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LAW O"ICI:.
SNELBAKIER ,
6
BRINNEMAN
KEVIN A, REITH, I IN THE COURT OF COMMON PLEAS OF
plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
t
v. t NO. 96-5785 CIVIL TERM
t
CASSANDRA 0, ROCKWELL, I CIVIL ACTION - CUSTODY OF
Defendant I MINOR CHILD
ACCEPTANCE OF SERVICE
I accept service of the Complaint in the above action on
bshalf of Defendant Cassandra D. Rockwell and certify that I am
authorized to do so,
FLOWER, MORGENTHAL, FLOWER
& LINDSAY
"
..K.
Oats:
,
Nuvember 14. 199.6, '
-"""'----
ndsay, Esqu re
Street
PA 17013
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NOV 2 7 1OO0(t
cuatody of the Child without the Mother present at the
paternal grandmother's residence on the following Monday
evenings from 4130 p.m. until 7:30 p.m.: January 13,
19971 January 20, 19971 January 27, 1997r February 3,
19971 February 10, 1997 and February 17, 1997.
O. For the next six weeks, the Father shall have partial
cuatody of the Child, not restricted to the paternal
grananother's residence, for one four hour period each
week on S~turday or sunday, beginning either February 22,
1997 or February 23, 1997, as scheduled by the parties.
E. For the next six weeks, the Father shall have partial
custody of the Child 011 alternating weekends from 9100
a.m. until 7100 p,m. on either Saturday or Sunday,
beginning either April 5, 1997 or April 6, 1997 and also
on ~lternating Mondays, beginning April 14, 1997 from
4130 p.m. until 7130 p.m.
F. For the next six weeks, the Father shall have partial
custody of the Child on alternating weekends beginning
the weekend of May 17, 1997 for a twenty-four (24) hour
period as scheduled by the parties. In addition, the
Father shall continue to have custody of the Child on
alternar.ing Mondays (following weekends when the Father
does not have custody) from 4:30 p.m. until 7130 p.m.
G. Beginning June 20, 1997, and thereafter, the Father shall
have custody of the Child on alternating weekends from
Friday at 5:00 p.m. until sunday at 5:00 p.m. and on
alternating Mondays (following weekends when the Father
does not have custody) from 4:30 p.m. until 7:30 p,m.
4. Beginning at such time as the Father's alternating full
weekend (Friday-sunday) custody schedule is implemented, the Father and the
Mother shall have shared legal custody of the Child and shall also
cooperate in establishing periOdS of holiday custody for the Father.
5. The Father shall have reasonable telephone contact with the
Child on an ongoing basis beginning after completion of the first six week
period of custody under this Order.
6. 'ltle Father shall not consume alcohol to excess prior to or
during his periods of custody with the Child.
7. In the event either party believes that an adjustment of the
custody schedule is necessary to serve the best interests of the Child
prior to implementation of the alternating full weekend schedule in June,
1997, that party may contl!lct the Custody Conciliator for sChedul1ng of a
LAW O....ICI.
SNILBAKER
l!I
BHFNN!MAN
KEVIN A. REITH,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO'q~. 5'1 '8 5 CIVIL TERM
Plaintiff
v.
CASSANDRA D. ROCKWELL,
Defendant
CIVIL ACTION - CUSTODY OF
MINOR CHILD
ORDER
AND NOW, this ~.,-t" day of [1. ILI~J' I / 1996/ upon
consideration of the attached complaint, it is hereby directed
that the parties and their respective counsel appear before
c.w" <,. ":....".1<0../ , Esquire, the conciliator, at
L" WI'")'"" )~. 'VII_(~.",; ,.tJ'''.~ , Pennsylvania, on
t ra '" day of ~I"'''''lol' , 1996, at q o'clock -.&_.M.
for a Pre-Hearing 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 by 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: ~ >..>./11 ",J ,J~ J...I.d= [..Y/
-+~~todY ConcirIiIlt'or P.ir:/~I
The Court of Common Pleas of Cumberland county is required by law
to comply with the Americans with Disabilities Act of 1990. For
information about accessible facilities and reasonable
accommodations available to disabled individuals having business
before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business
before the court. You must attend the scheduled conference or
hearing.
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.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
LAW QI"ICU
6NEI.BAICER
l!I
BRENNEMAN
6. The relationship of Defendant to the child is that of
mother. The Defendant currently resides with the following
persons r,
tiAU
RELATIONSHIP
Daughter
Amber Nicole
7. Plaintiff has not participated as a party or witness or
in any other capacity in other litigation concerning custody of
the child in this or any other court.
Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
Plaintiff does not know of a person not a party to
these proceedings who has physical custody of the child or claims
to have custody or visitation rights with respect to the child.
8. The best interest and permanent welfare of the child
wil~ be served by granting the relief requested because the child
needs to establish and maintain a relationship with her father.
9. Each parent whose parental rights to the child have not
been terminated and the person who has physical custody of the
child have been named as parties to this action. All other
persons, named below, who are known to have or claim a right to
custody or visitation of the child will be given notice of the
pendency of this action and the right to intervene: None.
-3-
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J<EVIN A. REITH/
Plaintiff
vs.
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I NO. 96-a785 CIVIL TERM
I
I CIVIL ACTION - LAW
I IN CUSTODY
CASSANDRA D. ROCKWELL,
Defendant
PETITION FOR EMERGENCY RELIEF
1. Petitioner is Cassandra D. Rockwell, an adult individual
rftsiding at 1444 Timber Chase Drive, Mechanicsburg,
Pennsylvania, Cumberland County (hereinafter "Mother").
2. Respondent is Kevin A. Reith, an adult individual residing
at 506 East Elmwood Avenue, Mechanicsburg, Pennsylvania,
Cumberland County (hereinafter "Father").
3. The parties are the parents of one minor child, namely Amber
Nicole Rockwell, whose date of birth is June l, 1992.
4. The parties to this action have never been married, however,
they lived together until the child was two and a half years
of age. At the time the child was two and a half years old
the Father left the child's life and had no further contact
with her until the Father filed a Petition for custody
requesting partial custody/visitation with the child on or
about October 26, 1996.
