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HomeMy WebLinkAbout00-01400 ,-- JAMES M. MINDER, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 00-1400 CML TERM MARGARET MARY KORFF MINDER, Defendant, CML ACTION - LAW CUSTODY PLAINTIFF'S PRE-TRIAL MEMORANDUM AND NOW, comes the Plaintiff, James M. Minder, by and through his attorney, Diane S. Baker, Esquire, and files his Pre-Trial Memorandum as follows: 1. Statement of Facts. This action pertains to custody of the minor child Sara Beth Minder, born October 27, 1983, age 17. The parties, James Minder and Margaret Minder, separated in March, 2000, when Defendant moved with the child to Beaver County, Pennsylvania. Plaintiff immediately filed a custody action contesting the move and an order was entered, dated May 15, 2000, granting him shared legal and partial physical custody to include the majority of the summer and school vacation times. Since the entry of that order, Plaintiff has had to file two contempt actions because of missed visits and Defendant's refusal to provide Plaintiff with information about the child's medical care or education. The issues before the court include the current custody schedule, primarily Plaintiffs request that the child spend the sunnner of 2001 with him. Also before the court is the issue of contempt for missed visits, and Defendant's failure to provide Plaintiff with copies of report cards, medical records, and in general the Defendant's concerted effort to alienate the child from her father. I .. -""",,, ..-- " 2. Summary of Witnesses. Plaintiff will testify on his own behalf concerning the matters raised in the contempt petitions filed on or about September 8, 2000, and December 26,2000. In general, it will be Plaintiffs testimony that Defendant has caused visits between Plaintiff and the child to be missed and also Defendant has refused to include Plaintiff in any legal custody decisions affecting the child. Plaintiff has not been provided with medical records or school records, despite numerous requests and an Order, dated October 16, 2000, specifically directing that medical records and report cards be provided to Plaintiff. Plaintiff will also offer testimony about the costs he has incurred as a result of Defendant's contemptuous behavior including unused train tickets, lost wages and attorney's fees. 3. Conclusion. Plaintiff respectfully requests that this Honorable Court issue an order directing that the minor child spend the summer of 2001 with him and that Defendant be found in contempt and directed to pay Plaintiffs costs and attorney's fees. (/~~ ! _Diane S. Baker, Esquire . Attorney for Plaintiff 27 South Arlene Street Post Office Box 6443 Harrisburg, P A 17112-0443 717-671-9600 -,- 1--- ....-.... . CERTIFICATE OF SERVICE I hereby certify that on this 6th day of April, 2001, a true and correct copy of the foregoing document was served on the following person by United States Mail, postage prepaid, addressed as follows: Cindy L. Koser, Esquire 4810 Derry Street Harrisburg, P A 17111 Respectfully submitted, e S. Baker, Esquire Supreme Court ill 53200 27 South Arlene Street Post Office Box 6443 Harrisburg, P A 17114-0443 (717) 671-9600 1.--., " -",..,~....- - . House Rules for Sara while visiting Dad flQ1fi ('In \ -rr~ 1. No long distance phone calls are to be made without Dad's permission. Consequence: Phone privileges will be suspended on the next visit. Long distance collect calls are permitted if they do not interfere with our time together. 2. Curfew is at 11:00 PM every night. You must be in the house by 11:00. Consequence: Must remain in the house for one day, with no visitors or phone privileges. (Grounding) 3. Friends can sleep over if Dad is asked, if Dad agrees and knows 1 day in advance. 4. Friends are to leave the house by 11 :00 PM every night. 5. You must clean up after yourself in the kitchen, including pots, pans, dishes, and countertops. Consequence: Must remain in the house with no visitors or phone privileges until the job is done. 6. You must speak to and treat your father with dignity, love and respect, at all times, whether you are staying with him or not. Consequence: Must go to your room until calmed down. May.not leave the house, or have visitors or have phone privileges for one day or until Dad deems it appropriate. There may be other punishment in addition tov grounding. PLAINTIFPS EXHIBIT 11,/ ~'~.cJ I f'C'.e3 ~ JAMES M. MINDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 00-1400 CIVIL TERM CIVIL ACTION - LAW MARGARET MARY KORFF MINDER, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 2.[ ~t day of June, 2001, upon consideration of Plaintiff's Petition for Contempt, and of the issue of a schedule for physical custody of the parties' younger child, Sara Beth Minder (d.o.b. October 27,1983) to supplement that provided by the order of court dated October 16, 2000, it is ordered and directed as follows: I. The Court finds that Defendant has intentionally, voluntarily and wilfully failed to comply with the terms of the order of court heretofore entered, and she is consequently adjudicated in contempt. Defendant is sanctioned to pay attorney's fees to Plaintiff in the amount of $400.00, and to pay to the prothonotary the sum of$100.00. Any future act of contempt will be sanctioned more severely. 2. Plaintiffs periods of partial or temporary physical custody hereafter shall be as follows: a. From Saturday, July 7, 2001, at 3:00 p.m. until Saturday, July 28, 2001, at 3:00 p.m. b. On the Labor Day weekend, from Saturday, September 1, 2001, at 3:00 p.m. until Monday, September 3,2001, at 3:00 p.m. , " '--~ .- -'1-'- " , , .. " ~~ ,-~-, .' .~'. ilil.llitl .' _Ifmt~~~~.. 'I=_'=m.~-I - --~ ~*u:r JI"~~ ~~~. -~,"'- .' ~" '"' ;-';\ \~'~i-''''';'''-Y~\~~~~. ~'.~.'\<Y\N(\l l'l \ t; ? \ P:.":\, \: G... \ j, ,J)\~ .."' \ CUM\3t:I:;L!'\~\) GOUNI'< PENNS'YL\f!\l\l\i\ ~.~- ',- " ~"~". '" - c. On the Columbus Day weekend, from Saturday, October 6, 2001, at 3:00 p.m. until Monday, October 8,2001, at 3 :00 p.m. 3. Exchanges of custody shall take place at Plaintiff s residence, and responsibility for, and the expense of, transportation ofthe child to and from the place of exchange shall be that of Defendant. 4. Neither party shall facilitate, accommodate or tolerate an abridgement of the other's custodial rights, except by mutual agreement in writing. 5. Except as by implication modified herein, the terms of the order of court dated October 16, 200 I, shall remain in full force and effect. Diane Baker, Esquire 27 South Arlene Street P. O. Box 6443 Harrisburg, P A 17112 For the Plaintiff Cindy L. Koser, Esquire 4810 Derry Street Harrisburg, P A 17111 For the Defendant Adrienne Johnson, Esquire 453 Buffalo Street Beaver, PA 15009-2003 For the Child :rlm I__'__n' BY THE COURT, CbFI'w m~lu-l ~/;).VOI .1. '", - .-,._- .FR(~ : Cind~ L. Koser, Esquire PHONE NO. 7175645158 Jun. 12 2001 04:42AM P2 JAMES M. MINDER, Plaintiff VS. IN TIlE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-1400 CIVIL TERM MARGARET MARY MINDER, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER ~ ,6ND NOW, this w}/L.. day of ~ ' 2001, upon consideration of the foregoing 1;\1li:iched Petition, a hearing in the above captioned ml!ttAr l'lcheduled for June 14, 2001 at 9:30 AM is continued. The matter is rescheduled for ~ d/{OJ ,2001 at I! 3D ~ The terms and conditions set forth in the order of February 13, 2001, apply to the hearing set forth herein. BY THE COURT: J. of&t: '--1?tfl] D I}V .~ .? ~O\ v\i' . .:", " >.... - -1- :"....., )!l_~!ili!lIlY~I_~'"""j~~~~&JWiI-'~'-~"-"".'~"~ '~'~-'--Mii1iIiiI ,l ~'~ru. ,~-"~ . '"' ,.L.".";[.i".!..' I' '" ~:;:t "; II' '0 , >". (,l1':~_";~~E . ". i'J07;11RY 01 JUfj I" ". ' '.:: /-1'1 I: I 0"". 2. vWI{j,cRI ."' PEN/fJ~~Jiv~UN7Y .. ~. .I~ ~__ - "_ - 'j ~ FR~ Cind~ L. Koser, Esquire PHONE NO. 7175645158 Jun. 12 2001 04:42AM P3 JAMES M. MINDER, Plaintiff vs. IN THE COURT OF r.OMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-1400 CIVIL TERM CIVIL ACTION - tAW IN CUSTODY MARGARET MARY MINDER, Defendant PETITION FOR CONTINUANCE AND NOW, comes the Petitioner, Cindy L Koser, Esquire, and respectfully represents the following: 1. Plaintiff, .JRmAR M Minder, is represented by Dioane S. Baker, Esquir~. 2. Defendant, Margaret Mary Minder, is represented by Petitioner. Cindy L KosAr, Esquire. 3. The child IS Independently represented by Adrienne Johnson, Esquire. 4. A hearing in the instant action ili liet for June 'J4, 2001 at 9:30 AM. 5. Petitioner is entering the hospital on June 12, 2001 and expects to be hospitalized for several days with discharge anticipated no earlier than June 15, 200'1. 6. Attorney Koser has communicated with both AllUlIIl:!Y Baker and Attorney Johnson and each concurs in this request for continuance. 7. Because summer visitation is an issue in this case, the parties would like to reschedule thilli matter at the earliest convenience of the court and counsel. WHEREFORE, Petitioner requests that this (Ionorable Court conlillul:! this matter to and reschedule the hearing at the earliest appropriate date. RESPECTFULLY SUBMITTED: tl a I Cindy L K. Attorney I. o. 75899 4810 DArry Street Harrisburg, PA 17111 PHONE (717) 564-1084 FAX (717) 564-5158 '1 -~ FROM Cind~ L. Koser, Esquire PHONE NO. 7175645158 Jun. 12 2001 04:43AM P4 VERIFICATION I verify that the statements made in this Petition are true and correct. I understand .that false statements made herein are made subject to the penalties of 18 Pa.C.S. ~904 relating tn un!';worn falsification to authorities. b,/IJ I&{ ~ ~~ 2 ;" I" - FRGM Cind~ L. Koser, Esquire PHONE NO. 7175645158 Jun. 12 2001 04:43AM P5 JAMES M. MINDER, PlaillliIT V$. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-1400 CIVIL TERM CIVIL ACTION -LAW IN cus" OUY MARGARET MARY MINDER, Defendant Clm'rJ:FJ:CA'rE 01' SERVJ:CE I hereby certify that on this day I served a true and correct copy of the foregoing Petition in the above-<.:<if.'l.luned action by depositing the same in T.hA IT.!';. Mail, first class postage pre-paid, addressed to the following persons: Diane Sommers Baker, Esquire P.O.Rox 6443 27 S. Arlene St. Harrisburg, PA 17112-0443 Adrienne Johnson, Esquire 453 Buffalo St. Beaver, PA 1500Q-?On3 rot0-1 Date 7Z:~ . Koser, Esquire c ID #75099 4810 erry Street H<iL',['lsburg, l?A 17111 Telephone {717} 564-1084 FAX (717) 564-5158 '"", . ..,.... - 'I Subj: Fw: Date: 11/9/007:17:15 AM Eastem Standard lime From: Minderr@paonline.com (Minderr) To: DSBAKERLAW@aol.com - Ori9inal Message - From: pegmin To: Minderr Sent: Monday, October 23, 2000 8:46 PM Subject: Re: Jim, I am writing to you, to request your consent for Sara's therapy session with Kathleen Cloonan. You can giw your consent by signing the bottom of the form. Please send the form to me for wrification. Peggy - Original Message - From: Minderr To: pegmin@bellatlantic.net Sent: Tuesday, October 17,20007:35 PM Peg, I am writing to you to haw Sara's appointment with the therapist postponed until I can be inwlwd in the decision for her treatment as stated in the court order. I would remind you that I haw joint custody of Sara and I have an equal right to be exercised jointly with you to make decisions regarding Sara's health. I consider this to be a major decision. Furthermore, an appointment was set without im.ollling me although I specifically told you I wanted to be inwlwd in the decision when you picked up Sara on October 9, 2000. I consider your making an appointment without my inwlwment disregard for the court order. If you do not postpone the meeting until I am inwlwd in the decision, then I will consider that also disregard for the court order. Jim Minder October 17, 2000, 7:19 PM <!DOCTYPE HTML PUBLIC "-//W3C//DTD HTML 4.0 Transitional//EN"> <HEAD> <META content="texUhtml; charset=iso-8859-1" http-equiv=Content-Type> <META content="MSHTML 5.00.2314.1000" name=GENERATOR> <STYLE></STYLE:> </HEAD> <DIV>&nbsp;</DIV> <DIV style="FONT: 10pt arial">- Original Message- <DIV style="BACKGROUND: #e4e4e4; font-color: black">From: peqmin </DIV> <DIV> To: Minderr </DIV> <DIV>Sent: Monday, October 23, 20008:46 PM</DIV> <DIV>Subject: Re: </DIV></DIV> <DIV> </DIV><DIV>Jim,</DIV><DIV>&nbsp;</DIV><DIV>&nbsp; I am writing to you, to request your consent for Sara's therapy session with Kathleen Cloonan.