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HomeMy WebLinkAbout00-01094 .' SHERRY L. BITTINGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. :MICHAEL STOLTENBURG, Defendant : NO. 00- /0 9 'f CIVIL TERM LAW : CIVIL ACTION : CUSTODY (') 0 c: Q :;;:: ::J: "'DOJ m(n ;u:...= 2.:0 zr- I CUSTODY ORDER 0~ l'V ~C) -0 AND NOW, this l OS f day of 1/11'\2-" L- L, ,2009, upon consideration of~8 =.:: parties' Consent Agreement, the following Order is entered with regard to custody ofthe:p~es'~ children, Mariah Stoltenburg, d.o.b. 8/7/93, and Carisa Stoltenburg, d.o.b. 9/16/90. =< ~ I. Plaintiff, Sherry L. Bittinger, hereinafter referred to as the mother, and Defendant, Michael Stoltenburg, hereinafter referred to as the father, shall share legal custody of the child. 2. The mother shall.have primary physical custody of the children. 3. schedule: The father shall have partial custody of the children according to the following a.) Every weekend from Friday at 6:30 p.m. until Sunday at 7:30 p.m. subject to the mother's right to have custody on selected weekends as agreed upon by the parties and upon reasonable notice to the father. b.) Periods during the swnrner as agreed by the parties. c.) Other times agreed upon by the parties. 4. The mother and father shall share periods of custody Qn Christmas Day and Christmas Eve each year as follows: the mother shall have the children from noon on Christmas Eve until noon on Christmas Day, and the father shall have the children from noon on Christmas Day until noon on December 26. 5. The father shall have the children on Thanksgiving Day. .. ~ ::;j f'iT-~' ::&:::.:1 . 't')Y ~~ ~-n ~o om ~ -< :- ~ 6. The mother and father shall alternate periods of custody on Easter as follows: the mother shall have the children on years that end in an odd number and the father shall have the children on years that end in an even number. 7. The mother and father shall alternate periods of custody for New Year's Eve and New Year's Day as follows: the mother shall have the children from noon on New Year's Eve lll1tilnoon on New Year's Day in years that end in an odd number. The father shall have the children from noon on New Year's Eve until noon on New Year's day in years that end in an even number. 8. The mother and the father shall alternate periods of custody for the children's birthdays as follows: the mother shall have the children on their birthday in years ending in an odd number and the father shall have the children on their birthday in years that end in an even number. 9. The mother and father shall share custody on all other holidays as agreed upon by the parties. 10. The mother and the father, by mutual agreement, may vary from this schedule at any time, but the Order shall remain in effect until further Order of Court. 11. The mother and the father agree that each shall notify the other immediately of medical emergencies which arise while the children are in that parent's care. Each parent will notify the other of all medical care the children receive while in that parent's care. 12. Neither the mother nor the father shall drink to excess or use illegal drugs while the children are in their custody 13. The parties realize that their children's well being is paramount to any differences they nlight have between themselves. Therefore, they agree that neither party shall do anything which may estrange the child from either parent, or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love or respect for the other parent. By the Court, ~ .; t If entered pursuant to the consent of the Plaintiff and the Defendant: ~~~ F Sherry L. Bitti ger, Plaintiff Cdvr // ~I Attorney for the PlamtIff . . SHERRY L. BITTINGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF v. : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 00- }DCI r CIVIL TERM MICHAEL STOLTENBURG, Defendant : CIVIL ACTION - LAW : CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Sherry L. Bittinger, residing at 519 Cherry Ct., Carlisle, Cumberland County, Pennsylvania. 2. The defendant is Michael Stoltenburg, residing at 181 Big Spring Terrace, Newville, Cumberland County, Pennsylvania. 3. The mother seeks custody of the following children: Name Mariah StQltenburg Carisa Stoltenburg Present Residence 519 Cherry Ct., Carlisle, PA 519 S::herry Ct., Carlisle, PA Age 6 years 9 years The children were born out of wedlock. The children are presently in the custody of the mother who resides at 5 I 9 Cherry Ct., Carlisle, Pennsylvania. During the children's lifetimes, they have resided with the following persons and at the following addresses: 1. Name Carisa Stoltenburg Sherry Bittinger Michael Stoltenburg Address 204 Meadow Dr., Shippensburg, P A Date 1990-1997 2. Mariah Stoltenburg Sherry Bittinger Michael Stoltenburg 204 Meadow Dr., Shippensburg, P A 1993-1997 . . 3. Mariah Stoltenburg Sherry Bittinger B Lincoln St., Carlisle, P A 1997-1998 4. Carisa Stoltenburg Michael Stoltenburg Carrie Stoltenburg Kaitlin Stoltenburg 181 Big Spring Terr., Newville, PA 1997-1999 5. Carisa Stoltenburg Mariah Stoltenburg Sherry Bittinger 519 Cherry Ct., Carlisle, PA 1999-Present The mother of the children is Sherry Bittinger, currently residing at 519 Cherry Ct., Carlisle, Pennsylvania. She is not married. The father of the children is Michael Stoltenburg, currently residing at 181 Big Spring Terrace, Newville, Pennsylvania. He is married. 4. The relationship of plaintiff to the children is that of the mother. 5. The relationship of defendant to the children is that of I. he father. The defendant currently resides with the following persons: Name Carrie Stoltenburg Kaitlin Stoltenburg Relationship Wife Stepdaughter 6. The plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 7. The plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 8. The plaintiff does not know of a person not a party to the proceedings who has .... . ",,' . .' physical custody of the children or claims to have custody or visitation rights with respect to the children. 9. The best interest and permanent welfare of the children will be served by granting the relief requested for reasons including the fact that the parties' agree that it is in the children's best interests that they reside with the mother. 10. Each parent whose parental rights to the children have not been terminated have been named parties to this action. WHEREFORE, the plaintiff requests that this Court grant primary physical custody of the children to her. Respectfully submitted, ~~ Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ... ~ ~ <'.. - . . VERIFICATION I verify that I am the Plaintiff as designated in the present action and that the facts and statements contained in the above complaint are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of I 8 Pa.C.S. g4904, relating to unsworn falsification to authorities. Dated: ;;)- jff'6h LJ{g jr/~#Ylrr Sherry L. ~nger, Plaintiff r"'. ~J~ ~J:__ ;':' ('c (..:~ , ' ' -',; r:..:c.' ~f: :;::-~ =< , ~ . r0 <':0 ~, :;? """ Iv ,. - ~ '--' ., -;1 -, ~'''l ..~ "'1 ;~ " -. r71 ::,~ 1,:,J :-:'Q , - ~,..! ;JO C);n ~5 -< t ~ ~'-' ~ -. SHERRY_L. BITTINGER, plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. MICHAEL STOLTENBURG, Defendant/Petitioner CIVIL ACTION - LAW IN CUSTODY 00-1094 CIVIL TERM AND NOW, this 9th day of November, 2001, upon consideration of Defendant's Petition for Special Relief Pursuant to Rule 1915.13, and following a conference in'chambers in which Plaintiff was represented by Joan Carey, Esquire, and Defendant was represented by Karen Kurts, Certified Legal Intern, Family Law Clinic, supervised by Teri I. Henning, Esquire, and pursuant to an agreement reached at the conference, it is ordered and directed, pending the conciliation conference scheduled in this matter, as follows: 1. Custody of the parties' children, Mariah Stoltenburg (date of birth August 7, 1993) and Carisa Stoltenburg (date of birth September 16, 1990), shall be in Plaintiff each weekend from Friday at 6:00p.m. until Sunday at 6 p.m.; provided, that, where the following Monday is a school holiday, Plaintiff's period of custody shall extend until 6:00 p.m. on that Monday. 