5. Thereafter, the parties attended a conciliation conference
with Dawn Sunday, Esquire, in November of 1996 and the
parties reached an agreed upon schedule for the Father to
have visitation with the child giving the Father steadily
M!VlRI. Dlll'OfI
"lONOArH~JfCONOSTllF.ET . PO BO)!; 1062 . HARRISBuRG, P^ I',oa
(/,flJJ6,g4}H . FA)( 1"JllJ6.2B17
. ,- ........
"-
inoreasing periods ot partial physical oustody with the
ohild. (See attached Exhibit A).
6. At the time the Order ot November 27, 1996 went into etfect
the child had no reoollection of her Father, nor did the
child have any sort ot relationship or rapport with him.
7. The Father has recently married and the child now has a
stepmother and a stepbrother who i. approximately nine years
of age.
8. Pursuant to the partie. agreed upon visitation schedule, the
tather and child resumed contact by having supervised
visits.
9. Pursuant to paragraph 3(d) of the Order of November 27,
1996, the Father could begin periOds of unsupervised
visitation with the child for a period of four hours. So
also pursuant to paragraph 3(e), the Father was given ten
hour periods of unsupervised visitation with the child.
During these periods of unsupervised visitation, the child
was with the Father and his new tamily.
lO. While the child has continually expressed to the Mother that
she does not wish to have visitation with the Father, the
Mother has encouraged the child to attend these visitation
periods with the Father. However, at the time when the
tather began the tour hour and ten hour periOdS of
3
MIYI~I. DlI_
.410 NORTH SECOND $TkEET . POBOX l0ti2 . HARRISBURG, PA 11108
m/l13&.942a . FAX 0171236'2817
unsupervised custody, the child's overall behavior and
demeanor changed dramatically.
11. The Mother is employed on Ii fuJ.l-time basis and the child
attends daycare at the Children's Garden of st. John's
Lutheran Church in Shiremanstown, Pa, The director and the
pre-kindergarten teacher at the daycare center both
contacted the Mother and advised her that they had noticed a
marked change in the child's behavior and that they wore
very concerned about the child.
l2. Both the director and the pre-kindergarten teacher, at the
daycare center, have advised the Mother that while Amber had
always been a shy child, she seemed to be doing very well
when she started in the pre-K class at daycare in September
of 1996. At that time the child was a much more confident
and happy child. In the Spring of 1997 both daycare
teachers noted a marked change in the child in that she had
become introverted and apprehensive and appeared to be quite
unhappy. The teachers conveyed this to the Mother both
verbally and by written correspondence. (See attached
EXhibits B and C) .
13. Mother has also noticed a marked change in the child's
behavior and the child does not seem to be her usual happy
self. The child clings to her Mother and has become
4
MIYEU.D1I_
41Q NORTH seCOND STREET . POBOX 10el . HARRISBURG, PA '7108
171 1l 23f'1.9428 . FAX 171712315'2817
introverted and apprehensive.
14. Because the child's behavior changed at the Bame time that
the Father's visits have increased in duration and became
unsupervised, the Mother became concerned that the paca of
the visitation schedule was too abrupt for the child who
appeared to be uncomfortable with the visits.
15. The Mother has represented to the Father that she has
noticed this marked change in the child and that she ie very
concerned about th. child's behavior and emotional state.
The Mother has requested that the father continue with the
ten hour periods of visitation and not proceed to the
overnight visits until the child appears to be more
comfortable with the situation. The Mother has expressed
her concern to the father both personally and through her
legal counsel.
l6. The Father has refused to heed tho Mother's requests and
appears to be completely unconcerned about the Mother's
representations to him.
17. The Mother believes and therefore avers that the child feels
threatened by her Father and threatened in some manner,
during her visits with the Father's family. There have been
various incidents during the exchange of the child which
have caused the child to become quite upset:
5
I
II
MEY!"I. DllfOII
410NORTHSECONDSTREET . PO 80)(1062 . HARAI5RUAG, PA 17108
011)236-94211 . FAX 17I11236-2817
.h. ju.t "hae to go" and "that's the way it is" and
makl. no attempt to make the child comfortable or to
la.1 the transition. More specifically, on May 17,
1997, thl child did not want to qet out of the mother's
oar to go with the Father. The Father and stepmother
blcaml very loud and advised that they were going to
grab thl child's car seat and the child out of the car.
Thl child ~ppeared to be quite threatened and afraid at
thil timo.
18. In light of the traumatic change in the child's demeanor an
behavior, and in light of the day care providers indication
to thl mother that they are concerned about the child's
wllfare, the Mother requests an emergency conciliation
conferlllce with the conciliator, Dawn Sunda~' before the
vieit. with the Father expand into overnight and weekend
vie it. with the Father. Pursuant to paragraph 7 of the
Ordlr of November 27, 1997, either party can request a
conciliation conference to adjust the custody schedule
blfore the Father is afforded full weekends of custody in
June, 1997.
19. Mother. requests that the Order of November 27, 1996 be
Buspendad and that the Father not have periods of visitation
with the child pending an emergency conciliation conference
7
MIVlAS . DESFOII
41QNORTH SECOND STREF.T . POBOX 1Ot:i2 . HARRISBURG. PA 11108
(71712J&94]8. FAX (7171236-2817
'';dt-J....
KEVIN A. REITH, I IN THB COURT OF COOt1ON PLBAS OF
Plaintiff I CUMBERLAND COUNTY/ PENNSYLVANIA
I
vs. I NO. 96-5785 CIVIL TERM
I
CASSANDRA D. ROCKWEr..L, I CIVrL ACTION - LAW
oefendant I IN CUSTODY
~ER OF COORT
AND NOW, this.;1'7 day of
ccnside!:'stion of the attaCFiedCustody
and dir~cted ss follows:
'7l <fV<-k.....,. I 1996, upon
Conci11~tlon -Report, it is orde!:'ed
l. The Mothe!:', Cassandra D. Rockwell, shall have primary
physical custody of Ambel:' Nicole Rockwell, be!:'n June 1, 1992.
Until such time as stated othel:'Wise in this Ordel:', the Mothel:'
shall also have SOle legal cllstody of the Child.
2. The pal:'ties shall pal:'ticipate in counseling with a
pl:'ofessional to be selected by mutual agl:'eement of the
pal:'ties and counsel. The pUl:'pose of the counseling is to
obtain advice on the Child I S needs in connection with the
manne!:' in which the pal:'ties implement the agl:'eed upon custody
schedule to gl:'adually I:'edevelop the Fathel:'-child
relationship. The Fathel:' shall be t'esponsible to pay the
cost of the first counseling session and the pal:'ties shall
share the cost of counseling thel:'eaftet'.
