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Home My WebLink About00-01803 "" , 1'- ~ , RONALD L, SHULDA, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : PENNSYLVANIA vs. . . JENNIFER A. VALENTINE, Defendant : CIVIL ACTION - CUSTODY NO. 00 ~ lib3 C-Oc.:-(r~ / ORDER OF COURT AND NOW, :SId"'! 2000, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before ~~~.~~+-- ~'conCi1iator, at ~ "'-l. ~\f'\&,.,\'\c(\.ct-.\~~Pl\ on the \1 day of ~ , 2000, at _~ ....fL.m., for a Pre-Hearing CuStody Conference. At such conferenc~, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: ~'\~,~~ Custody Conc1liator l ~ 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 by made at least 72 hours prior to any hearing or business before the court. You must attend scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 - II.. .I - IllllbililJil-~ilIW.(,hlft<'l~"~~UI!i~i!I;i"~.!I~~,j!-J~;;(<jI"~~~-- ~1Bm l ' '-~-';~' " '" ,. ' f30,a:; 3-30.?lt' 3 - 3 tJ'cJtJ " -,.<> ,-],. -,-,~ --"~>~,,~~]~~'" -~, -" i: '~ I}L~Q-()FFICE 0, I :!'C :;"fiTi.''''NOTARY .' I Il,I'-k I 00 M~R so pn 3: Ii . CU",v.." ' '., 1\j10'''-!''~' j)'" , f\'~U 'PEi-i:~Syty/~i~ NTY &d.~~<1mf~ ~~~~ ~~~4'~~ p !I .", RONALD L. SHULDA, JR., IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY . PENNSYLVANIA . vs. . . . CIVIL ACTION - . . CUSTODY . JENNIFER L. VALENTINE, . . Defendant . NO. . NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed ih the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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 ~ Mary A. Etter Dissinger, Attorney for Plaintiff '- squire - " RONALD L. SHULDA, JR., . IN THE COURT OF COMMON PLEAS . Plaintiff : OF CUMBERLAND . PENNSYLVANIA . vs. . . . CIVIL ACTION - . CUSTODY JENNIFER A. VALENTINE, /:;03 c;;J. -r .L.A-<- Defendant . NO. h- . COMPLAINT FOR OBTAIN AND EXPAND CUSTODY 1. Plaintiff is Ronald L. Shulda, Jr., residing at 614 North Front Street, wormleysburg, Cumberland County, Pennsylvania. 2 . Defendant is Cumberland Street, Jennifer A. Valentine, residing at 510 Enola, Cumberland County, Pennsylvania. West 3. Ronald L. Shulda, Jr. seeks custody of the following child: Name Chase R. Shulda Present Residence 510 West Cumberland Street Enola, Pa. 17025 Age 9/23/94 4. The child was born out of wedlock. 5. The child is presently in the custody of Defendant who resides at 510 West Cumberland Street, Enola, Cumberland County, pennsylvania. 6. During the past five years, the child has resided with the following persons at the following addresses: Persons Jennifer A. Valentine Addresses 510 West Cumberland Street Enola, PA. 17025 410 Salt Road Enola, PA 17025 Date summer 98 to present Terry Magaro Skip Magaro Jennifer A. Valentine 7/95 summer 98 ,____-- '!"f<-!''"- , ", Per SODS Addresses Date Jennifer A. Valentine Ronald L. Shulda, Jr. Western village Enola, Pa. 17025 9/23/94 until 7/95 7. The mother of the child is Jennifer A. Valentine who currently resides at 510 West Cumberland street, Enola, Cumberland County, Pennsylvania. 8. She is not married. 9. The father of the child is currently resides at 614 North Cumberland County, Pennsylvania. Ronald L. Shulda, Jr. who Front street, Wormleysburg, 10. He is married to Tracey L. Shulda. 11. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with his wife, Tracey L. Shulda. 12. The relationship of Defendant to the child is that of mother. The Defendant currently resides with child. 13. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 14. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 15. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. i- , . I 'I 16. The best interest and permanent welfare of the child will be served by granting the relief requested because the parties have encountered conflicts with regard to athletic events and activities. 17. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child have been named! as parties to this action. All other persons, named below who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: None. WHEREFORE, He prays the Court to grant him joint legal custody and physical custody that is more expansive than the current custodial arrangement which was entered by agreement of the parties and never formalized by the Court. Respectfully Submitted: DISSINGER & DISSINGER BY:~ 'a~,~~ Mary A~ter D1ssinger, Esqu1re Attorney for Plaintiff Supreme Court I.D. #37736 28 North 32nd Street Camp Hill, PA 17011 (717) 975-2840 ~$ ,.",- , ~-~ ....... II r .l J VERIFICATION I, Ronald L. Shulda, Jr., verify that the statements made in the Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsification to authorities. "" ~'"<1" ,- i ,cC,. .':C"" , " ;: f. F!IL R - ft. c9~ ~~ , - ~ ,,,..,,,, -~".