2. At all remaining times, custody of the said children shall be in Defendant. 3. Neither party shall remove the children or either of them from the central Pennsylvania area, nor shall secrete the location of either child from the other party at any time. 4. TransportatiDn with respect to exchanges of custody shall be the responsibility of the party receiving custody. 5. Nothing herein is intended to preclude the parties frDm devia~~ng from the terms of this order by mutual agreement or from making such other arrangements as to custody as 'tIIN\lAl)'SN1\8d )J.NnOo GM/l1::B8v~no S;; : I lid ": I 110N fa Ai:JIflONOiilC-i:b ;];--11 JO 30.i:1:i:)-.03'}!:! ","" \ ~J.. - they choose by mutual agreement. By the Court, Joan Carey, Esquire Mid-Penn Legal Services 8 Irvine Road Carlisle, PA 17013 For the Plaintiff/Respondent Karen Kurts, Certified Legal Intern 45 North pitt Street Carlisle, PA 17013-2899 For the Defendant/Petitioner pcb .... .il ..~ $' ~ j NOIf 0 :1 2001 r- SHERRY L BITTINGER, Plaintiff/Respondent IN THE COURT OF C0:Ml\10N PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CML ACTION-LAW IN CUSTODY MICHAEL STOLTENBURG, Defendant/Petitioner NO. 00-1094 CNIL TERM TEMPORARY CUSTODY ORDER AND NOW, this day of November, 2001, based upon the petition of Michael Stoltenburg, it is hereby ordered and decreed that: Michael Stoltenburg shall have primary physical custody of the children, Mariah Stoltenburg, and Caris a Stoltenburg, pending conciliation in this matter. Sherry L. Bittinger shall have partial physical custody, every weekend from Friday at 6 p.m. until Sunday at 6 p.m., pending conciliation in this matter, and at such other times as the parties may agree. Neither party shall remove either child from the Commonwealth of Pennsylvania, until further Order of Court. This Order shall remain in effect until modified by agreement of the parties or further Order of Court. BY THE COURT: J. SEERRY L. BITTINGER, Plaintiffi'Respondent IN TEE COURT OF COl\1MON PLEAS OF CutvIBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN CUSTODY MICHAEL STOLTENBURG, Defendant/Petitioner NO.00-1094 CIVIL TERM PETITION FOR SPECIAL RELIEF PURSUANT TO RULE 1915.13 -- - - -_..- Petitioner, Michael Stoltenburg, by and through his attorneys, the Family Law Clinic, petitions this court for special relief pursuant to Pa.R.c.P. 1915.13 to maintain primary custody of the parties' children, Mariah Stoltenburg, d.o.b. 8/7/93, and Carisa Stoltenburg, d.o.b. 9/16/90, pending conciliation in this matter, and avers the following in SUPPOlt thereof: 1. Petitioner, Michael Stoltenburg (Father), is the biological father of the children. 2. Respondent, Sherry Bittinger (Mother), is the biological mother of the children. 3. On March 1, 2000, pursuant to the consent of the parties, this Court entered a Custody Order in this matter. A true and correct copy of the March 1, 2000 Custody Order is attached hereto. 4. Under the March 1, 2000 Custody Order, Mother was granted primary physical custody of the children, and Father was granted periods of partial physical custody. 5. Despite the March 1, 2000 Order, Mariah Stoltenburg has lived with Father since June of 2000. Mariah has been living with her Father continuously since that time. 6. In August 2001, Mother took Carisa Stoltenburg to live with Father and moved to Florida. Carisa has been living with her Father.since that time. 7. The children are currently enrolled in the Big Spring School District. Carisa is in 5th grade. Mariah is in 3" grade. 8. Father has been living at the same residence for five years. 9. At the beginning of November, 2001, Mother returned to the Carlisle area. Upon information and belief, Mother is currently staying with her sister in Carlisle and does not have a residence of her own. 10. When the children were in the custody of Mother they did not have a stable living environment. She moved multiple times when she had custody of the children, sometimes taking only one child with her and leaving the other one with Father. She has also moved to Florida on two separate occasions without the children, once in June of 2000 and again in August of 200 1. II. Mother has informed Father that she would like custody of the children this weekend, from Friday, November 9,2001, until Monday, November 12, 2001. 12. Father does not object to Mother spending time with the children, and is willing to agree to partial physical custody of the children every weekend, pending conciliation in this matter. 13. Mother's temporary residence is not in the children's school district. 14. Under the March 1, 2000 Custody Order, Mother has primary physical custody of the children. Father believes that it is in the children's best interest to remain with him, pending conciliation in this matter. Father is concerned that Mother will not return the children after her weekend visit. IS. On November 9,2001, Father filed a Petition to Modify Custody in this matter. The parties are currently waiting for a conciliation to be scheduled. 16. On November 9,2001, the Family Law Clinic contacted counsel for Mother in this matter, Joan Carey, Esquire, to ask whether she concurred with this Petition. Ms. Carey informed the Family Law Clinic that she would not concur with this Petition, and that she would like the opportunity to be heard by the Court before an Order is entered in this matter. WHEREFORE, Petitioner respectfully requests this Court to enter an Order granting Father primary physical custody of the children pending conciliation in this matter, with liberal periods of partial custody for Mother. November 9,2001 K;G! f(wk Certified Legal Intern ~!.!:~) . Robert E. Rains Teri L. Henning Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 SHERRY L. BITTINGER, Plaintiff : IN THE COURT OF CO:MMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00- /09'1' CIVIL TERM MICHAEL STOLTENBURG, Defendant : CIVIL ACTION - LAW : CUSTODY CUSTODY ORDER AND NOW, this ) ~l:. . day of J!)OSc.h ,2000, upon consideration of the parties' Consent Agreement, the following Order is entered with regard to custody of the parties' children, Mariah Stoltenburg, d.o.b. 8/7/93, and Carisa Stoltenburg, d.o.b. 9/16/90. 1. Plaintiff, Sherry L. Bittinger, herebafter referred to as the mother, and Defendant, Michael Stoltenburg, hereinafter referred to as the father, shall share legal custody of the child. 2. The mother shall have primary physical custody of the children. 3. The father shall have partial custody of the children according to the following schedule: a.) Every weekend from Friday at 6:30 p.m. until Sunday at 7:30 p.m. subject to the mother's right to have custody on selected weekends as agreed upon by the parties and upon reasonable notice to the father. b.) Periods during the summer as agreed by the parties. . c.) Other times agreed upon by the parties. 4. The mother and father shall share periods of custody on Christmas Day and Christmas Eve each year as follows: the mother shall have the children from noon on Christmas Eve until noon on Christmas Day, and the father shall have the children from noon on Christmas Day until noon on December 26. 5. The father shall have the children on Thanksgiving Day. 6. The mother and father shall alternate periods of custody on Easter as follows: the mother shall have the children on years that end in an odd number and the father shall have the children on years that end in an even number. 