3. ' The Fathel:' shall have visitation/partial custody of the Child
on the following schedule:
A. For the fit'st four weeks, the Father shall have one hour
'pedods of visitation with the Child at the Mothet"s
residence fl:'om 6:00 p.m. until 7:00 p.m. on the following
dates: Thul:'sday, Decembet' 5, 1996; WedneSday, Decel11bet'
11, 1996; WedneSday, Decembel:' 18, 1996 and Thul:'sday,
Decemi:Je1:' 26, 1996.
fl. Fot' the next two weeks, the Fathel:' shall have pEll:'iods. of
partial custody with the Child at the patet'nal
grandmothe.'s t'esidence with the Mothel:' pl:'esent ft'om 6:00
p.m. until 7:00 p.m. on ~londay, Decembel:' 30. 1996 and
Wednesday, Januat'y 8, 1997.
'C. Fot' the next six weeks, ~he father: shall have pal:'tial
EXHIBIT
I A
custody of the Child without the Mother present at the
paternal grandmother's reaidence on the following Monday
evenings from 4:30 p.m. until 7130 p.m. 1 January 13,
1997r January 20, 1997r January 27, 1997r February 3,
19971 February 10, 1997 and February l7, 1997.
D. For the next six weeks, the Father. shsll have partiE 1
custody of the Child, not restri~ted to the paternal
grananother's residence, for one foUt. r'lllr period each
week on Saturdsy or Sunday, beginning eit~er February 22,
1997 or February 23, 1997, as scheduled by the parties.
E. For the next six weeks, the Father shall have partial
custody cf the Child on alternating weekends from 9:00
a.m. until 7:00 p.m. em either Saturday,,;: Sunday,
beginning either April 5, 1997 or April. 6/ 1997 and also
on alternating Mondays, beginning April 14, 1997 from
4130 p.m. until 7:30 p.m.
F. For the next six weeks, the Father shall have partial
custody . of the Child on alternating weekends beginning
the weekend of May l7, 1997 for a twenty-four (24) hour
period as scheduled by the par.ties. In addition, the
Father shall continue to have custody of the Child on
alternating Mondays (following weekends when the Father
does not have custody) from 4:30 p.m. until 7:30 p.m.
G. Beginning June 20, 1997, and thereafter, the Father shall
have custody of the Child on alternati 19 weekends from
Friday at 5:00 p.m. until Sunday at 5:00 p.m. and on
alternating Mondays (following weekends when the Father
does not have custody) from 4:30 p.m. until 7:30 p.m.
4. Beginning at such time as the Father's alternating full
weekend (FrJ.day-Sunday) custody schedule is implemented, the Father and the
Mother shall have shared legal custody of the Child and shall also
cwil6rate in estal::l.ishing !=ariod:; of hcliday custody for the Fsthe!:".
5. The ~ather shall have !:"easonable telephone contact with the
Child on an ongoing basis begi.nning afte!:" completion of the first six week
period of custody un~e!:" this Order.
6. The Fathe!:" shall not ~Clnsume alcohol to excess pdo!:" to or
during his periods of custody with the Child.
7. In the event either pa!:"ty believes that an adjustment of th~
custody schedule is necessary to se!:"ve the best inte!:"ests of the Chi 1d
pdor to implementation of the alternating full weekend schedule in June,
i997, that pa!:"ty may contact the Custody Concil iato!:" fo!:" scheduling of a
KEVIN A. REITH, 1 IN THE COURT OF CXX>IMOO PLEAS OF
Plaintiff 1 CUMBI!:RLAND COUNTY/ PENNSYLVANIA
1
vs. 'I NO. 96-5785 CIVIL TERM
.
.
CASSANDRA D. ROCKWELL/ 1 CIVIL Ar.TION - LAW
Defendant I IN CUSTODY
CUSTOOY cnlCILIATICI>l StMIARY REPOOT
. -
IN ACCXJIUlANCE WITH CUMBEitLANO CXXlN'l'Y RULE OF CML l:'~
1915.3-8, the undersigned Custody Conciliator submits the following report:
l. The pertinent infolmation concernir.g thll Child who is the subject
of this litigation is as follows:
NAME
BIRTHDA'l'E
CtJRRml'LY IN CUSTODY OF
Amber Nicole Rockwell
June l, 1992
Defendant/Mother
2. A Conciliation Conference was held on November 21, 1996, with the
following individuals in attendance: the Father, Kevin A. Reith, wIth his
counsel, Philip H. spare, Esquire, and the Mother, Cassandra D. Rockwell,
with her counsel, Carol J. LIndsay, Esquire.
3. This matter involves a difficult situation in which the parties,
who never married, tet,ninated their relationship in 1994. The Father had
no contact with the Child, who il' now six years old, 3ince the parties'
separation. The par.ties are to be commended for their reasonableness and
abHity to focus on the best interests of their Child in working out
arrangements to gradl~ally allow the developl1ent of the Ii'ather-<:hild
relationship. The parties agree to cooperate with each other in adjusting
the gradually in~reasing visitation/partial custo:ly schedule, if necessary,
to meet the Child's needs on a ongoing basis.
4. The parties agree to entry of an Order in the form as attached.
;\)0'\JUn,/w, ,:) S" I 9 ~ (;
Date I
~~dJ~cla...l
Dawn s. Sunday/ Esquire I
Custody r.onciJ.iator '
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KEVIN A. REXTH,
Plaintiff
vs.
I IN THE COURT OF ro-1MON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I NO. 96-5785 CIVIL TERM
I
I CIVIL ACTION - LAW
I IN CUSTODY
CASSANDRA D. ROCKWELL,
Defendant
OODBR OP CXlURT
AND toi, this ~ 0 day of ~\.M.Q.. , 1997, upon
consideration of the attached Custody ConciITiiITon Report, it is ordered
and directed as follows:
1. The parties shall submit themselves and the Child to an
evaluation/counseling to be conducted by a prOfessional select~ by mutual
agreement of the parties and counsel. The purpose of the
evaluation/counseling shall be to assess and determinE! the source of any
problems the Child may be having and to determine how to address those
problems, if any, in relation to the custody arrangements. The parties
shall equally share the cost of the evaluation/counseling.
