1996,
at._ CL'-(~'Il.,m, on the 4th+!t1or.ofthe Cumberland ftlunty Courthouse/au he law otlices of
_--Z>..'..L.I..~',I\rlq~'1 ,,),1 ,IV) l , II" 1>, ,,,bq 'J " Cumberland Counly.
Pennsylvania. for a Pre-Ilearing Custody Conference. At such conference, an ellort will be made
to resolve the issues in dispute; or if this cannot be accomplished, to deline and narrow the issues
to be heard by the court, and to enter into a temporary order. Failure to appear at the conference
may provide grounds for entry of a temporary or permanent order. , I /
For the ~'oyrt, j)'l" I) '&<'./..'/1/
(":,:;if~~~~~(~~~~-jjztl(.,~() "'If'
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YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE:. II" YOU 1)0 NOT
IIAVE A LAWYER OR CANNOT AFFORD ONt:. GO TO OR n:U:PHONE HIE
OFFICE SET FORTIIIJELOW TO FIND OIIT WHERE VOl) CAN GET U:GAL IIELP.
COURT ADMINISTRATOR, 4T11 FUXlR
CUMBERLAND COUNTY COURTHOUSE
CAIU,ISI.E, I'ENNSYI.V ANIA 1701.1
TELEPBONE. (717) 2411-<'>21)(1
AMERICANS WITII mSA/lIU71ES ACT OF /99()
The Court of ("ol11l11on Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For infclrmation about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court.
please coni act OlJr otlicc All arrangements must be made at least 72 hours prior to any hearing
or business betore the court.
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NINA MARIE TOBERY
PlalntUr
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
v,
: NO.lJ6.
CIVIL CIVIL TERM
JOSEPH HENRY FISHER. SR,.
Defendant
: CUSTODY
AFFIIM VIT IN SUPPORT OF PETITION
FOR LEA VI: TO PROCUO IN "'ORMA PAUPERIS
I, I am the plaintUl' in the above matter and because of my tlnanclal condition am
unable to pay the fees and costs of prosecuting. defending. or appealing the action or proceeding,
2, I am unable to obtain fimds from anyone, including my family and associates. to
pay the costs of litigation,
3, I represent that the information below relating to my inability to pay the fees and
costs 15 true and correct.
a)
Name: Nina Marie Tobery
Address: 461 North Pitt Street. Carlisle. P A
Social Security Number: 202.56.9143
b)
If you are presently employed. state
Employer: N/A
If you are presently unemployed. state
Date of last employment: 1985
Salary/wages per month:
Type of work:
c),
Other Income within the past twelve months
Business/profession: N/ A
Other self-employment: N/A
Interest: N/A
Dividends: N/A
Pension and annuities: N/ A
Social Security benelits: N/ A
Support payments: $50 per month DPW Passthroullh
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again belilre the lillnlly Illuwd tu Mlssuurlln Junll, 1997 Whllnthllllluther 1IIl1ll ned tu Cllrllslllln
10111 June. 11)97, tu IIIUW the IlIst urlhllliunlly's IIIlSslIsslllns, Ihlllilther, whu WIIS lit her nclghbur's
house, yelled III hilI' un the street, but never IIppmllched her III Inquire IIhuut the child ur wherll
she WIIS residing
The litthllr hild the lIIuther\ 1I111111nl:\ IIddress Inllllrly Octubllr, 1')1)7, IInd un Decelllbllr ,11,
1997, the lillher's Illturney WIIS pruvided with II telephune Illlluber hy l.el:\lIl Services. Inc stiliI'
wherll he cuuld cllllthe child The liuher telephllncd Ihe child Ilnll lillle helilrll thll cuncillatlun
conlerence scheduled Iln Jllnullry 9, IIJ'll!
The lIIother IInd her liuuily were in the process Ilrrelllcllting tOil ncw residence Illthlltlme
Ilf the concllilltiou conference in Jllnullry, 1')1)8, IInd were in trllnsiliun IiII'll pllrilld of tillle IIller
thlll. ^Iler thll liuuily settled intuthdr new residence, Ihe mill her cunlllcled /.el:\lIl Services. Inc.
stlltl' with her new IIddrllss IInd her Ielephllne nUlllber This infunulltiun WIIS lorwllrded lU the
litther's lI110rney IInd thlllillher hilS siuclI had tclllphunll contllct with the child
The liuuity hilS he en receiving public IIssistllnce henelits since ^ugust, 1997, and currel1lly
resides in a lilllr-bcdruom IIlID-subsidized hllllse The lIIother dues not have the financial
resources totransporl the child back IInd lilrth to visit with the till her; the till her has a vehicle and
is IImployed tilll-time
The tat her has been living in a lIIotel room since appro~imately October, 19<J6, when he
separllted Ihllll his wile, Klltherine Brenner, IIller approxinllltely one munth of lIIarriage. Betore
the child moved to Missouri, her weekend visits with the lather consisled of staying in his motel
room with him where she slept on the 110m on hlankets or on two chillI's pushed together, IInd his
allaln betlmlthe family moved to Missouri In June. 1997, When the mother returned to Carlisle In
late June. 1997, to move the last oflhe l'amlly's possessions. Ihe tlllher. who was al her nelghbor's
house. yelled at her on the street. but never approached her 10 inquire IIbout the child or where
she was resldlnll'
The father had the mother's mallingllddress in early October, 1997, and on December 31.