7. The mother and father shall alternate periods of custody for New Year's Eve and New Year's Day as follows: the mother shall have the children from noon on New Year's Eve until noon on New Year's Day in years that end in an odd number. The father shall have the children from noon on New Year's Eve until noon on New Year's day in years that end in an even number. 8. The mother and the father shall altemate periods of cUstody for the children's birthdays as follows: the mother shall have the children on their birthday in years ending in an odd number and the father shall have the children on their birthday in years that end in an even number. 9. The mother and father shall share custody on all other holidays as agreed upon by the parties. 10. The mother and the father, by mutual agreement, may vary from this schedule at any time, but the Order shall remain in effect until further Order of Court. II. The mother and the father agree that each shall notifY the other immediately of medical emergencies which arise while the children are in that parent's care. Each parent will notify the other of all medical care the children receive while in that parent's care. 12. Neither the mother nor the father shall drink to excess or use illegal drugs while the children are in their custody 13. The parties realize that their children's well being is paramount to any differences they might have between themselves. Therefore, they agree that neither party shall do anything which may estrange the child ~orp eitherparerrf;cif'iiijure the opinion o'rfIfe-cliiIa-as totbeother pareiirorwIll~h mayhan)p'eIth<e.tre~ and natural de~eiopmenrotTfiechi1d's love or'respect for " the-other parent. ..- . ',-.. -.. '---" . .-.........-... ..-...~..--..........~. -~ . "~--. ................-.-..-.- .>". ... - By the Court, T~~P::' !"'t)ljrt"\.r >:'1i1....~~A ""'l;-~""'..f')rr>n ~ J~.~..f,,, ':...,~.': f ; ~\1,,;'j\.. : 1$.. \.-,."dr"-.IO..-' 2T1 TrJsfF'Eyny ~.~:i. {,:,c.f,. 1 h't.:, ',pf";-' ~.~t my hen.ft ~2;:jfjfi~f;~ Prothonct~ If entered pursuant to the consent of the Plaintiff and the Defendant: ~~~ /()(~/;/J!F~\~b}td; Sherry L. Bittinger, Plaintiff .' Michael S oltenburg, Defendant / ~~/ I clan Carey . 7 . . Attorney for the Plamtlff VERIFICATION I verifY that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. g 4904 relating to unsworn falsification to authorities. Date 11/1/01 SHERRY L. BITTINGER, Plaintiffi'Respondent IN THE COURT OF C01\1MON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN CUSTODY WCHAEL STOLTENBURG, Defendant/Petitioner : NO. 00-1094 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Michael Stoltenburg, Petitioner, to proceed in forma pauperis. I, Karen L. Kurts, of the Family Law Clinic, Certified Legal Intern, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. Dme' \\ \ ~ \ 0 \ ~ :1. ~ K en L. Kurts Certified Legal Intern 7- '- 1!;2/ ~AS M. PLACE ROBERT E. RAINS TERI L. HENNING Supervising Attorneys THE FAMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Attorneys for Plaintiff , (") c. ~~ C :?- ~ ~, ~.:_~ c:> - - nO; . . .-:: , :_1:J ,.- ~ " 2'.: -. ~ (/2 UJ ',- ;:::'J ....-, ',.:~Q <: ~ ~}~ )> 0- Z 5- 0 6rn c: ~ :?: '-!1 =< CD '''' -< ~. , SHERRY L. BITTINGER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, pENNSYL V ANlA v. 00-1094 CIVILACTIDNLAW :MICHAEL STOLTENBURG DEFENDANT IN CUSTODY ORD.ER OF COURT AND NOW, Thursday, November 15, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland Connty Courthonse, Carlisle on Wednesday, December 05, 2001 at 9:30 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 defme 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Jacqueline M. Verney. Esq.';1./l/\ Custody Conciliator V The Court of Common 1'Ieas of Cumberland County is required by law to comply with the Americans with Disabilites 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 ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY 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 Telephone (717) 249-3166 RLcD....OFFICE ..... RV . ..,. DonTr\QNOI!\! . OF 1He \ I'."; . \e; l1.i'i\O: 2\ 0\ NOIJ '" .... RLAt'lO COU\\'T\' CUMtl!:., , ^ >.,.!\ f'ENNSYLV/"In\ ItjIS-jO/- <1..d, C!..of"'I /Yl~Jsc( -/0 Fav-n.ay ~a-0~'c:. A.)d.r''-€-Yn~~M --Ie:, My ~y C:. f '( p~"" ~C"L I;.:) ~/ tJ€A.D2'{ Is .f2~. V NOV 1 3 2001 P'-- SHERRY L BITTINGER, Plaintiffi'Respondent IN THE COURT OF C0Ml\10N PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CML ACTION-LAW IN CUSTODY MICHAEL STOLTENBURG, Defendant/Petitioner NO. 00-1094 CN1L TERM ORDER OF COURT AND NOW, this day of , 200 I, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before, , the conciliator, at on the _ day of ,2001, at m., for a Pre-Hearbg Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme 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: Custody Conciliator YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT 1M VE 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, PA 17013 (717) 249-3166 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 heanng or business before the court. You must attend the scheduled conference or hearing. SHERRY L. BITTINGER, PlaintifflRespondent IN THE COURT OF CO:M:MON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNILACTION-LAW IN CUSTODY V. MICHAEL STOLTENBURG, Defendant/Petitioner NO. 00-1094 CNIL TERM PETITION FOR MODIFICATION OF CUSTODY ORDER 1. The petition of Michael Stoltenburg, respectfully represents that on March 1, 2000, an Order of Court was entered for the custody of Mariah Stoltenburg, d.o.b. 8/7/93, and Carisa Sto1tenburg, d.o.b. 9/16/90, a true an-d correct copy of which is attached. 2. This Order should be modified because: a. Father has had primary physical custody of the children due to Mother's absence. Mariah Stoltenburg has been living with Father since June 2000. Carisa Stoltenburg has been living with Father since August 200 I, when Mother moved to Florida. b. Father has acted as the children's primary care giver in the past. c. Fatherprovides astable living environment for the children. Father has had stable employment for the last year. Father has lived in the same house for the last five (5) years. Father has created a loving and nurturing living environment for the children. d. Mother has ahistory offrequently moving from residence to residence, which does not provide a stable living environment for the children. Mother has moved between Florida and Pennsylvania on at least two (2) occasions in the last eighteen (18) months. Upon information and belief, Mother changed residences on at least six (6) occasions between August 200 1 and November 200 I, while in Florida. e. Father has children enrolled in the Big Spring School District. It is in the best interest of the children to remain in their school and classroom environments. WHEREFORE, Petitioner asks that the Court modify the existing Order for Custody, granting Father primary physical custody, because it will be in the best interest of the children. ~7 ~!?J Kar n L. Kurts Certified Legal Intern ---? L T MAS M. PLACE ROBERT E. RAINS TERI L. HENNING Supervising Attorneys November 9,2001 FAMILY LAW CLINIC 45 N. Pitt. St. Carlisle, PA 17013 717 243-2968 '. . SHERRY L. BIITINGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF v. : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00- /0'1'1 CNIL TERM NITCHAELSTOLTENBUR~ Defendant : CNIL ACTION - LAW : CUSTODY CUSTODY ORDER AND NOW, this ) ~t. day of J!)a.rc.h ,2000, upon consideration of the parties' Consent Agreement, the following Order is entered with regard to custody of the parties' children, Mariah Stoltenburg, d.o.b. 8/7/93, and Carisa Stoltenburg, d.o.b. 9/16/90. 