HomeMy WebLinkAbout00-01706
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LAURl A. BECKER,
Plaintiff
vs.
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)
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)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 00-1706
CIVIL TERM
DAVID J. BECKER,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this
day of
,2001, upon consideration of the
attached Petition, we hereby order and decree as follows:
1. The Plaintiff, Lauri A. Becker, is hereby authorized to take the minor children,
Kaitlin Becker, born November 16, 1989 and Jordan Becker, born March 25, 1994 with her to
Cancun,. Mexico between the dates of 4 January 2002 and 12 January 2002.
2. In the event that the father of the children, David J. Becker, does not sign a
written document consenting to her taking the children with her on the trip, this order shall
be deemed sufficient authority for her to take the children with her on the trip without
further written authorization from the father.
BY THE COURT,
J.
Distribution:
Samuel L. Andes, Esquire (Attorney for Plaintiff)
525 North 12th Street, Lemoyne, P A 17043
Laurie A. Saltz giver, Esquire (Attorney for Defendant)
410 North Second Street, Harrisburg, PA 17101
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vs.
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IN 'tHE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
LAURI A BECKER,
Plaintiff
CIVIL ACTION - LAW
NO. 00-1706
CIVIL TERM
DAVID J. BECKER,
Defendant
IN CUSTODY
ORDER
AND NOW this
day
L2001, a conference is
hereby scheduled before the undersigned, in his chambers at the Cumberland County
Courthouse on Plaintiffs attached Petition. The conference is to be held at
o'clock
.m.on
. the
day of
, 2001 and shall be
attended by counsel for both parties. Both parties shall be available, in person or by
telephone, to participate in the conference or answer questions that may arise at the
conference.
BY THE COURT,
J.
Distribution:
Samuel L. Andes, Esquire (Attorney for Plaintiff)
525 North 12th Street, Lemoyne, PA 17043
Laurie A Saltzgiver, Esquire (Attbrneyfor Defendant)
410 North Second Street, Harrisburg, PA 17101
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LAURl A. BECKER,
Plaintiff
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IN CUSTODY
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYL VANIA
vs.
CIVIL ACTION - LAW
NO. 00-1706
DAVID J. BECKER,
DefendaJit
ORDER
AND NOW this
1'O~ day
~
CIVIL TERM
,2001, a hearing is
hereby scheduled before the undersigned, in his chambers at the Cumberland County
Courthouse on Plaintiff's attached Petition. The hearing is to be held at.}) : \ 'S. O'c1ock-fl
.m.on~H.~A-A{,9 the 8rfi'- dayof ..QfL~-<: .. ,2001 and shall be
attended by counse for both parties.
.....
Distribution:
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(C(l~Q1..SO~ L(y
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Samuel L. Andes, Esquire (Attorney for Plaintiff)
525 North 12'h Street, Lemoyne, P A 17043
Laurie A. Saltzgiver, Esquire (Attorney for Defendant)
410 North Second Street, Harrisburg, PA 17101
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vs.
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)
)
)
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)
1
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
LAURI A. BECKER,
Plaintiff
CIVIL ACTION - LAW
NO. 00-1706 CIVIL TERM
DAVID J. BECKER,
Defenn:mt
IN CUSTODY
PLAINTIFF'S PET{'l'10N FOR AUTHORIZATION TO TAKE CHILDREN ON TRIP
AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and
petitions the court for permission and authorization to take her two minor children on a trip
to Cancun, Mexico, based upon the following:
1. The Petitioner herein is the Plaintiff, Lauri A. Becker. The Respondent herein is
the Defendant, David J. Becker.
2. The parties are the parents of two minor children, Kaitlin Becker, born 16
November 1989 and Jordaii Becker, born 25 March 1994. The children reside in the primary
physical custody of Plaintiff and are the subject of an order of this court dated 20 July 2000,
a copy of which is attached hereto and marked as Exhibit A.
3. In early January of 2002, Plaintiffs cousin will be married in Cancun, Mexico at a
ceremony at which Plaintiff and most of the members of her extended family will attend.
Plaintiff's cousin has arranged for both of Plaintiff's children to participate in the marriage
ceremony.
4. Plaintiff has made all arrangements necessary for the children to accompany her
to Cancun, Mexico for this family wedding. Those arrangements include:
A. She prOVided Defendant with notice of her intended trip on 29
October 2001. A copy of her letter of notification is attached hereto and
marked as Exhibit B.
B. She obtained permission from the two schools attended by the
children for them to be out of school for four days for the purposes of their trip
-r.o
with Plaintiff to Cancun, Mexico. Copies of the two letters of approval for the
two children are attached hereto and marked as Exhibit C.
5. Plaintiff has been advised that the airline on which she and the children are
scheduled to fly to Cancun, Mexico will not allow the children to board the plane without
the written permission or presence of both parents or an Order of Court authorizing them to
make the trip with just one parent.
6. Defendant has refused to grant permission for the children to go with Plaintiff on
the trip to the family wedding in Cancun, Mexico.
7. Defendant's refusal to consent to the children accompanying Plaintiff on this trip
has been made in bad faith and without proper regard for the best interests of the children.
Defendant's action in this regarq. is improper and vexatious.
8. Plaintiff has incurred legal fees and expenses, and will continue to incur such fees
to obtain authorization to take the children on this trip for their benefit
WHEREFORE, pl,.;ntiff prays this court to enter an order authorizing her to take the
children with her on the trip to Cancun and to award to Plaintiff reasonable attorneys fees
for the costs incurred in her effort to take the children on that trip.
~
Attorney for Plaintiff
Supreme Court LD. #17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761-5361
VERIFICATION
I verify that the statements made in this Petition are true and correct. I understand
that any false statements in this Petition are subject to the penalties of 18 Pa. C.s. 4904
(unsworn falsification to a'1l1)nriti..,,).
Date:
ld-I Co {" I
LA
. BECKER
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LAURI A. BECKER, : IN THE CDURT OF CDMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : NO. 00-1706 CIVIL TERM
:
DAVID J. BECKER, : CIVIL ACTION - LAW
Defendant : IN CUSTODY
CEDER OF COJRT
AND l'Di, this ,;lOl.:h day of ~J:i.
consideratioo of the attached Custody Conc Ii ion Report,
and directed as follows:
, 2000, upon
it is ordered
1. The Mother, Lauri A. Becker, and the Father, David J. Becker,
shall have shared legal custody of KaitHn Becker, born November 16, 1989,
and Jordan Becker, born March 25, 1994. Each parent shall have an equal
right, to be exercised jointly with the other parent, to make all major
non-emergency decisions affecting the Children's general well-being
including, but not limited to, all decisions regarding their health,
education and religion.
2. The Mother shall have primary j;X1ysical custody of the Children.
3. The Father shall have partial physical custody of the Children on
alternating weekends from Friday at 6:00 p.m. through Monday at 8:00 a.m.,
beginning Friday, June 23, 2000. During weeks following the Father's
weekend period of custody, the FatheJ; shall also have custody of the
Children on Thursday fran 5:30 p.m. through 8:00 p.m. during the school
year and through 8:30 p.m. during the summer school break. During weeks
following the Mother's weekend period of custody, the Father shall have
custody of the Children on Tuesday and Thursday evening from 5:30 p.m.
through 8:00 p.m. during the school year and through 8:30 p.m. during the
summer school break.
4. The parties shall share or alternate having custody of the
Children on holidays as follows:
A. CBlUSl'MAS: The Christmas holiday shall. be divided into
Segment A, which shall run fran Christmas Eve at 12:00 noon
through Christmas Day at 12:00 noon and Segment B, which shall
run fran Christmas Day at 12:00 noon through December 26 at
12:00 noon. In even nUlllbered years, the Father shall have
custody of the Children during Segment A and the Mother shall
have custody during Segment B. In odd numbered years, the
Mother shall have custody of the Children during Segment A and
the Father shall have custody during Segment B.
B. THANKSGIVING: In every year, the Mother shall have custody of
the Children on Thanksgiving Day until 2:00 p.m. and the
A
.
Father shall have custody from 2:00 p.m. until 8:30 p.m. on
Thanksgiving.
C. EASTER: The Easter holiday shall be divided into Segment A,
which shall run from 12:00 noon on the Friday before Easter
through 12:00 noon on the Saturday before Easter and Segment
B, which shall run from noon on the Saturday before Easter
through 12:00 noon on Easter Sunday. In even numbered years,
the Mother shall have custody of the Children during Segment A
and the Father shall have custody during Segment B. In odd
m.nnbered years, the Father shall have custody of the Children
during Segment A and the Motheru shallha:ve custody during
Segment B.
D. FATHER'S DAY/MOTIlER'S DAY: The Father shall have custody of
the Children every year on Father's Day and the Mother shall
have custody of the Children every year on Mother's Day from
8:00 a.m. until 8:00 p.m. Notwithstanding the foregoing, in
2000, the Father shall have custody of the Children for
Father's Day from Saturday, June 17 when the Mother returns
from vacation with the Children through Sunday, June 18 at
8:00 p.m.
E. The parties shall have custody of the . Children on the
remaining holidays as arranged by agreement.
F. The holiday custody schedule shall s_upersede and take
precedence over the regular custody schedule.
G. In the event the Father's period of hoHday CUstody falls
inrnediately before or after his regular period of custody, the
Father's holiday/regular period of custody shall run
continuously.
5. Each party shall be entitled to have custody of the Children for 2
non-consecutive weeks for vacation, which shall be scheduled during the
surrmer school break Imless otherwise agreed between the parties. The
parties shall schedule extended periods of custody under this provision to
fall immediately before or after that party's regular weekend period of
custody. Each party shall provide the other party with at least 30 days
advance notice of his or her selection of dates under this provision. The
party providing notice first shall be entitled to preference in his or her
selection of vacation dates.
6. The party receiving custody of the Children shall be responsible
to provide transportation for the exchange of custody unless otherwise
agreed between the parties.
7.
telephone
parent or
The non-custodial parent. shall be entitled to have reasonable
contact with the Children which may be initiated either by the
the Children.
8. The partiesu shall cooperate and work together in making any
necessary adjustments to the custody schedule and in addressing issues
conce=ing the Children.
9. 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 IlRltual consent. In the absence of IlRltual consent, the terms
of this Order shall control.
BY THE <XlURT,
/5/
cc: samuel L. Andes, Esquire - Counsel for Mother
Laurie A. Saltzgiver, Esquire - Counsel for Father
T""e:: I'''M'r fOr">' I h'-C. ORD
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In Te"timu^,Y '" ,.: ,d, : k:FC unto set my hand
*Ild j "~""!;f 'ld C 'urt at Carlisle, Pa.
W H...J'il.~Y of...::JuJ.~... ,~
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LAURI A. BECKER, : IN TBE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : NO. 00-1706 CIVIL TERM
:
DAVID J. BECKER, : CIVIL AcrION -LAW
Defendant : IN CUSTODY
OJSTCOY CCN::ILIATICN SUMMARY REI?CRL'
IN ACCCIIDI\NCE WITH COMBERLAND CXXlNTY RULE OF CIVJ:L PROCEDURE
19l5.3-8, the nndersigned CUstody Conciliator submits the following report:
1. 'lhe pertinent information. conce-rning the Children who are the
subjects of this litigation is as follows:
NAME
DI\TE OF BIRTH
CURRENl'Ly IN OJSTCOY OF
Kai tlin Becker
Jordan Becker
November 16, 1989
March 25, 1994
Motner
Mother
2. A Conciliation Conference was held on Jnne 8, 2000; with the
following individuals in attendance: 'lhe Mother, Lauri A. Becker, with her
counsel, Samuel L. Andes, Esquire, and the Father, David J. Becker, with
his counsel, Lauri A. Saltzgiver, Esquire.
3. 'lhe parties agreed to entry of an order in the form as attached.
Date
J//71/J
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1/
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CUstody Conciliator
. .
October 29, 2001
Ms. Saltzgiver:
This is to inform you to inform your client, David Becker, of my impending vacation schedule
for 2002. I will be taking the children to a cousin's wedding in Cancun, Mexico from January 4th
tbru January 12th, 2002. The children are in the wedding. I will also be taking them on their
normal beach vacation in the Outer Banks on June 7th thru June 15th 2002.
Please inform your client of these dates.
.,
Sincerely//
, ,7
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ALLen 1Vllaale :::,cnOOl
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November 19,2001
Ms. Lauri Becker
4002 Gettysburg Road
Camp Hill, P A 17011
Re: Educational Field Trip Request for Kaitlin Becker - Grade 6
Dear Ms. Becker:
I have received and approved your request for an educational field trip for
Kaitlin for January 7 through 11, 2002.
For these dates to be considered as excused absences the following requirements
must be met within five (5) days of Kaitlin's return to school:
a. A written report must be presented to the office on January 22, 2002
by 2:45 p.m. which explains how the trip provides an educational
experience.
b. She must complete any work that she misses during her absence.
According to the West Shore School District's educational field trip policy, a
student is only permitted a total of five (5) days of absence for an educational
field trip during a school year.
In closing, I would like to wish you and your family an enjoyable trip.
Since
JAG/ des
Cc: Student File
Teachers
MAITHEW J. SZEJK
I.M-E.
4225 Gettysburg Road
Camp Hill. Pennsylvania 17011-6630
Phone (717) 761-1500
www.wssdk12.pa.us
An equal apport\.Jnity employer
LARRY A. SAYRE
Superintendent
JOSEPH A. GARGIULO
Principal
JEAN M. DYSZEL
Assistant Superintendent
c...
" "qLJ
Lower Allen Elementary School
November 21, 2001
Ms. Lauri Becker
4002 Gettysburg Road
Camp Hill, Pa. 17011
Dear Ms. Becker:
Please be advised that the educational field trip request for your child, Jordan, has
been approved for January 7 - 11, 2002.
(a) Within five days of your child's retum to school, a report from Jordan,
must be presented to me. The report must explain and show what he
learned on this trip.
(b) All work missed during the period of absence must be completed
within five days of the student's return to schooL
According to the West Shore School District's educational field trip policy, a
student is only permitted a total of five days of absence for an educational trip
during a school year.
I hope your child will have a rewarding experience. I look forward to receiving a
report from Jordan. The report is due by January 17, 2002.
Sincerely,
l._ch"tMw"'- ,;/:~/;':' J1tC./
Mrs. Joanna L. McIntyre
Principal
JOANNA L. McINTYRE
Principal
4100 Gettysburg Road
Camp Hill, Pennsylvania 17011-6709
Phone (717) 761-8415
www.wssd.k12.pa.us
An equal opportunity employer
LARRY A. SAYRE
Superintendellt
JEAN M. DYSZEL
Assistallt Superintendent
12/21/213131 13:47
2352817
PAGE 82
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-1706
LAURI A. BECKER
. Plaintiff
. .
DAVID .41 .. BECKER
. Dafendant
~ CIVIL ACTION , LAW
, IN CUSTODY
ORDER
AND NOW, this
day of
, 20_,. uIJcm
consideratiqn of Def~nn~nt'B Motion for Continuance, the
. .
conferencescneduledfor Thursday, Dece~er~27, 2001 at.2:1:
p.m. is hereby continued to
.o'Glock..
, 20
at
BY THE COURT:
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J.
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IIEYEtt5t Dc5f"U~ SALJ.LtifVCH !tI. HUYLIi
-4.10 NORrH SSCONO snU::ET Ii P.O.130X 1062 .. HARRISBURG. FA 17~e.e
. . ('11" (!\3G (J,c:l'$- ". F~ ('T17):!$6 ::!S17 .
12/21/2001 13:47
2362817
PAGE 03
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LAtmI A.. I;IECKEF.
plaintiff
ys..
IN THE COORT OF COMMONP~~
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-1706
CIVIL ACTION - LAW
IX; t,;Uo'~'VI.n:
DAVID.J~ BECKER.
Defendant
HpTION FOR CONTlmJANClj:
AND NOW comes the Defendant, David J. Becker, .by and
through his attorneys. Meyers, Desfor, Saltzgiver & Boyle, and
files this Motion for continuance, and in support.thereof aVers
as follows:.
L Movant is .bav),.d. J, Becker, Defendant in the above-captioned
action (hereimi.fter referred to as "Father").
2. Res];>orident..1s :Lauri ./I.. Becker, Plaintiff in. theiiliove':'
9apt.ionedac:ction (hereinafter referred to as "Mot,her")..
3 _ . . Mother filed a. Petition for Authorization to Take Children
On Trip on December 13, 2001. This Honorable Court issued
an Drder on December 18, 2001 scheduling a. conference
regarding saiq petition for December 27. 2001.
Exhibit "A"l.
(See
4 .Fat:h~r'!'l <"<'1ll.Ti"'..', T"",rie A. Saltzeriv..r. Esquir\> is: ou.t. .or
. . .
town for.t?e holidays during the week ofth... conference ~d
will beuriable. to attend. Me. S~ltzgivcr'o partner,
.C",thcrinc..1\.i B';'ylc, Esquire, is "-1150 out of .town. for the
h01:Lday". du",",ing. that week and wi;Ll 1>.. ulldJJ1.. Lt.> rill in ~or
Laurie A. salt~g~V~Lr E~qulre_
S.. Jr..l.h",,r;' L...qlolests. that the conference scheduled foi; DeCember.
MEYERS, DEaFeR, SALTZG1VEIl .. BOYlE . .
.,'oNOfrmSEGONDETREET . P.O.BOX1062 . HARRISBURG,PA171OS
. . (717) 2~'942B . FAX (717) 2SQ-2.'7
12/2112001 13:47
2362817
PAGE 04
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27, 200~ beC9ntinued to a date and time wh~n ~ath~r'a
,oounSEll - is available.
WImnBl?OrlE" Defendant, bavid J. Deoker re"pect.fully requei!its
I:.bis. Hono:rable COUl'..'~ ~p:~i1.t_ hi:s Motion fOL CU.L.Ll..l.LJ.udl.lt.:~ cLLlU..
rescheduie't.he ~Onference present.ly scheduled-for December 27,
2UU.L.
Respecttuily submitted,
\~
Laurie A.