2. Pending further Order of Court or agreement of the parties,
this Court's prior Order dated November 27, 1996 shall continue in effect
with the fOllowing modifications:
A. Paragraph 3 G of the Order shall be suspended.
B. The six week limitation set forth in paragraph 3 F shall
be suspended and the specific times for the 24 hour
period of custody under paragraph 3F shall be from
Friday at 5:00 p.m. until Saturday at 5:00 p.m.,
beginning May 30, 1997, on every fourth weekend and from
Saturday at 5:00 p.m. until Sunday at 5:00 p.m.,
beginning June l4, 1997 on every fourth weekend. Under
this schedule, the Father's alternating weekend periods
of custody wlll alternate from a Friday through Saturday
schedule to a Saturday through Sunday schedule.
C. The Father shall have two make-up periods of custody
with the Child on June l8, 1997 from 4:30 p.m. until
7:30 p.m. and on July 2, 1997 from 4:30 p.m. until 7:30
p.m.
D. All exchanges of custody under this Order shall take
place at the Mother's residence.
E. The parties shall make every effort to avoid involving
the Child in the custody issues and disputes between the
parties.
KEVIN A. REITH/,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY/ PENNSYLVANIA
vs.
I
I
I
I
I
I
I
NO. 96-5765
CIVIL TERM
CASSANDRA D. ROCKWELL,
Defendant
CIVIL ACTION - LAW
IN CUSTODY
PRIm JUDGB~ l'Jdgar B. Bayley
CUSTOOY cx:fiCILIATIClIl StMARY REPCRT
IN ACXXJmANCE WITfI CUffiERLAND CXUllY RULE OF CIVIL PIlOCBIlURB
19l5.3-8/ the undersigned Custody Conciliator submits the following report I
1. The pertinent information concerning the Child who is the
subject of this litigation is as follows:
NMB
DATE OF BIRTfI
OJRIU'Nl'LY IN CUSTODY OF
Amber Nicole Rockwell
June 1, 1992
Defendant/Mother
2. A second Conciliation Conference was held in this matter on
May 28, 1997, with the following individuals in attendance: The f'ather,
Kevin A. Reith, with his counsel, Philip H. Spare, Esquire, and the Mother,
Cassandra D. Rockwell, with her counsel, Laurie A. Saltzgiver, Esquire.
3. This Court. previously entered an Order in this matter on
December 27, 1996, based on an agreement of the parties at a Conciliation
Conference. The Order set forth a gradually increasing visitation/partial
custody schedule for the Father, who had no contact with the Child (age 6)
up to that time. At the prior Conference, the parties agreed to cooperate
with each other in adjusting the gradually increasing schedule as necessary
to meet the Child's needs. The second Conciliation Conferenc~ was held at
the Mother's request, based on her concerns with respect to changes in th~
Child's behavior and personality which have been particularly noted by the
Child's daycare providers. The Mother believes that the Child I S problems
have arisen as a result of the increasing custody schedule through the
Spring and that the Father's periods of overnight custody should be
curtailed until the Child is evaluated by a professional. 'l'he Father,
although not disputing t.hat the Child is experiencing some problems which
have become most apparent at daycare, believes that decreasing the Child's
periods of contact with him would be counter-productive. The Father stated
that the Child exhibited no anxiety or problems during her first overnight
period at his home on May 17, 1997 and that the overnight period of custody
went very smoothly.
4. Th~ parties agree to jointly obtain an evaluation/counseling
to assess the nature and source of the Child's problems. The parties,
how~ver, did not agree to the Conciliator's recommendation with regard to
custody arrangements pending the evaluation/counseling. The Mother sought
to eliminate all overnight periods of custody for the Father during the
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LAW O"lct5
SNI:l.BAKIiR,
BRENNEMAN
&: SPARE
KEVIN A. REITH, I IN THE COUR'r OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff I
v. I NO. 96-5785 CIVIL TERM
~
CASSANDRA D. ROCKWELL/ CIVIL ACTION - LAW
Defendant IN CUSTODY
MOTION FOR CONCILIATION CONFERENCE
BY AGREEMENT OF PARTIES
TO THE HONORABLE EDGAR B. BAYLEY:
AND NOW, comes the Plaintiff, Kevin A. Reith, by his
attorneys, snelbaker, Brenneman & Spare, P. C. and moves your
Honorable Court to establish a custody ccnciliatioll Conference
based upon the following:
1. This actio~ was initiated by complaint filed on or about
October 21, 1996.
2. Following a November 21, 1996 Custody conciliation
Conference before Dawn S. sunday, Esquire, the parties reached an
agreement and an Order of Court dated December 27, 1996 was
entered.
3. Pursuant to a Petition For Emergency Relief filed by
Defendant, a second Conciliation Conference was held on May 28,
1997. The parties agreed to submit themselves and the Child to
an evaluation/counseling to be conducted by a professional
selected by mutual agreement of the parties.
4. As a result of the agreement of the parties reached at
\
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..
. .
KEVIN A. REITH,
Plaintiff
I IN THE: COURT OF CX>>IMON PLEAS OF
I CUMBERLAND COONTY, PENNSYLVANIA
I
I NO. 96-5785 CIVIL TERM
I
I CIVIL ACTlOO - LAW
I IN CUS'roOY
vs.
CASSANDRA D. ROCKWELL,
Defendant
ClUlBR 01 CXXlRT
AND Iof, this I () day of a.. .u....
consideration of the attached Custody COnci~n Report,
and directed aa follows I
, 1997, upon
it is ordered
1. The parties ahall submit themselves and the Child to an
evaluation/counseling to be conducted by s prOfessional aelected by mutual
agreement of the parties and counsel. The purpose of the
evaluation/counseling shall be to assess and determine the source of any
problems the Child may be having and to determine hOll to address those
problems, if any/ in relation to the custody arrangements. The parties
shall equally share the cost of the evaluation/counseling.