1. Plaintiff, Sherry L. Bittinger, hereinafter referred to as the mother, and Defendant, Michael Stoltenburg, hereinafter referred to as the father, shall share legal custody of the child. 2. The mother shall have primary physical custody of the children. , ". schedule: The father shall have partial custody of the children according to the following a.) Every weekend from Friday at 6:30 p.m. until Sunday at 7:30 p.m. subject to the mother's right to have custody on selected weekends as agreed upon by the parties and upon reasonable notice to the father. b.) Periods during the summer as agreed by the parties. c.) Other times agreed upon by the parties. 4. The mother and father shall share periods of custody on Christmas Day and Christmas Eve each year as follows: the mother shall have the children from noon on Christmas Eve until noon on Christmas Day, and the father shall have the children from noon on Christmas Day until noon on December 26. 5. The father shall have the children on Thanksgiving Day. 6. The mother and father shall alternate periods of custody on Easter as follows: the mother shall have the children on years that end in an odd number and the father shall have the children on years that end in an even number. 7. The mother and father shall alternate periods of custody for New Year's Eve and New Year's Day as follows: the mother shall have the children from noon on New Year's Eve until noon on New Year's Day in years that end in an odd number. The father shall have the children from noon on New Year's Eve until noon on New Year's day in years that end in an even number. 8. The mother and the father shall alternate periods of custody for the children's birthdays as follows: the mother shall have the children on their birthday in years ending in an odd number and the father shall have the children on their birthday in years that end in an even number. 9. The mother and father shall share custody on all other holidays as agreed upon by the parties. 10. The mother and the father, by mutual agreement, may vary from this schedule at any time, but the Order shall remain in effect until further Order of Court. II. The mother and the father agree that each shall notifY the other immediately of medical emergencies which arise while the children are in that parent's care. Each parent will notifY the other of all medical care the children receive while in that parent's care. 12. Neither the mother nor the father shall drink to excess or use illegal drugs while the children are in their custody 13. The parties realize that their children's well being is paramount to any differences they might have between themselves. Therefore, they agree that neither party shall do anything which may estrange the child from eithe~QTIDJUre the opinion oftliecIiildait.othe other 'p'areiii"oi-whlchrn~y, h.~p~r thy fr,~~. an~E~n:T~_~evefopmenfOfTfiediild's love oi-respect fOf" ,'. the'other parent. .... .... ..---......-.,-..".... .......~......."...,.,- '..",,~.~.~......~ ,,....-..'-...---. By the Court, '1r'''''~~C''' 'f""c""'lf}"\>T ""'4'>#'>>,..~ ~~,~,f')IT"r:l\ ~ ~Y~.:;'a;lt,', ::....,'......'f1 ~ i.~\1<)J\:~t 1'il';._"o-'.Jt>::.!l..,2." in T[:~;ri';n'l:'Hl'{ '.,.-~:J. rr::cf i f: "1':, ~>;!":' ~,}t m~/ h2r~i Emd ih,:-. S8:.:! of s~:jd CO'Jrl tlt Ccr!islSJ Pd. t!xi~nf;~ Prothonot~ '- ~ If entered pursuant to the consent of the Plaintiff and the Defendant: a.<'f~ ! Ji' ,- / F C ?a ,d? Sherry 1. Bitti ger, Plaintiff . Michael Stoltenburg, Defendant ~~/ OM Carey 'J ~ttorney for the Plaintiff . VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa.C.S 9 4904, I verify that I am the Plaintiff in the present action, and that the facts and statements contained in the above Petition are true and correct, to the best of my knowledge, information and belief. Date: -11-/.ll 01 Michael St ltenburg ., , . . SHERRYL. BITTINGER, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW IN CUSTODY MICHAEL STOLTENBURG, Defendant/Petitioner NO. 00-1094 CIVIL TERM CERTIFICATE OF SERVICE I, Karen L. Kurts, of the Family Law Clinic, hereby certify that I served a true and correct copy of the Petition to Modify Custody on Joan Carey, Respondent's attorney, by mailing the same to her at MidPenn Legal Services, 8 Irvine Row, Carlisle, Pa 17013 on November 9,2001. Date: II-CJ-O( i~urtsj K~ o c: s:-: Vi",'; mi'" ~s~ ~(:' "'-'-" ~n )~8 -"- ---< -< > . . , 7 a o " .-" ._,._~ --; '" '::) :z ::~ I .n ?".:> ..::::..,c::) ~ <0 ::~:~-~ ..-; ---: :D -< --- SHERRY L. BITTINGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-1094 CIVIL MITCHAELSTOLTENBURG, Defendant : CUSTODY PRAECIPE TO ENTER APPEARANCE I, Joan Carey, of MidPenn Legal Services, enter my appearance as Attorney for Plaintiff, Sherry L Bittinger, in the above captioned case. II /,;Lo /0 I / I Date ~(OAJ<~ U oan Carey Attorney at Law MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 , (') 0 (') c -" $: """ :::j "'Om D -,'n ~9:i -c .t.;::::::; ~ -,.,[." z<;:; 0 ~.3'~ ~2: '.-IC... ~~.- "'0 :z: '7, (""):n ~(') ::2;: .z~ 5>2 s-'? on -j Z W -".: ~ ~ -< <D SHERRY L. BITTINGER, Plaintif:EiRespondent IN THE COURT OF C0Ml\10N PLEAS OF CUMIlERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN CUSTODY MICHAEL STOLTENBURG, DefendantlPetitioner NO. 00-1094 CIVIL TERM AMENDED CERTIFICATE OF SERVICE I, Karen L. Kurts, of the Family Law Clinic, hereby certify that I served a true and conect copy of the Petition to ModifY Custody and Order of Court scheduling conciliation on Joan Carey, Respondent's attomey, by mailing the same to her at MidPenn Legal Services, 8 Irvine Row, Carlisle, Pa 17013 on November 20,2001. Date: I h~{) -0 I ~J{~1M ci ~-h- Karen L. Kurts (") 0 ~ c: '1 :s: :z: :,::1 U.("J'J 0 ~h fl1 mn", "< Z::c: N -m ZS;- <=> _~:I::':; ~:i ~Q -. !:=\..'; "'" ::;c_i-j :S:(") :::;;:: !~c5 Zo of'rJ 5c: "'" Z ~ :D =< ..... -< ~.....~-_... JAN 11 2002 jJ.- , SHERRY L. BITTINGER, Plaintiffi'Respondent IN THE COURT OF COl\1MON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN CUSTODY MICHAEL STOLTENBURG, Defendant/Petitioner NO.00-1094 CNIL TERM TEMPORARY CUSTODY AGREEMENT AND ORDER OF COURT TillS AGREEMENT, made this '7.. i r-I- day of December, 2001, between Michael Stoltenburg, hereinafter Father, and Sherry L. Bittinger, hereinafter Mother, concerns the custody of their children, Mariah Stoltenburg, born August 7, 1993, and Carisa Stoltenburg, born September 16, 1990. Mother and Father are the biological parents of the children and desire to enter into an agreement as to the custody of the children. Mother and Father agree as follows: 1. Mother and Father shall have shared legal custody of the children. 2. Father shall have primary physical custody of the children, and Mother shall have partial physical custody of the children, as set forth in this Agreement and Order. 3. Mother shall have custody of the children three out of every four weekends, from Friday at 6:00 p.m. until Sunday at 6:00 p.rn. The parties shall agree as to which weekend each month that the father shall have custody of the children. 4. Mother shall have custody of the children every Wednesday from 5 p.m. until 8 p.m., provided that she can share in the transportation of the children (unless otherwise agreed by the parties t i='\1 ED-r\::~.:tCE OF ,1-4::'- ow,,"i'l~l~i',IIJTARY " 1.._ I "J .11_1 1 02 JAN I I PI; 3: 35 CUMBERLA\iD caUNiY PENNSYLVA1\1lA ............-... .",,-.