~ Jr <'e "~""~~-' ,. -. ~j"~"-"'iIii (') c.: s: '"'On.', mn-"l Z:o ZI);' ~-":: ~L. ~O ~O :'i>Q L. ~ l~ f jt ~.' Cl o ::Jt ,'" "<1 N w " ::~ o -n '-i -~ fil;2! '1rn~ ~)l? ~~C) 6=-fi b :70 Om --J ~ -< g ~ 9 h ~ ~ ~gD~ r I ~o ~~ J ~ o (.,) ., ~ ~ ,- ~~ -!!Qi!ll r'lt~. ,.-t,,,,,,, ~i ' ~"!E!~,?-:~"'''''",:I''!Bfl.::''')\j;'il(lill!'i:lll61~rM~~~~iOOIIiW!'!_~~~III!I!m , . , RONALD L. SHULDA, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 00-1803 CIVIL TERM . . . JENNIFER A. VALENTINE, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . ORDER OF COURT AND ~, this /',- day of ~\J,,",- consideration of the attached CUstody Concil ation and directed as follows: , 2000, upon Report, it is ordered 1. The Father, Ronald L. Shulda, Jr., and the Mother, Jennifer A. valentine, shall have shared legal custody of Chase R. Shulda, born september 23, 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 Child's general well-being ~ncll.1ding, but not limited to, all decisions regarding his health, education 'and religion. 2. The parties shall have physical' custody of the Child during the summer school break in accordance with the following schedule: A. The Father shall have custody of the Child on alternating weekends from Friday after work, when the Father shall pick up the Child from day care, through Sunday at 8:00 p.m., beginning June 16, 2000. B. During weeks following the Father's weekend periods of custody, the Father shall have custody of the Child every weekday from after work, when the Father shall pick up the Child at day care, until 5:15, when the Mother shall pick up the Child at the Father's residence after work. C. During weeks following the Mother's weekend periodS of custody, the Father shall have custody of the Child every weekday from after work, when the Father shall pick up the Child from day care, until 8:00 p.m., with the exception of Friday when the Father shall retain custody of the Child for the weekend period of custody. D. The Mother shall have custody of the Child at all times not otherwise specified for the Father in this provision. 3. In 2000, the Mother shall have custody of the Child on July 4th and the Father shall have custody on Father's Day, with the specific times to be arranged by agreement of the parties. The parties shall make arrangements for custody of the Child on the remaining holidays by agreement. .?" .,.."." " ,--,. , ~~ .' , 4. Each party shall be entitled to have custody of the Child for 2 uninterrupted weeks (consecutive or non-consecutive, as agreed between the parties) during the summer school break upon providing at least 30 days advance notice to the other party. 5. The Mother shall ensure that the Child is at the day care provider by 3:00 p.m. on each weekday when the Father is picking the Child up for a period of custody. In the event the Father has off work, the Father shall be given preference in having custody of the Child over other relatives (non-parents) or the day care provider. 6. The parties and their counsel shall attend a second CUstody Conciliation Conference in the office of the Conciliator, Dawn S. Sunday, on August 29, 2000 at 11:00 o'clock, a.m. for the purpose of addressing any necessary adjusbnents to the custody schedule if the parties have not been able to reach an agreement as to ongoing custody arrangements by the date of the Conference. 7. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J- J. cc: Mary A. Etter Dissinger, Esquire - Counsel for Father Maria P. Cognetti, Esquire - Counsel for Mother -"\~ (i';'~ 00 lJ1Y- ~~16' ~ <f-.~ " ~iliI<!;jUii!i!iili!lfa!M~il:!Illi~9!!lli~~.ii~i~1l>>iili-,",,"""'>"","';'MJ~'~- '"",,...'" '. - '<"['h~;t;lIli@"i",'~~"'-"...Jj FI1ed (" Profhol'ottl,y oW,&' L, - (5 'oC IlIJQW"",,,,,,,",,s,", , _ .r ,_":_ ,_, ~",,_, _ _,_" _" __""'" '., "." ~_ .',_ c ,"_^,__,,-.". ,'" _J~""""'I- -" " ~ " . .' , RONALD L. SHULDA, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-1803 CIVIL TERM . . JENNIFER A. VALENTINE, . CIVIL ACTION - LAW . Defendant : IN CUSTODY CUSTODY CXH:ILIATICN SUMMARY REPCRr IN AOOORDANCE WITH CUJIIBERLAND OOUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Chase R. Shulda September 23, 1994 Mother 2. A Custody Conciliation Conference was held on June 6, 2000, with the following individuals in attendance: The Father, Ronald L. Shulda, Jr., with his counsel, Mary A. Dissinger, Esquire, and the Mother, Jennifer A. Valentine, with her counsel, Maria P. Cognetti, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date Dawn S. Sunday, Esquire Custody Conciliator T .'