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Home My WebLink About00-00430 . . ,_, ."M' -' ,- " e~ -- ., ;,,--"\,-,' ' ~ '., ' ''''', .~"'" "_ ,-, ~, ---I ,"" BEVERLY M. TRAINUM, Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 00- I{ 30 CIVIL TERM ROBERT G. TRAINUM, Respondent , IN CUSTODY ORDER OF COURT AND NOW, this .....ald:b day of .~o.Y\uC\"(,"'1 ,2000, upon consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before !-\,) b~(""t b . ~; \ rn iro: Esquire, the conciliator, at CUIV\b..___\a ",d Coo n~ ( "') <+\.-.n:6 Q 4th rc;;~ , on the.9.:th. day of lYla rch ,2000 at /0:311. AM. 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 this conference may provide grounds for entry of a temporary or permanent order. By the Court, By: ;d . 6t/ uk.. "=-;<~ 1 ~- Custody Conciliator . 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 1-800-990-9108 . ;.S' _t;,' ',', .' --~........ lliIiIllIliilil~~ ~...I..~' "7~ ~. ~ >>r ~ #Zf.p (1cJ l C' '~ 2. ~ ~ {1(/,ff ffrt:'~ ~~ ~ r?(/,j.{> )JJ ~Vv/\lASNN:jd \/nl "l ,'to ~ - . "'" Ui\,,("1U::n'''n'"' ,: k'._:('ji'~ Iv 9S :t {Iii-! . 8"'j ..If ,-." 00 . ..J' ),'''1'0' .dVl Inr";;.J >"j' i' . Sr;~.I'r '-~:J~.J-~'l ::.:;.Hj 'r :lvl..,.J, .-0::)"{1' .::JU '---v U-1..:] AMERICANS WITH DISABILITIES ACT OF 1990 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 scheduling conference or hearing. , , '>, ~, - ~. '.' . .-~,~- " " " .,.\; __.' _ o"~ - """,,1,, ,.'.'"d BEVERLY M. TRAINUM, Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 00- '130 CIVIL TERM ROBERT G. TRAINUM, Respondent IN CUSTODY PETITION FOR CUSTODY AND NOW, this ~y of January 2000, comes the Petitioner, Beverly M. Trainurn, by her attorneys, Irwin, McKnight and Hughes, and presents the following Petition for Custody. 1. The petitioner is Beverly M. Trainum, an adult individual residing at 538 2nd Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The respondent is Robert G. Trainum, an adult individual residing at 9 Mill Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of three minor children, namely, Kimberly G. Trainum, born December 18, 1990, age 9 years, Robert Gray Trainum, II, born July 18, 1993, age 6 years, and Kathryn R. Trainum, born March 3, 1997, age 2 years. ,-.", , ;,~ - ~. "'- "" ,~-,-" ..",. '''." ,-- ~-~ . ':. ' 4. Petitioner desires primary physical custody of the children and joint legal custody with periods of visitation to respondent as can be mutually arranged between the parties. 5. The best interest of the children requires that the court grant the petitioner's request as set forth above. WHEREFORE, petitioner respectfully seeks the entry of an Order of Court seeking primary physical custody of the children and joint legal custody with periods of visitation to respondent as can be mutually arranged between the parties. Respectfully submitted, By: Marl{ D. Schwartz, Esquire Attorney for Petitioner, Beverly M. Trainum 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I. D. No. 70216 Date: January ~ 2000 -", -< '^ ,~."- -~ ,-~ .~ 1"- ".,--.. VERIFICATION The foregoing Petition for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. !il~ m.j,'l~ BEVE Y M. TRAINUM Date: Jan. 24 , 2000 .~^' - ,,-~ (") 0 C) ~t' C 0 ~ ~ "W_ ----I -oel! :J...~ h\-~ 92C1' :;Z ,.u N :--r1 2C <;J (J)~ .0;- , ~,.f_> ,-,oj kG -0 --:---'" :E'; ::5; ;l~ 20 ~9 r;: 0 ~ -, ~ """ .r:- ~ - ~ '" "" -' ".