-j """-"-_,'~_""~_,"'lI. ~. ~ 5. Holidays: a. School Holidavs: If a school holiday falls on a Monday following a weekend in which Mother has custody of the children, Mother's period of custody shall extend until Monday at 6:00 p.m. If a school holiday falls on a Friday prior to a weekend in which Mother has custody of the children, Mother's period of custody shall begin on Thursday evening at 6:00 p.m. On other school holidays, if the Father works on that day, Mother shall have custody of the children dUling the hours that Father works. b. Christmas: In 2001, Mother shall have custody of the children from noon on Christmas Eve until noon on Christmas Day. Father shall have custody of the children from noon on Christrrlas Day until noon on December 27,2001. Mother shall have custody of the children from noon on December 27ili until 6:00 p.rn. on December 30ili, 2001. In subsequent years, the parties shall share the Christmas holiday equally, as they agree. c. Mother and Father shall share ail other holidays, as the parties agree. 6. Transportation with respect to exchanges of custody shall be the responsibility of the party receiving the children, unless otherwise agreed upon by the parties. 7. The parties may modifY this Order by mutual consent. In the absence of mutual consent, the terms of this Order control. 8. No party to this Agreement and Order will do anything which may estrange the children from the other party, or injure the opinion of the children as to the other party or which may hamper the free and natural development of the children's love and respect for the other party. "~,- >- ~ 9. The parties intend to be bound by the terms of this Agreement and intend that this Agreement be entered as an Order of the Court. 10. A custody conciliation shall be scheduled for March 20,2002 at 10:30 a.m. ...f: ~ Michae toltenburg, De7 ~ L. IL!.-c. Jr-U-I Karen L. Kurts I Certified Legal Intern for Defendant ~ d~- Sherry L. ~er, Plaintiff ~ ~L~ J~ o M. Place '\:J Robert E. Rains Teri L. Henning Supervising Attorneys y11AMII.Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ~~ Att~ey for Plaintiff Mid-Penn Legal Services 8 Irvine Road Carlisle, PA 17013 (717) 243-9400 L~ ~ OJ-It.j-~~ AND NOW, this (Iii ORDER ~"""'vo..r"1 200'2:. day ofDeeembcI, 26&l the above custody agreement is approved and entered as an Order of Court. J. MAR 2 1 2.00') SHERRY L. BITTINGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2000-1094 CIVIL TERM MICHAEL STOLTENBURG, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 20th of March, 2002, the Conciliator being notified that the parties have signed a Custody Stipulation in the above matter, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ~,L 'eline M. Verney, Esquire, Cus / dy Conciliator !5~./ ,r,' fk.JJ<Y>okr!J- '3~ d::1 --ct.? < SHERRY L. BITTINGER, : Plaintiff v. MICHAEL STOL TENBURG, Defendant IN THE COURT OF CO:M:MON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00-1094 CIVIL TERM ORDER OF COURT AND NOW, this 16th day of May, 2002, the attached custody agreement is approved and entered as an Order of Court. ~~arey, Esq. Mid-Penn Legal Services 8 Irvine Row Carlisle, PA 17013 Attorney for Plaintiff Georgina A. Howells Certified Legal Intern ~as M. Place, Esq. Robert E. Rains, Esq. Lucy Johnston-Walsh, Esq. Supervising Attorneys Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Attorneys for Defendant :rc BY THE COURT, J. >L~ ()!j-/7-0 Q --~---------- FlLED-Cf'f~CE OF T~.~F P::;OTrCf-~OT,llJiY 02HilYl7 Pri !:20 CUM8ERLPJ-D COUNTY PENNSYLVA,lIJiA .~ ?! tn'j<<' v, ~t {e.nIo~'4 ORDER c..M\ 1\~l>V'\ - l.cu.,) Y \\1\. (bs-h~ MAIl 5 2001 No. em -( oqt OVI'/ Wf'l.1 ,. AND NOW, this _ day of May, 2002 the above custody agreement is approved and entered as an Order of Court. BY THE COURT: J. -" " SHERRY L. BITTINGER, Plaintiffi'Respondent IN THE COURT OF CO:MMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION-LAW IN CUSTODY MICHAEL STOLTENBURG, DefendantlPetitioner NO.00-I094 CNIL TERM CUSTODY AGREEMENT AND ORDER OF COURT TillS AGREEMENT, made this _ day of May, 2002, between Michael Stoltenburg, hereinafter Father, and Sherry L. Bittinger, hereinafter Mother, concerns the custody of their children, Mariah Stoltenburg, born August 7, 1993, and Carisa StoItenburg, born September 16, 1990. This Agreement modifies the Temporary Custody Agreement entered on January 11,2002 as an Order of Court. Mother and Father are the biological parents of the children and desire to enter into an agreement as to the custody of the children. Mother and Father agree as follows: . 1. Mother and Father shall have shared legal custody of the children. 2. Father shall have primary physical custody of the children, and Mother shall have partial physical custody of the children, as set forth in this Agreement and Order. 3. Mother shall have custody of the children three out of every four weekends, from Friday at 6:00 p.rn. until Sunday at 6:00 p.m. The parties shall agree as to which weekend each month that Father shall have custody of the children. If Mother is scheduled to work on weekends, she shall have the right to comparable make up periods of custody during the week. 4. Mother shall have custody of the children every Thursday from 5 p.m. until 8 '-' p.m., provided that she can share in the transportation of the children (unless otherwise agreed by the parties). Mother shall have the option of keeping the children overnight if she is able to take them to school or return them to Father's custody the next day. 5. Holidays: a. School Holidavs: If a school holiday falls on a Monday following a weekend in which Mother has custody of the children, Mother's period of custody shall extend until Monday at 6:00 p.rn. If a school holiday falls on a Friday prior to a weekend in which Mother has custody of the children, Mother's period of custody shall begin on Thursday evening at 6:00 p.m. On other school holidays, if Father works on that day, Mother shall have custody of the children during the hours that Father works. b. Summer Vacation: Mother shall have custody of children for two consecutive weeks in the summer and other times as agreed by Mother and Father. c. Christmas: In 2002, Mother shall have custody of the children from noon on Christmas Eve until noon on Christmas Day. Father shall have custody of the children from noon on Christmas Day until noon on December 27,2002. Mother shall have custody of the children from noon on December 27th until 6:00 p.m. on December 30'" 2002. In subsequent years, the parties shall share the Christmas holiday equally, as they agree. -, d. Easter and Thanksgiving: Parties shall have custody of the children on Easter and Thanksgiving on an alternating yearly basis. Father shall have custody of children for Easter and Mother shall have custody of children for Thanksgiving in even-numbered years. Mother shall have custody of children for Easter and Father shall have custody of children for Thanksgiving in odd-numbered years. e. Mother and Father shall share all other holidays, as the parties agree. 6. Transportation with respect to exchanges of custody shall be the responsibility of the party receiving the children, unless otherwise agreed upon by the parties. 7. The parties may modify this Order by mutual consent. In the absence of mutual consent, the terms of this Order control. 8. No party to this Agreement and Order will do anything which may estrange the children from the other party, or injure the opinion of the children as to the other party or which may hamper the free and natural development of the children's love and respect for the other party. 9. Mother shall not take the children out of the Commonwealth of Pennsylvania without the express consent of Father; however, Father shall not unreasonably withhold consent if Mother wishes to take the children out of the state to visit relatives in West Virginia and/or Florida as long as Mother provides a phone number and address where she and the children can be reached. 10. The party with custody of the children shall keep the other party informed as to -, the phone number and address where the children can be reached. 