&nbsp; You can giw your consent by signing the bottom of the form. Please send the form to PLAINTIFPS EXHIBIT Thursday, November 09, 2000 America Online: DSBAKERlAW Page: 1 - Attorney billings- custody/contempt related thru June 9, 2001 September, 2000 November, 2000 December, 2000 January, 2001 February, 2001 March,200l April,200l May,200l June,2001 Total thru June 9, 2001 . ~ - '"1. ~- - - ~': -':-_' ~,- . - - _ ,,'1 _'" - -_~ " . _ ^ , "' r,' . 256.50 108.00 135.00 216.00 364.50 256.50 283.50 27.00 108.00 1755.00 PLAINTlFPS EXHIBIT (). , ~, ,. co, Diane Baker, Esquire Post Office Box 6443 Harrisburg PA 17112 James Minder 713 Harding Street New Cumberland PA 17070 September 8, 2000 Professional services J 8/14/00 Hours Amount j ) Discussion with client re: custody status 0.20 27.00 9/2/00 Discussion with client re: contempt, prepare petition 1. 50 202.50 9/6/00 Discussion with client re: petition for contempt 0.20 27.00 For professional services rendered 1. 90 $256.50 Previous balance $240.28 8/22/00 Payment - thank you 9/1/00 Payment - thank you ($550.00) ($500.00) Total payments ($1,050.00) .Balance due ($553.22) You have a credit balance. No payment is due at this time. This account is past due. Payment is due upon receipt. . . c..' -. :--"':1;:-' ;'- r-. -5- '." - ,- - -~ -"" --"-"-"!i.~'~_"_ >~,-. - =;."" '-f'\-'> ,,~_ - - --'f. ., - ,'---~- Diane Baker, Esquire Post Office Box 6443 Harrisburg PA 17112 James Minder 713 Harding Street New Cumberland PA 17070 November 4, 2000 Professional services ) 10/18/00 Review order, discuss with client J Hours Amount 0.20 27.00 10/31/00 Correspond with client via e-mail 0.20 27.00 J 11/3/00 Correspond with client via e-mail, dictate letter to opposing counsel 0.40 54.00 For professional services rendered 0.80 $108.00 ($107.72) Previous balance Balance due $0.28 Payment is due 20 days from the date of this invoice. Partial payments are accepted. There is a $10 rebilling/late fee on accounts where no payment is made during the billing cycle -'~ 1!1 . . "b" ~ 'H ~. .; _ ".r_' -.' - Diane Baker, Esquire Post Office Box 6443 Harrisburg PA 17112 James Minder 713 Harding Street New Cumberland PA 17070 December 7, 2000 Professional services j 11/7/00 Review correspondence and forward to j client ( 11/15/00 Conference with client, dictate and review letter Hours Amount 0.20 27.00 0.80 108.00 For professional services rendered 1. 00 $135.00 Previous balance $0.28 Balance due $135.28 Payment is due 20 days from the date of this invoice. Partial payments are accepted. There is a $10 rebilling/late fee on accounts where no payment is made during the billing cycle -,.', "fl'__ - , ~-, f".;, "_~' - _ ' f-'~-' "." ~_ ."_'. _h_" , I Diane Baker, Esquire Post Office Box 6443 Harrisburg PA 17112 James Minder 713 Harding Street New Cumberland PA 17070 January 6, 2001 Professional services / 12/7/00 Discussion with client Dr. Cheek records / 12/12/00 Discussion with opposing counsel / 12/18/00 Correspond with client via e-mail j 12/19/00 Prepare contempt petition 12/28/00 Discussion with client re: personal property 1/2/01 Correspond with client via e-mail 1/4/01 Conference with client For professional services rendered Additional charges: 1/6/01 Bank check charge Total costs Total amount of this bill Previous balance . ~, , -"',-,-"--- ~ ,-~ Hours Amount 0.20 27.00 0.20 27.00 0.20 27.00 1. 00 135.00 0.20 27.00 0.20 27.00 1. 50 202.50 ._-~----- 3.50 $472.50 "' ,~ ^. 7.00 $7.00 $479.50 $135.28 James Minder Page 2 Amount 12/27/00 Payment - thank you ($500.00) Balance due $114.78 Payment is accepted. payment is due on or before February 1, 2001. Partial payments are There is a $10 rebilling/late fee on accounts where no made during the billing cycle '-" -j ,_0.'_"_"'''_--''.;:-_' ,~-r,' '," ,_ ., _', ".e<_ ,-, Diane Baker, Esquire Post Office Box 6443 Harrisburg PA 17112 James Minder 713 narding Street New Cumberland PA 17070 February 8, 2001 Professional services Hours Amount 0.20 27.00 2.50 337.50 0.20 27.00 2.90 $391.50 $114.78 ($500.00) $6.28 1/8/01 Discussion with client Attny Van Eck J 2/7/01 Travel and attend hearing J Discussion with Dawn Sunday For professional services rendered Previous balance 1/26/01 Payment - thank you Balance due Payment is accepted. on account due on or before March 1, 2001. Partial payments are There is a $10 rebilling/late fee if no payment is made during the billing period. '-<'l ~>, , ,'_c_~,., ",_,,_ _ ~_ " 'cC __,_~ ,_ ,~ _ __, ,,,____~_. . !' -,- . /,~, x '."l-" Diane Baker, Esquire Post Office Box 6443 Harrisburg PA 17112 James Minder 713 Harding Street New Cumberland PA 17070 >larch 9, 2001 Professional services ) 2/8/01 Discussion with client Attny Johnson / 2/l2/01 Correspond with client via e-mail ) 2/14/01 Review correspondence and forward to client J 2/15/01 Review conciliator's report and I forward to client 2/16/01 Correspond with client via e-mail, discussion with client I 2/20/01 Discussion with client i 2/26/01 Discussions with client and Attny i Johnson I 3/6/01 Correspond with client via e-mail For professional services rendered Interest on overdue balance Total amount of this bill Previous balance I I '1";-" ~ - -. ~"-:C~r .' "" .-' ,,- -" , . Hours Amount 0.20 27.00 0.20 27.00 0.20 27.00 0.20 27.00 0.30 40.50 0.20 27.00 0.40 54.00 0.20 27.00 1. 90 $256.50 $0.09 $256.59 $ 6.28 - '" Page 2 .James ~Jli~der Amount $262.87 Balance due paymenc is due on or before April 1, 2001. Interest is charged at che race of 18% per annum on all past due balances. There is also a $10 rebilling/late fee if no payment is made on account during the billing period. 1."";'_ . - -~- ,r__~_ . ,.~o__ _~, _ ",",r ,"- -,'-' '-' Diane Baker, Esquire Post Office Box 6443 Harrisburg PA 17112 James Minder 713 Harding Street New Cumberland PA 17070 \","", ;"'.~( r14V\ -.\ \L \j0'C- April 7, 2001 Professional services { 3/12/01 Discussion with client \ 3/22/01 Discussion with client \ 4/3/01 Discussion with Adrienne Johnson, Esquire \ 4/5/01 Review file, dictate pretrial statement. For professional services rendered Interest on overdue balance Total amount of this bill Previous balance Balance due Payment is due by May 1, 2001. -I ~ .,",-, i'_ Hours Amount 0.20 27.00 0.20 27.00 0.20 27.00 1. 50 202.50 2.10 $283.50 $3.76 $287.26 $262.87 $550.13 Jiane Baker, Esquire POSe Office Box 6443 Harrisburg PA 17112 :ames '.1inder -13 ~arding Street New Cumberland PA 17070 May 7, 2001 Professional services ! / ) 4/17 /01 Hours Amount Discussion with client 0.20 27.00 For professional services rendered 0.20 $27.00 Previous balance $550.13 Balance due ($550.001 $27.13 4/26/01 Payment - thank you Paymene is due by June 1, 2001. There is a $10 rebilling/late paymene fee if no payment is received on account by the due date. '"C' . , '-~',~ ." ,-,."-~ ,,----; ~ '- Jiane Baker, Esquire Post Office Box 6443 Harrisburg PA 17112 James Minder 713 Harding Street clew Cumberland PA 17070 June 9, 2001 Professional services 5/21/01 Discussion with client, dictate letter to opposing counsel 6/5/01 Review correspondence and forward to client, dictate letter For professional services rendered Interest on overdue balance Total amount of this bill Previous balance Balance due Hours 0.50 0.30 0.80 Amount 67.50 40.50 $108.00 $0.44 $108.44 $27.13 $135.57 Payment is due by July 1, 2001. There is a $10 rebilling/late payment fee if no payment is received on accoun~ by the due date. !',.. 1- , ~---" - - 'r ,. <, . '-- ~ ,-?-,-.'-'._-' . ~,,- Un-reimbursed Trips Labor Day Christmas Martin Luther King President's Day March Make Up Easter Memorial Day $104.00 $104.00 $76.00 $82.00 $0.00 $82.00 0.00 Not Reimbursed - No show Not Reimbursed Not Reimbursed Not Reimbursed - No show 100% Peg Makeup No Show $50 reimbursed No Show Total $448.00 50.00 $398.00 Total Less $50.00 Lost Wages October 2000 February 2001 June 2001 3.0 hrs 3.0 hrs 8.0 hrs Total hours for contempt 14.0 @22.23/hr= $311.22 Missed Parent teacher Conf. Last years report card refused Not informed of course scheduling (f<;.~ !fI.1.O--1.- e?l) Late on school calendar . t~ Late on ~. -.1 ~~m~ter report card Never received ~ report card Fourth one dw:, I R. c.'" 6 ~ ra.. PLAINTIFPS EXHIBIT #3 6'!)JOI Pf!b ", - I',' '. '."',.J-. ~ _ . ~._;<-- .," FROM : BERVER VRLLEY LRBOR NEWS PHONE NO, : 724 775 9733 Oct. 03 2000 11: 01RM P4 I. 'S-'1' (')SP Ii lfVL-G1- {l.o._~h 6"LfY/ll- S/-V/A-. ~J:~b 10 ecJ}1v... 7 d. q" C, -;)lrtrO Lf '--/ ( 'If.., q-L, . ). /r'OD '5; O<.j rlY) 1- r,.. OLiJ'""&" S', 0"; pJ'h . , 1-io .;+/}1l't\ 7: 3, fJrvl 1-'/ - J ""'0 I..{: J':;J f/1' 1-7 - .,)".....", /0: D I Phl q - I " ,:)tr04 10',01 (m 1-, ~ ;).Crl>-O jO: /0 PiYl q - 1 - ;) o.c-() '3 ~ 1<' ffYl q ,- 'J '-5' '~ ()"6 0-,'53 Pm DEFENDANT'S EXHIBIT it! (}r fj()-Ol f?r!j /op1X'i d C!.Jo 1firUV-. ~ ~ ~ ~ ;U~. ~ '-~J..A.~76z......~. ~ <;'~Lpf C-~. ~o lfM/ "jJ.-L-c-,u.~ ~. ~ ~. '--v~~ H. if ~ Tb <~ ~t) !r _-1~~ C~~ D(jJ !!.<oJ: w"" ~~~'i t;t:/~~ p/..c lMOA ~ o~ h".""l ~ '-tr~ ~. '--'1~.,/I-~--v-(.,~ W-(~.Jc ~ _ A (') u'. f+e- rJ-d 1'lAt'f' -N~ ~ 1-0 CL ~ A ^-i- .p' \\. <. ",} _ i" &-vI.. I / IL<~; 0"--- !J-v?f2..]. /", r .. I ,. / &-v1 q- I -J.6{y1j ""c~~v:;,,~ O~~ J /i A JAMES M, MINDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs, No, 00-1400 CIVIL TERM MARGARET MARY MINDER, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER .AND NOW, this I ~ II:: day of '? ... l) t , 2001, upon consideration of the foregoing attached Petition, a hearing in the above captioned matter scheduled for June 14, 2001 at 9:30 AM is continued, The matter is rescheduled for , 2001 at AM/PM. The terms and conditions set forth in the order of February 13, 2001, apply to the hearing set forth herein, BY THE COURT: J, '" JAMES M, MINDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No, 00-1400 CIVIL TERM MARGARET MARY MINDER, Defendant CIVIL ACTION - LAW IN CUSTODY PETITION FOR CONTINUANCE AND NOW. comes the Petitioner, Cindy L. Koser, Esquire, and respectfully represents the following: 1. Plaintiff, James M. Minder, is represented by Diane S, Baker, Esquire, 2. Defendant, Margaret Mary Minder. is represented by Petitioner, Cindy L Koser, Esquire. 