- I,.' - " "--,---,"",-;,". "~' >~.t{ ~"4''-C;>''J"",,~ <"""'~ I ~, MAR 1 4 200~ \-~-,j \. BEVERLY M. TRAINUM, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA CIVlL ACTION - LAW ROBERT G. TRAJNUM, Defendant NO. 00-430 CIVlL IN CUSTODY COURT ORDER r AND NOW, this ..1L day of March, 2000, upon consideration of the attached Custody Conciliation Report, the following temporary custody order is entered: 1. The Mother, Beverly M. Trainum, and the Father, Robert G. Trainum, shall enjoy shared legal custody of Kimberly G. Trainum, born December 18, 1990, Robert G. Trainum, II, born July 18, 1993 and Kathryn R. Trainum, born March 3, 1997. 2. The Mother shall enjoy primary physical custody of the minor children. 3. The Father shall enjoy periods of physical custody of the minor children as follows: A. On alternating weekends starting at 3:00 p.m. on Friday. The minor child Kathryn shall not stay overnight with the Father. Additionally, the Father shall return all three children on Saturday evening for the Mother to take the children to church on Sunday moming, after which the Mother shall return custody of the children to the Father. The Father shall return all three (3) children to the Mother on Sunday at 7:30 p.m. B. On every Tuesday and Thursday evening from 4:30 p.m. until 7:30 p.m. C. At such other times as agreed upon by the parties. 4. This order is entered with the understanding that Father is currently unemployed. In the event Father obtains employment and his work schedule interferes with this custody arrangement, the parties are directed to modify this arrangement between themselves to provide the Father with similar time that will accommodate his work schedule. 5. Father shall enjoy reasonable telephone and e-mail contact with the minor children when the children are in the custody of the Mother. 6. This is a temporary custody order entered and does not in any way prejudice either party from asserting that a different custodial arrangement should be in place in the event the parties are unable to reach an agreement upon a permanent order. The parties shall meet again with the Custody Conciliator on Friday, June 2, 2000 at 9:30 a.m. In the event the parties are able to reach an agreement on a permanent order prior to the scheduled Custody Conciliation Conference, the Conciliation Conference may be cancelled. 7. In the event that this Order becomes unworkable for the parties for any reason, counsel for the parties may contact the Conciliator directly to arrangement an accelerated Conciliation Conference or to have a Conciliation Conference over the phone. 8. It is the goal of this case to achieve Father having more expanded time with the minor children, and it is anticipated that Father will be provided with additional time, including overnights with the youngest child, at the next Conciliation Conference if everything goes well over the next few months. 9. Mother shall handle transportation for exchange of custody on late Friday evening, early Saturday morning, late Saturday evening and early Sunday morning. Father shall pick up the children Friday starting his periods of custody, and shall pick up the children after church on Sunday and return the children on Sunday evening. Additionally, Father shall handle exchange of transportation on Tuesday and Thursday. This parties may modifY this provision as they may agree. '.~.j;J/ o{/ BY THE COUJ{{'. /> " " J~ ~,\\iOb ') ~ y.. C?, cc: Mark D. Schwartz, Esquire Joan Carey, Esquire "'"' ~'-'lIi1l~b..' '".......,.-;.,~ ~~.~i11l1li1iill11~'~Iilil_b_~ ~. ~ ~ ~ ~f& ~ cs:> D7' . .,'i ~ 9{\ ..,~'g, ~ ~~ i~~~ ~ ~ ,. ~~. a "(;1 , 'l;2, ~ -;v ~' ~ -. '" ' -~,~, " ' ~^ '"" " ~" ~ '< '" '''' '. ,,~, . . ~'. +__-, ",.J;.