11. The parties intend to be bound by the terms of this Agreement and intend that this Agreement be entered as an Order of the Court. ~~ Robert E. Rains . Lucy Johnston-Walsh Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ~~ Attomey for Plaintiff Mid-Penn Legal Services 8 Irvine Road Carlisle, PA 17013 (717) 243-9400 , y (') 0 "'" ~ N ~O ::11: --! -0 0.) "'" , mrn -< ".....=- Z::.:; _,w,f-;l ZS::- .;:". -:-,"\;::: ~-'"~ :f~~ ~c -0 >0 ::.: Z' 01,., >2 Cd -, Z :;:) ~ ~ --J -< , SHERRY L. BITTINGER PLAINTiFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN1Y, PENNSYLVANIA v. 00-1094 CIVIL ACTION LAW MICHAEL STOLTENBURG DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, January 10, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courtbouse, Carlisle on Tuesday, February 11, 2003 at 10:30 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 def'me 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Isl Tacqueline M. Vern'O'. Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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 TIllS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland COWIty Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 FILFD-"P"r,c: CF~' ,." 7.:..,,,..... J,'-..I1- H ! ;;.:, ", t, ~7L!~f'!OT''\D\.I ". "..., \ ~ IJ-'UlI 03 -IAN i 3 P/i 12: ! 5 CUM8EFjLA,~J COUNTY PENNSYLVANIA " /./3.03 j'/J.CU /'/3-02 M.C'~~c4~% '11~ ~Z X5- ~.,~r4~;# ~- J SHERRYL. BITTINGER, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CUSTODY V. MICHAEL STOLTENBURG, Defendant/Petitioner NO. 00-1094 CIVIL TERM ORDER OF COURT AND NOW, this day of ,2003, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before, , the conciliator, at , on the day of , 2003, at 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 defme 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 ently of a temporary or permanent order. FOR THE COURT: By: Custody Conciliator YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT I-fA VB 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, PA 17013 (717) 249-3166 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 scheduled conference or hearing. ,. .r- - JAN 0 9 2003 C- SHERRY L. BITTINGER, Plaintiffi'Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION-LAW IN CUSTODY V. MICHAEL STOLTENBURG, DefendantlPetitioner : NO. 00-1094 CIVIL TERM PETITION FOR MODIFICATION OF CUSTODY ORDER 1. The petition of Michael Stoltenburg, respectfully represents that on May 16,2002, an Order of Court was entered for the custody of Mariah Stoltenburg, d.o.b. 8/7/93, and Carisa Stoltenburg, d.o.b. 9/16/90, a true and correct copy of which is attached. 2. TIlls Order should be modified because: a. Mother has been inconsistent in exercising her visitation with the children since the order was entered. Mother frequently does not appear for a visit. \Vhen she does arrange for a visit, she does not arrive at the scheduled time. b. Father is concerned that Mother will attempt to exercise her rights to visitation and will not be able to make sound decisions regarding the children. Therefore, Father is concerned for the children's safety while they are in the custody of Mother. c. In the past, Mother has left the children with other individuals at times when she is to be providing care for the children. d. Most recently, on December 28,2002, Mother left suddenly for Texas during her period of visitation with the children. Mother left the children with an individual unknown to them. Mother previously reported to Father that this individual had threatened Mother with physical violence in the past. e. To Father's knowledge, while Mother has a permanent address, she is currently traveling around the country with a truck driver she recently met. ... ~-~-~ ~ '" WHEREFORE, Petitioner asks that the Court modify the existing Order for Custody, granting Father primary physical custody, and Mother supervised visitation to be at Father's home, as this is in the best interest of the children. January 8, 2003 ~11( ~hl/M~ Meg alone Certifi d Legal Intern ~~0k ROBER E. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 N. Pitt. St. Carlisle, PA 17013 717243-2968 ....- "'- "-' VERIFICATION I verifY that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of IS Pa. C.S. S 4904 relating to unsworn falsification to authorities. Date I /- /73 ~~ 4_1 ro11<nb~g / SHERRY L. BITTINGER, PlaintiflJRespondent JAN 0 9 2003 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CNIL ACTION-LAW : IN CUSTODY V. MICHAEL STOLTENBURG, DefendantlPetitioner : NO. 00-1094 CERTIFICATE OF SERVICE CML TERM I, Megan Malone, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of the Petition for Modification of a Custody Order on the following by first class United States mail, postage prepaid, on this, the 8th day of January, 2003: Joan Carey MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 Date: pal;! lA riA Zf I( 2CV ~ ~Jl1d5Y70 Megan alone Certified Legal Intern (') 0 () c- w ~ -" l:.Tt"7i '- fJJr.r ;J::r... -" ~ '" ..,., ~r'.;- - I -~, 1'71 (.,)~. CO ~'-:' C:; f:$ ,;~_. ~~:t~~ ;"-l....,J -0 5;: [j~} ._~ - -<:;. ::;.-() -C ~ c5r;'/ :<:: --.; =< .,-> :s Co -< -_/' JAN 1~ SHERRY L. BITTINGER, Plaintiff IN THE COURT OF COMMON PLEAS OF CillvlBERLAND COUNTY, PENNSYLVANIA CNIL ACTION-LAW IN CUSTODY V. MICHAEL STOLTENBURG, Defendant NO. 00-1094 CNIL TERM ORDER OF COURT AND NOW, this n fl,day of ::J 2J'J U vI is approved and entered as an order of court. ,2003, the attached stipulation, BY THE COURT: (it J. Lucy Johnston-Walsh Attorney for Defendant ^"-P--vl ~ /J.<.~&r _ J-) 7-03 Family Law Clinic "', I U 45 N. Pitt Street Carlisle, PA 15013 Joan Carey Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 ~C'--h -rvt-~ 1- j'7_tJ.3 0.. j::'ii. ::U-C::'F1CE 0:= ';r'- : >':. -':':'j.<::\~OT;\RY 03 .JM.! I 7 Pd L: I 7 CU~AEk.l~L"',,\i) COUNTY PENNSYLVANlA ~ f SHERRYL. BITTINGER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA. CNIL ACTION-LA W IN CUSTODY V. MICHAEL STOLTENBURG, Defendant NO. 00-1094 CNIL TERM STIPULATION 1. On May 16, 2002, an Order of Court was entered for the custody of Mariah Stoltenberg, d.o.b. 8/7/93, and Carisa Stoltenberg, d.o.b. 9/16/90. 2. On January 8, 2003, the Defendant (Father) filed a Petition for Modification of the Custody Order. 3. On January 16, 2003, the parties, by and through their counsel, agree that neither party shall relocate outside of Pennsylvania with the children during their periods of custody. 4. The parties also agree Ms. Bittinger will not allow the children to be 'in the presence of Rick Weaver at any time. 5. The parties intend for this stipulation to be entered as an order of court. By: By: ~~ Joan Carey, Esquire MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 Attorney for Plaintiff, Sherry Bittinger Lucy Jo tn-Walsh, Esquire Family Law Clinic 45 N. Pitt Street Carlisle, PA 17013 Attorney for Defendant, Michael Stoltenberg (") r; v!~r' fT1r,-' ..,... -( 0i~.~ c<C; ~:;21 ;pc: Z =< ~ .~ o w ~ "..J -1'1 , ~~ ~. i~-.~ -.J ~.::i -v ~ ~~~ (3 CiP' .,,< -- :7) -< ::::> (...""1 SHERRYL. BITTINGER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CNIL ACTION-LAW IN CUSTODY MICHAEL STOLTENBURG, Defendant : NO. 00-1094 CNIL TERM CERTIFICATE OF SERVICE I, Douglas A. Miltenberger, hereby certifY that I served a true and correct copy of the Stipulation on Joan Carey, Esq., at Legal Services, 8 Irvine Row, Carlisle, PA 17013, by depositing a copy of the same in the United States Mail, postage prepaid on the l7tl> day of January, 2003. 1//7/0 Y I Date .------, l~~~__v1 4~- // Douglas A. Miltenberger Certified Legal Intern FAMlLYLAWCLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ,..... ~.:: -::' -c: f( (Tlr~'o ~;?