2. Pending further order of Court or agreement of the parties,
this Court's prior Order dated November 27, 1996 ehall continue in ,effect
with the following modifications:
A. Paragraph 3 G of the Order shall be sUBpended.
B. The six week limitation set forth in paragraph 3 F ehall
be suspended and the specific times for the 24 hour
periocl of custody l\/'lder paragraph 3F shall be from
Friday at 5:00 p.m. until Saturday at 5:00 p.m.,
beginning May 30, 1997, on every fourth weekend and from
Saturday at 5:00 p.m. until Sunday at 5:00 p.m.,
be9inning June l4, 1997 on every fourth weekend. Under
thie schedule, the Father's alternsting weekend periods
of custody will alternate from a Friday through Saturday
schedule to a Saturday through Sunday schedule.
C. The Father shall have two make-up periods of custody
with the Child on June l8, 1997 from 4:30 p.m. until
7:30 p.m. and on July 2, 1997 from 4:30 p.m. until 7:30
p.m.
o. All exchanges of custody under this order shall take
place at the Mother's residence.
E:. The parties shall make every effort to avoid involving
the Child in the ~ustody iasues and disputes between the
parties.
I':XIII B r'i' ;\
CERTIFICATE OF SERVICE
I, PHILIP H. SPARE, ESQUIRE, hereby certify that I have,
on the below date, caused a true and correct copy of the
foregoing Motion to be served upon the person and in the manner
indicated beloWI
FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS I
Laurie A. Saltzgiver, Esquire
Meyer.s & Desfor
410 North Seccnd Street
" P. O. Box 1062
Harrisburq, PA 17108
P P H.
SNELBAKER, BRENNEMAN & SPARE, P. c.
44 West Main Street
P.O.. Box 318
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Plaintiff
Kevin A. Reith
Datel
Octobe~ 22, 1997
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c~bEc 1 7 1997"
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A. Christmas I OVer the Christmas holiday in 1997, the
Mothorlilisll have custody of the child on Christmas Day
until 1100 p.m. and the FatheL" shall have custody of the
Child from Christmas Day at llOO p.m. through the
following Saturday at 7130 p.m.
B.
Nllw Years Da~ Easter Sunday and 'l'hanks<Jivin~1 In
1998, the Father shall have cUlltody of the CilfIOon New
Years Day, Easter sunday and Thanksgiving Day from 9:00
a.m. until 2:00 p.m. and the Mother sholl have custody of
the Child on the remainder of the holiday.
Memorial Day, July 4th, Labor Day: In 1998, the Father
shall have custody of the child on Memorial Day snd Labor
Day and the Mother shall have custody of the Child on
July 4th/ at times to be arranged by mutual agreement of
tl1e parties.
Mother's Day/Father's Day: In 1998, the Mother shall
have custody of the Child on Mothor's Day and the Father
shall have custody of the Child on Father's Day, at times
to be arranged by mutual agreement of the parties.
C.
D.
8. The holiday custody schedule shall suparsede the t;"egular
custody arrangements.
9. ~'e party receiving custody of the Child shall be responsible
to provided transportatJ.on. The Mother shall authorize the Child's daycare
provider to permit the Father's wife, DeAnna Reith, to pick up the Child
from daycare for the Father's regular periods of custody under this Order
as is necessary in an emergency when the Father is not able to provide
transportation.
10. ThCl partiea shall make arrangements with a third party
individual or individuals to participate in regular meetings between the
parties for the purpose of exchanging information, making special
arrangements and making decisions concerning the Child. 'fhe third party
indi vidual or indi vidul;lls participating in the meetings shall be selected
by mutual agreement of the parties and counsel.
ll. The Father shall be enti tled to have telephone contnct wi th
the Child at least two times per week. The Mother shall be entitled to
have telephone contact with the Child two times per week during the
Father's extended periods of custody during the summer school break. The
custodial party shall be responsible to ensure that the Child initiates the
telephone calls under this provision.
12. In the event that, after experience with the first two weeks
of extended vacation custody in June and July under paragraph six of this
Order, either party believes that a third period of extended custody would
be detrimental to the Child, counsel for either par.ty may contact the
CUstody Conciliator to schedule a Conference to address the issue.
'I'
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-5785 CIVIL TERM
CIVIL ACTION - LAW
CHILD CUSTODY
KEVIN A. REITH/
Plaintiff
CASSANDRA D. ROCKWELL,
Defendant
PE'rITION FOR MODIFICATION OF A PARTIAL CUS'rODY ORDER
AND NOW, comes the Plaintiff, Kevin A. Reith, by his
attorneys, snelbaker;' Brenneman & Spare/ P. C., and avers as
follows:
1. The custody of the parties' daughter, Amber Nicole
Rockwell, age 6 (DaB 6/1/92), is controlled by the Order of
Court dated December 17/ 1997 which was entered into as a result
of an agreement of the parties reached at a conciliation
conference. A true and correct copy of said Order is attached
hereto as "Exhibit A".
2. The December 17, .1998 Order of Court should be modified
because it is in Amber's best interest to spend an increased
amount of time with her father and for her father to become more
involved in her day-to-day activities.
WHEREFORE, Petitioner, Kevin A. Reith, respectfully
requests your Honorable Court to modify the existing Order for
LAW O,"'ICU
SNELSAKER.
BRENNEMAN
& SPARE
Plaintiff
I IN '1'HE CXXJRT OF <nIMOO PLEAS OF
I CUMBERLAND CXXJN'1'Y, PRlSYLVANIA
I
I NO. 96-5785 CIVIL TERM
I
I CIVIL ACTION - LAW
I CUSTODY
KEVIN A. REITH,
vs.
CASSANDRA D. ROCKWELL /
Defendant
CIUlBR (R cnm
AND tUf, this !a
consideration of the attach
and directed as follows:
day of r,~.~.,-, , 19 9'7, upon
CUstody concl1'ration Report, it -r;-ordered
1. The pri'lr Orders of this Court dated November 27/ 1996 and
June lO, 1997 are vacated and replaced by this Order.
2. The Father, Kevin A. Reith, and the Mother/ call1landra D.
Rockwell, shall have shared legal custody of Amber Nicole Rockwell, born
June 1, 1992.
3. The Mother shall have primary l*1ysical custody of the Child.
4. The Father shall have partial physical custody of the Child
on alternating weekendll, beginning December l2, 1997 from Friday at 5:00
p.m. through Sunday at 5:00 p.m. The Father shall pick up, the Child at the
Mother's residence on Friday.