<' -', -, -''> ,"" " ~ RONALD L. SlillLDA, JR. PLAINTIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER A. VALENTINE 00-1803 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 12th day of June ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on the 25th day of July ,2000, atll:00AM 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 TIIE COURT, By: Isl Dawn Sunda 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 ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE 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 ,~ ,. ,~ ''C "",' ' _lIiII*' - -~.:... '1Ilidl.~'. -.',;. ,"~ - "~'......".--~-~ ~~~ ~'""- l""~ - ~Bli~Jili' ...."o;"""''''''.......~S!~~~'......,.' /; -I5~'&{) IP '/-5- CO ? -r5'>t:z; (,~ ",. :,':."iL_iJ)-CfF!CF J,'" ! I r:;,:,:'jTAfW nn 1'/'1 I" '-",j ,.,.;\ :J fli'I' c: ~" () ,)J CU1Vj81~~jLiJ\~D COUNT pClmSYLVANiA Y M-&w~~'a1~' '7!4 ~ ~~. ~ ~ -G a7F~<fr .. . ,~, -, ~'-- ~ ."< .,=.- ., .,. " ~, ,~~-"~,~ , \\Ntsb\family IllW\ClJent DlrectoryWalentine-J\Pleadings\Answer and Counterclaim May IS, 2000 RONALD L. SHULDA, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYL VANIA v. : NO. 00-l803 JENNIFER A. VALENTINE, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Counterclaim, it is hereby directed that the parties and their respective counsel appear before Conciliator, at the , Esquire, ! , Pennsylvania, on the day of , 2000, at .m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or, if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary Order. 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 the entry of a temporary or permanent Order. FOR THE COURT DATED: BY: Custody Conciliator YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, P A 17013 (717) 240-6200 . ~, ,L.~_7_,_~ .U _ e' .',...."."_,".,'.'~_'"'__. roc _ _, \\NtsblfamiLy law\Client DirectoryWalentine-J\Pleadings\Answer and Courrterclaim REAGER, ADLER & COGNETTI, PC MARIA P. COGNETTI, ESQUIRE Attorney J.D. No. 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717)763-1383 Attomevs for Defendant RONALD L. SHULDA, JR., Plaintiff v. JENNIFER A. VALENTINE, Defendant M7..ylS,2000 : IN THE COURT OF COMMON PLEAS : DAUPHIN COUNTY PENNSYLVANIA : NO. 00-1803 : CIVIL ACTION - LAW : IN CUSTODY ANSWER AND COUNTERCLAIM AND NOW, comes the Defendant, Jennifer A. Valentine, by her attorney, Maria P. Cognetti, Esquire and files the within Answer and Counterclaim, and in support thereof, respectfully represents as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. 9. Admitted. ,- '.~ ...,--~, .-" ~'--. ~--'--- , . ~ - . -. -- "- -~i -~ \\Ntsb\family law\Client Directory\Valentine-J\Pleadings\Answer and Counterclaim May 15,2000 10. Admitted. 11. Admitted. 12. Admitted. 13. Admitted. l4. Admitted. l5. Admitted. 16. Admitted in part and denied in part. It is admitted that the parties have encountered conflicts with regard to athletic events and activities. It is denied that the best interest and permanent welfare of the child will be served by granting the relief requested by Plaintiff Ronald L. Shulda, Jr. 17. Admitted. COUNTERCLAIM 18. Paragraphs 1 through 17 of Plaintiff's Complaint and Defendant's Answers thereto are incorporated herein by reference thereto. 19. Defendant seeks custody of the following child: Name Present Address Age Chase R. Shulda 510 West Cumberland St. Enola, P A 17025 9/23/94 20. The child was born out of wedlock. The child is are presently in the custody of Defendant Jennifer A. Valentine who resides at 51 West Cumberland Street, Enola, Cumberland County, Pennsylvania. -2- "A ,,"' , - ~ ,.- - "--_._~.-" .' -, " ,'~ - . " \\Ntsb\family law\Client DirectoryWalelltille-J\Pleadillgs\Answer and Counterclaim May 15,2000 21. During the past five (5) years the child resided with the following persons at the following address(es): Name Address Dates Jennifer A. Valentine Ronald L. Shulda, Jr. Western Village Enola, P A 17025 9/23/94 to 7/95 Jennifer A. Valentine Terry and Skip Magaro 410 Salt Road Enola, P A 17025 7/95 to summer '98 Jennifer A. Valentine 51 0 West Cumberland St. Enola, P A 17025 summer '98 to present 22. The mother of the child is currently residing at 51 0 West Cumberland Street, Cumberland County, Pennsylvania. She is single. 23. The father of the child is currently residing at 614 North Front Street, Wormleysburg, Cumberland County, Pennsylvania. He is married. 24. The relationship of Plaintiff to the child is that of father. Plaintiff currently resides with the following persons: Name Relationship Tracey L. Shulda Wife 25. The relationship of Defendant to the child is that of mother. Defendant currently resides with the following persons: Name Relationship Chase R. Shulda Son -3- ,<..' .,.r.""' . - , ~"''''''-~.