3. The child is independently represented by Adrienne Johnson, Esquire, 4, A hearing in the instant action is set for June 14, 2001 at 9:30 AM. 5, Petitioner is entering the hospital on June 12, 2001 and expects to be hospitalized for several days with discharge anticipated no earlier than June 15, 2001. 6, Attorney Koser has communicated with both Attorney Baker and Attorney Johnson and each concurs in this request for continuance, 7. Because summer visitation is an issue in this case, the parties would like to reschedule this matter at the earliest convenience of the court and counsel. WHEREFORE, Petitioner requests that this Honorable Court continue this matter to and reschedule the hearing at the earliest appropriate date, RESPECTFULLY SUBMITTED: I' ~ II d ( Oat Cindy L. K Attorney I o. 75899 4810 Derry Street Harrisburg, PA 17111 PHONE (717) 564-1084 FAX (717) 564-5158 ,-, ",. - VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa,C.S. 94904 relating to unsworn falsification to authorities. b/l/& I ~ 2 - ._~ - - ~- -, - , . JAMES M, MINDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS, No, 00-1400 CIVIL TERM MARGARET MARY MINDER. Defendant CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on this day I served a true and correct copy of the foregoing Petition in the above-captioned action by d~positing the same in the U.S. Mail, first class postage pre-paid, addressed to the following persons: Diane Sommer.s Baker, Esquire P.O. Box 6443 27 S. Arlen~ St. Harrisburg, PA 17112-0443 Adrienne Johnson, Esquire 453 Buffalo St. Beaver, PA 15009-2003 fo~01 Date /f~ . Koser, Esquire e ID #75899 4810 erry Street Harrisburg, PA 17111 Telephone (717) 564-1084 FAX (717) 564-5158 ,. ~ -I e l 'w_...... ~~ - " "~ " ~" """" < ~ .. ,~- <- "-,'~- (') 0 0 c -" s:: <- \::leu c:: -n nl fT1 ::z: p Z:::tJ ","1." ZS: W ;;~? ~2"'_ ~~ '-0 -u <: -. ~c ->> -=0 r;-? om )>c -~ z: '" ~ ::;! ()"\ '~~r- =. ,~_.. "~lIl'i~_~-!Il\'l'~~~~" ~," '~,' _":~ 1 ~'~ i~""..~....lI!~W JAMES M. MINDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 00-1400 CIVIL TERM MARGARET MARY MINDER, Defe:1dant CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this day of , 2001, upon consideration of the foregoing attached Petition, a hearing in the above captioned matter scheduled for June 14, 2001 at 9:30 AM is continued, The matter is rescheduled for , 2001 at AM/PM. The terms and conditions set forth in the order of February 13, 2001, apply to the hearing 3et forth herein, BY THE COURT: J, Wesley Oler, Jr., Judge ~1 JAMES M. MINDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 00-1400 CIVIL TERM MARGARET MARY MINDER, Defendant o 0 ~ c:: s:: <- -onJ - rnrn Z Z::D Z, ):co w ~:z AND NOW, comes the Petitioner, Cindy L, Koser, Esquire, and respec~ ~ represents the following: ~6 N.. rC ~ ~ 1. Plaintiff, James M, Minder, is represented by Diane S, Baker, Esquire, 2. Defendant, Margaret Mary Minder, is represented by Petitioner, Cindy L Koser, Esquire. 3. The child is independently represented by Adrienne Johnson, Esquire. 4. A hearing in the instant action is set for June 14, 2001 at 9:30 AM. 5. Petitioner is entering the hospital on June 12, 2001 and expects to be hospitalized for several days with discharge anticipated no earlier than June 15, 2001. CIVIL ACTION - LAW IN CUSTODY ~-:1 ;~"12 , om ~nCJ _.~ T {:::J~~~ ..:S;-...,-: 'J- '...,:;..C) bin _.0' ~ '-< PETITION FOR CONTINUANCE :i 6. Attorney Koser has communicated with both Attorney Baker and Attorney Johnson and each concurs in this request for continuance, 7, Because summer visitation is an issue in this case, the parties would like to reschedule this matter at the earliest convenience Of the court and counsel. WHEREFORE, Petitioner requests that this Honorable Court continue this matter to and reschedule the hearing at the earliest appropriate date, RESPECTFULLY SUBMITTED: \" lQ II d ( Dat Cindy L. K Attorney I o. 75899 4810 Derry Street Harrisburg, PA 17111 PHONE (717) 564-1084 FAX (717) 564-5158 I . VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa,C,S. S4904 relating to unsworn falsification to authorities. fe/Zid I ~ , , 2 '-t . ' JAMES M. MINDER, Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-1400 CIVIL TERM MARGARET MARY MINDER, Defendant CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on this day I served a true and correct copy of the foregoing Petition in the above-captioned action by depositing the same in the U.S. Mail, first class postage pre-paid, addressed to the following persons: Diane Sommers Baker, Esquire P.O. Box 6443 27 S. Arlene St. Harrisburg, PA 17112-0443 Adrienn€ JOhnson, Esquire 453 Buffalo St. Beaver, PA 15009-2003 i ~0! Date ~~/z:~ Cindy y.) Koser, Esquire Attozn~y ID #75899 4810 Derry Street Harrisburg, PA 17111 Telephone (717) 564-1084 FAX (717) 564-5158 "-~ c -1- , , . vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-1400 CIVIL TERM JAMES M, MINDER, Plaintiff MARGARET MARY MINDER, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this day of , 2001, upon consideration of the foregoing attached Petition, a hearing in the above captioned matter scheduled for June 14, 2001 at 9:30 AM is continued, The matter is rescheduled for , 2001 at AM/PM, The terms and conditions set forth in the order of February 13, 2001, apply to the hearing set forth herein, BY THE COURT: J, Wesley Oler, Jr" Judge . . ~- - "' JAMES M, MINDER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-1400 CIVIL TERM vs. MARGARET MARY MINDER, Defendant CIVIL ACTION - LAW IN CUSTODY o S c S. L.. -00;; C rn rrt ~ PETITION FOR CONTINUANCE 2e' W CfJ.~- AND NOW, comes the Petitioner, Cindy L, Koser, Esquire, and respec~1fy represents the following: ~8 )7C ~ \~ 1. Plaintiff, James M. Minder, is represented by Diane S. Baker, Esquire. 2. Defendant, Margaret Mary Minder, is represented by Petitioner, Cindy L Koser, Esquire, 3. The child is independently represented by Adrienne Johnson, Esquire, 4. A hearing in the instant action is set for June 14, 2001 at 9:30 AM, 5. Petitioner is entering the hospital on June 12, 2001 and expects to be hospitalized for several days with discharge anticipated no earlier than June 15, 2001. --0 ?' ~ 6, Attorney Koser has communicated with both Attorney Baker and Attorney Johnson and each concurs in this request for continuance. 7, Because summer visitation is an issue in this case, the parties would like to rdschedule this matter at the earliest convenience of the court and counsel. WHEREFORE, Petitioner requests that this Honorable Court continue this matter to and reschedule the hearing at the earliest appropriate date. RESPECTFULLY SUBMITTED: \' (0 II 0 ( Dat (!p Cindy L. Ko Attorney I o. 75899 4810 Derry Street Harrisburg, PA 17111 PHONE (717) 564-1084 FAX (717) 564-5158 '1 ',' o --n :.::;J "'"11 01,";::; -o~ i:.~i'Q, -'"-.-n T"""'\'.'- '20 _,en ~ ~ '< VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa,C.S, ~4904 relating to unsworn falsification to authorities, b/z/rJ I ~ 2 ~,. , , . JAMES M. MINDER, Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-1400 CIVIL TERM MARGARET MARY MINDER, Defendant CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I hereby certify that on this day I served a true and correct copy of the foregoing Petition in the above-captioned action by depositing the same in the U.S. Mail, first class postage pre-paid, addressed to the following persons: Diane Sommers Baker, Esquire P.O. Box 6443 27 S. Arlene St. Harrisburg, PA 17112-0443 Adrienne Johnson, Esquire 453 Buffalo St. Beaver, PA 15009-2003 fc!0-1 Date /~~ Cind~. Koser, Esquire Atto ~ ID #75899 4810 erry Street Harrisburg, PA 17111 Telephone (717) 564-1084 FAX (717) 564-5158 " ~ r' ", , n< vs, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-1400 CIVIL TERM JAMES M, MINDER, Plaintiff MARGA"ET MARY MINDER, Defendant CIVIL ACTION - LAW IN CUSTODY ORDER AND NOW, this day of , 2001, upon consideration of the foregoing attached Petition, a hearing in the above captioned matter scheduled for June 14, 2001 at 9:30 AM is continued. The matter is rescheduled for , 2001 at AM/PM, De terms and conditions set forth in the order of February 13, 2001, apply to the hearing set forth herein. BY THE COURT: J, Wesley Oler, Jr., Judge I ~-I ., e'> vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-1400 CIVIL TERM JAMES M. MINDER, Plaintiff MARGARET MARY MINDER, Defendant g 0 ~ 3;: C- -~ -U (J;: c:: men z PETITION FOR CONTINUANCE ~e AND NOW, comes the Petitioner, Cindy L. Koser, Esquire, and respect~'& ~ represents the following: ~8 ::ll: ;r; c: r:-? ~ ~ 1. Plaintiff, James M. Minder, is represented by Diane S. Baker, Esquire, 2. Defendant, Margaret Mary Minder, is represented by Petitioner, Cindy L Koser, Esquire. 3. The child is independently represented by Adrienne Johnson, Esquire, 4, A hearing in the instant action is set for June 14, 2001 at 9:30 AM. 5. Petitioner is entering the hospital on June 12, 2001 and expects to be hospitalized for several days with discharge anticipated no earlier than June 15, 2001, CIVIL ACTION - LAW IN CUSTODY r~1~ -2J -.-.,rn :_ZlQ ~,:~16 i~:8 ~-o Zrn S ?5 '< 6. Ilttorney Koser has communicated with both Attorney Baker and Attorney Johnson and each concurs in this request for continuance. 7, Because summer visitation is an issue in this case, the parties would like to reschedule this matter at the earliest convenience of the court and counsel. WHEREFORE, Petitioner requests that this Honorable Court continue this matter to and reschedule the hearing at the earliest appropriate date. RESPECTFULLY SUBMITTED: (' l0 II d I Oat Cindy L. Ko Attorney I 0, 75899 4810 Derry Street Harrisburg, PA 17111 PHONE (717) 564-1084 FAX (717) 564-5158 l _ ." ~1' _. ._ r_'F_ VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S, S4904 relating to unsworn falsification to authorities, b/z/rJ I ~ 2 ,I' ~ ~, I ,-" "-,,,--,,-- :1:"'> _ e:~~\..1 ::2. C) ~ ~. ~oo = c: ~ ~,.., ca-<2:_ ;'(/'It"l~ >1.':1' ~ " CD 1-01 ....!. >- It... ""'i "'""i 0 ~ ~ ... > ~ ~ 6'; 00 ~ ~ =""""0 III --.J 0' _. ... r~ ll:l "'3i ':f!-'.. == ~.). = ~ C-"'8CJ'l = -..., <: ...go-,SI I!ll (l> "" = ,j;;,,- '"CClJw~ '>..... ., ,1'> ZI ... --.J ... .... N I Q ... ... f.H = III ~ ~... 1'0< ~.. ..c :: -, ... ('!> .,,"~_, F,;_:'-,:_j'"_"~_-,'" , -I = 01>>)>- ('I> UlQ. III ~., ~ = ;' ('I> ., == = ~ ~:= '"d II) ('I> > -;.. o 0 - OO:r (Jl :+ == <:::l '" <:::l 0 \0 := , ~ N t'"'l Q Q '" ,.Q ~ = -. ., ('I> """'''''' " - y- 'I -"!.~v.,-- ~'r:o'" ~;,""'!~_"''' -_~" - ,,~'o' ,--, x....> ",.... = ~,.., \...J. ::!.o ~ ..... &;'0= ca~ ~ ~ ;'(Ill"l~ :l>;>< ...~~ ~ ... ....,. ~ t"' pPo( ... >~ ~O '(j'J t:D ~ II -"--,,,- -. "1- .'" :J:"""- AI...... - ~..a.~ \....J. ii' 0 ""'3 ,.... C' CO""" c" I-' @~EgQ. "D en ~1:...ooI >~><'i .... la > t"'l ~ ~. ~ &: ~ ~O rn ('0 "1 :J:"""- AI...... - ~ ~~ \....J. oj' C.., 1o?i. C'.. 0 """ c...~1-' @ -< Q.. "D en 1:...o?I >~><'i .... la > t"'l :1 """. ~ &: ~ ~O rn ('0 "1 ~ /.,'" w I"" W ",'" C '~ ~ ~~~: ~ / """,", ~\( 'l~ ~~ ,~', I,' ~, . {ljimwJ.