MEYF.RS. DI':SF'01<,
& BOYLE .
Attorney I.D. #6~3B2
410 North Second Streee
1;'.0. Box J.062
Harrisburg, PA 17108
(717) 236 !)428
Attorney for Defendant
" "
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MEYERS. DESFOR. SA1.TXG:1VQII .It. BOYLE
410 NOR11i SECONO 'STREeT . P.O, eox 1002 . HARRISBURG, PA "1<'.
lI'nl!:.1t>-l.M~B . J-AX{7'7)236-~'1
12/21/2001 13:47
2362817
PAGE 05
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LAURI A. BECKER,
. Plaintiff
IN THE COURT OF COMM:ON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
)
)
)
)
.)
)
)
)
)
VB.. .
CIVIL ACTION- LAW
NO. 00"1706
CIVIL TERM
DAVIDJ. BECKER.
D'ilfandanJ;
IN CUSTODY
ORnE!\,
AND NOW this l~ day i};("f" ~J,~ ,2001, a conferenpe is
hereby sched.ule.d befare the. undersigned, in his chambers at the Cumberland Caunty .
I
I Gaurthouse on Plaintiff's attiched Pe~tion. The conference is to. be heldat.,,2. . /... ( o'clock
i :fJ- .m, on ....7t;.,jJfi,~~t the ..Yl'f-t day of ~,-~......,b~A' -..... ., 2001 and shall be
.! attended by caurtsel tor botli parties. Bath parties shall be avanabl~, ill fJtW;U.' 01 by
I
r telepb.ane"W p.artlClpate.!n:tbbl cour",.",u"", or allswer questions that may arise at the
I
,
I confer~nce*.
I
. BY THE COURT;
N~2 i1v~
.I)istributian:
Samuel L. Andes, Esquire (Attorney far PlaiIltiff)
525 North 12'" Street, Lemoyne, P A l'/U4a
. .' .
Laurie A.. SaltZgiver, ESqillre . '(Attarney {QJ; Defendant)
410 Nbr1;hSecond Street, IIan:lsburg. rA 17101
'.,.
" L:;.uE OOPY FROM RECORD
~;J:nwf WhoJroot, , here unto set my ha~~
r'''; 1 ~ Mid . rt 111 Car1lsl.o. i.
,. ay .. 0
. EXHIBIT. .
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12/21/2001 13:47
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2362817
PAGE 06
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LAURI A. .BECKER
pl",i-nt:if'f
IN TH~ COURT OF COMMON PLEAS
CUMBERLAND CODNTY., PENNSYLVANIA
v...
NO. 00-170"
DAVID J. EEC1CE:R.
Defendant
CiVIL ACTION - LaW
IN COSTODY
cERTIFlCA~ ~SERVlCE . . ..~ ."A .
I hereby oer1:ifY on this J-\~day Of~~\.2001,
that a qopyofthe foregoing Motion for Continuance was sent. via
facsimiJ.e. to:. .
The Honorable Edgar B. Bayley
CUMBERLAND COUNTY COURTHOUSE
. One. Courthouse Square
Carlisle, PA 17013
Samuel Andes, Esquire
525 North Twelfth StrQQt
P.O. Box 168
Lcmoyn~. PA 1?0~3
,
I
MEYER$, DESFOA. ......lZGII/ER i. aOYLE
..nO"NOR1H SecoND STREET ". P.O.ro,X101S2 . HAHf1ISBURG.PA ~7J08
.171'7"'. _.tU~ . t:'AY I"1t7\ 1>'lR.~A'l"
LAW OF"FICES
MEYERS, DESFOR, SALTZGIVER & BOYLE
....10 NORTH SECOND STREET
P.o. BOX 1062:
l. EMANUEL MEYERS (1915-1970)
BRUCE 0_ DESFOR
LAURIE A, SALTZGIVER
CATHERINE A. BOYLE.
HARRISBURG, PA. 17108
(717) 236-9428
FAX(717) 2:36-2:817
WEBSITE www.meyersdesfor.com
EMAIL IsaltzgiverOmeyersdesfor.com
cboyIeCmeyersdesfor,com
December 19, 200l
VIA FAX ~ U.S. MAIL
The Honorable Edgar B. Bayley
CUMBERLAND COUNTY COURTHOUSE
One Courthouse Square
Carlisle, PA l70l3
RE: Becker v. Becker
OO-l706
Dear Judge Bayley:
I have received a Petition for Authorization to Take
Children on Trip filed by Sam Andes on behalf of Lauri Becker.
This petition was apparently filed with the Court on December l3,
200l, however, I have only received a copy today.
Accordingly, I would request that Your Honor postpone any
decision on the petition without an opportunity to review my
client's response. I intend to file a response to the petition
on my client's behalf by the end of the week.
Thank you for your attention and cooperation in this matter.
~erel~' ,
Laur~al z v
LAs/clk
cc: David Becker
Samuel Andes, Esquire
LAURI A. BECKER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
Defendant
CIVIL ACTION - LAW
NO. a:J- /70t!, ti;../
IN CUSTODY
vs.
DAVID J. BECKER,
ORDER OF CQUBT
AND NOW, 3/;;)'1
2000. upon consideration of the attached complaint, it is
hereby directed that the parties and their respective counsel appear before
~v...\"S.~ Esquire, the conciliator, at.:39 W V\o\r) -S\"1 ~llcm\(sb.G;
, Pennsylvania. on ~ )~'S. the \C-, day of. N~ .2000,
at \ o'clock ~.m., for a Pre-Hearing Custody Conference. At such conference, an
effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to
define and narrow the issues to be heard by the court, and to enter into a temporary order.
Either party may bring the child who is the subject of this custody action to the conference,
but the children'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 <~'(o~.n\\ ~,.~\\~~~>
Custody Conciliator C~)
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
LAURI A. BECKER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
Defendant
CIVIL ACTION - LAW
NO. (TtJ- /76(,
IN CUSTODY
CIVIL TERM
DAVID J. BECKER,
COMPLAINT IN CUSTODY
AND NOW comes LAURI A. BECKER, by her attorney, Samuel L. Andes, and makes
the following Complaint for custody based upon the following:
1. The Plaintiff is LAURl A. BECKER, who resides at 4002 Gettysburg Road, Camp
Hill, Cumberland County, Pennsylvania.
2. The Defendant is DAVID J. BECKER, who resides at 3500 Lisburn Road,
Mechanicsburg, Cumberland County, Pennsylvania.
3. The parties are the parents of two minor children, Kaitlin Becker, born 16
November 1989, and Jordan Becker, born 25 March 1994.
4. The Plaintiff and Defendant are husband and wife.
5. Plaintiff seeks custody of the minor children, Kaitlin Becker and Jordan Becker.
6. The children were not born out of wedlock and are presently in the custody of
the Plaintiff.
7. During the past five years, the minor children have resided with the following
persons at the following addresses:
1995 to September
1998
3500 Lisburn Road
Mechanicsburg, PA
Plaintiff and
Defendant
September, 1998 to
September, 1999
1453 Hillcrest Court
Camp Hill, PA
Plaintiff
1
..
September, 1999
to 1 8 February 2000
3500 Lisbum Road
Mechanicsburg, PA
Plaintiff
(Defendant was
present in the house
but Plaintiff provided
the custodial care of
the children and
Plaintiff and Defendant
were physically
separated.)
18 February 2000
to the present
4002 Gettysburg Road
Camp Hill, PA
Plaintiff
8. The father of the children is thePefendant who resides at the address set out
above. He is married to the Plaintiff.
9. The mother of the children is the Plaintiff who resides at the address set out
above. She is married to the Defendant.
10. The Plaintiff is the natural mother of the children. Plaintiff currently resides
with the children.
11. The Defendant is the natural father of the children. Defendant currently resides
alone.
12. There was a divorce action between the parties to file No. 98-3499 Civil Term
before the Court of Common Pleas of Cumberland County in which a temporary custody
order was entered in December of 1998. The divorce action, however, was terminated in
1999 and such termination also terminated the prior custody order.
Plaintiff knows of no other person not a party to this action already who has physical
custody of or claims to have custody or visitation rights with the said children.
2
13. The best interests and permanent welfare of the children will be served by
granting the relief requested by Plaintiff for the following reasons:
A. She has been the primary care provider and the custodial parent of
both children since their birth;
B. The Defendant is not close to the children and is not in a position to
provide properly for their emotional and other needs;
C. Plaintiff, because of her personality, disposition, and work
schedule, is best able to meet the needs of the children and provide a safe,
secure, and appropriate home for them.
14. Each parent whose parental rights to the children have not been terminated and
the person who has physical custody of the children have been named as parties to this
action.
WHEREFORE, LAURI A. BECKER requests this Court to grant her custody of the
children, Kaitlin Becker and Jordan Becker.
BYS?'~
Sa el e. Ande
Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
3
~ .j
COMMONWEALTH OF PENNSYLVANIA
)
( 55.:
)
COUNTY OF CUMBERLAND
LAURl A. BECKER, being duly sworn according to law, deposes and says that the
facts set forth in the foregoing Complaint for Custody are true and correct to the best of
her knowledge, information, and belief.
.".- '\
(~h
LAURI A. BECKER
Sworn to and subscribed
before me thisC:O-hday
of tltlAcn ,2000.
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4
LAURI A. BECKER
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ANSWER TO COMPLAINT IN CUSTODY AND COUNTERCLAIM
1. No answer required.
2. Admitted.
3. Admitted.
4. Admitted.
5. No answer required.
6. Admitted.
7. Denied. This averment is denied insofar as Plaintiff
alleges that Defendant did not care for the children from
September 1999 until February 18, 2000.
8. Admitted.
9. Admitted.
10. Admitted.
11. Admitted.
12. Admitted. By way of further answer, the documents speak fo
themselves.
13. Denied. The best interest and permanent welfare of the
children will be served by granting the parties shared lega
and physical custody of the children because it is in the
children's best interests that they develop lasting,
nurturing relationships with both parties. Furthermore,
MEYERS, DESFOR. SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9428 . FAX (717) 236-2817
Plaintiff has attempted to interfere with Defendant's
relationship with the children and to alienate the children
from the Defendant. Defendant believes that awarding the
parties shared physical custody will minimize the effects 0
Plaintiff's efforts to alienate the children from him.
14. No answer required.
WHEREFORE, Defendant requests the Court grant the parties
shared legal and physical custody of the children Kaitlin Becker
and Jordan Becker.
COUNTERCLAIM
15. Numbers one through fourteen are incorporated herein by
reference, as if set forth in full.
16. The parties to this action have separated on two separate
occasions. During both periods of the parties separation,
Plaintiff has interfered with Defendant's relationship with
the children, and has attempted to alienate the children
from Defendant.
17. Defendant requests that the Court award the parties shared
physical and legal custody so that he may minimize the
effects of Plaintiff's alienation on his relationship with
the children, and so that Defendant can develop lasting and
loving relationships with the children.
18. Defendant requests that the parties be awarded shared legal
and physical custody of the children.
WHEREFORE, Defendant, David A. Becker, respectfully request
the Court grant shared legal and physical custody of the
MEYERS, DESFOR, $ALTZGIVER & BOYLE
410 NORTH SECOND STREET . P,O. BOX 1062 . HARRISBURG, PA 17108
(717) 236.9428 . FAX (717) 236-2817
children, Kaitlin Becker and Jordan Becker to both parties.
Respectfully s
~
1 gi
R,\SALTZGI
& BOYLE
Attorney I.D. #61382
410 North Second Street
P.O. Box 1062
Harrisburg, PA 17108
(717) 236-9428
Attorney for Defendant
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1082 . HARRISBURG, PA 17108
(717) 236-9428 . FAX (717) 236-2817
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
I hereby
CERTIFICATE ,fIJ, SERVICE
certify on this ~ day of June,
2000, that a
copy of the foregoing Answer to Complaint in Custody and
Counterclaim was hand-delivered to:
Samuel Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemay,\; " "';<
Ii
MEYERS, DESFOR. SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236.9428 . FAX {717) 236.2817
~
LAURI A. BECKER, : IN THE COURT OF OOMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : NO. 00-1706 CIVIL TERM
:
DAVID J. BECKER, : CIVIL ACTION - LAW
Defendant : IN CUSTODY
CRDER C8!" CCURT
AND I'D'I, this 2-0 tt, day of I I{ h '
consideratioo of the ",t-t-"C'hed Custody Conc1l1ation Report,
and directed as follows:
, 2000, upon
it is ordered
1. The Mother, Lauri A. Becker, and the Father, David J. Becker,
shall have shared legal custody of Kaitlin Becker, born November 16, 1989,
and Jordan Becker, born March 25, 1994. Each parent shall have an equal
right, to be exercised jointly with the other parent, to make all major
non-emergency decisions affecting the. Children's general well-being
includin;;, but not limited to, all decisions regarding their health,
education and religion. .
2. The Mother shall have primary physical custody of the Children.
3. The Father shall have partial physical custody of the Children on
alternating weekends from Friday at 6:00 p.m. through Monday at 8:00 a.m.,
beginning Friday, June 23, 2000. During weeks following the Father's
weekend period of custody, the Father shall also have custody of the
Children on Thursday fran 5:30 p.m. through 8:00 p.m. durin;; the school
year and through 8:30 p.m. during the summer school break. During weeks
followin;; the Mother's weekend period of custody, the. Father shall have
custody of the Children on Tuesday and Thursday evening from 5:30 p.m.
through 8:00 p.m. durin;; the school year and through 8:30 p.m. during the
S\.1lXllle!." school break.
4. The parties shall share or: alternate having custody of the
Children on holidays as follows:
A. CHRISTMllS: The Christmas holiday shall be divided into
Segment A, which shall run fran Christmas Eve at 12:00 noon
through Christmas Day at 12:00 noon and Segment B, which shall
run from Christmas Day at 12:00 noon through December 26 at
12:00 noon. In even numbered years, the Father shall have
custody of the Children during Segment A and the Mother shall
have custody during Segment B. In odd numbered years, the
Mother shall have custody of the Children during Segment A and
the Father shall have custody during Segment B.
B. TBl\NKSGIVlNG: In every year, the Mother shall have custody of
the Children On ThanksgIvIng Day until 2:00 p.m. and the
Father shall have custody from 2:00 p.m. until 8:30 p.m. on
'Ihanksgiving.
C. EASTER: The Easter holiday shall be divideCl into Segment A,
which shall run from 12:00 noon on the Friday before Easter
through 12:00 noon on the Saturday before Easter and Segment
B, which shall run from noon on the Saturday before Easter
through 12:00 noon on Easter sunday. In even numbered years,
the Mother shall have custody of the Children during Segment A
and the Fathe.. shall have custody during Segment B. In odd
numbe..eCl yea..s, the Fathe.. shall have custody of the Child..en
during Segment A and the Mother shall have custody during
Segment B.
D. FATBER'S DAY/MOl'IlER'S DAY: The Fathe.. shall have custody of
the Children every year on Father's Day and the Mother shall
have custody of the Children every year on Mother's Day from
8:00 a.m. until 8:00 p.m. Notwithstanding the foregoing, in
2000, the Father shall have custody of the Child..en fo..
Father's Day fran saturday, June 17 when the Mother returns
from vacation with the Children through sunday, June 18 at
8:00 p.m.
E. The parties shall have custody of the Children on the
remaining holidays as arrangeCl by agreement.
F. The holiday custody scheClule shall superseCle and take
precedence over the regular custody scheClule.
G. In the event the Father's period oX holiday custody falls
immeCliately before or after his regular period of custody, the
Father's holiday/regular period ofcuatody shall run
continuously.
5. Each party shall be entitleCl to have custody of the Children for 2
non-consecutive weeks for vacation, which shall be scheCluleCl during the
surrrner school break unless otherwise agreed between the parties. The
parties shall schedule extendeCl periods of custody under this provision to
fall immeCliately before. or after that party's regular weekend period of
custody. Each party shall provide the other party with at least 30 days
advance notice oX his or her selection of dates under this provision. The
party providing notice first shall be entitleCl to preference in his or her
selection of vacation dates.
6. The party receiving custody oX the Children shall be responsible
to provide transportation for the exchange of custody unless otherwise
agreeCl between the parties.
7.
telephone
parent or
The non-custodial parent shall be entitleCl to have reasonable
contact with the Children which may be initiateCl either by the
the Children.
8. The parties shall cooperate and work together in making any
necessary adjustments to the custody scheClule and in addressing issues
concerning the Children.
9. 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 CXJURT,
J.
=: Samuel L. Andes, Esquire - Counsel for Mother
Laurie A. Saltzgiver, Esquire - Counsel for Father
~~
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. .
LAURI A. BECKER, : IN THE COURT OF CXJMMrn PLEAS OF
Plaintiff : . CUM5ERLAND COUNTY, PENNSYLVANIA
:
vs. : NO. 00-1706 CIVIL TERM
:
DAVID J. BECKER, : CIVIL ACrrClil - LAW
Defendant : IN CUSTODY
CllS'.l'CIJY CCtiCILIATIClil SU!lMARY REPCRI.'
IN ACO:lIDl\NCE WITH <nmERLAND CClJIlITY RIlLE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF BIRTH
alIlRENTLY IN CllS'.l'CIJY OF
Kaitlin Becker
Jordan Becker
November 16, 1989
March 25, 1994
Mother
Mother
2. A Conciliation Conference was held on June 8, 2000, with the
following individuals in attendance: 1he Mother, Laud A. Becker, with her
counsel, Samuel L. Andes, Esquire, and the Father, David J. Becker, with
his counsel, Lauri A. saltzgiver, Esquire.
3. 1he parties agreed to entry of an Order in the form as attached.
Date
J/A10
o r) e!n{)
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Custody Conciliator
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VERIFICATION
I,
David J. Becker
, verify that the
statements made in this Defendant's AmAnded Answer to Complaint
I
I,
I of my knowledge, information and belief.
I
I
II
in Divorce and New Matter
are true and correct to the bes
I understand that fals
statements herein are made subject to the penalties of 18 Pa.