5. The Father shall also have partial physical custody of the
Child during weeks following the Mother I s weekend period of custody, on
Monday, from 4:30 p.m. until 7:30 p.m. During the weeks following the
Father's period of weekend custody, the Father shall have custody of the
Child on Wednesday from 4:30 p.m. until 7:30 p.m. For purposes of this
paragraph, the Father shall pick up the Child at the ~ycare facility.
6. During the sUlllllSr school break in 1998, the Father shall have
custody of the Child for three nonconsecutive weeks, with one week to be
taken in each of the months of June, July and August. The Father shall
notify the Mother of the weeks during lIhich he intends to exercise his
right to custody under this paragraph by May l, 1998. The Father's periods
of custody under this provision shall be scheduled to either begin or end
on the Father' s regular period of weekend custody so as not to interrupt or
interfere with the ongoing alternating weekend schedule for both parties.
7. The parties shall share or alternate having custody of the
Child on holidays in 1997 through 1998 as follows:
EXHIBIT A
A. Olrilstmall: OVer the Christmaa holiday in 1997, the
Mother shall have custody of the Child on Christmas Day
until 1100 p.m. and the Father shall have custody of the
Child from Christmaa Day at 1100 p.m. through the
fol1011il'l9 saturday at 7:30 p.m.
B. and Th ivi In
8, e Fa er a ve custody of e New
Years Day, Easter Sunday and Thanksgiving Day fran 9:00
a.m. until 2:00 p.m. and tho Mother shall have custody of
the Child on the remainder of the holiday.
c. Memorial Day, July 4th, Labor Day: In 1998, the Father
shall have custody of the Child on Memorial Day and Labor
Day and the Mother shall have custody of the Child on
July 4th/ at times to be arranged by m~tual agreement of
the parties.
D. Mother's Day/Father's Day: In 1998/ the Mother shall
have custody of the Child on Mother's Day and the Father
shall have custody of. the Child on Father's Day, at times
to be arranged by mutual Elgreement of the parties.
8. The holiday custody schedule shall supersede the regular
custody arrangements.
9. The party receiving custody of the Child shall be responsible
to provided transportation. The Mother shall authorize the Child's daycare
provider to permit the Father's wife, DeAnna Reith, tc pick up the Child
fran daycare for the Father's regular periods of custody under this Order
118 is nscGlssary in an emergency when the Father is not able to provide
transportation.
lO. The parties shall make arrangements with a third party
individual or individuals to participate in regular meetings between the
parties for the purpose of exchanging information, making spacial
arrangements and making decisions concerning the Child. The third party
individual or individuals participating in the meetings shall be selected
by mutual agreement of the parties and counsel.
lJ.. The Father shall be entitled to have telephone contact with
the Child at least two times per week. The Mother shall be entitled to
have telephone contact with the Child two times per week during the
Father's extended periods of custody during the sll/lll1ltr school break.. The
custodial party shall be responsible to ensure that the Child initiates the
telephone calls under this provision.
12. In the event that, after experience with the first two weeks
of extended vacation custody in June and July under paragraph six of this
Order, either party believes that a third period of extended custody would
be detrimental to the Child, counsel for either party may contact the
CUstody Conciliator to schedule a Conference to address the issue.
EXIIIIlIT A
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KEVIN A. REITH, I IN THE CXlURT OF CCX>IMOO PLEAS OF
Plaintiff I CUMBERLAND COUNT.lr, PENNSYLVANIA
I
vs. I NO. 96-5785 CIVIL TERM
I CIVIL ACTION - LAW
CASSANDRA D. ROCKWELL / I
Defendant I It1 CUSTODY
PRICR JUOOB: Bdgar B. Bayley
ClJS'roDY <nlCILJ.ATIm 5lJIlIARY RBl'CRT
IN ACCIClUlANCB WI'l'H CUIllBRLAND CXlm'Y RIJLB OF CIVIL PIlCa''''nJRB
19l5.3-8/ the undersigned CUstody Conciliator submits the following report:
l. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
IWlB
DATe OF BIR'l'II
aJRRPNl'L'{ IN aman Of'
Amber Nicole Rockwell
June 1, 1992
Mother
2. A conciliation Conference waf; held on April l4, 1999, with the
fOllowing individuals in attendance: The Father, Kevin A. Reith, with his
counsel, Philip H. Spare, Esquire, and the Mother, Cassandra D. ROCkwell,
with her counsel, Maria P. Cognetti, Esquire.
3. This COurt previously entered an C'rder in this matter on December
l7, 1997 under which the Mother had primary physical custody of the Child
and the Father had partial physical custody on alternating weekends and one
weekday per week. The Father filed this Petition to Modify the current
custody schedule so that the Father has equally shared physical custody.
The parties were not able to reach an agreement concerning ongoing custody
arrangements and it will be necessary to schedule a Hearing in this matter.
4. The Father's position on custody is as follows: The Father seeks to
have custody of the Child on an equally shared schedule with the Mothoer.
The Father proposed that the parties either share custody on a biweekly
cycle, which basically expands the Father's periodS of custody under the
existing order and would involve about three exchanges of custody each week,
or alternatively share custody under a week on/week off schedule. The
Father indicated that he ha& boen gradually trying to increase his time with
the Child over the past years and wants to become rrore involved in the
Child's daily activities than is permitted under the existing schedule. The
Father reterred to the temporary nature of the prior order which only
provided for holidays in 1998.
l..AW OI"ICI!:.
SN&:L.BAKEA,
BRItNNEMAN
81 SPARE
Trevor, in their home in Mechanicsburg. Father is a fit parent
with a genuine desire, to be more to his daughter than an "every
other weekend dad." Father resides close to the school Amber
currently attends. There are no compelling reasons to deny this
father an opportunity to be a greater part of his daughter's
life.
It is Father/s position that the current custody
arrangement should be modified to allow Amber to spend
alternating weeks with her Father.
II. LIST OF WITNESSES:
1. Kevin A. Reith, Father of the Child. Kevin will
testify as to his relationship with Amber; Amber's relationship
with Kevin's wife, Deanna Reith, and Kevin'S step-son, Trevor
(age 10); Fcther's activities with Amber and why Father believes
it would be in Amber's best interest to have a shared custody
arrangement.