~ {7jakr- ATTORNEY AT LAW POST OFFICE BOX 6443 27 SOUTH ARLENE STREET HARRISBURG, PA 17112-0443 (717) 671-9600 FAX (717) 671-9601 DSBAKERLAW@aol,com Apri16,2001 Cumberland County Prothonotary Courthouse One Courthouse Square Carlisle, P A 17013 RE: Minder v, Minder No, 00-1400 Civil Dear Sir or Madam: Enclosed please find Plaintiff s Pre-Trial Memorandum in the above matter. Please file the original and forward to Judge 01er, Please also return the copy to me in the enclosed self-addressed envelope, Thank you for your cooperation and if you have any questions, please feel free to contact me. DSB :jb Cc: Cindy Koser, Esquire James Minder ''0. JAMES M. MINDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW MARGARET MARY MINDER, Defendant NO. 00-1400 CIVIL TERM ORDER OF COURT AND NOW, this 17th day of April, 2001, upon consideration of Defendant's request for a continuance of the hearing scheduled for April 20, 2001, due to impending surgery of her counsel, the request is granted and the hearing is rescheduled for Thursday, June 14, 2001, at 9:30 a,m" in Courtroom No, 1, Cumberland County Courthouse, Carlisle, Pennsylvania, BY THE COURT, f\-:~ .0\ G 6f' q' ~~ Diane S. Baker, Esq, P,O, Box 6443 27 South Arlene Street Harrisburg, PA 17112-0443 Attorney for Plaintiff Cindy L. Koser, Esq, 4810 Derry Street Harrisburg, P A 17111 Attorney forDefendant 'V1N\fi\lASNr,;::Jd )J'I""'" r-'." /''' :~":"n" .1\11..,,' ,_';:: <-'..~::i/'~I v :rc ~.. -, ".' 'I 'J::J :(.. 1. j L I ,-~ r" ~ tJ X:J:!IC.;'~ "'I ~,-"!'1:-_"_"""-,,_,,,r,_.- -" .-.-, -, -, " .' " '. JAMES M. MINDER, Plaintiff, v. MARGARET MARY KORFF MINDER, Defendant. .... , ... . IN THE COURT OF COMMON FLEAS CUMBERLAND COUNTY,PENNSYLVANIA No. 00-1400 Civil Term Civil Action - Law Praecipe for Appearance To the Prothonotary: Kindly enter my appearance in the above-captioned action on behalf of the parties' min~hild, Sara Minder. /~/.~ ~ p.'. ",," 1'---' . '~-'-~,_'-"_':-~,,_F"_' ,',r__, -'~;_"'f_:""-'_~'-_ ;,"'''''-'! ,"'':-~ -, -," rienne Joh Pa.Id.No. 36241 q. 453 Buffalo Street Beaver, FA 15009-2003 (724) 775-8535 _~r~ ,__~","". , ' .. . K . '. JAMES M. MINDER, Plaintiff, v. MARGARET MARY KORFF MINDER, Defendant. . .... ./ ,"" IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA No. 00-1400 Civil Term Civil Action - Law Certificate of Service I hereby certify that I served a true and correct copy of the foregoing Praecipe for Appearance on the 31st of May 2001 by U.S. Mail, first class, postage prepaid, to the following persons at the following addresses: Cindy L. Koser, Esq. 4810 Derry Street Harrisburg, PA 17111 Diane Sommers Baker 27 South Arlene Street Harrisburg, PA 17112-0443 i-:>o' . ,"~ , __'-r-:: -,_d ,"-'," - . '" .,. ~_'_' 7__'>-~_}"_~!' ~ _ //-------:;::;> -7 ~/? ~/.:;;~ Adrienne JO~g:;;;;;// / .C ", - -'r~ _ "U'''''''..'.__~'''_____ ;-~ -. - .. ,~ - . ,'. " .. , -- " "\. .n.., , . . . ... '_~'hc" ,"~c ,,'n. ..... ." ..-< -- -",- ~-- . " c.. (') 0 ~ ~i C- ..... c= ~1: % m~ ~~ I -0 . .+:" 56 .,-\. ,J ,<0 ." :c=fj ~(') 3 0- ZO 5>g ca Om ~ c..:> ~ N "< -~9lIIl!'-'__--f.r"""_-;'e;..,-, '--"-1'-;'''''--"- ..I!!lllli JAMES M. MlNDER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 00-1400-CIVIL TERM MARGARET MARY KORFF MlNDER, Defendant : IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE Please withdraw the appearance of Patrick G. O'Connor, Esquire, on behalf of the Plaintiff, JAMES M, MlNDER, in the above captioned action, By Patrick G, O'Connor, Esquire 3105 Old Gettysburg Road Camp Hill, P A 17011 PRAECIPE FOR ENTRY OF APPEARANCE PLEASE enter of the appearance of Diane S, Baker, Esquire, on behalf of the Plaintiff, JAMES M. MlNDER, in the above-captioned action, , e S. Bake Esquire 27 South Arlene Street P,O. Box 6443 HalTisburg, PA 17112 (717) 671-9600 DATE: S-j7- 00 . . ~~ ~ . (') c:> ~ c 0 ~ :x .-J "'1.").(:D ~,CIII :J:-n mrn --< en p:: 2:-.0 ..,,--'}m Zr;:; .~,o ({),-;;~ ,:::> [')6 -<~~. ~ , ~G -0 .-=0 :!i J>C' :x ?5-U ':.",,(-' :;-"'6 ~ .-c-rn >c: .. ~ ,,,- N ~ =< - ~'.' '., ~'''o ,~ ",~Ii$!!-1'j1~Jlll!~ ~~ ~, _,<,'~, ~_~.u '!fll.'HW.'I'l1H11'<'''''''''''T''iI'~'1'-'iW,~';j'li/i\'i';j!'','Cf'ii'f!J;.r,~",,,!I'''''''l~~"lif!i:~~t>ll!8'j"!~\'~;!.~!aty"""r_'fWII~!!l '~I~ , " . JAMES M. MINDER, Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : NO. 00-1400 CIVIL TERM : MARGARET MARY KORFF MINDER, Respondent : CIVIL ACTION - LAW : IN CUSTODY aIDER OF COURT AND ISDi, this ts1l day of VV1z 1 consideration of the attached CUstody Conciliation and directed as follows: , 2000, upon Report, it is ordered 1. The FatheJ:', James M. Minder, and the Mother, Margaret Mary Korff Minder, shall have shared legal custody of Sara Beth Minder, born October 27, 1983. Each par:ent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. The parties shall have physical custody of the Child in accordance with the following schedule: A. During the Summer 2000, the Father shall have custody of the Child from Sunday, June 18 through Saturday, July 1, from Sunday, July 9 through Saturday, July 29, and from Sunday, August 6, through Saturday, August 19. The Mother shall have custody of the Child during the Summer 2000 at all times not otherwise specified for the Father under this provision. The Father shall provide transportation for the exchanges of custody on June 18 and July 1. Unless otherwise agreed between the parties or the Father agrees to provide the transportation, the parties shall make arrangements for the Child to travel by train for the remaining exchanges of custody during the Summer 2000. The Mother shall be responsible to pay for the round trip train ticket for exchanges in July and the Father shall be responsible to pay for the round trip train ticket for the exchanges in August. B. During the school year, the Father shall have custody of the Child as follows: Labor Day weekend from September 2 through September 4. Columbus Day weekend from October 7 through October 9. Thanksgiving break: from November 22 or 23 (depending on the train schedule) through November 27. --. .1""""""'] ILi~"'-~ ~, ~"~lISM!l!l!i>~il!Ma;i"!l~~lH'.lkW" " . ,~..~ " ".'._;1.;"' ~,-- . -, '-. ~"~" 'c .;,... ~ .< - " " ~ -I ~ I :1 ii '.1 i FILED-OfFlCE OF iHE PROTHONOTARY 00 MAY 16 Pt-\ 3: 12 CUIV18ERL!\HD COUNlY PENNSYLVANIA h . Christmas holiday break from December 26 through January 1. Dr. Martin Luther King weekend (January). President's Day weekend (February). Easter school break (March or April). Memorial Day weekend (May). In 2000, the Father shall provide transportation for the Child to and from the Mother's residence over the Memorial Day weekend. The exact days (Friday evening or Saturday morning) and times for the foregoing holiday periods of custody shall be arranged by agreement of the parties based on the train schedule. In the event the parties are not able to agree on exchange times, the pick up times shall be the train departure time which is closest to 10:00 a.m. and the return time shall be the train departure time which is closest to 7:00 p.m. Each party shall be responsible to pay a portion of the Child's train fare for exchanges of custody during the school year in proportion to that party's income as allocated in percentage form in the Child Support Order. 3. The parties agree that the Child shall participate in counseling with the Father, with the counseling sessions to be scheduled during the Father's periods of custody. 4. If the Child wants to go to church during the Father's periods of custody, the Father shall provide transportation and ensure that the Child is able to attend Mass. 5. 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. Each party shall ensure that third parties comply with this provision as well during his or her periods of custody. 6. This Order is entered pursuant to an agreement of the parties at a CUstody conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J. cc: Diane S. Baker, Esquire - Counsel f Father Cindy L. Koser, Esquire - Counsel for Mother ~~ ,5-/t ~OO ~K3 JAMES M. MINDER, Petitioner . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . : vs. : NO. 00-1400 CIVIL TERM : MARGARET MARY KORFF MINDER, Respondent : CIVIL ACTION - LAW : IN CUSTODY CUSTODY CCNCILIATIOO SUMMARY REPORT IN ACOORDANCE WITH CUMBERLAND CXXlN'.lY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned CUstody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Sara Beth Minder October 27, 1983 Mother 2. A Conciliation Conference was held on May 10, 2000, with the following individuals in attendance: The Father, James M. Minder, with his counsel, Diane S. Baker, Esquire, and the Mother, Margaret Mary Korff Minder, with her counsel, Cindy L. Koser, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Pate /I1a g L~, a-oon ~ CUstody Conciliator >- a:: <( C'~~ g;'~ C);::.:, c.:..~ ~:-- L.L! ._-~ " , '...L" . ~ JAMES M. MINDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. : NO. 00-1400 CIVIL TERM : MARGARET MARY KORFF MINDER, : CIVIL ACTION - LAW Defendant . IN CUSTODY . ORDER OF CXlURT fl AND lOI1, this \ S. day of consideration of the attached Custody and directed as follows: FcL f"~ Conciliation eport, , 2001, upon it is ordered A Hearing is scheduled in COurt Room # / , of the Cumberland County Court House, on the ~ i1t day of ~ j.J , 2001, at /: 30 o'clock, p.m., at which time testimony will be taken. For . purposes of the Hearing, the Father, James M. Minder, shall be deemed to be the moving party and shall ~oceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who are expected to testify at the Hearing, and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten (10) days prior to the Hearing date. ..:;1' c:; j?:: :7 ~<J'" \"~)7 U<i" C)~ CO Z ..2: , iJw ,~{1- U ...::J :~ ~ ("0") 12:-:: t ~... C, co \......5 '-'- .~ ~ cc: Diane S. Baker, Esquire - Counsel for Father Cindy L. Koser, Esquire - COunsel for Mother . . ~D\ tfo~~ . \ . . JAMES M. MINDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : NO. 00-1400 CIVIL TERM . . MARGARET MARY KORFF MINDER, : CIVIL ACTION - LAW Defendant . IN CUSTODY . PRIOO JUDGE: J. wesley Oler, Jr. CUS'lOOY CO'iCILIATICfi SUMMARY REPCRT IN ACXXIIDANCE WITH CUMBERLAND COONTY RULE OF CIVIl[, PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRE!ilTLY IN CUS'lOOY OF Sara Beth Minder October 27, 1983 Mother 2. A Conciliation Conference was held on February 7, 2001, with the following individuals in attendance: The Father, James M. Minder, with his counsel, Diane S. Baker, Esquire, and the Mother's counsel, Cindy L. Koser, Esquire. The Mother, Margaret Mary Minder, who resides in Beaver, Pennsylvania was not present at the time of the COnference at 9:30 a.m. However, the Mother, the parties' daughter and an attorney who may enter her appearance on the daughter's behalf in this matter, appeared at the Conciliator's office at 1:00 on the day of the Conference, apparently due to a miscommunication between the Mother's counsel, the Mother and the Child'S counsel. 3. The Father filed this Petition for Contempt alleging that the Mother had failed to provide information concerning the Child's diagnosis and treatment from the Child's physician. The Father also raised the issue of surrnner custody arrangements at the Conference noting that the prior Order only provided arrangements for the surrnner of 2000. An agreement was not reached at the Conference and it will be necessary to schedule a Hearing in this matter. 