C.S. Section 4904, relating to unsworn falsification to
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II
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authorities.
Dated:
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Plaintiff
(X)
Defendant
MEYERS, DESFOR, SALTZGIVER &: BOYLE
410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236.9428 . FAX (717) 236.2817
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LAURI A. BECKER
PLAINTIFF
V.
DAVID J. BECKER
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERI.AND COUNTY, PENNSYL VANIA
00-1706 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COlTRT
AND NOW, this 23rd day of August ,2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear before Dawu S. Suuday, Esq. , the conciliator,
at 39 West MaiuStreet, Mechauicsburg.,PA 17055 on the 26th day of September ,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 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
\
Dflwn S. Sunda;y. ES~
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR A ITORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATIORNEY 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
FLF} OFFiCE
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~------- ~.~
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, , upon consideration
of the attached complaint, it is hereby directed that the partie
and their respective counsel appear before
on th
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 eempurary order. All
children age five or older may also be present at the conference
Failure to appear at the conference may provide grounds for entr
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 reasonabl
accommodations available to disabled individuals having business
before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business
before the court. You must attend the scheduled conference or
hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TH
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
CUmberland County Courthouse
One Courthouse Square, 4th Floor
Carlisle, pennsylvania 17013
(717) 240-6200
MEYERS, OESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET .. P.O. BOX 1062 .. HARRISBURG. PA 17108
(717) 236-9428 .. FAX (717) 236-2817
II
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
: CIVIL ACTION - LAW
IN CUSTODY
PETITION FOR CONTEMPT AND FOR MODIFICATION OF CUSTODY ORDER
AND NOW, comes Defendant, David J. Becker, by and through
his attorneys, Meyers, Desfor, Saltzgiver & Boyle and files the
following Petition for Contempt and for Modification of Custody
Order and in support thereof avers as follows.
1. Petitioner is David J. Becker, Defendant in the above-
captioned action.
(hereinafter "Father").
2. Respondent is Lauri A. Becker, Plaintiff in the above-
captioned action.
(hereinafter "Mothern).
3. The parties are the parents of two minor children namely
Kaitlin Becker, date of birth 11/16/89 and Jordan Becker,
date of birth 3/25/94.
4. The parties attended a conciliation conference before Dawn
Sunday, Esquire on June 8, 2000 and reached an agreement
which became an Order of Court dated June 20, 2000.
(See
Exhibit "An).
5. Pursuant to the Order of June 20, 2000, paragraph 3, Father
is provided alternating weekends of partial physical custod
with the children, as well as one or two evenings during th
week. The weekend of July 21, 2000 was Father's alternatin
weekend of custody.
MEYERS, DES FOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9428 . FAX (717) 236-2817
-
6. On July 22nd, Father had an open house and block party to
celebrate the Grand Opening of his new business Camp Hill
Auto & Truck, located at 3303 Hartzdale Drive, Camp Hill,
pennsylvania. On that Saturday, July 22nd, Mother appeared
at the business next door to Father's business "Kathies
Christmas and Collectibles" and coaxed the children to her,
and then refused to return the children to Father. When
Father approached Mother and requested she return the
children, she screamed rude things at him causing the
children to cry and become upset. Because Mother refused t
return the children, Father was forced to call the police.
The police spoke to all involved and advised Mother to
return the children to Father, which she eventually did.
7. Father believes and therefore avers that Mother is in
contempt of the Order of June 20, 2000 by interfering with
his weekend of partial physical custody on July 22, 2000.
8. Pursuant to paragraph 7 of the Order of June 20, 2000, the
parties are afforded reasonable telephone contact with the
children. Mother has continuously refused to permit
Father's telephone contact with the children. Father calle
Mother's residence on Monday, July 24, 2000 and asked to
speak with their son, Jordan. Jordan had severe poison ivy
and Father wanted to speak to him to ask how he was doing.
Mother refused to let Father speak to Jordan. Additionally,
Father telephones Mother's residence daily and leaves a
3
MEYERS, DESFOR. SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9428 . FAX (717) 236.2817
message for the children to call him. andMother does not
permit the children to return their Father's telephone
calls.
9. Pursuant to the Order of June 20, 2000, the parties have
shared legal custody of the children. Additionally,
paragraph 8 of the Order, requires the parties to cooperate
and work together in making any adjustments to the custody
schedule as well as in addressing any issues involving the
children. Mother has clearly and continuously violated
these provisions of the Order, as well as the spirit and
intent of the Order, by consistently interfering with
Father's relationship with the children, as follows:
a. Mother has advised the children that their Father is a
"mean, rotten, evil. person and is out to destroy the
three of them" (meaning the two children and mother) .
b. Mother has advised the children that: they do not have
to take a shower at Father's house, and that they do
not have to obey Father.
Furthermore, specifically on
July 23, 2000, Father Overheard a conversation wherein
Mother advised their daughter, Kaitlin, that she does
not have to take a shower, and if her Father tries to
make her take a shower or if he touches her, then she
(Mother) would call the police and get her dad
arrested.
c. On Friday, August 4, 2000, Mother spoke to Kate on the
4
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND S1REET . P.O. BOX 1062 . HARRISBURG. PA 17108
(717) 236-9428 . FAX (717) 236-2817
telephone and spoke negatively about Father. Mother
convinced xate that she hates her Father and doesn't
want to be at his house. Kate was extremely upset and
crying when she got off the telephone with her Mother.
Father got Kate calmed down and Father and both
children had an enjoyable weekend.
d. Additionally, during various exchanges of the children,
Mother has sworn at Father and made rude and insulting
comments to him. Also, Mother frequently makes obscen
gestures toward Father inclUding giving him "the
finger" in front of the children.
Specifically, Mothe
gave Father "the finger" in front of the children at a
soccer game on July 18, 2000. Mother also frequently
gives Father "the finger" when she picks the children
up from his home, and specifically on Monday, August 7
2000.
e. On numerous occasions, Mother has made a scene during
the exchanges of custody and in front of the children.
Specifically, on Monday morning, July 24, 2000, Mother
went to Father's residence to pick up the children fro
the weekend and during the exchange, Mother hit Father
with Jordan's suitcase.
f. Father believes and avers that Mother is taking the
children to a psychologist without his consent and
agreement.
5
MEYERS, DESFOR, SALiZGIVER & BOYLE
410 NORTI-i SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9428 . f:"AX (717) 236-2817
g. Mother refuses to consult with Father regarding the
children's activities. Mother unilaterally enrolled
Jordan in a soccer league without consulting with
Father.
Furthermore, Father believes that Jordan
wanted to play football and Mother refused to sign him
up for football. Also, Mother failed to consult with
Father in enrolling Kate in a soccer league.
10. Father believes and avers that the above referenced actions
by Mother are a conscious effort on her part to interfere
with Father's relationship with the children and to alienat
the children from him.
11. Pursuant to the Order of June 20, 2000, paragraph 5, each
party is entitled to have the children for two non-
consecutive weeks of vacation time during the school summer
break.
Because the conciliation conference was not held
until June 8th, the parties agreed that they would attempt
to provide each other with as much notice as possible in
requesting vacation time with the clilTaren.
12. Mother has previously requested a week of vacation time wit
the children and Father agreed to same despite Mother's
failure to comply with the thirty (30) day notice
requirement.
13. Father advised Mother of the two weeks of vacation which he
wanted with the children, by way of letter dated July 21,
2000.
(See Exhibit "B").
6
MEYERS. DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STFtEET . P.O. BOX 1062 . HARRISBURG, PA 17108
{717} 236-9428 . FAX. (717) 236-2817
14. Father was advised by Mother's counsel's office that
Mother's counsel was out of town when the correspondence of
July 21st was received, but that the correspondence had bee
forwarded to Mother. However, Mother did not provide any
information on the children's availability, nor did she
provide any justification as to why they would be
unavailable at that time. Accordingly, Father's counsel
faxed a letter dated July 26, 2000 advising the date and
time that Father would be picking up the children for his
first week of vacation.
(See Exhibit "C").
15. Father appeared at Mother's residence at the specified time
and Mother was not home and did not have the children
available for the period of vacation time.
16. In light of all of the above, and Mother's efforts to
interfere with Father's custody and relationship with the
children, Father requests this Honorable Court award him
additional periods of partial physical custody of the
children, so he can repair his relationship with them.
17. Mother has attempted to alienate the children from Father
and Father should be afforded additional periods of custody
with the children so they can repair their relationship.
18. Mother has continuously and repeatedly violated both the
letter and the intent of the custody Order of June 20, 2000
by her actions and efforts to thwart Father's attempts to
have a relationship with the children. As a result, Father
7
MEYERS, DESFOR, SAl TZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9428 . FAX (717) 236-2817
should be afforded additional time with the children so tha
he may repair his relationship with them. Furthermore,
Mother should be ordered to pay Father's counsel fees, cost
and expenses incurred in bringing the within Petition.
WHEREFORE, Petitioner, David J. Becker, respectfully
requests this Honorable Court find Mother in contempt of the
custody order of June 20, 2000, award Father additional periods
of custody of the children and order Mother to pay
Petitioner/Father's counsel fees, costs and expenses incurred in
bringing the within Petition.
Respectfully submitted,
Laur~ A. a z i r,
MEYERS, DES FOR , SALTZ
& BOYLE
Attorney I.D. #61382
410 North Second Street
P.O. Box 1062
Harrisburg, PA 17108
(717) 236-9428
Attorney for Petitioner
MEYERS, DESFOR. SALTZGIVER & BOYLE
410 NORTH SECOND STREET . F'.O. BOX 1062 . HARRISBURG, PA 1710B
(717) 236-9428 . FAX (717) 236-2817
LAORI A. BECKER, : IN THE COURT OF COMMON' PLEAS OF
Plaintiff : CUMBERLAND caJNTY, PENNSYLVANIA
:
vs. : NO. 00-1706 CIVIL TERM
:
DAVID J. BECKER, : CIVIL AcrION' - LAW
Defendant : IN CUSTODY
CEDER OF CXXlRT
AND fOg, this ~ot'n day of ~ ~\ I. ~n e..
consideraticn of the attached Custody Conc~l:Lat:Lon Report,
and directed as follolo1S:
, 2000, upon
it is ordered
1. The Mother, Lauri A. Becker, and the Father, David J. Becker,
shall have shared legal custody of lCaitlin Becker, born November 16, 1989,
and Jordan Becker, born March 25, 1994. Each parent shall have an equal
right, to be exercised jointly with the other parent, to make all major
non-emergency decisions affecting the Children's general well-being
inCluding, but not limited to, all decisions regarding their health,
education end religion.
2. The Mather shall have primary physical custody of the Children.
3. The Father shall have partial physical custody of the Children on
alternating weekends from Friday at 6:00 p.m. through Monday at 8:00 a.m.,
beginning Friday, June 23, 2000. During weeks fallowing the Father's
weekend period of custody, the Father shall also have custody of the
Children an Thursday fran 5:30 p.m. through 8:00 p.m. during the school
year end through 8:30 p.m. during the summer school break. During weeks
fallowing the Mother' s weekend period of custody, the Father shall have
custody of the Children an Tuesday and Thursday evening fram 5:30 p.m.
through 8:00 p.m. during the school year end through 8:30 p.m. during the
SUllUUE!r school break.
4. The parties shall share or alternate having custody of the
Children an holidays as follows:
A. CIlRIm1'!AS: The Christmas holiday shall be divided into
Segment A, which shall = fram Christmas Eve at 12:00 noon
through Christmas Day at 12:00 noon and Segment B, which shall
run frcm Christmas Day at 12:00 noon through December 26 at
12:00 noon. In even numbered years, the Father shall have
custody of the Children during Segment A and the Mother shall
have custody during Segment B. In odd numbered years, the
Mather shall have custody of the Children during Segment A and
the Father shall have custody during Segment B.
B. TBl\NKSGIVING: In every year, the Mather shall have custody of
the Children on Thanksgiving Day until 2:00 p.m. and the
'I ~BIT 1
Father shall have custody from 2:00 p.m. nntil 8:30 p.m. on
Thanksgiving.
c. EAS:rER: The Easter holiday shall be divided into Segment A,
which shall run from 12:00 noon on the Friday before Easter
through 12:00 noon on the Saturday before Easter and Segment
B, which shall run from noon on the Saturday before Easter
through 12:00 noon on Easter SUnday. In even numbered years,
the Mother shall have custody of the Children during Segment A
and the Father shall have custody during Segment B. In odd
numbered years, the Father shall have custody of the Children
during Segment A and the Mother shall have custody during
Segment B.
D. FATHER'S DAY/M:Jl'IlER'S DAY: The Father shall have custody of
the Children every year on Father's Day and the Mother shall
have custody of the Children every year on Mother's Day from
8:00 a.m. nntil B:DO p.m. Notwithstanding the foregoing, in
2000, the Father shall have custody of the Children for
Father's Day from Saturday, Jnne 17 when the Mother returns
from vacation with the Children through sunday, June 18 at
8:00 p.m.
E. The parties shall have custody of the Children on the
remaining holidays as arranged by agreement.
F. The holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
G. In the event the Father's period of holiday custody falls
irn:nediately before or after his regular period of custody, the
Father's holiday/regular period of custody shall run
continuously.
5. Each party shall be entitled to have custody of the Children for 2
non-consecuti ve weeks for vacation, which shall be scheduled during the
summer school break unless otherwise agreed between the parties. The
parties shall schedule extended periods of custody under this provision to
fall immediately before or after that party's regular weekend period of
custody. Each party shall provide the other party with at least 30 days
advance notice of his or her selection of dates under this provision. The
party providing notice first shall be entitled to preference in his or her
selection of vacation dates.
6. The party receiving custody of the Children shall be responsible
to provide transportation for the exchange of custody unless otherwise
agreed between the perties.
7.
telephone
parent or
The non-custoClial parent shall be entitled to have reasonable
contact with the Children which may be initiated either by the
the Children.
8. The parties shall cooperate and work together in making any
necessary adjustments to the custody schedule and in addressing issues
concerning the Children.
9. 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 =nsent. In the absence of mutual =>sent, the terms
of this Order shall control.
BY TEE OOURT I
151-1, (..Jy c0L 1 J.
cc: Samuel L. Andes, Esquire - Counsel for Mother
Laurie A. Saltzgiver, Esquire - Counsel for Father
LAURI A. BECKER, : IN THE COURT OF CDMMON' PLEAS OF
Plaintiff : CUMBERLAND COtJNTY, PENNSYLVANIA
:
vs. : NO. 00-1706 CIVIL TERM
:
DAVID J. BECKER, : CIVIL AcrION' - LAW
Defendant : IN CUSTODY
~"".I.UlJY CCtilCILIATIW SOMMl\RY REPCRI.'
IN Aca:IIDANCE WITH cnmERLl\ND CCXlNTY RULE OF CIVIL PROCEOORE
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF IlJRl'H
C!lRRml'Ly IN ~"".I.UlJY OF
Kai tlin Becker
Jordan Becker
November 16, 1989
JI',arch 25, 1994
Mother
Mother
2. A Conciliation Conference was held on June 8, 2000, with the
following individuals in attendance: The Mother, Lauri A. Becker, with her
counsel, Samuel L. Andes, Esquire, and the Father, David J. Becker, with
his counsel, Lauri A. Saltzgiver, Esquire.
3. The parties agreed to entry of an order in the form as attached.
Date
J/A'ltJ
~ ,,? &Y>f)
{d<s~
Custody Conciliator
LAW OFFICES
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STRm
P.O. BOX 1062
l. EMANUEL MEYERS (1915-1970)
BRUCE: D. DES FOR
LAURIE A. SALTZGIVE.R
CATHERINE A. BOYLE.
HARRISBURG. PA. 17108
(717) 236-9428
FAX (717) 236-2817
July 21, 2000
VIA FAX & U.S. MAIL
Samuel Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
RE: Becker
Dear Sam:
Please be advised that my client would like to ~ave ~is
weeks of summer vacation during the week of July 31, 2000 until
August 7, 2000 and the week of August 14, 2000 until August 21,
2000.
Thank you for your attention.
Sinceyely,
'\ \ \ . " ,
~". ." .... :. 1_:, ,-\
~, . ,-'..... ~ '-./'
Laurie A.........
I
,1
(
,
'---
"
~ci.1tzg~ver
"
'.
LAS/clk
cc: David Becker
EXHIBIT
I 8
LAW OFFICES
MEYERS, DESFOR, SALTZGIVER & BOYLE
0410 NORTH SECOND STREET
P.O. BOX 1062
I. EMANUE.L ME.YERS (\9\S.1970)
BRUCE o. OESFOR
LAURlE. A.. SALTZGlVER
CATHERINE: A. BOYl-E
HARRISBURG, PA. 17108
(7171 23e;..942.B
F'AX (717) 236-;::617
July 26, 2000
VIA FAX & U.S. MAIL
Samuel Andes, Esquire
ATTN: Lynn Ehrenfeld
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
RE: Becker
Dear Lynn and Sam:
I am addressing this letter to Lynn as I am aware that Sam
is presently out of town on vacation. I am aware that Lynn has
forwarded my letter of July 21, 2000, which specifies my client's
weeks of vacation time, to Lauri. Since Lauri has not provided
any information regarding the children's availability, Dave will
pick the children up on Monday morning, July 31, 2000 at 10:00
a.m. for his first week of vacation. Please advise Lauri, as
such.
Thank you for your attention.
LAS/clk
cc: David Becker
(~~~~aLivar'
//
/'
V
EXHIBIT
J l-,
I,
"
I'
II I
;i i
'I I
I' '. "ovid .'. Be",", VERmCArrOl' . verify <ha. <he I
111,OSFtatements made in this PRTITION FOR r.ONTRMPT ANn FOR MonTFICATIO~
CUSTODY ORDER are true and correct to the bes1
I of my knowledge, information and belief. I understand that fals,
I statements herein are made subject to the penalties of 18 Pa. I
I, C. S. Section 4904, relating to unsworn falsification to I
'I I
~ authorities. !
II
i'
:1 Dated:
'I
11
Ii
I
,
:1
,
R/g/OO
~Lldd-.