2. Deanna Reith, Kevin's wife. Deanna will testify to
Amber's relationship with her, Kevin and Deanna's son, Trevor;
Amber's activities and behavior during her visits with her
Father; and Father's parenting abilities.
3. Bradley Fisher, a friend of Kevin's for many years.
Brad will testify as to Father'a activities with Amber and
Father's parenting abilities.
4. Leonard Heckert, Kevin'S father-in-law. Mr. Heckert
will testify as to Amber'a time with Kevin, Deanna, Trevor and
extended family; Amber's relationship with family members;
-2-
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'11II,21, I'M'
II. PLAINTIFF'S POSITION:
Defendant believes that Plaintill: aller having been gone tbr a lIlajor part ofthe
child's life. now desires week on, week on: shared custody. Detendant believes that
Plaintiff is taking this position without any regard to the needs and well being ofthe
child.
III. WITNESSF:S AND THEIR ANTICIPATED TI::STIMONY:
a) Cassandra D. Rockwell, mother of the minor child. She will testily to her
relationship with her daughter; the day to day activities she engages in with the child; the
child's present and past emotional state; whether the child is doing well in school and
other activities; why in her opinion the present custodial arrangement is working; and
why any new arrangement. particularly a shared custodial arrangement. will not be in the
child's best interest.
b) Todd Holt. Mr. Holt has becn dating the Dcfendant tor approximately 9
months and will give testimony on his observation of the relationship betwcen mother and
the minor child.
c) Bert Cameron. Mrs. Cameron is a good friend of Defendant who has
known her for many years and has also known the minor child since she was 3 years of
age. She will testily to her observation orthe relationship between mother and the minor
child and the closeness ofmother's relatives.
II \Wr"MH~m~^Nl)lJllk~~tll. tlcllh, Mrlllllu.ndum 'Ill "hlJ"'I">>llId~ IIjlll
hin.n I~N
d) Vince Corrno. He is the step-father of the Dctcndnntnnd is the step-
grnndfather orthe minor child, Amber Rockwell. lie has known the minor child since
birth. He willtesl[fy as to how Ambcr IIcts when returning home Ihml visits with her
father. He will testily as to the (j'equency of lumily functions In which Amber
participntes.
e) Julie Orris. This is the child's First Grnde Teacher which grude the child
just completed. Mrs. Orris will testily us to the contents of Al1lber',s report curds und will
indicute thut she is doing very well. She will discuss the parties' respective participation
in school uctivities. She wiil contiI'm that the child is well adjusted. happy und with many
friends in school. She is ulso a very good student.
t) Julie Seifried. This is the Program Director fill' Childrcn's Garden, u
daycare center where Amber previously uttended und still ullends during thc summer
months. Ms. Seifricd has known Amber sincc she was about 3 years old and will testily
to how Amber is prcscntly doing in daycare and how she previously did atler her lather
decided to reenter her Iile. Ms. Seifried has observed interaction between mother and her
daughter and to some degree the interaction between lather and daughter.
g) Susan Krawchuk. This was Amber's Kindergarten Teacher ut Children's
Garden and is also her present Group Teacher for slimmer duycarc. She will testily thut
she has known Amber since she was in pre-school and how she wus quietllnd introverted
LAW O,,.ICJ.tl
SNEI.DAKI!/t,
BRENNEMAN
8l SP^Rf:
weeks following the Father's period of weekend custody, the
Father shall have custody of Amber on Wednesday from 4r30 P.M.
to 7130 P.M. For purposes of this paragraph, the Father shall
pick up Amber at the day care facility.
6. During the summer achool break, the Father shall have
custody of Amber. for four (4) nonconsecutive weeks. The Father
shall notify the Mother of the weeks during which he intends to
exercise his right to custody under this paragraph by May 1.
The Father's periods of custody under this provision shall be
scheduled to either begin or end on the Father's regular period
of weekend custody so as not to interrupt or interfere with the
ongoing alternating weekend schedule for both parties. Mother
shall be entitled to two non-consecutive weeks of uninterrupted
custody of Amber. during the summer school break. Mother shall
notify Father of the weeks she intends to exercise the
uninterrupted time by May 1.
7. The parties shall share or alternate having custody of
Amber on holidays as follows:
A.
Christmas: The Christmas holiday shall be divided
into three (3) segments. Segment A shall be defined
as the day school ends from after school through
December 25th at ncon. Segment B shall be defined as
Decembe~ 25th at noon through a date equal to one-half
(1{2) of the entire school break at noon. Segment C
shall begin at noon on the day Segment B ends and go
through until the evening before school resumes at
7:00 P.M. In odd numbered years, Mother shall have
Segments A and C and Father shall have Segment B. In
even numbered years, Mother shall have Segment Band
Father shall have Segments A and C.
-2-
e. .....
B. Easter Sunday and Thankscivinq~: Father shall have
custody of Amber on Easter Sunday and Thanksgiving Day
from 9100 A.M. until 2:00 P.M. and the Mother shall
have custody of Amber on the remainder of the holiday,
C. Memorial Dav. Julv 4th, Labor Dov: In 2000 and even
numbered years, the Father shall have custody of Amber
on Memorial Day and Labor Day frcm 9:00 A.M. to 8:00
P.M. and the Mother shall have custody of Amber on
July 4th from 9rOO A.M. to 8:00 P.M. In 2001 and odd
numbered year.s, Mother shall have custody of Amber on
Memorial Day and Labor Day from 9:00 A.M. to 8:00 P.M.
and the Father shall have custody of Amher nn J~ly 4th
f~om 9:00 A.M, to g:OO P.M.
D. Mother's DaY/Father's Day: The Mother shall have
custody of Amber cn Mother's Day and the Father shall
have custody of Amber on Father's Day from 9:00 A.M,
to 8:00 P.M.
8. The holiday custody schedule shall super.sede the
regular custody arrangements.
9. The party r.eceiving custody of Amber shall be
responsible to provide transportation. The Mother shall
authorize Amber's day care provider to permit the Father's wife,
DeAnna Reith, to pick up Amber from day care for the F~~her's
regular periods of custody under this Order as is necessary in
an emergency when the Father is not able to provide
transportation.
..