4. The Father's position on custody is as follows: The Father stated that the Mother failed to provide information pertaining to the 17 year old Child's medical diagnosis and treatment from her current physician as required by this Court's prior Order dated May 15, 2000. The Father does not accept the Mother's assertion that the Child wishes to keep those records confidential as they pertain to reproductive health. The Father rejected, as a resolution of the contempt issue, the Conciliator's recommendation of a modification to the Order which would require the 0__ ~_ , . Mother to authorize the physician to release any records pertaining to the Child to the extent permissible by law. Instead, the Father requests the scheduling of a Hearing to address the recovery of expenses he has incurred in his efforts to obtain the medical records. In addition, the Father requests that a summer custody schedule be established for 2001 under which either the parties would share custody on an alternating biweekly basis or the Father would have custody of the Child for the entire summer to enable the Child to maintain employment. 5. The Mother's position on custody is as follows: The Mother does not believe she has violated the terms of this Court I s Order pertaining to sharing medical information. According to the Mother, the daughter wishes her medical records to remain private and argues that records with regard to reproductive rights are confidential under federal statutes. with respect to summer custody arrangements, the Mother's counsel proposed that the arrangements be made between the Father and the Child as the Child will be 18 years of age in October and should be able to determine where she spends her summer. According to the Mother, the relationship between the Child and the Father is extremely strained and difficult at this time and the Child does not wish to live with the Father during the summer or for any extended period. The Child may have separate counsel enter an appearance on her behalf for the purpose of these proceedings. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing. It is expected that the Hearing will require at least one-half day and, if possible, should be scheduled in the afternoon to accorrnnodate the Mother and Child's travel time from Beaver, PA. It is anticipated that the Child will be represented by separate counsel at the Hearing. Date ~ ~ ;;'001 Da~ Custody Conciliator .~ ~'" ,. " ,. Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES M. MINDER, vs, MARGARET MARY KORFF MINDER, Respondent CIVIL ACTION - LAW NO. 0-0 _ / 'I (J1) ~ J Lv'- ORDER OF COURT AND NOW, 'OIl'" 2000, upon consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before ~::" ~, Esquire, the conciliator, at 3CI W. \---\'c1\\'\' ~\, ) \-\:~\ (\'o~ ' Pennsylvania, on \rJe6 the ~day of ~\ ' 2000, at \ \ '. (j() o'clockO. ,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. Either party may bring the child who is the subject ofthis custody action to the conference, but the child's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order, FOR THE COURT, By ~(\hN\.sAl~\~~~I% Custody Conciliator l i)~ 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 ~~ lililii" -'Iiiili ,[ -~',-~- -...- .~ '~'~~W1;~j~~/I!;!_rili:~ -~ ''(''',., ~ --"-'- 'C, , , 11[',: !j 1'1 :1 'I 1'1 Ii ii i ;i ,i II 'i i" ! I,i I:' I ; I ,I I! Ii !! ~ r{,C'f' ~f" '.., r ,..c,J-('ffil"/::- u ~ ! :---rr i:;,''){!1~1,~i'~v'' '.,. "JNOli'\RY 00 tHR 22 P1112: .15 CUMBEFiL.AN" C PENNS\lVAN~UNTY J~O?OCJ &;/- ~ ~ -$:7/ (J~ J.,;;,)'C!P 7!~ ~ ~ _~. 3'C)0I.C)t7 I'~ ~ -$'~~ Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES M. MINDER, vs, MARGARET MARY KORFF MINDER, Respondent CIVIL ACTION - LAW NO, ()1J - 1'f(Jl) CluJ l.e-.. CUSTODY PETITION AND NOW, Petitioner, James M. Minder, by and through his attorney, Q, Patrick O'Connor, Esquire, files a Petition For Custody of which the following is a statement: 1, Peititioner is James M, Minder, Father, who currently resides at 713 Harding Street, New Cumberland, Cumberland County, PA 17070, 2, Respondent is Margaret Mary Korff Minder, who currently resides at 713 Harding Street, New Cumberland, Cumberland County, PA 17070, 3, Plaintiff seeks custody of the following child/children: Name Present Address Date of Birth Sara Beth Minder 713 Harding Street New Cumberland, PA October 27, 1983 4, The child was not born out of wedlock. 5, The child is presently in the custody of the Mother and Father who currently reside at 713 Harding Street, New Cumberland, Cumberland County, Pennsylvania, Mother and Father are separated, although both currently reside at the marital residence, 6, During the past five (5) years, the child resided with the following persons at the following addresses: . """ Persons Address Date James M, Minder 78 Sunnybrook Ave, 1988 to 5/10/96 Margaret Mary Korff Minder Aliquippa, PA 15001 Daniel Minder Margaret Mary Korff Minder 3303 7th Avenue 5/1 0/96 to 10/20/97 Beaver Falls, PA 15010 James M, Minder 1001 Roman Knoll Dr, 10/20/97 to 11/20/97 Margaret Mary Korff Minder Town & Country Estates Daniel Minder Harrisburg, PA 17109 James M, Minder 713 Harding Street 11/20/97 to present Margaret Mary Korff Minder New Cumberland, PA 17070 Daniel Minder 7, The Mother of the child is Margaret Mary Korff Minder, whose current address is 713 Harding Street, New Cumberland, Cumberland County, PA 17055, 8, The Father of the child is James M, Minder, who currently resides at 713 Harding Street, New Cumberland, Cumberland County, PA 17055, 9, The parties are married, but are living in a separated manner, 10, The relationship of Petitioner to the child is that of Father, Petitioner currently resides with the following persons: Person Relationship Mary Korff Minder Daniel Minder Sara Beth Minder Wife Son Daughter -~ - - "-, ,,- "' 11, The relationship of Respondent to the child is that of Mother, Respondent currently resides with the following persons: Relationship Person James M, Minder Daniel Minder Sara Beth Minder Husband Son Daughter 12, Petitioner and Respondent have not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 13, Petitioner and Respondent have no information of a custody proceeding concerning the child pending in a court of this Commonwealth, 14, Petitioner and Respondent do not know of a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the child, 15. Petitioner is concerned and has reason to believe that Respondent will take the minor child to live in Pittsburgh, Pennsylvania, without adequate regard for the child's education and schooling needs, thereby disregarding the best interests of the child, 16, The best interests and permanent welfare of the child will be served by granting the relief requested, 17, Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the children have been named as parties to this action, ," ", , WHEREFORE, Petitioner respectfully requests that this Honorable Court enter an Order granting custody to Petitioner, Respectfully submitted: By: G,. atrick O'Connor, Esquire 3105 Old Gettysburg Road Harrisburg, PA 17011 717-737-7760 Attorney I.D, #64720 ATTORNEY FOR PETITIONER DATE: 3/7 /~O ATTORNEY VERIFICATION I, G, Patrick O'Connor, Esquire, hereby certify that I am the attorney for the Petitioner and that the information contained in the herein petition is based on information give to me by the Petitioner and is true and accurate to the best of my knowledge, information and belief, G. Patrick O'Counor, Esq, DATE: 3/7/iJ{) , , ~I" - ,- . . CERTIFICATE OF SERVICE I hereby certify that I have, this day, served the herein Custody Petition to the party indicated below by depositing same in the United States mail, postage prepaid, at Camp Hill, Pennsylvania: Margaret Mary Korff Minder 713 Harding Street New Cumberland, PA 17070 DATE: 3/'i/t;() A4~~ /G, Patrick O'Connor, Esquire Attorney No, 64720 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 737-7760 Attorney for Petitioner > . , JAMES M. MINDER, : IN THE OOORT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-1400 CIVIL TERM . . MARGARET MARY KORFF MINDER, . CIVIL ACTION - LAW . Defendant : IN CUSTODY ORDER OF COORT AND roq, this I c" t);, day of consideration of the attached Custody and directed as follows: DS..locr Conciliation Report, , 2000, upon it is ordered 1. The prior order of this Court dated May 15, 2000 shall continue in effect as modified by this order. 2. The Father shall have custody of the Child from Friday, October 6, 2000, between 7:00 p.m. and 10:00 p.m. through Monday, October 9, 2000, at 12:00 noon. The Mother shall be responsible to provide all transportation for this period of custody. The Mother shall contact the Father if she is unable to have the Child at the Father's residence by 10:00 p.m. on Friday evening due to traffic or other unavoidable circumstances. 3. The Father shall have additional periods of custody with the Child from November 11 through 12, 2000 (for which the Father shall be responsible to provide transportation) and from March 10 through 11, 2001, for which the Mother shall be responsible to provide transportation. 4. Unless otherwise specified in this order as the Mother's responsibility for providing transportation, the Father shall purchase train tickets for the Child at the train departure time which is closest to 10:00 a.m. at the beginning of the period of custody and at the return time which is closest to 7:00 p.m. on the last day of the period of custody. Within 10 days after each period of custody, the Mother shall reimburse the Father for the Child's train fare in an amount proportionate to the Mother's income as allocated in percentage form in the Child support order. The parties shall cooperate in contacting each other two days in advance of each exchange of custody to confirm the transportation arrangements. 5. Within 10 days of the date of this order and on an ongoing basis thereafter, the Mother shall provide to the Father the name and telephone numbers of all physicians and counselors evaluating and providing treatment to the Child. In addition, the Mother shall provide all information which she obtains from Dr. Edwin Cheek concerning the Child's diagnosis and treatment. ~- ._"lIIi&iIl" ..J .....'~.-~'''"''''ff,_ ~6lalilWl~' -~'liiliIlIlllMlll~ ""'~:- '" ",.;,," ., ,- ,~~ ~Iii" ~""r '. ~. nL~ ~, F:LL~n.~ornCE 7,~J ',,~ ."h~>"r" I,...., ""'-\r\Y : ";; ,'-: ";:), ':'-'J':_.Y\I~} il,!! 00 OCT J 7 .4.'1 iJ: ld Cu" /,',\',;qj:.j:::,ll !.:hiU"'~ ""'''/' 'f\/'fY L...., l..1~", l-,,-,U. I PENNSY/JI,..WfA . , 6. within 10 days of the date of this Order and on an ongoing basis thereafter, the Mother shall provide to the Father copies of the Child I s school calendar and report cards. BY THE COURT ;}}G4 cc: Diane S. Baker, Esquire - Counsel Cindy L. Koser, Esquire - Counsel J. r Father ~ \ for Mother f\~ C~ 11.00 \0' ~ i-j -'-1-' JAMES M. MINDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. : NO. 00-1400 CIVIL TERM . . MARGARET MARY KORFF MINDER, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . PRICR JUDGE: J. Wesley OIer, Jr. CUS'.l'ODY CXBCILIATICtiI SUMMARY REPCRT IN ACCXJRDANCE WITH a::JMBERLAND CXJIJNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN OUSTODY OF Sara Beth Minder October 27, 1983 Mother 2. A Conciliation Conference was held on October 3, 2000, with the following individuals in attendance: The Father, James M. Minder, with his counsel, Diane S. Baker, Esquire, and the Mother's counsel, Cindy L. Koser, Esquire. The Mother, who resides in Beaver, Pennsylvania, participated in the Conference with her counsel by telephone. 