~, ~~', ~--- Z~-:-<,;, 5>C -7 ::::; -< c.:.:-, (." ,;-';': , , ~ , ,--',>" .c '" i",;. . '.1- ;'~l: ::: Or-r, ';:;/ -< MAY 1 3 Z003~ SHERRY L. BITTINGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2000-1094 CIVIL TERM MICHAEL STOLTENBURG, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 13th day of May, 2003, the Conciliator not being contacted for 90 days following a general continuance, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, %.ft dy Conciliator E2 ...:1' >- c; .,- ;:.~ ?' r- C"l ~$ 2t:'~ -~ '-J~ -,~ a... -<,> 9t:!. ,C,,';;:! \.D '~:;-r (..') ~~;~ .::2 ..x:z: ~~, >-- w.JLU ~ ':"'1.10.... r=: :r: ~ 1.1.. M 0 D 0 ....- { - , SHERRY BITTINGER PLAINTIFF IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 00-1094 CIVIL ACTION LAW MICHAEL STOLTENBURG DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, _ Friday, May 23, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, . at 4th Floor, Cumberland Connty Courtbouse, Carlisle on Monday, June 23, 2003 at 9:30 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 defme 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. The court hereby directs the parties to furnish auy and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. fJJ-- By: Isl Tacqueline M. Verney. Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. An 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 ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY OR CAJ.'<NOT AFFORD ONE, GO TO OR TELEPHONE nIB OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 RLED-OFFICE OF THE PROTHONOTARY 03 MAY 23 p;~ 3: 17 CUMBERLANO COUNl'Y PENNSYLVANIA .5.;23 .03 ..5;)J "C23 ..5':;)3 . tU M.~~/~-&4 #r~ 'J1~~ cdf~ ~~~4~,r~' l - .. .~ ... SHERRY. BITTINGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA -J v. : CIVIL ACTION -LAW : IN CUSTODY MICHAEL STOLTENBURG, Defendant : NO. 00-1094 ORDER OF COURT AND NOW, _ ,20---.--> upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of , 200----, at 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: Custody Conciliator 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. Cumberland County Bar Association 32 North Bedford Street Carlisle, PA 17013 717-249-3166 SHERRY. BITTINGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION -LAW : IN CUSTODY MICHAEL STOLTENBURG, Defendant : NO. 00-1094 PETITION TO MODIFY CUSTODY AND NOW, comes Michael Stoltenburg, by and through his privately retained counsel, Karl E. Rominger, Esquire and in support of his Petition to Modify Custody avers as follows: 1. Petitioner is Michael Stoltenburg, who resides at 181 Big Spring Terrace Newville, PA 17241 2. Respondent is Sherry Bittinger, who is believed to be residing in Plainfield, Pennsylvania. 3. On May 16, 2002, the Honorable J. Wesley Oler, Jr., entered the following Custody Agreement attached as Exhibit "A". 4. Since the entry of said Order, there has been a significant change in circumstances in that: (a). Respondent is not following the Court Order as she does not give advance warning if she cannot make the regularly scheduled weekend visitation. (b). Respondent tries to schedule visitation through the children instead of Petitioner. (c). Respondent does not make contact with the children during the week by telephone. (d). Respondent does not keep Petitioner informed of her address or telephone number. 5. The best interest of the children will be served by the Court in modifying said Order. WHEREFORE, Petitioner prays this Court to grant the modification of the Custody Agreement. Respectfully submitted, ROMINGER & BAYLEY ;? ---" Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA ] 7013 (717) 241-6070 Supreme Court ID # 8] 924 Attorney for Petitioner SHERRY. BITTINGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION -LAW : IN CUSTODY MICHAEL STOLTENBURG, Defendant : NO. 00-1094 VERiFICATION KARL E. ROMINGER, ESQUIRE, states that he is the attorney for, Defendant in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. g4904, relating to unsworn falsification to authorities. Date: May 21, 2003 ? ~--< ~l E. Rominger, Esquire Attorney for Defendant " -.. . SHERRY L. BITTINGER, : Plaintiff v, MICHAEL STOLTENBURG, Defendant .- .' IN THE COURT OF CO:MMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V AN1A CIVIL ACTION - LAW NO. 00-1094 CIVIL TERM ORDER OF COURT AND NOW, this 16th day of May, 2002, the attached custody agreement is approved and entered as an Order of Court. Joa arey, Esq. Id-Pe(ll1 Legal Services 8 Irvine Row Carlisle, PA 17013 Attorney for Plaintiff Georgina A. Howells Certified Legal Intern Thomas M. Place, Esq. Robert E. Rains, Esq. Lucy Johnston-Walsh, Esq. Supervising Attorneys Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Attorneys for Defendant :rc BY THE COURT, /. / -' /if , /. ! ./ i J. Ex h/j,'i: I:A It SHERRY L. BITTINGER, PlaintiffiRespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. CIVIL ACTION-LAW IN CUSTODY MICHAEL STOLTENBURG, Defendant/Petitioner : NO.00-1094 CIVIL TERM CUSTODY AGREEMENT AND ORDER OF COURT TillS AGREEMENT, made this _ day of April, 2002, between Michael Stoltenburg, hereinafter Father, and Sherry L. Bittinger, hereinafter Mother, concerns the custody of their children, Mariah Stoltenburg, born August 7, 1993, and Caris a Stoltenburg, born September 16, 1990. This Agreement modifies the Temporary Custody Agreement entered on January 11, 2002 as an Order of Court. Mother and Father are the biological parents of the children and desire to enter into an agreement as to the custody of the children. Mother and Father agree as follows: 1. Mother and Father shall have shared legal custody of the children. 2. Father shall have primary physical custody of the children, and Mother shall have partial physical custody of the children, a,; set forth in this Agreement and Order. 3. Mother shall have custody of the children three out of every four weekends, from Friday at 6:00 p.m. until Sunday at 6:00 p.rn. The parties shall agree as to which weekend each month that Father shall have custody of the children. If Mother is scheduled to work on weekends, she shall have the right to comparable make up periods of custody during the week. 4. Mother shall have custody of the children every Thursday from 5 p.m. until 8 r p.rn., provided that she can share in the transportation of the children (unless otherwise agreed by the parties). Mother shall have the option of keeping the children overnight if she is able to take them to school or return them to Father's custody the next day. 5. Holidays: a. School Holic]ays: _ If a school holiday falls on a Monday following a weekend in which Mother has custody of the children, Mother's period of custody shall extend until Monday at 6:00 p.m. If a school holiday falls on a Friday prior to a weekend in which Mother has custody of the children, Mother's period of custody shall begin on Thursday evening at 6:00 p.m. On other school holidays, if Father works on that day, Mother shall have custody of the children during the hours that Father works. b. Summer Vacation: Mother shall have custody of children for two consecutive weeks in the summer and other times as agreed by Mother and Father. c. Christmas: In 2002, Mother shall have cu~tody of the children from noon on Christmas Eve until noon on Christmas Day. Father shall have custody of the children from noon on Christmas Day until noon on December 27, 2002. Mother shall have custody of the children from noon on December 27th until 6:00 p.m. on December 30'" 2002. In subsequent years, the parties shall share the Christmas holiday equally, as they agree. d. Easter and Tlianksgjving; Parties shall have custody of the children on Easter and Thanksgiving on an alternating yearly basis. Father shall have custody of children for Easter and Mother shall have custody of children for Thanksgiving in even-numbered years. Mother shall have custody of children for Easter and Father shall have custody of children for Thanksgiving in odd-numbered years. e. Mother and Father shall share all other holidays, as the parties agree. 