"
Plaintiff
(X
Defendant
MEYERS, DESFOR, SAl TZGIVER & BOYLE
410 NORTH SECOND STRE:ET . P_O. sox 1062 . HARRISBURG, PA 17108
(717) 236-9428 . fAX (717) 236-2817
II
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
CERTIFICATE OF SERVICE
I hereby certify on this 9th day of Auqust, 2000, that a
copy of the foregoing Petition for Contempt and for Modification
of Custody Order was mailed, first-class, postage pre-paid to:
Samuel Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
MEYERS, DESFOR, SALTZG1VER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9428 . FAX (717) 236-2817
~I
LAURI A. BECKER,
Plaintiff
vs.
)
}
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 00-1706
DAVID J. BECKER,
Defendant
IN CUSTODY
ANSWER AND CROSS PETITION FOR MODlEl!d\TIQN Qf CUSTODY ORDER
AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and
makes the fOllowing Answer to the Plaintiff's Petition and her own Cross Petition for
Modification, all based upon the following:
1 through 5. Admitted.
6. Denied. It is admitted that Defendant had the children at his place of employment
where they were not properly supervised. Following a disagreement with her father, the
daughter, Kaitlin, called Plaintiff and asked her to come see her. Sensing that the children
were extremely upset and being concerned for their well-being, Plaintiff went to a location
near Defendant's place of business in an effort to speak to the children to calm them down.
Defendant became argumentative and belligerent when he saw Plaintiff and called the police
to whom he made false claims about Plaintiff's conduct. The other averments set out in
Paragraph 6 of Defendant's Petition are denied.
7. Denied. Plaintiff did not attempt to interfere with Defendant's period of
temporary custody and came to Defendant's place of business only to mollify the children
who were extremely upset and worried.
8. Denied. Plaintiff has not denied Defendant's telephone access to the children. To
the contrary, Defendant has refused to permit the children to call Plaintiff or to have
reasonable contact with Plaintiff when the children are in his temporary custody.
.1
9. Denied. Plaintiff denies that she has interfered with Defendant's relationship with
the children and further specifically states:
a. Plaintiff has not made such statements about Defendant. The
children have reached their own conclusions about Defendant based upon his
conduct in their presence.
b. Although it is admitted that Plaintiff has advised the children that
they need not shower at Defendant's home, she has done that only because
the children have expressed concern about the cleanliness of the Defendant's
home and bathroom. Plaintiff has not advised the children that they do not
have to obey Defendant or that she has made any statements to the effect that
she would have the Defendant arrested.
c. Denied. Plaintiff has not made such statements about Defendant.
Defendant has a difficult time with the children, particularly the parties'
daughter, because of his own misconduct in the children's presence.
d. Denied as stated. Plaintiff denies that she makes obscene gestures
or statements to Defendant or in his presence. To the contrary, it is Defendant
who is guilty of such conduct directed at Plaintiff.
e. Denied. Plaintiff has not Mmade a scene" during custody exchanges.
Plaintiff admits that the parties have disagreed and exchanged unpleasant
words during those exchanges but states that Defendant himself is guilty of
that conduct and causes it by his own misconduct.
f. Denied. Plaintiff has consulted a psychologist, who has met with the
children and with Defendant himself, for guidance in assisting the children
through the difficult time the children are having with the periods of the
Defendant's temporary custody. Defendant is aware of that process and has
cooperated in it.
-*.
g. Defendant is aware of the children's activities and Plaintiff has not
involved the children in the regular activities without Defendant's knowledge.
10. Denied. Plaintiff wants the children to have a calm and good relationship with
Defendant so as to reduce the trauma in their lives and reduce the problems such trauma
causes for her. Plaintiff has not done anything to interfere with Defendant's relationship
with his children.
11. Admitted.
12. Admitted. By way of further answer, however, Plaintiff states that she and the
children have had the same week for vacation for a period of five years or more, that
Defendant knows that, and that Plaintiff's request for that week of vacation time was
anticipated by, and knowing in advance to, Defendant.
13. Admitted. However, Defendant's notice was inadequate because it was not
timely (coming many weeks after Defendant had a full opportunity to give the thirty days
notice) and did not advise Plaintiff of where the children would be or how they could be
contacted.
14. Plaintiff's counsel was unavailable to assist in resolving the problem of the
summer visitation. Unfortunately, Defendant's counsel just unilaterally issued a ultimatum
that Defendant would take the children.
15. Plaintiff does not know whether the Defendant appeared at her residence but
acknowledges that the children did not go with the Defendant at the time he demanded to
have them.
16. Plaintiff denies that she has attempted to interfere with the Defendant's
relationship with the children or that Defendant should have additional time with them. The
averments set out in Plaintiff's Cross Petition are incorporated herein by reference.
17. The averments set out forth in Paragraph 16 above are incorporated herein by
reference.
,- ))
18. Denied. Plaintiff has not violated the custody order in this matter and has not
attempted to thwart the Defendant's attempts to have a relationship with the children.
Defendant should not be given additional time with the children. The averments set forth in
Plaintiff's Cross Petition are incorporated herein by reference.
WHEREFORE, Plaintiff prays this court to deny Defendant's Petition, including his
request for counsel fees, and to modify the custody order in accordance with her Cross-
Petition.
CROSS PETITION FOR MODIFICATION OF CUSTODYORDERANQ~EQa
PSYCHOLOGICAL EXAMINATION OF THE PARTIES AND CHILDREN
19. Defendant, by his own conduct, has impaired his relationship with his children.
Defendant's conduct includes, but is not limited to, the following:
A. Defendant takes the children to his place of employment during his
periods of temporary custody, takes them along on business calls and trips he
makes during those periods of time, and generally fails to supervise them and
to make any effort to provide an enjoyable experience for them while they are
with him.
B. Defendant refuses to take the children to their regularly-scheduled
activities or to permit them to participate in those activities during his periods
of temporary custody.
C. Defendant makes little or no effort to participate in enjoyable
activities with the children or to entertain them or have fun with them while
they are in his temporary custody.
D. Defendant fails to maintain his home in a clean and orderly fashion,
to the extent that the children are uncomfortable staying at Defendant's home.
E. Defendant loses his temper in the presence of the children, raises his
voice and shouts at them, verbally abuses them, and generally terrorizes them
when he loses his temper.
~ )
F. Defendant has physically abused the children by slapping them and by
hitting the daughter Kaitlin with other objects.
G. The Defendant, by his conduct, has made the children afraid of him
and afraid to speak candidly and open with him.
20. As a result of the conduct of Defendant, the younger child is afraid to stay at the
Defendant's home without his older sister and the parties' daughter is afraid of the
Defendant and does not wish to be in his presence or stay at his home.
21 . Defendant has aggravated the problems described above by demanding that the
children obey the letter of the custody order and by becoming angry at them when they
show any reluctance or hesitation to do so.
22. Defendant has refused to allow the children to communicate with Plaintiff during
the times that he has them in his temporary custody.
23. Defendant has verbally argued and fought with Plaintiff in the presence of the
children, which has further aggravated_the problems he has in his relationship with the
children.
24. Plaintiff believes that Deferiifiuif requires the intervention and advise of a
professional to help him deal with problems he is experiencing, which problems include, but
are not limited to:
A. The Defendant's failure to control his temper and anger; and
B. The Defendant's inability to understand what the children need from
him so that he can provide that in such a way to establish a healthy parent-
child relationship; and
c. An ability to cooperate with Plaintiff as a co-parent in raising the
children and shielding them from the disputes between Plaintiff and Defendant.
25. Plaintiff further believes that the children require the intervention and assistance
of a professional to help them deal with the problems they are experiencing in the current
, I
custody arrangement, particularly those problems caused by the anger and unreasonableness
of the Defendant.
26. Plaintiff believes that the children are suffering irreparable, emotional,
psychological, and personal harm as a result of Defendant's conduct and the disruption that
conduct has worked upon the children's relationship with the Defendant.
WHEREFORE, Plaintiff prays this court to take the following actions:
A. Modify the current custody order to reduce the Defendant's time
with the children and to suspend overnight visitations with the children until
they are better able to adjust to the present situation and form a better parent-
child relationship with Defendant; and
B. Direct both parties and the children to meaningfully participate in
family counseling, including anger management instruction for Defendant, in an
effort to reduce the friction between Plaintiff and Defendant, to protect the
children from the stresses they are under as a result of the current custody
situation, and to assist the children in dealing with the problems the Defendant
causes in his relationship with them; and
C. Such other action as the court deems appropriate or necessary for
the protection of, and in the best interest of, the parties' children.
~~~
Samuel l. Andes
Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
-
.
COMMONWEALTH OF PENNSYLVANIA
}
( 55.:
)
COUNTY OF CUMBERLAND
LAURI A. BECKER, being duly sworn according to law, deposes and says that the
Answer & Cross Petition
facts set forth in the foregoing are true and correct to the best of her
knowledge, information, and belief.
h~
. BECKER
Sworn to and ~scribed
be{.o[e me this f-t~day
of .:::::.e~\fi.-\. 2000.
~~~~l U--
Notary Pu lie. ~_"'.'''_.'_
1<<.n1iRiAl. S$AL
~\w.~~~~PA
Q..::: r ~_ .~~~!~....~,~4..--of.?rl, ~
~ ." - - .' -~ . ". ....".-..,
-', .
.
.
"
CERTIFICA TE OF SERVICE
I hereby certify that I served an original of the foregoing Answer and Cross
Petition for Modification of Custody order upon counsel for the Defendant herein by
regular mail, postage prepaid, addressed as follows:
Laurie A. Saltzgiver, Esquire
410 North Second Street
Harrisburg, P A 1 71 08
Date: \\.,~ ~
~>- .~,9,
Samu L. Andes .
Attorney for Plaintiff
<
.
....
.
LAURI A. BECKER, : IN THE COURT OF cx:t1M0N' PLEAS OF
Plaintiff : CUMBERLAND CXXJNTY, PENNSYLVANIA
:
vs. : NO. 00-1706 CIVIL TERM
:
DAVID J. BECKER, : CIVIL ACTION' - LAW
Defendant : IN CUSTODY
aIDER OF <nJaT
AND ~,this ;4S(t, clay of , 0 r...-'t:L<:)
upon consideration of the attached CuStodY CO~~;1iat~on
ordered and directed as follows:
, 2000,
Report, it is
1. The parties .shall submit themselves and their minor Children to a
custody evaluation to be performed by a professional selected by the Father
at the Father's sole cost. The parties shall sign any authorizations
deemed necessary by the, evaluator' in order to cbtain additional information
pertaining to the parties or the '-Ch,ildren. The Mother shall cooperate in
completing the evaluation process and shall make herself and the Children
available for all necessary sessions.
2. The parties shall ensure that Kaitlin continues in her current
course of counseling with Sally Rooney.
3. Pending further order of Court or agreement of the parties, the
prior Order of this Court dated June 20, 2000 shall continue in effect.
4. Within 60 clays of receipt of the evaluator's written
reCOlmllendations, counsel for either party may contact the Conciliator if it
is necessary to schedule an additional Custody COnciliation COnference.
BY THE COURT,
=:
samuel L. Andes, Esquire - COunsel for Mother .. . . ;. .1
" c...u.u;. /r~
Laurie A. Saltzgiver, Esquire - COunsel for Father / r
)tJ' oU,. /rO
....,...,'"'
FiLEO-{;CFICE
OF -,., ,,' c,-- --- ',-' 'OT'AlR'"
irp'--, "'~'_ 'I 'J.,N, .f'\i. I
00 OCT 26 PM 2: 1 6
CUMBERLAND COUf'ffi'
PENN::.11.VANIA
,
~'
LAURI A. BECKER, : IN THE COURT OF COMMON' Pr.EAS OF
Plaintiff ~ CUMBERr.AND caJNTY, PENNSYI,VANIA
:
vs. : NO. 00-1706 CIVIr. TERM
:
DAVID J. BECKER, : CIVIr. ACTION - LAW
Defendant : IN CUSTODY
PRICR JUDGE: J. WESLEY CLER, .JR.
"ISI(;OY CY'N('TT.Tl>.'l'TCH ~ REPCRr
IN ACXn<<lANCE WITH <nmERLAND ClJCH'l'Y RIlLE OF crvn. PROCEDURE
1915.3-B, the tindersigned Custody COnciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN c.....",.....uu:l OF
Kaitlin Becker
Jordan Becker
November 16, 1989
March 25, 1994
Mother
_Mother
2. A Conciliation Conference was held on September 26, 2000, with the
following individuals in attendance: The Mother, Lauri A. Becker, with her
counsel, Samuel r.. Andes, Esquire, and the Father, David J. Becker, with
his counsel, Laurie A. Saltzgiver, Esquire.
3. The parties agreed at the Conference to have a custody evaluation
performed. However, the Mother's counsel requested that the conciliator
retain the proposed Order for a couple of days to enable the Mother to
determine whether she would agree to share the costs of a joint evaluation
or to participate in an evaluation obtained at the Father's expense. The
conciliator was subsequently advised that the Mother is financially uniilile
to share the evaluation costs. Acoordingly, the Conciliator recorrnnends an
Order in the form as attached.
CJcNbv. ..2fl.~
Date I
DatQ~
custody conciliator
LAURI A. BECKER
PLAINTIFF
V.
DAVID J. BECKER
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00.1706 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COFRT
AND NOW, Friday, June 01, 2001 . upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Monday, June 18, 2001 at 10:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Is!
Dawn s. Sund~. Esq. ~I\,
Custody Conciliator i
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 an'angements
must be made at least n hours prior to any hearing or business before the court. You must attend the
scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFI'ORD 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
l:" _ f'!ED-DfFICE
0, ,[.,.... ppry[' 'rJN01',n
..";:" It'.n.Y
Of JUN - 5 PM I: r 2
CUMBERlfND COO
PENNSYD/ANIA N1Y
)
';u',?f M- ~ _/#.:.dr -F .dIt ~
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.
!)
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER OF COURT
AND NOW, . , upon consideration
of the attached complaint, it is hereby directea that the
parties and their respective counsel appear before
FOR THE COURT,
By:
Custody Conciliator
The Court of Common Pleas of Cumberland County is required
by law to comply with the Americans with Disabilities Act of
1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals
having business before the court, please contact .our office.
All arrangements must be made at least 72 hours prior to any
hearing or business before the court. You must attend the
scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
OFFICE OF THE COURT ADMINISTRATOR
Cumberland County Courthouse
One Courthouse Square, 4th Floor
Carlisle, Pennsylvania 17013
(717) 240-6200
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTI-I SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108
(717) 236-9429 . FAX (7f7) 23E>>2S17
II
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
PETITION FOR CONTEMPT
AND NOW, comes Defendant, David J. Becker, by and through
his attorneys, Meyers, Desfor, Saltzgiver & Boyle and files the
following Petition for Contempt and in support thereof avers as
follows.
1. Petitioner is David J. Becker, Defendant in the above-
captioned action.
(hereinafter "Father").
2. Respondent is Lauri A. Becker, Plaintiff in the above-
captioned action.
(hereinafter "Mother").
3. The parties are the parents of two minor children namely
Kaitlin Becker, date of birth 11/16/89 and Jordan Becker,
date of birth 3/25/94.
4. The parties attended a conciliation conference before Dawn
Sunday, Esquire on June 8, 2000 and reached an agreement
which became an Order of Court dated June 20, 2000.
(See
Exhibit "A").
5. Pursuant to the Order of June 20, 2000, paragraph 3, Father
is provided alternating weekends of partial physical
custody with the children, as well as one or two evenings
during the week. The weekend of May 11-13, 2001 was
Father's alternating weekend of custody.
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG. PA 17108
(717) 23$-9428 . F'AX (717) 236~261'7
6. On Saturday, May 12, 2001, both children had various
activities.
Kaitlen had a soccer and a baseball game and
Jordan, also had a baseball game.
7. In addition to the children's activities that Saturday, May
12, 2001, was the Penndot dump truck and equipment auction
on the farm show grounds.
Father is self-employed in two
businesses namely, Becker's Service Center and Camp Hill
Auto and Truck. Father's businesses engage in auto and
truck repair as well as towing and snow removal.
Father
intended to attend the penndot auction on Saturday, May 12,
2001 in the hopes of purchasing a dump truck.
The parties'
son, Jordan, was excited about the auction and wanted to
bid on the dump trucks with his Father.
8. Mother was well aware of Father's plans that weekend and
his intention to attend the auction.
Jordan's baseball
game started at 1:00 p.m.
Father left the game early to
attend the Penndot auction, however, Father's parents, the
children's grandparents, were in attendance at the game.
The children were aware that after Jordan's baseball game,
the grandparents were taking them to their Father at the
auction.
Jordan hoped to make it to the auction in time to
bid on the dump trucks with his Father.
9. After Jordan's game was over, Mother told the children they
were not going with their grandparents, and since their dad
was not there, she was taking them with her. Mother
3
MEYERS, DESFOR. SALlZGlVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108
(717) 2'36-&428 . FAX (717) 236-2817
informed Father's parents that because Father was not
there, she was taking the children with her.
10. Father's parents, the children's grandparents, became
concerned and contacted Father at the auction.
Father left
the auction and went to Mother's home to retrieve the
children. When Father retrieved the ~hildren, Mother
laughed in his face because she knew he missed the auction
and the chance to bid on cheap equipment.
Father reminded
her that Jordan was excited to bid on the dump trucks with
him.
Mother did not care that Jordan was disappointed and
advised Father that now no one could bid on the dump
trucks.
11. Father believes that Mother is in contempt of the Court
Order of June 20, 2000 by interfering with his alternating
weekend of custody with the children.
12. Additionally, the Court Order of June 20, 2000 provides
vacation time for the parties and their children,
specifically in paragraph number 5.
13. Pursuant to paragraph 5 of the Order of June 20, 2000, each
party is entitled to have two nonconsecutive weeks of
vacation time with the children, which are to be scheduled
over the parties' regular weekend period of custody.