3. The Father filed this Petition for Contempt primarily concerning a period of partial custody which he missed over the Labor Day weekend due initially to some confusion with the train ticket arrangements but ultimately due to alternative plans made by the Child for the weekend. The mandatory nature of the custody schedule was discussed at length at the Conference and it is clearly understood that no adjustments may be made to the May 15, 2000 Custody Order except by agreement of the parties or Court Order. 4. The parties agreed to entry of an Order in the form as attached providing makeup custody periods for the Father and establishing a more definite transportation schedule for exchanges of custody. It should be noted that the Mother objects to the provision requiring her to provide transportation for the March 2001 makeup weekend, which is the recommendation of the Conciliator. () lJon J..bJ Date '1 ~ ( fa..,. iL~ Dawn S. Sunday, Esquir Custody Conciliator \.--- .1- -~-- " - . " - . JAMES M. MINDER PLAINTIFF V, MARGARET MARY KORFF MINDER DEFENDANT IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-1400 CIVILACTlONLAW IN CUSTODY ORDER OF COURT AND NOW, this 15th day of September ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on the ~ day of October ,2000, at 3:00 p.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 entry of a temporary or permanent order. FOR TIlE COURT, By: Isl 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 HAVE 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 ~~~ 'I' " ~ ". .iiI""" , I~~ -- -, ~ ~ ..-........~-.u...l!IIlllil!lliill!liliil1l~_'-'" ._,,' - " ~ Hl1=T)--Qi:fICE OF 1>'~'"""',-<:',"r'~';'.~NOTARY 00 SEP 19 Pi! 3: 12 CUM8ERL4i~O COUNTY PENNSYLVANIA 9/faJ M- tW~;;V~ 4&4 1/f-CtJ 7ln:u,~ -z a:4 /c~ tj'/f-?J/J ~ 1n~Z; q ~ ~ ' _ .. 1 .. . ," ,,, , ^ ~, ,- ""~" ,,- "# JAMES M, MINDER, P1aintiffIPetitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 00-1400 -CIVIL TERM MARGARET MARY KORFF MINDER, Defendant/Respondent CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, , 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 , 2000, 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 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 TIllS 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 TWO LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 1-800-990-9108 ,.;~ ~ , JAMES M, MlNDER, P1aintifflPetitioner, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-1400 CIVIL TERM MARGARET MARY KORFF MlNDER, Defendant/Respondent : CIVIL ACTION - LAW : CUSTODY ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the Petition for Contempt, a hearing is hereby scheduled for the day of , 2000, at m, BY THE COURT: J, ~~'''''''''''.~, - '0___",'''''''''' JAMES M. MINDER, PlaintifflPetitioner, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 00-1400 CIVIL TERM MARGARET MARY KORFF MINDER, DefendantJRespondent CIVIL ACTION -LAW CUSTODY PETITION FOR CONTEMPT AND NOW, comes Petitioner, James M, Minder, by and through his attorney, Diane S, Baker, Esquire, and files this Petition for Contempt as follows: 1. Petitioner, James M, Minder, is an adult individual residing at 713 Harding Street, New Cumberland, Pennsylvania 17070, 2, Respondent, Margaret Mary Korff Minder, is an adult individual residing at 400 Buffalo Street, #4, Beaver, Peunsy1vania, 15009. Respondent is represented by Cindy Koser, Esquire. 3, The parties are the natural parents of the minor child Sara Beth Minder, born October 27, 1983, age 16, 4, On May 15,2000, following a Custody Conference with Dawn S, Sunday, Esquire, the Honorable Wesley 01er, Jr" issued a custody order, a copy of which is attached hereto as Exhibit A. 5, The Order provides that Respondent has primary physical custody and Petitioner has partial physical custody to include approximately six (6) weeks during the sununer along with holiday weekends and school vacations during the school year, In - "-, - .. particular, the Order provides that Petitioner shall have custody of the child for Labor Day weekend, 6. Pursuant to the order, transportation shall be by train, 7, On or about Tuesday, August 29, 2000, Petitioner corresponded with the child via e-mail and confirmed that he would send her a ticket for the train that was to depart on Friday, September 1, 2000, at 4:53 p,m, Petitioner then purchased the ticket but realized that he could instead purchase a ticket for Sara that could be picked up at the train station upon departure, The cost of the ticket was $102, On Thursday, September 1, 2000, Petitioner corresponded with Sara via e-mail and advised her that the ticket was waiting for her at the train station and that he would meet her when she arrived in the Harrisburg area, 8, On Friday, September 1, 2000, Petitioner called Respondent's residence at approximately 3:30 p,m, to confirm that the travel plans were in order. He spoke to Sara who said that she wasn't coming because she did not have a ride to the train station because her mother was working, Petitioner then called Respondent at work and suggested that Sara take the train the next morning at 8:30 a,m, instead but Respondent said she would be working then also so could not take her to the train station, Petitioner next suggested that he would drive to Beaver either that evening (Friday) or the next morning (Saturday) and pick Sara up at her residence, At this point Respondent told Petitioner that Sara had no intention of coming to visit him but instead had made plans for the weekend including a pool party so he should not bother making the trip, 9, Pursuant to the custody order dated May 15, 2000, the parties share legal custody of the child, Some time ago the child's family doctor prescribed a one month supply of birth control pills to control an irregular menstrual cycle with instructions that the ~- ~. ~~ child then be re-examined, During the Memorial Day visit Petitioner became aware that Sara had never been re-checked by the family doctor but was still taking the birth control pills through a prescription from doctor from Florida who had never examined the child, 10, On June 2, 2000, through a letter sent to Respondent's counsel, Petitioner inquired as to why the child was still taking the prescription, A second request for information about this medical matter was sent to Respondent's counsel on June 21, 2000, Copies of both letters are attached hereto as Exhibit B, To date, Petitioner has not been provided with any information about this medical issue, 11. Petitioner requests that Respondent be held in contempt for denying him visitation with the child and denying him information about the child's medical care, 12, As a result of Respondent's contemptuous behavior Petitioner has incurred attorney's fees in the amount of $400 for correspondence with counsel and preparation and filing of the within petition, Petitioner also incurred a $30 cancellation fee for the unused train ticket. WHEREFORE, Petitioner requests this Honorable Court issue an order fmding the Respondent in contempt and ordering sanctions to include attorney's fees and costs and further directing make-up visitation time with the child, qHOO , e S, Baker, Esquire Supreme Court ill #53200 27 South Arlene Street Post Office Box 6443 Harrisburg, P A 17112-0443 (717) 671-9600 DATE: ~" - ~1 ~ ...... - " VERIFICATION I, James M, Minder, verify that the statements made in the foregoing Petition are true and correct to the best of my knowledge, information and belief, I understand that the statements herein are made subject to the penalties of 18 Pa,C,S, Section 4904 relating to unsworn falsification to authorities, '<.... ~~~ ~- . ~..,.., "-, CERTIFICATE OF SERVICE I hereby certifY that on this ~ day of September, 2000, a true and correct copy of the foregoing document was served on the following person by United States Mail, postage prepaid, addressed as follows: Cindy L. Koser, Esquire 4810 Derry Street Harrisburg, P A 17111 , e S, Baker, Esquire Supreme Court ill 53200 27 South Arlene Street Post Office Box 6443 Harrisburg, P A 17112-0443 (717) 671-9600 ~~,,,. 1-0 . 0' )- vl'{ dlq/~a JAMES M. MINDER, petitioner : IN THE OOURT OF COMMOO PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. ~1400 CIVIL TERM : MARGARET MARY KORFF MINDER, Respondent : CIVIL ACTIOO - LAW : IN CUSTODY aIDER OF 00lJRT AND lOf, this 11+h day of consideration of the attached Custody and directed as follows: , 2000, upon it is ordered 1. The Father, James M. Minder, and the Mother, Margaret Mary Korff Minder, shall have shared legal custody of Sara Beth Minder, bom October 27, 1983. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's gener.<\l well-being including, but not limited to, all decisions regarding her health, education and religion. 2. The parties shall have physical custody of the Child in accordance with the following schedule: A. Dliring the Summer 2000, the Father shall have custody of the Child from Sunday, June 18 through Saturday, July I, from Sunday, July 9 through Saturday, July 29, and from Sunday, August 6, through Saturday, August 19. The Mother shall have custody of the Child during the Summer 2000 at all times not otherwise specified for the Father under this provision. The Father shall provide transportation for the exchanges of custody on June 18 and July 1. Unless otherwise agreed between the parties or the Father agrees to provide the transportation, the parties shall make arrangements for the Child to travel by train for the remaining exchanges of custody during the Summer 2000. The Mother shall be responsible to pay for the round trip train ticket for exchanges in July and the Father shall be responsible to pay for the round trip train ticket for the exchanges in August. B. During the school year, the Father shall have custody of the Child as follows: Labor Day weekend from September 2 through September 4. Collnnbus Day weekend from October 7 through October 9. Thanksgiving break from November 22 or 23 (depending on the train schedule) through November 27. ,.,,,_~__ ,"'1._ -~-~~ - ~~~ ~ - . Christmas holiday break from December 26 through January 1. Dr. Martin Luther King weekend (January). President's Day weekend (February). Easter school break (March or April). Memorial Day weekend (May). In 2000, the Father shall provide transportation for the Child to and fran the Mother's residence over the Memorial Day weekend. The exact days (Friday evening or Saturday morning) 'and times for the foregoing holid~y periods of custody shall be arranged by agreement of the parties based on the train schedule. In the event the parties are not able to agree on exchange times, the pick up times: shall be the train departure time which is closest to 10:00 a.m. and the return time shall be the train departure time which is closest to 7:00 p.m. Each party shall be responsible to pay a portion of the Child's train fare for exchanges of custody during the school year in proportion to that party's income as allocated in percentage form in the Child Support Order. 