LA..... O....ICIIt
SNI;I.BAKER,
BRENNEMAN
a SPARE
10. The Father shall be entitled to have telephone contact
with Amber at least two times per week. The Mother shall be
entitled to have telephone contact with Amber two times per week
during the Father's extended periods of custody during th~
summer school br.eak. The custodial party shall be responsible
-3-
LAW O"..ICI:!J
SN!l.BAICER,
BRINNi!MAN
& SPAR&:
,
to eneure that Amber initiates the telephone calls under this
provision.
11. Neither party shall consume alcohol to excess prior to
or during his or her periods of custody with the Child.
12. Neither party shall do or say anything which may
estrange the child from the other parent, injure the opinion of
the child as to the other parent or hamper the free and natural
development of the Child's love and respect for the other
parent.
13. The parties may mcdify the provisions of this
stipulation and Order by mutual agreement. In the absence of
mutual agreement, the terms of this stipulation'and Order shall
control.
14. This stipulation shall not be subject to modification
absent agreement of the parties or a substantial or material
change in circumstances.
15. Tho parties hereto and their respective counsel
respectfully request your Honorable Court to cause the terms of
this stipulation to become an Order of Court.
,Y . ~~~
~e th, Pla nt ff
arhrl't. /I t{L"vt
assandra D. Rockwell, .
Defendant
-
-4-
CERTIFICATE OF SERVICE
1/ PHILIP H. SPARE, ESQUIRE, hereby certify that I have on
the below date, caused a true and correct copy of the foregoing
Stipulation to be served upon the person and in the manner
1ndiaated below:
FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS:
Maria p, Cognetti, Esquire
200 North Third Street
Twelfth Floor
P. O. Box 689
Harrisburg, PA 17108-0689
_ (//t) ~ fin "
P~~~~, Esquire
SNEL~R, BRENNEMAN & SPARE, P. C.
44 W. Main St!:'eet
P. O. Box 318
Mechanicsburg, PA 17055
(717) 697-8528
Attorney~ for Plaintiff
Kevin A. Reith
LAW O"IC."
SNELIIAKE".
BRENNEMAN
a SPARI!
Date: Oecember 8, 1999
EXHIBIT A
'.
RECEIVED DEe 1 3 1999
DEe . 9 19~ J :
~ !
KEVIN A. REITH,
Plaintiff
IN THE COURT OF COMMON l?Ll'AS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 96-5785 CIVIL TE1~
CASSANDRA D. ROCI<WELL,
Defendant
CIVIL ACTION - LAW
CHILD CUSTODY
ORDER
AND NOW, this
Ii>
day of December, 1999, upon
,
consideration of the Stipulation of the Parties and Motion Ii'or
Court Order dated December 6, 1999, the Motion is GHl\N'J'ED <lnd
the prlor Orders of this Court dated December 17, 199'/ and ^J"i J.
26, 1999. are vacated and replaced by this Order. The
aforementi,oned Stipulation is incorporated herein by roferenc.a
thereto.
Isf ~"-' ~ '~'d---""'--'
Edgar B. Bayley, J. '.
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I.AW O"'C16
SNELBAI<IR.
BRENNEMAN
BI SPARE
LAW OI'I'ICIG
SN&:I..BAl<lEA,
BRENNEMAN
Be SPARE
weeks fallowing the Father's period of weekend custody, the
Father shall have custody of Amber on Wednesday from 4:30 P.M.
to 7:30 P.M. For purposes of this paragraph, the Father shall
pick up Amber at'the day care facility.
6. During the summer school break, the Father shall have
custody of Amber fo~ four (4) nonconsecutive weeks. The Father
shall notify the Mother Of the weeks during which he intends to
exercise his right to custody under this paragraph by May 1.
The Father.'s periods of custody under this p~ovision shall be
scheduled to either begin or end on the FathA.r's regular period
of weekend custody so as not to interrupt or interfere with the
ongoing alternating weekend schedule for both parties. Mother
shall be entitled to two non-consecutive weeks of uninterrupted
custody of Amber during the summer school break. Mother shall
notify Father of the weeks she intends to exercise the
uninterrupted time by May 1.
7. The parties shall share or alternate having custody of
Amber on holidays as follows:
A.
Christmas: The Christmas holid<lY shall be divided
into three (3) segments. Segment A shall be defined
as the day school ends from after school through
December 25th at noon. Segment B shall be defined aG
December 25th at noon through a date equal to one-hall
(1/2) of the entire school break at noon. Segment C
shall begin at noon on the day Segment B ends and go
through until the evening before school resumes at
7:00 P.M. In odd numbered years, Mother shall have
Segments A and C and Father shall have Segment B. III
even numbered years, Mother shall have segment Band
Father shall have Segments A and C.
-2-
. ,
.
B. Easter Sundav and Thanksaivina Dav: Father shall have
custody of Amber on Easter Sunday and Thanksgiving Day
from 9100 A.M. until 2:00 P.M. and the Mother shall
have custody of Amber on the remainder of the holiday.
C. Memori~l Dav. Julv 4th. Labor Day: In 2000 and even
numbered years, the Father shall have custody of Amber
on Memorial Day and Labor Day from 9:00 A.M. to 8:00
P.M. and the Mother shall have custody of Amber on
July 4th from 9:00 A.M. to 8:00 P.M. In 2001 and odd
numbered years, Mother shall have custody of Amber on
Memorial Day and Labor Day from 9:00 A.M. to 8:00 P.M.
and the Father shall have custody of Amher r:>n July ~th
f~om 9:00 A.M. to 8:00 P.M.
D. Mother's Dav/Father's Day: The Mother shall have
custody of Amber on Mother's Day and the Father shall
have custody of Amber on Father's Day from 9:00 A.M.
to 8:00 P.M.
8. The holiday custody schedule shall supersede the
regular custody arrangements.
9. The party receiving custody of Amber shall be
responsible to provide transportation. The Mother shall
authorize Amber's day care provider to permit the Father's wife,
DeAnna Reith, to pick up Amber from day care for the Father's
regular periods of custody under this Order as is necessary ill
an emergency when the Father is not able to provide
transportation.
I..AW on:rel'
SNEl.DAI(ER,
BRENNEMAN
Be SPARE
10. The Father shall be entitled to have telephone contact
with Amber at least two times per week. The Mother shall be
entitled to have telephone contact with Amber two times per w'
during the Father's extended periods of custody during the
summer school break. The custodial party sha 11 be responsJ hi
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