1997, the father's allorney was provided with a telephone number by Legal Services. Inc, stalf
where he could caJl the child, The father telephoned the child one time before the conciliation
conference scheduled on January 9, 1998
The mother and her family were In the process of relocatlnllto a new residence at the time
of the conciliation conference In January, 1998. and were In transition for a period of time after
that, Aller the family sell led Into their new residence. the mother contacted Lellal Services, Inc,
staff with her new address and her telephone number. This Inlonnatlon was forwarded to the
father's allorney and the father has since had telephone contact with the child,
The family has been recelvlnll public assistance benefits since August, 1997, and currently
resides in a Ibur-bedroom HUD-subsldized house, The mother docs not have the linancial
resources to transport the child back and Ibrth to visit with the father; the father has a vehicle and
is employed full-time,
The father has been living In a motel room since approximately October, 1996, when he
separated Irom his wife, Katherine Brenner. after approximately one month of marriage, Before
the child moved to Missouri, her weekend visits with the lather consisted of staying in his motel
room with him where she slept on the l100r on blankets or on two chairs pushed together, and his
..
.
NINA MARlB TOBERY.
PlalntllT
IN THE COURT Of COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLV ANIA
Vs.
NO. 96-4858
JOSEPH HENI~Y FISHER, SR"
Defendant
CUSTODY
CIVIL ACTION. LAW
~~Il):)~,~~'~:~~~:' ~~~~OItANOlIM ON
~U' t') .: ' ~ . " U)U HENRY FISHER, SR.
DEFENDANT'S WITNESSES AND ANTICIPATED I ,ENOTll OF TESTlMONY~
Margie Roadcap. Shippcnsburg. Pennsylvania - Defendant's
stepdaughter who will testify as to Dd'cndant's parenting ability,lU1d his relationship
with Mindy, (20-30 minutes)
Lillian Ruth Babcock. Carlisle. PennsYlvania - Defendant'!!
girlfriend. who will testify as to Defendant's parenting ability and his relationship with
his daughter, Mindy, (20.30 minutes)
.-
v.
I IN THE COURT OF COMMON PLEAS or
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I
I
I CIVIL ACTION - LAW
I NO. 96-4858 CIVlL TERM
NINA MARIE TOBZRY,
Plaintirr
JOSEPH HENRY FISHER, SR.,
Defendant
IN REI CUSTODY
ORDER OF COURT
AND NOW, this 20th day of August, 1998, after
hearing, the Court orders as followSI
1. The parties shall have Joint. legal custody or
Mindy Jo Fink born July 10, 1989.
2. Mother shall have primary physical custody or said
child.
3. Father shall have partial physical of the child as
follows I
(a) From today until sunday, August 23 at noon.
(b) From the first saturday or sunday in June
after Mindy is done with school until seven days before the
start of school in the fall of each year.
(c) One week during Christmas vacation each
year. Mother shall be responsible for transportation costs to
be deducted from the support paid by father. If father visits
the child in Missouri, he may present receipts for his gas,
food, and lodging during that trip to the Domestic Relations
office and receive oredit against the support due.
Father also has the option of sending mother a round
trip air ticket for Mindy to travel to Pennsylvania. It he
pursue~ this route, upon presentation ot a receipt tor said
ticket to the Domestio Relations ottioe, his support shall be
qredited in that amount.
It mother advises father at least sixty days prior to
christmas vacation that she is coming to Pennsylvania and that
tather will be given the opportunity to visit with Mindy in
Pennsylvania during that Christmas vacation, he will not be
entitled to credit for transportation costs.
Father shall also give mother forty-five days notice
of his intention to exercise Christmas visitation and what means
of transportation he intends to employ.
(d) Both parties shall keep each other informed
ot their current address and phone number at which they may be
reached.
(e) Between now and the summer period of partial
custody, father shall be allowed frequent contact by phone with
his daughter. In addition, mother shall see that daughter
attempts to call father at least one evening per week. Mother
shall also send all report cards to father and shall have
daughter write to him at least once per month.
(f) Mother shall make sure that the six-week
follOW-Up appointment ordered by Hershey Medical Center be taken
care of in Missouri. She shall obtain a report from the
physician and submit it to father's counsel.
(g) It tather travels to Missouri tor any reason
other than tor visitation as otherwise set forth herain, father
may visit with the ohild any evening after SQhool and any
weekend he is in Missouri provided he gives at least ten days
notioe.
(h) Likewise, when father has porioda of partial
oustody eaoh summer, if mother comes to the Central Pennsylvania
area, mother shall be allowed to visit with the child when
father is at work for up to seven days provided she gives father
at least ten days notice,
(i) Father shall be responsible for transporting
the child from Missouri to cumberland county at the beginning of
the partial oustody each summer. Mother shall be responsible
for transporting the ohild back to Missouri at the end of tho
partial custody each summer.
(j) During the summer periods of partial
custody, mother ~hall be entitled to frequent telephone contact
with daughter. Father shall see that daughter attempts to call
mother at least one evening per week.
(k) This Court shall retain jurisdiction.
.y~
Edward E. Guido, J.