3. The parties agree that the Child shall participate in counseling with the Father, with the counseling sessions to be scheduled during the Father I s periods of custody. 4. If the Child wants to go to church during the Father's periods of custody, the Father shall provide transportation and ensure that the Child is able to attend Mass. 5. Neither party shall do or say anything which may estrange the Child fran 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. Each party shall ensure that third parties comply with this provision as well during his or her periods of custody. 6. This Order is entered pursuant to an agreement of the parties at a CUstody Conciliation Conference. The parties may modify the provisions of this Order by llRltual consent. In the absence of llRltual consent, the terms of this Order shall control. :~~3~:~:" :::~~~~~.;~.. ~~~'.f;~\; ~~:C':;{~ , In "0..1.,",", '"",:<~ ; !i'.o "",-, ..,",. "1" nand ' '. _, '" ~,I,. ~ .c" "! j and "l"he seai ,..J ~;);d r"'.r-t .~ ~,.~ l,:~le Da . --, ........, ,",'."Iu, 111 0 I..." , j r. T~:~t of... .....ay-, ...<1.0 ... . . . ' p;~ honot~~ ...4j cc: Diane S. Baker, Esquire - Counsel Cindy L. Koser, Esquire - Counsel BY THE COURT, for Father for Mother !~(l,~_ ~~I ." .~~. -;,~. , . {lJianbtJommRJ<& {7JaAer- ATTORNEY AT LAW POST OFFICE BOX 6443 27 SOUTH ARLENE STREET HARRISBURG, PA 17112-0443 (717) 671-9600 FAX (717) 671-9601 June 2, 2000 Cindy L. Koser, Esquire 4810 Derry Street Harrisburg, P A 17111 RE: Minder v, Minder Dear Cindy: I received a caIl from my client yesterday because he is concerned about certain medical treatments that are being administered to Sara, SpecificaIly, as is fairly common with teenage girls, Sara has problems with an irregular menstrual cycle, My client understood that some time ago Sara's family doctor gave her a one month supply of birth control pills with instructions to return in a month for a re-check. Unfortunately when the first prescription ran out Mrs, Minder canceled the scheduled follow-up appointment and had a doctor who lives in Florida rewrite the prescription, This doctor is related to your client and for whatever reason issued the prescription long distance without ever examining or otherwise treating Sara who continues to take the pills without medical monitoring, My client became aware ofthe situation when Sara brought the prescription from the Florida doctor with her when she visited last weekend and told my client he had to have it filled because she was out of pills, This put him in the uncomfortable position of having to fiIl what he feels is not only an illegal prescription done without a medical exam but more importantly a prescription that may not be in Sara's best interest. Only proper medical care including the recommended follow-up visit would determine if the medication was appropriate or perhaps it is masking a problem that needs altemate treatment. My client recognizes that this is likely a sensitive issue with Sara and while he does not want to embarrass her he is concemed about the medical and legal ramifications of her taking a prescription without proper medical care. As you are aware, our clients share legal custody of Sara and therefore my client is certainly within his rights to be informed and have input into Sara's medical care. I would appreciate it if you would review this situation with your client and advise me what steps are being taken to assure that Sara's medical needs are being properly met. I look forward to hearing from you, DSB:jb . . ~"""""""'" q;~J~ {lJaAer- . ATTORNEY AT LAW POST OFFICE BOX 6443 27 SOUTH ARLENE STREET HARRISBURG, PA 17112.Q443 (717) 671-9600 FAX (717) 671-9601 June 21, 2000 Cindy L. Koser, Esquire 4810 Derry Street Harrisburg, P A 17111 RE: Minderv. Minder Dear Cindy: I received a call from my client who is concerned that Mrs. Minder is now hinting that she wants to move back into the residence either on a permanent or temporary basis. James is not sure whether she is actually looking for a reconciliation or merely is seeking a convenient place to stay when she is in the area, but he is adamantly opposed to the idea, If necessary, we will file a Petition for exclusive possession, as the hostilities that exist between the parties can only cause harm to the minor child, who, as you are aware, is spending a significant amount of time at her father's this summer. Jim also is concerned that mother's appearance at his residence will only serve to undermine his relationship with the minor child. Please discuss this with your client and confirm that she will not attempt to access the residence. If I don't hear from you in the next ten days, I will have no choice but to file an exclusive possession in order to avoid a potentially dangerous situation. I am also awaiting a response to my letter of June 2, 2000 conceming Sarah's medical care, which my client continues to be uninformed about. Thank you for your attention, and I look forward to hearing from you. DSB:1sf Cc: James Minder ~~ --"-,' JAMES M. MINDER, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-1400 CIVIL TERM MARGARET MARY KORFF MINDER, Defendant, CIVIL ACTION - LAW CUSTODY PLAINTIFF'S PRE-TRIAL MEMORANDUM AND NOW, comes the Plaintiff, James M, Minder, by and through his attorney, Diane S, Baker, Esquire, and files his Pre-Trial Memorandum as follows: 1. Statement of Facts, This action pertains to custody of the minor child Sara Beth Minder, born October 27, 1983, age 17, The parties, James Minder and Margaret Minder, separated in March, 2000, when Defendant moved with the child to Beaver County, Peunsy1vania, Plaintiff inunediate1y filed a custody action contesting the move and an order was entered, dated May 15, 2000, granting him shared legal and partial physical custody to include the majority of the sunnner and school vacation times, Since the entry of that order, Plaintiff has had to file two contempt actions because of missed visits and Defendant's refusal to provide Plaintiff with information about the child's medical care or education, The issues before the court include the current custody schedule, primarily Plaintiffs request that the child spend the sunnner of 2001 with him, Also before the court is the issue of contempt for missed visits, and Defendant's failure to provide Plaintiff with copies of report cards, medical records, and in general the Defendant's concerted effort to alienate the child from her father. ",- . I -, -~ ''''- :---_'"_ 'v F-,f,--:',,- _ --1"<"'_'_ . ',' ,,~-, ,_,', u _<" ",,,. _, , .' 2, Summary of Witnesses. Plaintiff will testifY on his own behalf concerning the matters raised in the contempt petitions filed on or about September 8, 2000, and December 26, 2000, In general, it will be Plaintiffs testimony that Defendant has caused visits between Plaintiff and the child to be missed and also Defendant has refused to include Plaintiff in any legal custody decisions affecting the child, Plaintiff has not been provided with medical records or school records, despite numerous requests and an Order, dated October 16, 2000, specifically directing that medical records and report cards be provided to Plaintiff, Plaintiff will also offer testimony about the costs he has incurred as a result of Defendant's contemptuous behavior including unused train tickets, lost wages and attorney's fees, 3. Conclusion, Plaintiff respectfully requests that this Honorable Court issue an order directing that the minor child spend the summer of 2001 with him and that Defendant be found in contempt and directed to pay Plaintiffs costs and attorney's fees, ;pr , /- fJ __Diane S, Baker, Esquire Attorney for Plaintiff 27 South Arlene Street Post Office Box 6443 Harrisburg, P A 17112-0443 717-671-9600 ~ ~ " '.'.'"'' "',". ','c"-'!'.,",_"", ,,- ,~ ~ -- --~, '---" " "~- ,-. ""hc'-_~-'- - CERTIFICATE OF SERVICE I hereby certifY that on this 6th day of April, 2001, a true and correct copy of the foregoing document was served on the following person by United States Mail, postage prepaid, addressed as follows: Cindy L. Koser, Esquire 4810 Derry Street Harrisburg, PAl 7111 Respectfully submitted, , e S, Baker, Esquire Supreme Court ill 53200 27 South Arlene Street Post Office Box 6443 Harrisburg, P A 17112-0443 (717) 671-9600 '~ - 1-- ,"'~ ,", V,., '-"-- ,- JAMES M. MINDER PLAINTIFF V. MARGARET MARY KORFF MINDER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-1400 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 3rd day of January, 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on the 23rd day of January, 2001 , at 9:30 a.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: Isl Dawn S. Sunday. ES~ Custody Conciliato~ 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 HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORlli BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,~_~_,o/''"' _~ Ii>>'""' -~.~ ~~!li'i'~1iti'<iIi:t!.I~..Iif,~__~ ~~.. .. -'F'. , -1 ' r"~~:'\Kn/J:rr' 01 I,C -8 I d," {Jt:; :): ~!h . " ""'" C! i,1t~'-'I-:- -', '. UII'ICL:rj (,;\1;-') {'-i"'.u'/I"ry _ J >... \. _I' ' PENNSYLVANV\ ,; l'f,CJI 1a/,.C#J7 hlJ/ ~ 4' ~ l.f'll?! ~ ~ ?;;;~ ~ l<f'tJtl C~",~ -h ~~~ . '. ,., , ~ H l:~ L-" ~i c ~~ [' I , l Ii Ii [I I, f il 1; It ! I Ii ~ , , JAMES M. MINDER, Plaintiff/Petitioner, : IN THE COURT OF COMMON PlLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-1400 CIVIL TERM MARGARET MARY KORFF MINDER, DefendantJRespondent CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, , 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 , 2000, 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 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 TillS 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 TWO LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 717249-3166 1-800-990-9108 ;;;'~,;~",,"'>~--=, 1 ~~~--~ ~.,., ~.....l' JAMES M. MINDER, Plaintiff/Petitioner, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-1400 CIVIL TERM MARGARET MARY KORFF MINDER, DefendantJRespondent CIVIL ACTION -LAW CUSTODY PETITION FOR CONTEMPT AND NOW, comes Petitioner, James M, Minder, by and through his attorney, Diane S, Baker, Esquire, and files this Petition for Contempt as follows: 1. Petitioner, James M, Minder, is an adult individual residing at 713 Harding Street, New Cumberland, Pennsylvania 17070, 2, Respondent, Margaret Mary Korff Minder, is an adult individual residing at 400 Buffalo Street, #4, Beaver, Pennsylvania, 15009, Respondent is represented by Cindy Koser, Esquire, 3, The parties are the natural parents of the minor child Sara Beth Minder, born October 27, 1983, age 17, 4, On May 15,2000, following a Custody Conference with Dawn S, Sunday, Esquire, the Honorable Wesley 01er, Jr., issued a custody order, a copy of which is attached hereto as Exhibit A. 5, The Order provides that Respondent has primary physical custody and Petitioner has partial physical custody, The order also provides that the parties share legal custody and have an equal right to make all non-emergency decisions concerning the child's health, education, and religion, qm;-""""",,- " - -,~""-~ ~"'"'1'''' ~.. 