14. Since the parties are also required to provide each other
with thirty (30) days advance notice of vacation time,
Mother advised Father that she wanted Friday, June 8
4
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9429 . FAX (717) 236-2S17
II
through Saturday, June 16th for vacation time.
15. Mother scheduled her vacation time over Father's
alternating weekend of custody in June and therefore,
Father will not see the children for at least three weeks.
16. Father advised Mother that she was in violation of the
Order, by scheduling her vacation time in such a manner,
and further advised that while he believed she was in
violation of the Order, in an effort to be flexible, Father
would permit Mother to have that vacation period provided
she provided him with a make-up weekend of custody with the
children.
(See Exhibit "B").
17. Mother refused to cooperate with Father's request.
(See
Exhibit "Cn).
18. Father believes that Mother's insistence upon the scheduled
vacation time is in blatant violation and contempt of the
Court Order of June 20, 2000.
19. Father had difficulty in retaining vacation~time during the
Summer of 2000 and accordingly, Father filed a Petition for
Contempt and for Modification of Custody Order on August
14, 2000. Said Petition remains pending and the parties
are engaged in a custody evaluation.
20. Wherefore, in light of all of the above, Father requests
this Honorable Court find Mother in contempt of the Custody
Order of June 20, 2000, award Father additional periods of
custody as the Court may deem appropriate, and impose fines
5
MEYERS, DESFOR. SALlZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(117) 236-9428 .. FAX (717) 236-l;!817
Ii
and sanctions upon her as well as reimburse Father for his
attorney fees incurred in bring the within Petition.
WHEREFORE, in light of all of the above, Father requests
this Honorable Court find Mother in contempt of the Custody
Order of June 20, 2000, award Father additional periods of
custody as the Court may deem appropriate, and impose fines and
sanctions upon her as well as reimburse Father for his attorney
fees incurred in bringing the within Petition.
Respectfully submitted,
Laurie A. S 1
MEYERS, DESFO
& BOYLE
Attorney I.D. #61382
410 North Second Street
P.O. Box 1062
Harrisburg, PA 17108
(717) 236-9428
Attorney for Petitioner
MEYERS, DESFOR. SALTZGIVER & BOYLE
410 NORm SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108
(717) 2~6-9429 FAX (717) 236-2917
,
LAURI A. BECKER, : IN THE CXJURT OF COMMa:! PLEAS OF
Plaintiff : CUMBERLAND CXXJNTY, PENNSYLVANIA
:
vs. : NO. 00-1706 CIVIL TERM
:
DAVID J. BECKER, : CIVIL AC:!'ION' - LAW
Defendant : IN CUSTODY
C1lDER OF CCXJRT
AND~, this cJOth day of ~~\\l ~I"\e.. , 2000, upon
consideration of the attached Custody Conc IJ.at~on Report, it is ordered
and directed as follows: ~ -
1. The Mother, Lauri A. Becker, and the Father, David J. Becker,
shall have shared legal custody of Kaitlin Becker, born November 16, 1989,
and Jordan Becker, born March 25, 1994. Each parent shall have an equal
right, to be exercised jointly with the other parent, to make all major
non-emergency decisions affecting the Children's general well-being
including, but not limited to, all decisions regarding their health,
education and religion.
2. The Mother shall have primary );hysical. custody of the Children.
3. The Father shall have partial physical custody of the Children on
alternating weekends frem Friday at 6:00 p.m. through Monday at 8:00 a.m.,
beginning Friday, June 23, 2000. During weeks following the Father's
weekend period of custody, the Father shall also nave custody of the
Children on Thursday fran 5:30 p.m. through 8:00 p;m. during the school
year and through 8:30 p.m. during the summer sChool break. During weeks
following the Mother I s weekend period of custody, the Father shall have
custody of the Children on Tuesday and Thursday eVening frotn 5:30 p.m.
through 8:00 p.m. during the school year and through 8:30 p.m. during the
stllIllIl8r school break.
4. The parties shall share = alternate having custody of the
Children on holidays as follows:
A. CBIlTm>M"'::' The Christmas holiday shall be divided into
Segment A, which shall run !rem ChristIrias Eve at 12:00 noon
through Christmas Day at 12:00 noon and Segment B, which shall
run fran Christmas Day at 12:00 noon through December 26 at
12:00 noon. In even numbered years, the Father shall have
custody of the Children during segment II and the Mother shall
have custody during Segment B. In odd numbered years, the
Mother shall have custody of the Children during Segment A and
the Father shall. have custody during Segment B.
B. iWINKSGIYJ:NG: In every year, the Mother shall have custody of
the Children on Thanksgiving Day until 2:00 p.m. and the
EXHIBIT
r
A
Father shall have custody from 2:00 p~m. until 8:30 p.m. on
Thanksgiving.
c. EASTER: The Easter holiday shall be divided into Segment A,
which shall run from 12:00 noon on the Friday before Easter
through 12:00 noon on the saturday before Easter and Segment
B, which shall run from noon on the saturday before Easter
through 12:00 noon on Easter Sunday. In even numbered years,
the Mother shall have custody of the Children during Segment A
and the Father shall have custody during segment B. In odd
numbered years, the Father shall have custody of the Children
during Segment A and the Mother shall have custody during
Segment B.
D. FATHER'S DAY/MOTHER'S DAY: The Father shall have custody of
the Children every year on Father I s Day and the Mother shall
have custody of the Children every year on Mother's Day from
8:00 a.m. until 8:00 p.m. Notwithstanding the foregoing, in
2000, the Father shall have custody of the Children for
Father's Day from Saturday, June 17 when the Mother returns
from vacation with the Children through SUnday, June 18 at
8:00 p.m.
E. The parties shall have custody of the Children on the
remaining holidays as arranged by agreement.
F. 1he holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
G. In the event the Father's period of holiday custody falls
irrnnediately before or after his regular period of custody, the
Father's holiday/regular period of custody shall run
=ntinuously.
5. Each party shall be entitled to have custody of the Children for 2
non-consecutive weeks for vacation, which shall be scheduled during the
summer school break unless otherwise agreed between the parties. The
parties shall schedule extended periods of custody under this provision to
fall inunediately before or after that party's regular weekend period of
custody. Each party shall provide the other party with at least 30 days
advance notice of his or her selection of dates under this provision. The
party providing notice first shall be entitled to preference in his or her
selection of vacation dates.
6. 1he party receiving custody of the Children shall be responsible
to provide transportation for the exchange of custody unless otherwise
agreed between the parties.
7. 1he non-custodial parent shall be entitled to have reasonable
telephone =ntect with the Children which may be initiated either by the
parent or the Children.
8. 1he parties shall cooperate and work together in making any
necessary adjustments to the. custody schedule and _in addressing issues
concerning the Children.
9. This Order is entered pursuant to an agreement of the parties at a
CUstody Ccnciliation 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 OJURT,
151-1.. f.J,t- cDJ,,) ,.
co: Samuel L. Andes, Esquire - Ccunsel for Mother
Laurie A. Saltzgiver, Esquire - Ccunsel for Father
yo.;.. ...........,~.
.. .-r-
Protho/lO'fary .
LAURI A. BECKER, : IN THE COURT OF COMMON' PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : NO. 00-1706 ClVIL TERM
:
DAVID J. BECKER, : CIVIL ACl'IOO - LAW
Defendant : .IN COSTODY
UJ>>LuJY cx:.NCILIATIrn SUMMARY REJ?CRr
IN ACCCIIDANCE WITH cnmE:RLAND COJNTY RULE OF CIVIL PRCCEDURE
1915.3-8, the undersigned CUstody Conci1iat= submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF BIRTH
OJRRENTLY IN aJSTODY OF
Kaitlin Becker
Jordan Becker
November 16, 1989
March 25, 1994
Mother
Mother
2. A Conciliation Conference was held on June 8, 2000, with the
following individuals in attendance: The Mother, Lauri A.. Becker, with her
counsel, Samuel L. Andes, Esqu:l:re, ana the Father, David J. Becker, with
his counsel, Lauri A_ Saltzgiver, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date
cL~o
q ~()
I
{l~s~
CUstody Conciliator
LAW OFFICES
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STRE:E:T
P.O BOX 1062
I. EMANUEL MEYERS n91S-1970l
BRUCE p, DESFOR
LAURIE A. SAL TZGIVER
CATHERINE: A. BOYLE
HARRISBURG, PA. 17108
(717) 236-9428
FAX.{717J 236-2617
WEBS1TE www.meyersdesfor.com
EMAIL lsa!tzQiverCmeyersdesfor.com
cboyleCmeyersdesfor.com
May 1, 2001
VIA FAX & U.S. MAIL
Samuel Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
RE: Becker v. Becker
Dear Sam:
Dave has advised that Lauri has given him notice that she
wants to take vacation with the children from Friday, June 8th
until Saturday, June 16th. She has scheduled her week of
vacation over Dave's weekend with the children, accordingly Dave
would not see the children for three weekends in a row. That
arrangement is contrary to the Order of J~~e 20, 20QO, paragraph
5. According to the Order, the parties are to schedule their
vacation time over their Qwn weekend of custody. However, if
Lauri has already made reservations for that time, Dave is
agreeable to permit her to have this vacation time, provided he
gets a make-up weekend with the children over the weekend of June
1st, 2nd and 3rd. I believe thac this is more than fair under
the circumstances, and provides an amicable resolution for
everyone.
Thank you for your attention. . Please contact me.
Sincerely,
~~a
4
tzgiver
LAS/cay
cc: David Becker
EXHIBIT
I
B
SA.MUEL L. ANDES
ATTORNEY AT LAW
15.2~ NORTH TWELFTH STREET
P. O. :BOX 168
LEMOYNE, PENNSYLVANIA 17043
TELEPHONE
(717) 761-15::131
9 May 2001
FAX
(7171 761'143~
Laurie A. Saltzgiver, Esquire
410 North Second Street
Harrisburg, PA 17101
RE: Becker - Custody
Dear Laurie:
I reviewed your letter of 1 May 2001, with Lauri Becker regarding her vacation. I
simply do not agree with your interpretation of the existing order. All that order requires
is that each party take their week of vacation adjacent to one of their weekends. If
they comply with the order. there is no way that the week of vacation will not deprive
the other parent of one weekend of their regular schedule of custody. It simply cannot
work any other way.
Moreover, my client has arranged her schedule so that she actually has the
children for less than a week. She plans to return from her vacation late Saturday night
so the children can spend Father's Day with your client. Everything concemed, it
appears that she is actually taking less than a full week of her vacation as
contemplated by the order. -
Finally, this is the arrangement the parties have had for several years and your
client has not complained before. In fact, she fook her week's vacation at the same
time last year and, although there was a dispute about Father's Day itself, your client
did not protest her taking her weeks vacation last year the same way she intends to
take it this year.
Having said all of that, I do not believe your client is entitled to a "make-up"
weekend. I suggest that he make up any "lost" time by taking his vacations the same
way my client does. In that way, each of the parties will have the children for a long
enough time to enjoy a reasonable vacation with them, and neither party will owe the
other any "make.up" time.
Sincerely,
~
Samuel L. Andes
amh
EXHIBIT
cc: Lauri A. Becker
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VERIFICATION
i'
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David Becker
r verify that tee
I,
statements made in this petition for Contempt
aye crue and correct to the bes~
of c.y knowledge, infor~a=io~ a~c te_~e=.
~ ~~=srsL&~d t~o~ fa~s2
sta~e~e~ts herei~ are ~aje s~tjes~ LC :~~
.. -
!=-2:-.~~:2.es ::::
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c.s. Section 4904, rEla~i~g LO u~s~=r~ f~lsi:ica~icr. tc
autr..orities.
1Jate:i:
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:;::"&.:..:-_:..:.::f
XI Ce.:-:=:-.c:a.:1t
MEYERS, DESFOR. SALTZG1VEA & SOYLE
4'10 NORTH SEconD STREET . po BOX 10&2 . H,t.P,R1SBUFG PA 17~08
!717l23F.'9428 . FAX (717) 236-2817
Ii
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
CERTIFICATE OF SERVICE
I hereby certify on this ~ day of Mav, 2001, that a copy
of the foregoing Petition for Contempt and for Modification of
Custody Order was mailed, first-class, postage pre-paid to:
Samuel N1des, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108
(717) 236-9428 .. FAX (717) 236-2817
"
.
LAURI A. BECKER, : IN THE COURT OF o::lMMal PLEAS OF
Plaintiff : CUMBERLAND CXXlNTY I PENNSYLVANIA
:
vs. : NO. 00-1706 CIVIL TERM
:
DAVID J. BECKER , : CIVIL ACrICIil - LAW
Defendant : IN CUSTODY
aIDER OF a::.uRT
AND NCK, this '\.;....
consideratico of the attached
and directed as follows:
day of ),.~v ~_
CUstody Conciliatico Report,
, 2001, upon
it is ordered
1. The prior Orders of this Court dated June 20, 2000 and the
subsequent Order entered in July, 2000 shall continue in effect- as modified
by this Order.
2. The parties shall engage in a course of counseling with Deborah L.
Salem, MRS, CAe, includin;j at a minimum, one separate session for each
party and two joint sessions. The purpose of the counseling shall be to
assist the parties in establishin;j sufficient ccmnunication, cooperation
and conflict resolution skills to enable them to effectively coparent their
Children. Each party shall be responsible to pay one-half of all costs
which are not covered by insurance. Each party shall contact the oounselor
within two weeks frcxn the date of the CUstody conciliatico conference to
schedule the first session.
3. The Father's periods of vacation custody during the summer school
break in 2001 shall run from 6:00 p.m. on July 27 through 6:00 p.m. on
August 5 and, fran 6:00 p.m. on August 16 through 6:00 p.m. on August 25.
4. Each party shall provide advance notice to the other party of the
address and telephone rnJmber where the Children can be contacted during
vacation periods.
5. The noncustodial parent shall be entitled to have one telephone
contact per day with the Children with the exceptico of emergencies. In
the event a party provides the Children with a cellular phone in order to
effectuate this provision, the custodial parent shall ~J:jtit the Child to
retain the phone and to have the phone remain on for ~es of compliance . 1
with this provision. . - .Y fir tfJd.;l..d...
BY TJlE OOURTt Lt.)$ -0 I l Rj{ 5
\ V'"11./)
Edgar B. Bayler,- 1 J.
,
=: Samuel L. Andes, Esquire - Counsel for Mother
Laurie A. Saltzgiver, Esquire - Counsel for Father
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LAURI A. BEK:KER, : IN THE CXJURT OF CCt1MClSl PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : NO. 00-1706 CIVIL TERM
:
DAVID J. BEK:KER, : CIVIL ACTION' - LAW
Defendant : IN CUSTODY
PRIm JUDGE: Edgar B. Bayl.ey
Ub.....OOy caqcn.IATJ:CN ~ REPCRT
IN ACCClIDANCE WITH cmBERLAND CCUNTY RIlLE OF crvn. PROCEOORE
1915.3-8, the undersigned CUstody COnciliator submits~the following report:
1. The pertinent information concernin:J the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUS'1OOY OF
Kaitlin Becker
Jordan Becker
November 16, 1989
March 25, 1994
Mother
Mother
2. A Conciliation Conference was held on June 18, 2001, with the
following individuals _in attendance: The Mother, Laud A. Becker, with her
counsel, Samuel L. Andes, Esquire, and the Father, David J. Becker, with
his counsel, Laurie A. Saltzgiver, Esquire.
3. The parties agreed to entry of an order in the form as attached.
Date+vU dO, ;1m}~e
CUstody Conciliator
- ".
LAURI A, BECKER
PLAINTIFF
V,
DAVID J, BECKER
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNS'r'L VANIA
00-1706 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COlTRT
AND NOW,
Wednesdat, AUllust 01, 2001
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S, Sunday, Esq. , the conciliator,
at 39WestMainStreet,Mechani~csbllrg,PA 17055 on Thursday, August 30, 2001 at 1:00 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 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.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/
Dawn S. Sunday. Esq. M
Custody Conciliator
The Court of Common Pleas ofCwnberland County is required by law to comply with the
Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the court, You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
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
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LAURI A. BECKER
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
RULE TO SHOW CAUSE
AND NOW, this
day of
, 200l, a
RULE is issued upon the Respondent, Lauri A. Becker, to show
cause why the within Petition for Contempt should not be
granted.
Said Rule returnable at hearing on the
day of
, 2001 at
m. o'clock, in
Courtroom No.
BY THE COURT:
Judge
MEYERS, DESFOR, SAL1ZG1VER & BOYLE
410 NORTH SECOND STREET .. P,O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9428 .. FAX (717) 236-2617
'.
;;. It. IiII
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
PETITION FOR CONTEMPT
AND NOW, comes the Defendant, David J. Becker, by and
through his attorneys, Meyers, Desfor, Saltzgiver & Boyle and
files the following petition for Contempt and in support thereof
avers as follows.
1. Petitioner is David J. Becker, Defendant in the above-
captioned action.
(hereinafter "Father").
2. Respondent is Lauri A. Becker, Plaintiff in the above-
captioned action.
(hereinafter "Mother").
3. The parties are the parents of two minor children namely
Kaitlin Becker, date of birth 11/16/89 and Qordan Becker,
date of birth 3/25/94.
4. The current custody schedule is set forth within the Order
of June 20, 2000.
(See Exhibit "An).
5. Pursuant to the Order of June 20, 2000, paragraph 3, Father
has custody of the children every Thursday evening.
6. Thursday, July 5, 2001 was Father's regularly scheduled
period of physical custody.
7. Approximately one week prior to July 5th, Mother advised
Father she had purchased concert tickets for herself and
the two children and intended to take the children to a
MEYERS. DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET. P.O. BOX 1062 . HARRTSBURG, PA 1710B
(717) 236-9428 .. FAX (717} 236-2817
.
-,
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concert at Hershey Park on Thursday evening, July 5th.
Mother purchased said tickets with the full knowledge that
Thursday evening is always Father's evening for custody of
the children. Mother offered Father a make-up evening of
time. however, Father was unavailable on that date. Father
suggested that the parties exchange the evenings of
Wednesday, July 4th and Thursday, July 5th, however, Mother
refused to do same.