-- """",,,t- oJ.. "'-<. ;"";~ '", " BEVERLY M. TRAINUM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v CIVIL ACTION - LAW ROBERT G. TRAlNUM, Defendant NO. 00-430 ClVlL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVlL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subj ect of this litigation is as follows: Kimberly G. Trainum, born December 18, 1990; Robert G. Trainum, II, born July 18, 1993; and Kathryn R. Trainum, born March 3, 1997. 2. A Conciliation Conference was held on March 9, 2000, with the following individuals in attendance: The Mother, Beverly M. Trainum, with her counsel, Mark D. Schwartz, Esquire; and the Father, Robert G. Trainum, with his counsel, Joan Carey, Esquire. 3. The parties agree to the entry of an order in the form as attached. 3. ~\ ')( (JO DA . . , ~ "~ , , ~ -, c. . I"' C-',_: ... " JUN 0 7 2001' BEVERLY M. TRAlNUM, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA CIVIL ACTION - LAW ROBERT G. TRAlNUM, Defendant NO. 00-430 CIVlL IN CUSTODY COURT ORDER AND NOW, this "?'() day of ~, upon consideration of the Conciliation Report, the following temporary custody order is entered: attached Custody 1. The existing order of March 15, 2000 shall remain in effect subject to the following modifications with respect to Father's periods physical custody: A. The Father shall have the children on alternating weekends starting at 3:00 p.m. on Friday until Sunday at 7:30 p.m. and every Wednesday from 9:00 a.m. until 7:30 p.m. 2. The parties shall meet again for a Custody Conciliation Conference on Thursday, August 24, 2000 at 10:30 a.m. In the event the parties are able to reach an agreement on a permanent order prior to the scheduled Custody Conciliation Conference, the Conciliation Conference may be cancelled. The order set forth herein is a temporary order and does not in any way prejudice either party from asserting that another custodial arrangement should be in place in the event the parties are unable to reach an agreement upon a permanent,prd.er. . ' //11 /,1 BY THE COURT, .,/ I f~ ;' -' J. , .f)~ C~J.I-OO (\~~ cc: Mark D. Schwartz, Esquire Joan Carey, Esquire ~ ~~~~~ " ~~- .,-.;..,- -~ ~~I__81_ ,I,,,,,,," V'lV~/"1 A..Lf\!n;", Y~I/:{DiVN.jd " !~.;;) ~ ]:\"'-~f!/-.l'":Ci!;J '--':_"-.["1/t) 6/ /1 f-'I- ~\C;':':~.'; ~ {7 " , /- . .'(J {j ~:,' '~!"-I'/." ~~n ,. '... If; t.'C ~" ~~ -'" ~" ~ ~~~ t' ... :-r~~ \!i: !! " '"r_'., _. '0" , ,~~ ,: -i U~ .-=;. 1.";, - - _ ~_ .;_1 "", .<-,.0'1 ... ... BEVERLY M. TRAlNUM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v CIVlL ACTION - LAW ROBERT G. TRAlNUM, Defendant NO. 00-430 CIVlL IN CUSTODY Prior Judge: Edgar B. Bayley CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CML RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Kimberly G. Trainum, born December 18, 1990; Robert G. Trainum, II, born July 18, 1993; and Kathryn R. Trainum, born March 3, 1997. 2. A Conciliation Conference was held on June 2, 2000, with the following individuals in attendance: The Mother, Beverly M. Trainum, with her counsel, Mark D. Schwartz, Esquire; and the Father, Robert G. Trainum, with Jan Terpening of Legal Services. 3. The parties agree to the entry of an order in the form as attached. -Ji' ~ f Of) DA! ( Hubert X. Gilroy, Custody Concili , "., q .. ,_,^', 's.;' ~ < 'e .j - "* " "_~ = """""'->1 aCT 1 2 200(J1lJ BEVERLY M. TRAlNUM, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA CIVlL ACTION - LAW ROBERT G. TRAlNUM, Defendant NO. 2000 - 430 CIVIL IN CUSTODY COURT ORDER AND NOW, this \ b day of October, 2000, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. All prior custody orders entered in this case are vacated. 2. The Mother, Beverly M. Trainum, and the Father, Robert G. Trainum, shall enjoy shared legal custody of Kimberly G. Trainum, born December 18, 1990; Robert G. Trainum, II, born July 18, 1993; and Kathryn R. Trainum, born March 3,1997. 