6, On September 19, 2000, Petitioner filed a Petition for Contempt because of missed visits and Respondent's refusal to discuss the child's medical care with the Petitioner or provide copies of records and hea1thcare information to the Petitioner. 7, A conciliation conference was held October 3, 2000, before Custody Conciliator Dawn S. Sunday, Esquire, Following the conference, an order was entered that provided in part that Respondent provide to Petitioner all information she obtains from Dr, Edwin Cheek concerning the child's diagnosis and treatment. A copy of the Order, dated October 16, 2000, is attached hereto as Exhibit B, 8, To date, Petitioner has been unable to obtain copies of Dr, Cheek's records or any information from the Respondent. He has requested the records directly from the doctor but has had no response, Petitioner believes that Respondent has advised the doctor not to provide the requested information, Petitioner has also requested the information through Respondent's counsel but has not received any information, The child has told him that Respondent has talked directly to the doctor about the treatment plans but this information has not been forwarded to the Petitioner. Petitioner believes that Respondent is receiving regular medical care for a gynecological problem but he has no further information about the diagnosis or treatment. 9, Respondent has also failed to consult with the Petitioner about counseling for the child and instead advised him that she had unilaterally chosen a counselor for the child and scheduled an appointment. This information was provided to the Petitioner one day before the scheduled appointment allowing him no input into choice of counselors or opportunity to consider the counselor's credentials, ,'1-"""''''''''''",1~, , <-~~ , - "i'_ ~_ ~_."_ . _~a 10, Petitioner requests that Respondent be held in contempt for denying him information about the child's medical care and refusing to consult with him about medical treatments or counseling, 11. As a result of Respondent's contemptuous behavior Petitioner has incurred attorney's fees in the amount of $400 to date for correspondence with counsel and preparation and filing of the within petition, WHEREFORE, Petitioner requests this Honorable Court issue an order finding the Respondent in contempt and ordering immediate compliance with the order and sanctions to include attorney's fees and costs DATE: I~I ~I 00 aile S, Baker, E~quire Supreme Court ill #53200 27 South Arlene Street Post Office Box 6443 Harrisburg, P A 17112-0443 (717) 671-9600 ~_~~''-"''~'''''l ' ~'\~ - " ~ ~ "~~"C'~ "'c VERIFICATION I, James M, Minder, verify that the statements made in the foregoing Petition are true and correct to the best of my knowledge, information and belief, I understand that the statements herein are made subject to the penalties of 18 Pa,C,S, Section 4904 relating to unsworn falsification to authorities, ~~1f/~ :,':""""'''''.'''''l''''''''''',<, ,~ '-1 __'M ~ '" ,_.._ ~_'^~~ ___."""' "'-, CERTIFICATE OF SERVICE I hereby certify that on this 'lA' day of December, 2000, a true and correct copy of the foregoing document was served on the following person by United States Mail, postage prepaid, addressed as follows: Cindy L. Koser, Esquire 4810 Derry Street Harrisburg, PAl 7111 Respectfully submitted, iane S, Baker, Esquire Supreme Court 10 53200 27 South Arlene Street Post Office Box 6443 Harrisburg, P A 17112-0443 (717) 671-9600 ;-..'-~~"P"I"',"'-'>~ 'K "~"~, I' " ...", ."_~"_~_ ~m ~ (j1'I' )llql~" JAMES M. MINDER, Petitioner : IN THE CXXJRT OF Cl:XolMC.U PLEAS OF : CUMBERLAND COON'lY, PENNSnVANIA . . vs. : NO. 00-1400 CIVIL TERM . . MARGARET MARY KORFF MINDER, Respondent : CIVIL ACTION - LAW : IN CUsroDY ClIDER OF CXllRT AND tUf, this /1+h day of consideration of the attached CUstody and directed as follows: , 2000, upon it is ordered 1. The Father, James M. Minder, and the Mother, Margaret Mary Korff Minder, shall have shared legal custody of Sara Beth Minder, bom October 27, 1983. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisiollS affecting the Child's gener<ll well-being inclUding, but not limited to, all decisions regarding her health, education and religion. 2. The parties shall have physical custody of the Child in accordance with the following schedule: A. During the Sl.1llIllE!r 2000, the Father shall have custody of the Child from sunday, June 18 through saturday, July 1, from sunday, July 9 through Saturday, July 29, and from Sunday, August 6, through Saturday, August 19. The Mother shall have custody of the Child during the Sl.1IlIIIer 2000 at all times not otherwise specified for the Father under this provision. The Father shall provide transportation for the exchanges of custody on June 18 and July 1. Unless otherwise agreed between the parties or the Father agrees to provide the transportation, the parties shall make arrangements for the Child to travel by train for the remaining exchanges of custody during the Sunmer 2000. The Mother shall be responsible to pay for the round trip train ticket for exchanges in July and the Father shall be responsible to pay for the round trip train ticket for the exchanges in August. B. During the school year, the Father shall have custody of the Child as follows: Labor Day weekend from September 2 through September 4. Columbus Day weekend from OCtober 7 through OCtober 9. Thanksgiving break from November 22 or 23 (depending on the train schedule) through November 27. EXHIBIT A ~~~l'_;"""Jj . ~-"-I- T" Christmas holiday break from Deceni:Jer 26 through January 1. Dr. Martin Luther King weekend (January). President I s '1a.y weekend (February). Easter school break (March or April). Memorial Day weekend (May). In 2000, the Father shall provide transportation for the Child to and fran the Mother's residence over the Memorial Day weekend. The exact days (Friday evening or Saturday morning) and times for the foregoing holiday periods of custody shall be arranged by agreement of the parties based on the train schedule. In the event the parties are not able to agree on exchange times, the pick up times. shall be the train departure time which is closest to 10:00 a.m. and the'return time shall be the train departure time which is closest to 7:00 p.m..' Each party shall be responsible to. pay a portion of the Child's train fare for exchanges of custody during the school year in proportion to that party's income as allocated in percentage form in the Child ~t Order. 3. The parties agree that the Child shall participate in counseling with the Father, with the counseling sessions to be scheduled during the Father's periods of custody. 4. If the Child wants to go to church during the Father's periods of custody, the Father shall provide transportation and ensure that the Child is able to attend Mass. 5. Neither party shall do or say anything which may estrange the Child fran the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural developllent of the Child's love and respect for the 01:l1er parent. Each party shall ensure that third parties comply with this provision as well during his or her periods of custody. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COl.lRT, . .. ......... ... -;.;. I c:...:~ .:'. .~.._... :,. ( 'pi~~o~..,4i cc: Diane S. Baker, Esquire - Counsel Cindy L. Koser, Esquire - Counsel for Father for Mother .'*"'''''''''''''''"''''''''' - JAMES M. MINDER, : IN THE OJORT OF COMMOO PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-1400 CIVIL TERM : MARGARET MARY KORFF MINDER, : CIVIL ACTIOO - LAW Defendant : IN CUSTODY OODER OF <XXlRT AND mi, this I/jjth day of LDc.L~eR consideration of the attached Custody Conciliation Report, and directed as follows: , 2000, upon it is ordered 1. The prior order of this Court dated May 15, 2000 shall continue in effect as modified by this Order. 2. The Father ehall have custody of the Child from Friday, October 6, 2000, between 7:00 p.m. and 10:00 p.m. through Monday, October 9, 2000, at 12:00 noon. The Mother shall be responsible to provide all transportation for this period of custody. The Mother shall contact the Father if she is unable to have the Child at the Father's residence by 10:00 p.m. on Friday evening due to traffic or other unavoidable circumstances. 3. The Father ehall have additional periods of custody with the Child from November II through 12, 2000 (for which the Father shall be responsible to provide transportation) and from March 10 through 11, 2001, for which the Mother shall be responsible to provide transportation. 4. Unless otherwise specified in this Order as the Mother's responsibility for providing transportation, the Father shall purchase train tickets for the Child at the train departure time which is closest to 10:00 a.m. at the beginning of the period of custody and at the return time which is closest to 7:00 p.m. on the last day of the period of custody. within 10 days after each period of custody, the Mother shall reimburse the Father for the Child's train fare in an amount proportionate to the Mother's income as allocated in percentage form in the Child Support Order. The parties shall cooperate in contacting each other two days in advance of each exchange of custody to confirm the transportation arrangements. 5. within 10 days of the date of this order and on an ongoing basis thereafter, the Mother shall provide to the Father the name and telephone numbers of all physicians and counselors evaluating and providing treatment to the Child. In addition, the Mother shall provide all information which she obtains from Dr. Edwin Cheek concerning the Child's diagnosis and treatment. EXHIBIT B ,;.~~,,~..,.~" ., , I -~"" ~~ .~ . .-. - '" . , 6. Within 10 days of the date of this order and on an ongoing basis thereafter, the Mother shall provide to the Father copies of the Child' s school calendar and report cards. J. cc: Diane S. Baker, Esquire - Counsel for Father Cindy L. Koser, Esquire - Counsel for Mother TRUE COpy F':O':'M r.ECORD In Teatimony wh';' ,.< .'; unto set my hand and the seal of ~:;id ~,;j'i a~~, Pa. m ..1'1.. __~_.::~ 'll~~''''''-_ "^ ~ "~~, _ ~,~ _ ~,__'''''' ~" 2r. _,~'P.""" JAMES M. MINDER, Plaintiff v, MARGARET MARY KORFF MINDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 00-1400 CIVIL TERM CIVIL ACTION-LAW IN CUSTODY IN RE: PETITION FOR CONTEMPT ORDER OF COURT AND NOW, this 20th day of June, 2001, upon consideration of Plaintiff's petition for contempt and of the issue of a summer custody schedule which has been submitted to the Court, the record is declared closed, and the matter is taken under advisement, Diane Sommers Baker, Esquire 27 South Arlene Street P.O, Box 6443 Harrisburg, PA 17112 For the Plaintiff Cindy L, Koser, Esquire 4810 Derry Street Harrisburg, PA 17111 For the Defendant Adrienne Johnson, Esquire 4531 Buffalo Street Beaver, PA 15009-2003 For the Child pcb ~;,;, " ^ =, 1~ " ' . ,. ~ , By the Court, "~, r' , " \.;~ C) C' "'?'- u;-;~ [T'ir; , ~~'." "'">.', - c,,- r; - <~ ~(-} ;.;t": z ::;! - c::) ,:,') I ,-,,) \,0 - ., -~-j -r:; >~,I' -,;;C) t:SiTi ~ :',j or. -, .~ -