8. After the parties were unable to agree upon an exchange of
evenings, Mother's counsel forwarded a letter to Father's
counsel. (See attached Exhibit "B").
9. Father advised Mother that in light of their inability to
arrange a suitable exchange of evenings, that he was more
than willing to take the children to the concert during his
Thursday evening of custody and additionally would
reimburse Mother for the concert tickets.
(See Exhibit
lien) .
10. Mother did not respond to said correspondence and when
Father went to Mother's home to pick up the children on
Thursday, July 5, 2001, neither Mother nor the children
were home.
11. By correspondence of June 18, 2001, Mother advised Father
she intended to take the children for vacation from 6:00
p.m. July 17, 2001 to 6:00 p.m. July 25, 2001.
(See
Exhibit "Dn).
3
MEYERS, OESFOR. SALTZGIVER & BOYLE
410 NORTH SECOND STREET. p.o. BOX 1062 . HARRISBURG, PA 17108
(T17) 2:36-94213 . FAX (717) 236-2817
~-, --..
" .
12. Pursuant to the Order of June 23, 2001, paragraph 4, the
parties were to provide advance notice of the address and
telephone number where the children can be reached on
vacation.
(See Exhibit "E").
13. Mother did not provide Father with an address or telephone
number for their vacation and accordingly, is in contempt
of the Order of June 23, 2001.
14. Father believes that Mother is in contempt of the Court
Order of June 20, 2000 by refusing to provide him with his
Thursday evening visitation of the children on July 5,
2001. Father also believes Mother is in contempt of the
Order of June 23, 2001 by failing to provide Father with an
address and telephone number for the children while on
vacation.
15. Father has filed two prior Petitions for Contempt in this
action. The first petition was a Petition for Contempt and
for Modification of Custody Order which was filed on August
14, 2000. Said petition is still pending. Father filed a
Petition for Contempt on May 24, 2001. A conciliation was
held before Dawn Sunday on said Petition and an Order dated
June 23, 2001 was issued.
16. Father believes that Mother's blatant disregard of the
Court Order is willful and malicious contempt and requests
that Mother be found in contempt of the Orders of June 20,
2000 and June 23, 2001 and ordered to reimburse his
4
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MEYERS, DESFOR. SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9428 . FAX (717) 236-2817
~
attorney fees incurred in bringing the within petition.
Father requests that he be awarded an additional period of
custody of the children to replace the evening of custody
he missed with them. Father further requests that Mother
be sanctioned for her continued failure to abide by the
Court Order.
WHEREFORE, Defendant/Father requests this Honorable Court
find Mother in contempt of the Orders of June 20, 2000 and June
23, 2001 and order her to reimburse his attorney fees incurred
in bringing the within petition. Father requests that he be
awarded an additional period of custody of the children to
replace the evening of custody he missed with them. Father
further requests that Mother be sanctioned for her continued
failure to abide by the Court Order.
Respectfully
.
La r
MEYERS,
& BOYLE
Attorney I.D. #61382
410 North Second Street
P.O. Box 1062
Harrisburg, PA l7108
(717) 236-9428
Attorney for petitioner
MEYERS, DESFOR, SAL TZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(T17) 236-94Z8 .. FAX (717) 236-2617
'. .
)
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LAURI A. BECKER, : IN THE COURT OF COMMON' PLEAS OF
Plaintiff : CUMBERLAND ca:JNTY, PENNSYLVANIA
:
vs. : NO. 00-1706 CIVIL TERM
:
DAVID J. BECKER, : CIVIL AcrION' - LAW
Defendant : IN CUSTODY
aIDER OF <XXlRT
AND!ni, this r20+h day of ~ ~\ i. XI'"I e. ,
consideration of the attached CUstody Conc~lJ_at~on Report, it
and directed as follows:
2000, upon
is ordered
1. The Mother, Lauri A. Becker, and the Father, David J. Becker,
shall have shared legal custody of Kaitlin Becker, born November 16, 1989,
and Jordan Becker, born March 25, 1994. Each parent shalluhave an equal
right, to be exercised jointly with the other parent, to make all major
non-emergency decisions affecting the Children's general well-being
including, but not limited to, all. decisions regarding their health,
education and religion.
2. lhe Mother shall have primary physical custody of the Children.
3. The Father shall have partial physical custody of the Children on
alternating weekends from Friday at 6:00 p.m. through Monday at 8:00 a.m.,
beginning Friday, June 23, 2000. During weeks following the Father's
weekend period of custody, the Father shall also have custody of the
Children on Thursday fran 5:30 p.m. through 8:00 p.m. during the school
year and through 8:30 p.m. during the summer school break. During weeks
following the Mother I s weekend period of custody, the Father shall have
custody of the Children on Tuesday and Thursday evening from 5:30 p~m.
through 8:00 p.m. during the school year and through 8:30 p.m. during the
surmner school break.
4. The parties shall share or alternate having custody of the
Children on holidays as follows:
A. CBRISTMAS: The Christmas holiday shall be divided into
Segment A, which shall run fran Christmas Eve at 12:00 noon
through Christmas Day at 12:00 noon and Segment B, which shall
run frcm Christmas Day at 12:00 noon through December 26 at
12:00 noon. In even numbered years, the Father shall have
custody of the Children during Segment A and the Mother shall
have custody cJ,uring segment B. In odCl numbered years, the
Mother shall have custody of the Children during Segment A and
the Father shall have custody during Segment B.
B. THIlNKSGIVING: In every year, the Mother shall have custody of
the Children on .Thanksqivinq Day until 2:00 p.m. and the
EXHIBIT
I
"A"
,. .
. .
II .'
Father shall have custody from 2:00 p.m. illltil 8:30 p.m. on
Thanksgiving.
C. EASTER: The Easter holiday shall be divided into Segment A,
which shall = from 12:00 noon on the Friday before Easter
through 12:00 noon on the saturday before Easter and Segment
B, which shall = from noon on the saturday before Easter
through 12:00 noon 00 Easter SUnday. In even numbered years,
the Mother shall have custody of the Children during Segment A
and the Father sPall have custody during Segment B. In odd
numbered years, the Father shall have custody of the Children
during Segment A and the Mother shall have custody during
Segment B.
D. FATHER'S DAY/MOTHER'S DAY: The FatheJ::" shall have custody of
the Children every year on Father's Day and the Mother shall
have custody of the dlildren every year on MotheJ::"'s Day from
8:00 a.m. until 8:00 p.m. Notwithstanding the foregoing, in
2000, the Father shall have custody of the Children for
Father's Day from saturday, June 17 when the MotheJ::" returns
from vacation with the Children thJ::"ough Sunday, June 18 at
8:00 p.m.
E. The parties shall have custody of the Children on the
remaining holidays as arranged by agreement.
F. The holiday custody schedule shall supeJ::"sede and take
precedence over the regular custody schedule.
G. In the event the Father's period of holiday custody falls
illll11ediate1y before or after his regular period of custody, the
Father's holiday/regular period of custody shall run
continuously.
5. Each party shall be entitled to have custody of the Children for 2
non-consecutive weeks for vacation, which shall be scheduled during the
surruner school break unless otherwise agreed between the parties. The
parties shall schedule extended periods of custody illlder this provision to
fall immediately before or after that party's regular weekend period of
custody. Each party shall provide the other party with at least 30 days
advance notice of hi", or her selection of dates illlder this provision. The
party providing notice fiJ::"st shall be entitled to preference in his or her
selection of vacation dates.
6. The party receiving custody of the Children shall be responsible
to provide transportation for the exchange of custody unless otherwise
agreed between the parties.
7.
telephone
parent or
The non-custodial parent shall be entitled to have reasonable
contact with the Children which may be initiated either by the
the Children.
8. The parties shall cooperate and work together in making any
necessary adjustments to the custody_ schedule and in addJ::"essing issues
.1 r." .
. ,
"\' '.ll
=nceroing the Children.
9. 'Ihis 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 llUltual =nsent. In the absence of llUltual consent, the terms
of this Order shall =ntrol.
BY THE COURT,
Isl i (,Jy rSJ!. i J.
=: Samuel L. Andes, Esquire - Counsel for Mother
Laurie A. Saltzgiver, Esquire - Counsel for Father
'I .
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LAURI A. BECKER, : IN THE COURT OF CDMMON' PLEAS OF
Plaintiff : CUMBERLAND cctJN'l'Y, PENNSYLVANIA
:
vs. : NO. 00-1706 CIVIL TERM
:
DAVID J. BECKER, : CIVIL ACTION' - LAW
Defendant : IN CUSTODY
Cub~(uy o:NC:II.IATICN SUMMARY REPCRl'
IN ACO:IIDANCE WITH cnmERLAND CCONTY RULE OF CIVIL PRO:::EDURE
1915.3-8, the undersigned CUstody conciliator submits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF BIRTH
CORREI:IITLY IN CIJS'.I'C[lY OF
Kaitlin Becker
Jordan Becker
November 16, 1989
March 25, 1994
Mother
Mother
2. A Conciliation Conference was held on June 8, 2000, with the
following individuals_in attendance: The Mother, Lauri A. Becker, with her
counsel, Samuel L. Andes, Esquire, and the Father, David J. Becker, with
his counsel, Lauri A. Saltzgiver, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date
J//11tJ
9 ~I ~()
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{2~
cUstody Conciliator
,~ .
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SAMUEL L. ANDES
.ATTORNl!;Y AT LAW
~2t!o NORTlI TWELFTH STREET
P. O. BOX 168
LEMOYNE, PENNSYLVANIA 17043
TELEPHONE
(717) 761.!S361
29 June 2001
FAX
(717) 761-143""
Laurie A. Saltzgiver, Esquire
410 North Second Street
Harrisburg, PA 17101
RE: David Becker
Dear Laurie:
I spoke with Mrs. Becker about the house. She will agree to list the house for
sale and she has agreed t.o allow me to select the realtor. As we discussed, I
suggest we use Donna Fleetwood of ReMax Realty. J have only ever had one
dealing with her before, in a divorce case, and she was able to perform very fairly.
Please contact your client and, if Donna Fleetwood is satisfactory, let me know so
you and I can contact her. David is going to have to give her a key to the house so
she can inspect it and come up with some suggestions about listing it.
In the meantime, another problem has arisen in the custody part of the case.
Lauri was able to get tickets for herself and the children to attend the Backstreet
Boys concert at Hershey next Thursday evening. She has requested that David
exchange custody evenings with her so she can take the children to the concert and
he can have them some other time. Up to now, he has refused. r trust you can
impress upon him the importance of cooperating on this matter so that the chiidren
can attend the concert and so the parties can at least start to show a little
cooperation.
Please confer with David on these two points and get back to me as soon as
you can. I cannot imagine there will be a problem with exchanging custody
evenings so, unless I hear from you to the contrary by some time Monday, I will
assume that she can plan to take the children to the concert Thursday evening and
that the two of them will work out another evening for him to make up his lost time.
SIncerely,
~es
amh
EXHIBIT
cc:
Lauri A. Becker
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LAW OFFICES
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECONO STREET
P.O. BOX 1062
I, EMANUEL MEYERS (1915-1970J
BRUCE D. DESFOR
LJt.URIE. A, SALTZGIVER
CATHERINF; A. BOYLE
HARRISBURG. PA. 17/08
(717) 23a.!M28
FAX (7!7) 236-28!7
WE:BS1TE: wwwmeyersdesforcom
E:MAlL IsaltzglVer@meyersdesfof.com
cboylaCmeversdestor.com
July 2, 2001
VIA FAX & U.S. MAIL
Samuel Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
RE: Becker v. Becker
Dear Sam:
Please be advised that my client is agreeable to using Donna
Fleetwood of ReMax Realty to list the marital residence for sale.
You have advised that upon my okay you would send a letter to
Donna Fleetwood advising her of same. Please do so as soon as
possible.
Regarding the Backstreet Boys concert on Thursday, July 5th,
Dave has advised that he and Lauri have been unable to work out
an exchange of evenings. Dave told Laurie that he was willing to
exchange Wednesday evening for Thursday eveninguof this week and
she has refused. Because Lauri has backed out of so many
agreements in the past, Dave is unwilling to exchange Thursday
for an unspecified future day. Accordingly, Dave is not
agreeable to Lauri having the children on Thursday, however, Dave
is more than willing to take the children to the concert. If
Lauri is agreeable to this, Dave will reimburse her for the
amount she paid for the tickets.
Please advise.
LAS/elk
cc: David Becker
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EXHIBIT
I
lien
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SAMUEL L. ANDES
ATTORNEY AT LAW
~25 NORTH TWEL1"'Y'H STREET
P_ O. EOX 168
LEMOYNE, PENNSYLVANIA 17043
TEI..1':1>HO~E
(717) 7131-1536(
18 June 2001
FAX
(717) 751-[-1.:3:5
SENT BY FAX & REGULAR MAIL
Laurie A. Saltzgiver, Esquire
410 North Second Street
Harrisburg, PA 17101
RE: David Becker
Dear Laurie:
Now that your client has selected his two weeks of summer vacation,
Lauri Becker has selected her remaining week.
She would like to have the children from 17 July 2001, which is a
Tuesday, through 25 July 2001. Her period of would start at 6:00 p.m. on
17 July 2001 and terminate at 6:00 p.m. on 25 Jury 2001.
Please consider this letter our formal notice to you and your client of
those dates.
Sincerely,
eJ L. Andes
amh
cc: Lauri A. Becker
EXHIBIT
I
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LAURI A. BECKER, : IN THE COURT OF COMMON' PLEAS OF
plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : NO. 00-1706 CIVIL TERM
:
DAVID J. BECKER, : CIVIL ACTION' - LNiI
Defendant : IN CUSTODY
etmER OF COJRT
AND liD'I, this J3
consideration of the attached
and directed as follows:
day of
Custody
, 2001, upon
~t is ordered
1. The pri= Orders of this Court dated June 20, 2000 and the
subsequent Order entered in July, 2000 shall continue in effect as modified
by this Order.
2. The parties shall engage in a course of counseling with Deborah L.
Salem, MHS, CAC, including at a minimum, one separate session for each
party and two joint sessions. The purpose of the counseling shall be to
assist the parties in establishing sufficient communication, cooperation
and conflict resolution skills to enable them to effectively coparent their
Children. Each party shall be responsible to pay one-half of all costa
which are not covered by insUJ:"ance. Eaci1 party shall contact the counselor
within two weeks fran the date of the CUstody Conciliation Conference to
schedule the first session.
3. The Father's periods of vacation custody during the sumner school
break in 2001 shall rIm from 6:00 p.m. on July 27 through 6:00 p.m. on
August 5 and, from 6:00 p.m. on August 16 through 6:00 p.m. on August 25.
4. Each party shall provide advance notice to the other party of the
address and telephone number where the Children can be contacted during
vacation periods.
5. The noncustodial parent shall be entitled to have one telephone
contact per day with the Children with the exception of emergencies. In
the event a party provides the Children wi th a cellular phone in order to
effectuate this provision, the custodial parent shall permit the Child to
retain the ;;::hone and to have the phone remain on for purposes of compliance
with this provision.
TRUE COPY FRO.Y. rrCC'"RD
In T8itimonY~Vhere f, 1 here lI"K "j ICIY hanG' 'd
~and the 11 of said au at Carlisle, Pc.
1 ..........'i..... y f.JLuJs::..., .~.. ..
.... .. . 'or .
Pr, honata(Y
cc: Samuel L. Andes, Es e - Counsel for Mother
Laurie A. Saltzgiver, Esquire - Counsel for Father
BY THE CJORT,
I?J~J/J~ J /5. ih!V-A/
Edgar B Bayley, J.l
EXHIBIT
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LAORI A. BECKER , : IN THE CXJURT OF COMMON' PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : NO. 00-1706 CIVIL TERM
:
DAVID J. BECKER, : CIVIL ACTION - LAW
Defendant : IN CUSTODY
PRICR JtJDGE: Edgar B. Bayley
CUSTODY CCNCILIllTICN SlNARY REPCRr
IN ACCClIDANCE WITH <XlMBERLAND CXXlN.I.'Y RIlLE OF CIVIL PRu..:t;/JUl<E
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who aJ:"e the
subjects of this litigation is as follows:
NAME
DATE OF BIRTH
ClJRRENl'LY IN CUS.Luu:l OF
Kaitlin Becker
Jordan Becker
November 16, 1989
March 25, 1994
Mother
Mother
2. A Conciliation Conference was held on June 18, 2001, with the
following individuals in attendance: The Mother, Lauri A. Becker, with her
counsel, Samuel L. Andes, Esquire, end the Father, David J. Becker, with
his counsel, Laurie A. Saltzgiver, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
~ J/YJ
Date
-J () d(X"J I
,
~Lr.{~
Dawn S. Sunday, Esqu e
Custody Conciliator
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VERIFICl'.TION
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David Becker
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verify that: the
I,
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statements made in this
Petition for Contempt
a~e true a~d correc~ to the tes~
of ~y knowledge, infQr~a=ic~ a~d ce:ie:.
sta~e~e~ts herei~ are ffia=e
I ~~6ers~a~d t~a~ fals~
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s~~je~~ ~~ t~e Fe~a~~les
C.s. Section 4904, rela~~~g ~~ u~s~~rn falsi=icatich tc
autr.orities.
Da'.:.e3:
7/19/01
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MEYERS, DESFOR, SALTZG1VER & BOYLE
410 tlORTH SECOND STFlEEi . PO BOX 1062 . H.ARRlSEUi=G PA 17108
/717) 23f..9428 . FAX (717) 23f3-2S\7
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LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
I hereby
CERTIFICATE:}l SERVICE
certify on this ~ day of QMly,
2001, that a
copy of the foregoing petition for Contempt was mailed, first-
class, postage pre-paid to:
Samuel Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043 r
e
ndant
MEYERS, OESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9-428 .. FAX (711) 236-2817
SEP ~001
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
LAURI A. BECKER,
vs.