3. The Mother shall enjoy primary physical custody of the minor children. 4. The Father shall enjoy periods of physical custody with the minor children as follows: A. On alternating weekends from 3:00 p.m. on Friday until Sunday at 7:30 p.m. B. On every Tuesday and Thursday from 3:30 p.m. until 7:30 p.m. 5. Father shall also enjoy at least one week for vacation during the summer months upon Father giving Mother thirty (30) days notice as to when he intends to exercise his vacation. 6. The parties shall alternate major holidays, excluding Christmas which is addressed below, with custody being from 9:00 a.m. until 7:30 p.m. The major holidays shall include Thanksgiving, Easter, Memorial Day, July 4th, and Labor Day. For Thanksgiving 2000, Father shall have Thanksgiving with the parties alternating thereafter. 7. The Christmas holiday shall be handled with Mother enjoying Christmas on every Christmas Eve until a time that is agreed upon by the parties. The presumption is that Father shall exercise custody on Christmas Day and Mother shall exercise custody on Christmas Eve. , ~ ~ ,'"'- - " "' - ,. '0'" _. -~~' ,~,,~,,'~~_"j'_,..,,~.'., """. 8. The holiday schedule shall always supercede any alternating weekend or other visitation schedule outlined in this order. Furthermore, Father shall always have the children on Father's Day and Mother shall always have the children on Mother's Day. This provision shall also supercede any other regularly scheduled visitation. 9. Both parties shall enjoy reasonable telephone and e-mail contact with the rninor children when the children are in the custody of the other parent. 10. The parties shall work out between themselves transportation for exchange of custody pursuant to an arrangement they have previously achieved. 11. Both parties shall ensure that the children are not exposed to any negative remarks concerning the other parent, and both parties shall ensure that they shall not alienate the children's affections from the other parent. 12. The parties may alter this custody arrangement by agreement between the parties. However, absent any agreement, the custody terms as set forth above shall control. 13. In the event the parties desire to modify this Order, either party may petition the court to have the case again scheduled for a Conference with the Custody Conciliator. cc: Jan Terpening Mark D. Schwartz, Esquire >~~ J. IO,j/,-UtJ- /'-' > -" h~",,""_ ~~"~~~I~ .."NII,.\:1"\ \H\\.'\"{\\,,.,':)NL"i_.,... .... ~ ',~ \:;. """, ~\_,r:', _1-::.'. ;:1'~,'\n',J \"'1......,(\'\ j! .,'. .' }JJ':I .'..,'" .. ..... I .h~' U"l t..\ .(, ,p,l 0, i i'JJ on ~. ,".' ... ~-~ :10 / , , "., " "~'_'U"."__ ,,' ,--,""..";",".:i "~,,';"~',-.0,_'!.__~,,,~,u ,.-1 ',,~ j BEVERLY M. TRAINUM, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROBERT G. TRAlNUM, Defendant NO. 2000 - 430 CIVlL IN CUSTODY Prior Judge: Edgar B. Bayley CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: I. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Kimberly G. Trainwn, born December 18, 1990; Robert G. Trainwn, II, born July 18, 1993; and Kathryn R. Trainwn, born March 3, 1997. 2. A Conciliation Conference was held on October 5, 2000, with the following individuals in attendance: The Mother, Beverly M. Trainwn, with her counsel, Mark D. Schwartz, Esquire; and the Father, Robert G. Trainwn, with his representative, Jan Terpening, of Legal Services. 3. The parties agree to the entry of an order in the form as attached. Hubert X. Gilroy, Esq . Custody Conciliator ((J~III 00 DA E {/)(f-KJ