6. Transportation with respect to exchanges of custody shall be the responsibility of the party receiving the children, unless otherwise agreed upon by the parties. 7. The parties may modify this Order by mutual consent. In the absence of mutual consent, the terms of this Order control. No party to this Agreement and Order will do anything which may estrange the children from the other party, or injure the opinion of the children as to the other party or which may hamper the free and natural development of the children's love and respect for the other party. Mother shall not take the children out of the ComriIonwealth of Pennsylvania without the express consent of Father; however, Father shall not unreasonably withhold consent if Mother wishes to take the children out of the state to visit relatives in West Virginia and/or Florida as long as Mother provides a phone number and address where she and the children can be reached. 10. The party with custody of the children shall keep the other party informed as to 8. 9. '.. ~. the phone number and address where the children can be reached. 11. The parties intend to be bound by the tenns of this Agreement and intend that this Agreement be entered as an Order of the Court. _~//!<~f3ti;jzA_ Sherry L. Bittj er, laintiff &L<~~"" ~J:r:1 or in . wells Tied regal Intern for Defendant ~// ~ Esquire (I Attorney for Plaintiff Mid-Penn Legal Services 8 Irvine Road Carlisle, PA 17013 (717) 243-9400 th~~ Thorn ' Place Robert E. Rains . Lucy Johnston-Walsh Supervising Attorneys F AMll.. Y LAW CLlNIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 , . ~ - '" ORDER AND NOW, this _ day of April, 2002 the above custody agreement is approved and entered as an Order of Court. BY THE COURT: J. AJR~ ~~p o -- ~ 0- ~~ ~ 6"' ~ J:2- q ,e_ C i 2-?"" - ,. 't", -': 7:" " v , ~~j ~:) 0 r:2 , ~? ~ ~ 1-' - -n - ('5 ,-. 5> _e' ~ m C 2: -., :.n "::,.; =< :u (',0 -< <- ~ JUN 2! 21J1)3 (;. SHERRY L. BITTINGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2000-1094 CIVIL ACTION - LAW MITCHAELSTOLTENBURG, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 2-sf{. day of ~ 4f> t. ,2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The prior Order of Court dated May 16, 2002 shall remain in full force and affect with the following modifications: 2. Paragraph 3 of the prior Order of Court shall be deleted and replaced with the following. Mother shall have the Children three out of every four weekends, with Father's weekend always being the second full weekend of the month. Mother's period of custody shall be from Friday at 6:00 p.m. to Sunday at 6:00 p.m. 3. Paragraph four shall be deleted and replaced with the following: During summer vacation, Mother shall have physical custody of the Children from Thursday at 5:00 p.m. to Sunday at 6:00 p.m. during her regularly scheduled weekends. 4. Paragraph 5a shall be deleted and replaced with the following: Mother shall have physical custody of the Children during school holidays as agreed by the parties. 5. Paragraph 5b shall remain in full force and affect with the following addition: Mother shall advise Father of the two consecutive weeks by May 30 of every year. 6. Paragraph 5e shall be deleted and replaced with the following: Christmas shall be shared as agreed by the parties. 7. Paragraph 9 is deleted and replaced with the following: Neither party shall remove the Children from the Commonwealth of Pennsylvania without first advising the other parent ofthe location and telephone number where the Children can be reached. 8. Paragraph 11 is deleted. F1LED-{)fFiCE OF Tr.E P;::OTH:JNOTARY 03 JUri 26 PH 3: 2 ! CUM8ERLP-ND COUN1Y PEJ'\lNSYLVANIA ,., .~ 9. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation ConferenclJ. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. - cc: Karl Rominger, Esquire, for Father Sherry Bittinger, pro se 11 Run Road Carlisle, PA 17013 b-d--1-61 Or~ ,"4.-_ .... SHERRY L. BITTINGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2000-1094 CIVIL TERM MICHAEL STOLTENBURG, Defendant : CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Mariah Stoltenburg Carisa Stoltenburg August 7,1993 September 16,1990 Father Father 2. A Conciliation Conference was held in this matter on June 23, 2003, with the following individuals in attendance: Father, Michael Stoltenburg, with his counsel, Michael Whare, Esquire for Karl Rominger, Esquire and Mother, Sherry L. Bittinger, pro se. 3. A prior Order of Court, dated May 16, 2002 was entered by the Honorable J. Wesley Oler, Jr., providing for shared legal custody with Father having primary physical custody and Mother having periods of partial physical custody. 4. The parties agreed to the entry of an Order in the form as attached. r;, -' J^3 ~O ~ Date - Ik i, cq line M. Verney, Esquire Custody Conciliator ); SHERRY BITTINGER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION -LAW : IN CUSTODY MICHAEL STOLTENBURG, Defendant : NO. 00-1094 AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLV ANlA ) COUNTY OF CUMBERLAND ) I, Karl E. Rominger, Esquire did serve by a Process Server to Sherry Bittinger, Defendant's Conciliation Order and Petition to ModifY Custody at her address at 11 Run Road, Carlisle, PA. 17013. Service was executed on June 18, 2003 at the above address. An Affidavit of Service is attached. Dated: June 20, 2003 Respectfully submitted, ROMINGER & BAYLEY ? Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ill # 81924 Attorney for Defendant . . '--~ AFFIDAVIT OF SERVICE Commonwealth of Pennsylvania County of Cumberland Common Pleas Court Case Number: 00-1094 Court Date: 6/23/2003 Plaintiff: Sherry Bittinger vs. Defendant: Michael Stoltenburg For: Karl Rominger Rominger & Bayley Law offices Received by ROMINGER LEGAL on the 18th day o~une, 2003 at 4:48 pm to be served on Sherry Bittinger :11 R,~d., Carlisle, PA 17013. I, Glenn ca.le ~ . being duly sworn, depose and say that on the day of .I u (Vi. , 20~ at ...L.:~.m., executed service by delivering a true copy of the Order of Court, Petition to Modify Custody, Verification, Order of Court, Custody Agreement and Order of Court, Order in accordance with state statutes in the manner marked below: () INDMDUAL SERVICE: Served the within-named person. USUBSTlTUTE SERVICE: By serving WilL TON fJ 1}t6i?:ibAJ as /" - Bi)'ft='/ZL2t-!P W10 wl/fS tJEW Pi(<'SO;J Sii7:VEi/ . ( ) POSTED SERVICE: After attempting service on -'_ at _ anoj on ----'_ at _ to a conspicuous place on the property described herein. - ( ) NON SERVICE: For the reason detailed in the Comments below. Military Status: ( ) Yes or ( ) No If yes, what branch? Marital Status: ) Married or ( ) Single Name of Spouse COMMENTS: (,/0" WI-ilk. /l'I"Je, blad hair,' nO Ihs I IO"'j .h~/'y I certify that I have no interest in the above action, am of legal age and have proper authority in the jurisdiction in which this service was made. ~~. _-~-;'J SubscribEi'd and Sworn to before me on the /,f Zlday of -0 () N"L . 0103bythe affiant who is personaIlYknownt~me. ~ - NO~ >Lv Notarial Seal UAdaJ. Jumper, Notary Public Carllsle BolO, Cumberland County My Camission Expires JlWj l!3. 2006 ~_1ian0f_ Copyright @ 1992~2a01 Database Services, Inc. - Process Se~s Toolbox V5.5f PROCESS SERVER # Appointed in accordance wffh State Statutes ROMINGER LEGAL 155 S. Hanover st. P.O. Box 1148 Carlisle, PA 17013 (717) 960-9260 Our Job Serial Number: 2003000144 - .....:..-.- .~'~~"- -.:;;~-' :,.1-. 1,',,- ,. 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