: NO. 00-1706
CIVIL TERM
DAVID J. BECKER,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 19th day of September, 2001, the Conciliator, being advised by counsel
for both parties that the Conference scheduled on the Father's Petition for Contempt is not necessary at
this time, hereby relinquishes jurisdiction. The Custody Conciliation Conference scheduled for
September 19, 2001 is canceled.
FOR THE COURT,
~~
Dawn S. Sunday, Esquire
Custody Conciliator
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LAURI A. BECKER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
DAVID J. BECKER,
Defendant
NO. 00-1706 CIVIL TERM
ORDER OF COURT
AND NOW, this 27th day of December, 2001, this matter
having come before the court on a petition by Lauri A. Becker,
it is ordered that Lauri A. Becker may take Kaitlin Becker,
born November 16, 1989, and Jordan Becker, born March 25, 1994,
on a vacation trip to Cancun, Mexico, between January 5 and
January 12, 2002.
Edgar B.
Samuel L. Andes, Esquire
For Plaintiff.
.teJ,~~ /~.;.?l.y
-1/~ />t~ /.:1.);.:>;0/
Laurie A. Saltzgiver, ~squire
For Defendant
Sheriff
prs
r:1EO OJ::F,~CE
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01 DFC 27 Pi, 2: 37
CWAi3tRLA;'!cJ COUNTY
PENNSYLVANIA
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II
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER
AND NOW, on this
day of
, 20_, upon
consideration of Defendant's Answer to Plaintiff's Petition for
Authorization to Take Children on Trip, it is hereby ORDERED and
DECREED that Plaintiff's Petition is denied.
BY THE COURT:
J.
MEYERS. DESFOR. SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717') 236.9428 .. FAX (717) 236-2817
Ii
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
DEFENDANT'S ANSWER TO PLAINTIFF'S PETITION
FOR AUTHORIZATION TO TAKE CHILDREN ON TRIP
AND NOW, comes the Defendant, David J. Becker, by and
through his attorneys, Meyers, Desfor, Saltzgiver & Boyle and
files the following Answer to plaintiff's Petition for
Authorization to Take Children on Trip and in support thereof
avers as follows.
1. No answer required.
2. Admitted, and by way of further answer, the Court Order
speaks for itself.
3. Neither admitted nor denied. Proof thereof will be
demanded at time of trial.
4. Neither admitted nor denied. Proof thereof will be
demanded at time of trial. By way of further answer,
Plaintiff has not previously advised Defendant regarding
any arrangements made with either of the children's
schools.
5. Neither admitted nor denied. Proof thereof will be
demanded at time of trial.
6. Admitted. Defendant has previously advised Plaintiff that
he is concerned for the children's safety in traveling
outside of the country in light of the September 11th
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108
(717) 236-9426 . FAX (717) 236-2817
attacks and security issues.
Defendant is especially
concerned about the children's safety in boarding a plane
for the return trip from Mexico.
Defendant has previously
advised plaintiff regarding his concerns by correspondence
of December 12, 2001.
(See Exhibit "A").
7 .
Denied.
Defendant denies that his objection to the
children traveling outside of the country has been made in
bad faith, in light of the September 11th attacks and their
aftermath. In fact, Defendant is withholding his agreement
in light of his concern for the children's safety.
Furthermore, pursuant to the Court Order of July 20, 2000,
paragraph 5,
"the parties are entitled to have the children for two
nonconsecutive weeks for vacation which shall be
scheduled during the children's summer school break
unless otherwise agreed between the parties."
The parties have previously agreed that vacations
should be taken during the summer school break.
Additionally, the parties' son, Jordan, has recently been
having problems in school, has claimed he doesn't like
school, doesn't want to go to school, and cries about going
to school on a daily basis.
The parties have been working
on this issue with Jordan and his counselor.
Defendant
does not believe it would be in Jordan's best interest to
miss a week of school at this time.
3
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9426 . FAX (717) 236-2817
8. Denied. Defendant has, in fact, incurred legal fees and
expenses in defending himself against the within petition.
Defendant denies that taking the children on this trip is
in any way for their own benefit. Defendant believes that
the safety of the children should come first and that they
should not be permitted to travel outside of the country at
this time.
WHEREFORE, Defendant requests this Honorable Court deny
Plaintiff's request for permission to take the children to
Cancun, Mexico and award Defendant attorney fees and costs
incurred in defending himself against the within petition.
Respectfully
r
Laurie
MEYERS,
& BOYLE
Attorney I.D. #61382
410 North Second Street
P.O. Box 1062
Harrisburg, PA 17108
(717) 236-9428
Attorney for Defendant
4
MEYERS. DESFOR, SALlZGIVER & BOYLE
410 NORTH SECOND STREIT . P.O. BOX 1062 . HARRISBURG. PA 17108
(717) 236-9428 . FAX (7'17) 236-21317
LAW OFFICES
MEYERS, DESFOR, SALTZGIVER .;. BOYLE
410 NORTH SECOND STREET
P.O. BOX 1062
I. EMANUEL MEYERS (1915.1970)
BRUCE: Q. DESFOR
LAURIE: A. 5AL TZGlVER
CATHERINE: A. BOYLE:
HARRISBURG. PA 17108
(717) 236-9428
FAX {717} 23e.'ZSI7
WE85lTE W>NW,meyersdesfor.com
E:MAIL lsalttglver@meyersdesfcr.com
cboy!e@meyersdesfor_com
December 12, 2001
VIA FAX & U.S. MAIL
Samuel Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
RE: Becker v. Becker
Dear Sam:
I received your correspondence of December 5, 2001, and
consent form. I have discussed this issue with Dave after
forwarding the prior correspondence on this issue. Dave has
seriously pondered the issue of the children going out of the
country, and in light of the September 11th attacks and the
aftermath, Dave cannot agree to permit the children to travel out
of the country.
Additionally, taking the children out of school is not in
compliance with the current Court Order which provides that
vacation time "shall be scheduled during the summer school break
unless otherwise agreed between the parties."
In light of the current situation in the world today, Dave
just cannot agree that the children can travel outside the
country with a clear conscience, as he is concerned for the
children's safety.
Thank you for your attention.
\S.i (
;~~
Laurie A. S~~i
LAS/elk
cc: Dave Becker
EXHIBIT
I
"An
,
"
(!
Ii
:1
II
VERI FI Cl'.T ION
I,
verify that the
David Becker
,
statements made in this Defendant's Answer to Plaintiff~s Petition
for Authorization to Take
Children on Trip a~e true and correc~ to the bes~
of ~y knowledge, infor~aci~~ a~c ce:ief.
I ~~dersca~d t~a~ 'false
sta=e~ents herein aye ffiaG: s~~je=~ cc t~e ~2~alties cf 18 Pa.
c.s. Section 4904/ relat~~; t8 ~~s~~r~ falsi:ica~ic~ to
aCltr~oyi;:ies .
D---~.
0._'=_.
12/20/01
cd d/fL
v -
?=-a.ir..~iff
x) D~feCldant
MEYERS, DESFOR. SALTZ GIVER & BOYLE
410 NORTH SECQrJD STREET. PO BOX 1062 . HARRIS8URG PA 1;108
1717) 2310-(>4:28 . FAX (71'7J 236.2817
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO . 00 -1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
I hereby
1,
that a copy of Defendant's Answer
Plaintiff's Petition for
Authorization to Take Children on Trip was mailed, first-class,
postage pre-paid to:
Samuel Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemo e, PA 17043
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG, PA 17108
(?17} 236-9428 .. FAX (717) 236-2917
CJ <::> ~
c::
:s: t::::J ...!'
EP trJ i." .~:-n
Q' C""") r:l~
:<cP' "" ~:;;r"r1
C1?~ -. 'i?
:-0:.;, ~_.. ~::~C)
~C7 " :-.-~i{
;P~C' ::r
z(j ~C)
~c: ~ om
~ .:.." ~
<J1 -<:
"
,
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 -1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER
AND NOW, on this
day of
, 20_, upon
consideration of Defendant's Answer to Plaintiff's Petition for
Authorization to Take Children on Trip, it is hereby ORDERED and
DECREED that Plaintiff's Petition is denied.
BY THE COURT:
J.
MEYERS, DESI="OR. SAL TZQIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) ~6~94::!8 . FAX (717) 236.2817
"
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 -1 706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
DEFENDANT'S ANSWER TO PLAINTIFF'S PETITION
FOR AUTHORIZATION TO TAKE CHILDREN ON TRIP
~ 0 ~
AND NOW, comes the Defendant, David J. Becker,~ a~ .~
~q n , ,pI
through his attorneys, Meyers, Desfor, Saltzgiver &~yl~anifp:jr'
cn.....~ C) -..
'< .<- -~J ,.,
files the following Answer to Plaintiff's Petition ~g ~ 6~
::C:o .....-~rn
Authorization to Take Children on Trip and in suppo~~he~eo~
=< (ll ~
avers as follows.
1. No answer required.
2. Admitted, and by way of further answer, the Court Order
speaks for itself.
3. Neither admitted nor denied. Proof thereof will be
demanded at time of trial.
4. Neither admitted nor denied. Proof thereof will be
demanded at time of trial. By way of further answer,
Plaintiff has not previously advised Defendant regarding
any arrangements made with either of the children's
schools.
5. Neither admitted nor denied. Proof thereof will be
demanded at time of trial.
6. Admitted. Defendant has previously advised Plaintiff that
he is concerned for the children's safety in traveling
outside of the country in light of the September 11th
"
!J
MEYERS, DESFOR. SALTZGlVER & BOYt..E
410 NORTH SECOND STREET . P.O. BOX fG62 . HARRISBURG, PA 1710a-
(717) 236.9428 . FAX (717) 236-2817
,
attacks and security issues.
Defendanc is especially
concerned about the children's safety in boarding a plane
for the return trip from Mexico.
Defendant has previously
advised Plaintiff regarding his concerns by correspondence
of December 12, 2001.
(See Exhibit "A").
7.
Denied.
Defendant denies chat his objeccion to che
children traveling outside of the country has been made in
bad faith, in light of the September 11th attacks and their
aftermath. In fact, Defendant is withholding his agreement
in light of his concern for the children's safety.
Furthermore, pursuant to the Court Order of July 20, 2000,
paragraph 5,
"the parties are entitled to have the children for two
nonconsecutive weeks for vacation which shall be
scheduled during the children's summer school break
unless otherwise agreed becween the parties."
The parties have previously agreed that vacations
should be taken during the summer school break.
Additionally, the parties' son, Jordan, has recently been
having problems in school, has claimed he doesn't like
school, doesn't want to go to school, and cries about going
to school on a daily basis.
The parties have been working
on this issue with Jordan and his counselor.
Defendant
does not believe it would be in Jordan's best interest to
miss a week of school at this time.
3
MEYERS, DESFOR SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P_C. BOX 1062 . HARRISBURG, PA 1710$
(717) 236.9428 . FAX (717) 236-2817
1/
8.
Denied.
Defendant has, in fact, incurred legal fees and
expenses in defending himself against the within petition.
Defendant denies that taking the children on this trip is
in any way for their own benefit.
Defendant believes that
the safety of the children should come first and that they
should not be permitted to travel outside of the country at
this time.
WHEREFORE, Defendant requests this Honorable Court deny
Plaintiff's request for permission to take the children to
Cancun, Mexico and award Defendant attorney fees and costs
incurred in defending himself against the within petition.
Respectfully submitted,
Laurie
MEYERS,
& BOYLE
Attorney I.D. #61382
410 North Second Street
P.O. Box 1062
Harrisburg, PA 17108
(717) 236-9428
Attorney for Defendant
\
"
4
MEYERS, DESFOR, SALTZGIVER & BOYtE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9428 . FAX (717) 236-281"7
<
LAW OFF"rCES
MEYERS, DESFOR, SALTZGIVER.s. BOYLE
410 NORTH SECOND S'rREET
P.O_ SOX JO'SZO
I. EMANUEl. MEYERS ~J915-19'70)
BRUCE:. O. DespeR
LAURIE A. SALTZGIVER
CATHERINE A. SOYLE
HARRISBURG. PA. 17106
(717) 236.9426
F'AX. (717) 23G-ZEl17
W(BS1TI: \'\f\oV'W,mayersdesfor,com
E:MAIL lsaltzgiverCmeyersdes.for.com
cboyle@mQyersdesfor_com
December 12, 2001
VIA FAX & U.S. MAIL
Samuel Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
RE: Becker v. Becker
Dear Sam:
I received your correspondence of December 5, 2001, and
consent form. I have discussed this issue with Dave after
forwarding the prior correspondence on this issue. Dave has
seriously pondered the issue of the children going out of the
country, and in light of the Sepcember 11th attacks and the
aftermath, Dave cannot agree to permit the children to travel out
of the country.
Additionally, taking the children out of school is not in
compliance with the current Court Order which provides that
vacation time "shall be scheduled during the summer school break
unless otherwise agreed between the parties."
In light of the current situation in the world today, Dave
just cannot agree that the children can travel outside the
country with a clear conscience, as he is concerned for the
children's safety.
Thank you for your attention.
~
~~
Laurie A. S~9i
LAS/clk
cc: Dave Becker
EXHIBIT
J
"AIf
.
.
y "
i:'
II
I.
,I
I!
II
"
il
"
I;
,
'"
'.
I!
"
II
VERIFICp.T:ON
I
;:
David Becker
verify that the
I,
I,
statements made in this Defendant's Answer to Plaintiff's Petition
for Authorization to Take
Children on Trip a~e true 2~d correct to t~e ces~
of l:".y k:1owledge r
infor:-na.::..:::-.
a:-:d
. ~. ~
.::e_l.et.
I 1",':'::8.ers~a.:1d
t:--_a:. fals.e
sta:.e~e~ts he~ei~ are ~a~e s~tje=:. tS :~e ~e~~l:.ies
:'.6
Pa.
~-
~~
C.S. Section 4904, re~at:"::2 C~ ~::2~2r~ falsi:icatic~ to
a'J'C!:crities.
:);;;.'.:e::.:
12/20/01
(' J':J d J1'L.
v __
- ~. . ....-
.:-'_~':;.:.lI 1:
x ) DE:=e:-~dant
MEYERS, DES FOR. SALTZGIVER &: BOYLE
410 ~JORTH SECOtJD STREET. PO BOX 1062 . HARAIS8uO::G PA. 1;108
1717) .2:>;:-9.:.:a . FAX ;7C') 2':.16-2817
, II
.
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
CERTIFICATE OF, SERVICE . ~J\\l.;~
I hereby certify on this(}C:, ~ay of~\JR: iLAfJ ,20\n,
if
that a copy of Defendant's Answer to Plaintiff's Petition for
Authorization to Take Children on Trip was mailed, first-class,
postage pre-paid to:
Samuel Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemo e, PA 17043
quire
MEYERS, DESFOR, SALlZGlVER & BOYLE
410 NORlH SECOND STREET .. P.O, BOX 1062 .. HARRISBURG, P!- 17106
(717) 236.9428 .. FAX (717) 236-2817
,
LAURI A. BECKER
plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER
AND NOW, on this
day of
, 20_, upon
consideration of Defendant's Answer to Plaintiff's Petition for
Authorization to Take Children on Trip, it is hereby ORDERED and
DECREED that Plaintiff's Petition is denied.
BY THE COURT:
J.
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARF\.lSBURG,?A 17108
(717) 2:36.9428 . FAX (717) 236-2817
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
DEFENDANT'S ANSWER TO PLAINTIFF'S PETITION
FOR AUTHORIZATION TO TAKE CHILDREN ON TRIP8 Cl ~
AND NOW, comes the Defendant, David J. Becker,~ a~ ~;~
:z :IJ ' Fi
through his attorneys, Meyers, Desfor, Saltzgiver &~Yl~anj$.
files the following Answer to Plaintiff's Petition t:Q$ ~ /,::1
~O-- - 5(")
:s> W ."rn
Authorization to Take Children on Trip and in suppor~th€feo~
=< U1 -<
avers as follows.
1. No answer required.
2. Admitted, and by way of further answer, the Court Order
speaks for itself.
3. Neither admitted nor denied. Proof thereof will be
demanded at time of trial.
4. Neither admitted nor denied. Proof thereof will be
demanded at time of trial. By way of further answer,
Plaintiff has not previously advised Defendant regarding
any arrangements made with either of the children's
schools.
5. Neither admitted nor denied. Proof thereof will be
demanded at time of trial.
6. Admitted. Defendant has previously advised Plaintiff that
he is concerned for the children's safety in traveling
outside of the country in light of the September 11th
MEYERS, DESFOR, $AlTZGIVER & BOYLE
410 NORm SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9428 . FAX (717) 236-2817
Ii
.
attacks and security issues. Defendant is especially
concerned about the children's safety in boarding a plane
for the return trip from Mexico.
Defendant has previously
advised Plaintiff regarding his concerns by correspondence
of December 12, 2001.
(See Exhibit "An).
7.
Denied.
Defendant denies that his objection to the
children traveling outside of the country has been made in
bad faith, in light of the September 11th attacks and their
aftermath. In fact, Defendant is withholding his agreement
in light of his concern for the children's safety.
Furthermore, pursuant to the Court Order of July 20, 2000,
paragraph 5,
"the parties are entitled to have the children for two
nonconsecutive weeks for vacation which shall be
scheduled during the children's summer school break
unless otherwise agreed between the parties."
The parties have previously agreed that vacations
should be taken during the summer school break.
Additionally, the parties' son, Jordan, has recently been
having problems in school, has claimed he doesn't like
school, doesn't want to go to school, and cries about going
to school on a daily basis.
The parties have been working
on this issue with Jordan and his counselor.
Defendant
does not believe it would be in Jordan's best interest to
miss a week of school at this time.
3
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 1710B
(717) 236-9428 . FAX (717) 236-2817
,
r
8. Denied. Defendant has, in fact, incurred legal fees and
expenses in defending himself against the within petition.
Defendant denies that taking the children on this trip is
in any way for their own benefit.
Defendant believes that
the safety of the children should come first and that they
should not be permitted to travel outside of the country at
this time.
WHEREFORE, Defendant requests this Honorable Court deny
Plaintiff's request for permission to take the children to
Cancun, Mexico and award Defendant attorney fees and costs
incurred in defending himself against the within petition.
Respectfully
r
\
Laurie
MEYERS,
& BOYLE
Attorney I.D. #61382
410 North Second Street
P.O. Box 1062
Harrisburg, PA 17108
(717) 236-9428
Attorney for Defendant
4
MEYERS, DESFOR. SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108
(717) 236.9428 . FAX (717} 236.2B17
LAW OFFICES
MEYERS, DESFOR;SALTZGIVER & BOYLE
410 NORTH SECOND STREET
P.O. BOX 1062
l. EMANITELM,EYERS 0915-1970)
BRUCE-o. DESFOR
LAURIE-A.SALTZGIVER
CATHERINE A. BOYLE
HARRISBURG, PA. 17108
(717) 236-9428
FAX 1717J ,236.2617
WF:BSlTE ,^"""",",.meyersdesfor.com
EMA.1L lsq:ltzgiver@meyersdesfor.com
cboyleCmeyersdesfor.com
December 12, 2001
VIA FAX & U.S. MAIL
Samuel Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
RE: Becker v. Becker
Dear Sam:
I received your corresponde~ce of December 5, 2001, and
consent form. I have discussed this issue with Dave after
forwarding the prior corresponde~ce on this issue. Dave has
seriously pondered the issue of the children going out of the
country, and in light of the September 11th attacks and the
aftermath, Dave cannot agree to permit the children to travel out
of the country.
Additionally, taking the children out of school is not in
compliance with the current Court Order which provides that
vacation time "shall be scheduled during the summer school break
unless otherwise agreed between the parties."
In light of the current situation in the world today, Dave
just cannot agree that the children can travel outside the
country with a clear conscience, as he is concerned for the
children's safety.
Thank you for your attention.
~
~~
Laurie A. S~9i
LAS/elk
cc: Dave Becker
EXHIBIT
I
"A"
,
,
/i
'I
II
II
II
:1
;;
"
i
,
"
VERIFICATION
I,
, verify that the
David Becke+
"
statements made in this Defendant's Answer to Plaintiff's Petition
for Authorization to Take
Children on Trip a~e true a~ci correc~ to the bes~
of r:-:y k:1owledge,
infor:na,::.::::-:
a.::c
. ~. ,-
r::E:_le::.
I ;.:::derSCCi!1d
t::a: fals~
sta:e~e~ts he~ei~ a~e ~a~e
. . . ~. .-
S~~:~~: c::: ~;.e F2~~~~~es ~=
1 ^
_c
Pa.
C.S. Section 4904, relac~~~ t~ ;':::S~2r~ falsi:icatic~ to
a:.ltr:.c!:"ities.
::a~e:i:
12/20/01
('v y1-/!-L
-
:?='ai~.,:iff
x ) DE: f e::c.a.:l t
MEYERS. DESFOR. SALTZGIVER & BOYLE
410 rJOATH 5ECOtJQ STRE:::T . PO BOx lG62 . HARAISBURG PA 1il08
1717: 2::<:-r!'4:e . F-\X ;71;": .?.J6-2817
,
.
LAURI A. BECKER
Plaintiff
IN THE COURT OF COl~I~ON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
CERTIFICAT
I hereby certify on thiS'~
that a copy of Defendant's Answer to
petition for
Authorization to Take Children on Trip was mailed, first-class,
postage pre-paid to:
Samuel Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoy e, PA 17043
-_ f\
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORlli SECOND SIAEtT .. P.O. BOX 1062 .. HARRISBURG, PA 17108
(717) 2:36-9428 .. FAX (717) 236-2817
~
~
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II
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER
AND NOW, this
day of
, 20_, upon
consideration of Defendant's Motion for Continuance, the
conference scheduled for Thursday, December~27, 2001 at 2:15
p.m. is hereby continued to
20
at
o'clock.
BY THE COURT:
J:
MEYERS, DESFOR, SALTZGIVER " BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717' 236-9426 .. FAX (717) 236-2817
II
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
MOTION FOR CONTINUANCE
AND NOW comes the Defendant, David J. Becker, by and
through his attorneys, Meyers, Desfor, Saltzgiver & Boyle, and
files this Motion for Continuance, and in support thereof avers
as follows:
1. Movant is David J. Becker, Defendant in the above-captioned
action (hereinafter referred to as "Father").
2. Respondent is Lauri A. Becker, plaintiff in the above-
captioned action (hereinafter referred to as "Mother").
3. Mother filed a Petition for Authorization to Take Children
on Trip on December 13, 2001. This Honorable Court issued
an Order on December 18, 2001 scheduling a conference
regarding said petition for December 27, 2001.
(See
Exhibit "A").
4. Father's counsel, Laurie A. Saltzgiver, Esquire is out of
town for the holidays during the week of the conference and
will be unable to attend. Ms. Saltzgiver's partner,
Catherine A. Boyle, Esquire, is also out of town for the
holidays during that week and will be unable to fill in for
Laurie A. Saltzgiver, Esquire.
5. Father requests that the conference sCheduled for December
MEYERS, DESFOR, SALlZGIVER & BOYLE
410 NORTH seCOND STREET. P.D, BOX 1062 . HA~RISBUAG, PA 17106
(717) 236-9426 . FAX (717) 236-2817
II
27, 2001 be continued to a date and time when Father's
counsel is available.
this Honorable Court grant his Motion for Continuance and
WHEREFORE, Defendant, David J. Becker respectfully requests
2001.
reschedule the conference presently scheduled for December 27,
Respectfully submitted,
Laurie A. 1
MEYERS, DESFOR,
& BOYLE
Attorney I.D. #61382
410 North Second Street
P.O. Box 1062
Harrisburg, PA 17108
(717) 236-9428
Attorney for Defendant
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236,9428 .. FAX (717) 236-2817
LAURI A. BECKER,
Plaintiff
vs.
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY,PENNSYLV~
CIVIL ACTION. LAW
NO. 00-1706
CIVIL TERM
DAVID J. BECKER,
Defendant
IN CUSTODY
ORDER
AND NOW this I~ day ~E" h'\J,~ ' 2001, a conference is
hereby scheduled before the undersigned, in his chambers at the Cumberland County
Courthouse on Plaintiff's attached Petition. The conference is to be held at";;.. "- (' o'clock
fL.m.on "-rt:<I''iASt the ..27"+1. daYOfV~r~I'h/"~/?___ ,2001 and shall be
attended by counsel for both parties. Both parties shall be available, in person or by
telephone, to participate in the conference or answer questions that may arise at the
conference.
BY THE COURT,
N8fT~2~
Distribution~
Samuel L. Andes, Esquire (Attorney for Plaintiff)
525 North 12th Street, Lemoyne, P A 17043
Laurie A. Saltzgiver, Esquire (Attorney for Defendant)
410 North Second Street, Harrisburg, PA 17101
~ ;:;.u;:: OQPY FROM RECORD
li1T~j\'f~ lhereu '
">i? too . at said' rt at ~: my ha~c
f.--r "'y' .
EXHIBIT
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nAil
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
I hereby
CERTIFICATE OF SERVICE~
certify on this ~day of , 2001,
the foregoing Motion for Continuance was sent
via
that a copy crf
facsimile to:
The Honorable Edgar B. Bayley
CUMBERLAND COUNTY COURTHOUSE
One Courthouse Square
Carlisle, PA 17013
Samuel Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
/
Esquire
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9428 . FAX (717) 236-2817
,.
,.r
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER
AND NOW, this
day of
, 20_, upon
consideration of Defendant's Motion for Continuance, the
conference scheduled for Thursday, Decembe~~27, 2001 at 2:15
p.m. is hereby continued to
, 20
at
o'clock.
BY THE COURT:
J.
MEYERS, DESFOR,. SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9429 . FAX (717) 23S-2817
J
r
...
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
MOTION FOR CONTINUANCE
AND NOW comes the Defendant, David J. Becker, by and
through his attorneys, Meyers, Desfor, Saltzgiver & Boyle, and
files this Motion for Continuance, and in support thereof avers
as follows:
1. Movant is David J. Becker, Defendant in the above-captioned
action (hereinafter referred to as "Father").
2. Respondent is Lauri A. Becker, Plaintiff in the above-
captioned action (hereinafter referred to as "Mother").
3. Mother filed a Petition for Authorization to Take Children
on Trip on December 13, 2001. This Honorable Court issued
an Order on December 18, 2001 scheduling a conference
regarding said petition for December 27, 2001.
(See
Exhibit "A").
4. Father's counsel, Laurie A. Saltzgiver, Esquire is out of
town for the holidays during the week of the conference and
will be unable to attend. Ms. Saltzgiver's partner,
Catherine A. Boyle, Esquire, is also out of town for the
holidays during that week and will be unable to fill in for
Laurie A. Saltzgiver, Esquire.
5.
Father requests that the conference scheduled for December
I
~
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STReET . P.O. BOX 1062 . HARRISBURG. PA 17108
(717) 236-9428 . FAX (717) 236-2817
,r
r
27, 2001 be continued to a date and time when Father's
counsel is available.
WHEREFORE, Defendant, David J. Becker respectfully requests
this Honorable Court grant his Motion for Continuance and
reschedule the conference presently scheduled for December 27,
2001.
Respectfully submitted,
Laurie A. 1
MEYERS, DES FOR ,
& BOYLE
Attorney I.D. #61382
410 North Second Street
P.O. Box 1062
Harrisburg, PA 17108
(717) 236-9428
Attorney for Defendant
~.
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108
(717) 238.9428 .. FAX (717) 236-2917
~
vs.
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
LAURI A. BECKER,
Plaintiff
CIVIL ACTION. LAW
NO. 00-1706
CIVIL TERM
DAVID J. BECKER,
Defendant
IN CUSTODY
ORDER
AND NOW this I~ day ~F h'lJ~_ ,2001, a conference is
hereby scheduled before the undersigned, in his chambers at the Cumberland County
Courthouse on Plaintiffs attached Petition. The conference is to be held aVo. "- (' o'clock
-p- .m. on '--r/;;-fl'~,...( ~t the.:2 7'1-1. day of ~ r(" "",bf'J?-.. ' 2001 and shall be
attended by counsel for both parties. Both parties shall be available, in person or by
telephone, to participate in the conference or answer questions that may arise at the
conference.
BY THE COURT,
N-8fr~t ~
Distribution:
Samuel L. Andes, Esquire (Attorney for Plaintiff)
525 North 12th Street, Lemoyne, PA 17043
Laurie A. Saltzgiver, Esquire (Attorney for Defendant)
410 North Second Street, Harrisburg, PA 17101
!f ,;.JE OOPY FROM to.;::CORD'
'-.'7~ n..... ....,.
'i~ ,. 00;01 w~, llJera unto set mv h"~-
;"? too . c{ said . rt al Carll&:!. . (t,.,
JIt ""'Y
EXHIBIT
I
nAil
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 0 0 - 1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
I hereby
CERTIFIC~ ~SRRVlCE .~ G
certify on this J-\~day of ~02001,
the foregoing Motion for Continuance was sent
that a copy of
via
facsimile to:
The Honorable Edgar B. Bayley
CUMBERLAND COUNTY COURTHOUSE
One Courthouse Square
Carlisle, PA 17013
Samuel Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
MEYERS, DESFOR. SALTZGIVER " BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9428 . FAX (717) 236-2817
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LAURI A. BECKER
plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00 -1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
ORDER
AND NOW, this
day of
20_, upon
consideration of Defendant's Motion for Continuance, the
conference scheduled for Thursday, Decembe~'27, 2001 at 2:15
p.m. is hereby continued to
, 20
at
o'clock.
BY THE COURT:
J.
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 239-9429 .. FAX (717) 23(1-2817
/
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 00-1706
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
MOTION FOR CONTINUANCE
AND NOW comes the Defendant, David J. Becker, by and
through his attorneys, Meyers, Desfor, Saltzgiver & Boyle, and
files this Motion for Continuance, and in support thereof avers
as follows:
1. Movant is David J. Becker, Defendant in the above-captioned
action (hereinafter referred to as "Father").
2. Respondent is Lauri A. Becker, Plaintiff in the above-
captioned action (hereinafter referred to as "Mother").
3. Mother filed a Petition for Authorization to Take Children
on Trip on December 13, 2001. This Honorable Court issued
an Order on December 18, 2001 scheduling a conference
regarding said petition for December 27, 2001.
(See
Exhibit "A").
4. Father's counsel, Laurie A. Saltzgiver, Esquire is out of
town for the holidays during the week of the conference and
will be unable to attend. Ms. Saltzgiver's partner,
Catherine A. Boyle, Esquire, is also out of town for the
holidays during that week and will be unable to fill in for
Laurie A. Saltzgiver, Esquire.
5. Father requests that the conference scheduled for December
MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NORTH SECOND STREET . PO. BOX 1062 . HARRISBURG, PA 17108
(717) 236-9428 .. F)I.X (717) 2$-2817
"
27, 2001 be continued to a date and time when Father's
counsel is available.
WHEREFORE, Defendant, David J. Becker respectfully requests
this Honorable Court grant his Motion for Continuance and
reschedule the conference presently scheduled for December 27,
2001.
Respectfully submitted,
Laurie A. 1
MEYERS, DESFOR,
& BOYLE
Attorney I.D. #61382
410 North Second Street
P.O. Box 1062
Harrisburg, PA 17108
(717) 236-9428
Attorney for Defendant
~
MEYERS, DESFOR. SALTZGIVER & BOYLE
410 NORm SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 236.9428 .. FAX (717) 236-2817
/
vs.
)
)
)
)
)
)
)
)
)
IN THE COuRT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
LAURI A. BECKER,
Plaintiff
CIVIL ACTION - LAW
NO. 00-1706
CIVIL TERM
DAVID J. BECKER,
Defendant
IN CUSTODY
ORDER
AND NOW this ,P--I-L--. day ~"'f' h-\J~ ,2001, a conference is
hereby scheduled before the undersigned, in his chambers at the Cumberland County
Courthouse on Plaintiff's attached Petition. The conference is to be held at,.,:7: /... \ o'clock
-p-.m. on '-rt'Nl '>...-I~t the .;)7'1-1. day of ~r€" """J.,f"/?_ ,2001 and shall be
attended by counsel for both parties. Both parties shall be available, in person or by
telephone, to participate in the conference or answer questions that may arise at the
conference.
BY THE COURT,
N8fr~t.~
Distribution:
Samuel L. Andes, Esquire (Attorney for Plaintiff)
525 North 12th Street, Lemoyne, P A 17043
Laurie A. Saltzgiver, Esquire (Attorney for Defendant)
410 North Second Street, Harrisburg, PA 17101
"An
EXHIBIT
I
LAURI A. BECKER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 0 0 - 170 6
DAVID J. BECKER
Defendant
CIVIL ACTION - LAW
IN CUSTODY
CERTIFICATE OF SERVICE . ~ ~ .
I hereby certify on this ~day of ~02001'
that a copy of the foregoing Motion for Continuance was sent via
facsimile to:
The Honorable Edgar B. Bayley
CUMBERLAND COUNTY COURTHOUSE
One Courthouse Square
Carlisle, PA 17013
Samuel Andes, Esquire
525 North Twelfth Street
P.O. Box 168
Lemoyne, PA 17043
~
I
!
MEYERS, DESFOR. $ALTZGIVER & BOYLE
410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108
(717) 2.36.942B . FAX (717) 236-2817
~
LAURI A. BECKER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
00-1706
CIVIL ACTION LAW
DAVID J. BECKER,
Defendant
IN CUSTODY
ORDER OF COURT
.! ,/
AND NOW, thisZ---"1 day of ,1 i'\.ti(I">C, ,2092,
upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows:
I. Paragraph 3 of the prior Order of this Court dated June 20, 2000 is modified so that the
Father's alternating weekend periods of custody shall end on Sunday at 9:00 p.m. when there is school
the following day and on Monday at 10:00 a.m. when there is no school on Monday.
2. Unless otherwise agreed between the parties, all exchanges of custody shall take place in the
parking lot of the Kmart located on the Carlisle Pike in Mechanicsburg, as close to the main doors of
the store as possible.
BY THE~<;:_OURTA /:7:?
/';P
,.
, t.
J.
/
cc: Laurie A. Saltzgiver, Esquire - Counsel for Father
Samuel L. Andes, Esquire - Counsel for Mother
~
~
4- 01-0-'-'
()..
~
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CNIL ACTION LAW
00-1706
LAURI A. BECKER,
Plaintiff
DAVID J. BECKER,
Defendant
IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent infonnation concerning the Children who are the subjects of this litigation is
as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Kaitlin Becker
Jordan Becker
November 16,1989
March 25,1994
Mother
Mother
2. A Conciliation Conference was held on March 13, 2002, with the following individuals in
attendance: The Mother, Lauri A. Becker, with her counsel, Samuel L. Andes, Esquire, and the Father,
David J. Becker, with his counsel, Laurie A. Saltzgiver, Esquire.
3. At the Conference, the Mother requested a modification of the current Order to establish an
exchange time for return of the Children following the Father's alternating weekends on Sunday
evening and to specify a public place for exchanges of custody so that exchanges would no longer take
place at the Father's residence.
4. The Conciliator submits a proposed Order in the form as attached reflecting the parties'
agreement on the exchange time for alternating Sunday evenings and the Conciliator's
recommendation as to a public place for exchanges of custody. It should be noted that the Father
objects to exchanges at any place other than the parties' residences as he believes it is neither necessary
nor in the Children's best interest. The recommendation is based upon discussions at the Conference
concerning an incident in which the police were contacted (not during the exchange) in response to the
Father's complaint that the Mother drove through his yard at the time of an exchange and upon the
and upon the escalating antagonism between the parties in general. The Conciliator strongly
recommended that the parties reinitiate co-parenting counseling to develop at least minimal
cooperation for the sake of the Children.
l~ch
Date
I y, dO();:r
.
~~~~
Dawn S. Sunday, Esquire
Custody Conciliator
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