<__ . - ~, ,.. -,-."-,' '. '.' I:\Client DirectoryWalentine-J\Plcadings\Answer lllld Counterclaim May 23, 2000 26. Defendant has not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the child in this or any other Court. 27. Defendant has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 28. Defendant does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 29. The best interest and permanent welfare of the child will be served by granting the relief requested. 30. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Defendant requests the Court to grant her majority physical custody and shared legal custody ofthe child. Respectfully Submitted: REAGER, ADLER & COGNETTI, PC Date: May 23, 2000 By: - 2331 Market Street Camp Hill, PA 1701l-4642 Telephone No. (717) 763-1383 Attorney for Defendant -4- , VERIFICATION I, Jennifer A. Valentine, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of l8 Pa. C.S.A. ~4904 relating to unsworn verification to authorities. DATE: ~I g (00 I:\Client Directof}'Walentine-J\Pleadings\Answer and Counterclaim May 23,2000 CERTIFICATE OF SERVICE I, Maria P. Cognetti, Esquire, Attomey for the Defendant herein, do hereby certify that on this date I served the foregoing Answer and Counterclaim by depositing a true and exact copy thereof in the United States mail, first class, postage prepaid, addressed as follows: Mary A. Etter Dissinger, Esquire 28 North 32nd Street Camp Hill, PA 1701l Attorney for Plaintiff Date: May 23, 2000 By: . 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717) 763-1383 Attorney for Defendant -6- ,~ " ow'"~ _. _ _:~" ,_""." ~", ;< -' ,i ~. . RONALD L. SHULDA, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-1803 CIVIL TERM : JENNIFER A. VALENTINE, Defendant : CIVIL ACTION - LAW : IN CUSTODY aIDER OF COORT AND !OJ, this ""7 - day of ~r~ consideration of the attached CUstody Concihation Report, and directed as follows: , 2000, upon it is ordered 1. The prior order of this Court dated June 14, 2000 is vacated and replaced with this order. 2. The Father, Ronald L. Shulda, Jr., and the Mother, Jennifer A. Valentine, shall have shared legal custody of Chase R. Shulda, born September 23, 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 Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 3. The parties shall have physical custody of the Child in accordance with the following schedule: A. Summer School Break:- The Father shall have custody of the Child on alternating weekends from Friday after work, when the Father shall pick up the Child from school or day care, through Sunday at 7:00 p.m. During weeks following the Father's weekend periods of custody, the Father shall have custody of the Child every weekday frc:m after work, when the Father shall pick up the Child at day care, until 5:15 p.m. During weeks following the Mother's weekend periods of custody, the Father shall have custody of the Child every weekday after work, when the Father shall pick up the Child from day care, until 7:30 p.m., with the exception of Friday when the Father shall retain custody of the Child for the weekend period of custody. B. School Year: The Father shall have custody of the Child on alternating weekends from Friday after work, when the Father shall pick up the Child from school or day care, through Sunday at 7:00 p.m. During weeks following the Mother's weekend periods of custody, the Father shall have custody of the Child on Tuesdays and Thursdays from after work, when the Father shall pick up the Child at school or day care, until 7:00 p.m., and on Mondays, Wednesdays and Fridays from after work, when the Father shall pick up the Child from day care or ~~, ~- ~~ , school, until 5:15 p.m., with the exception of Friday when the Father shall retain custody for the weekend period of custody. During weeks following the Father's weekend periods of custody, the Father shall have custody of the Child on Monday through Friday from 3:30 p.m., when the Father shall piCk up the Child from day care or school, until 5:15 p.m., with the exception of Tuesdays, when the Father shall have custody of the Child until 7:00 p.m. C. During weeks following the Mother's weekend periods of custody, the Father shall transport the Child to the Mother's residence at the end of his periods of custody and during weeks fOllowing the Father I s weekend periods of custody, the Mother shall pick up the Child at the Father's residence at the end of the Father's periods of custody. D. The Mother shall have custody of the Child at all times not otherwise specified for the Father in this provision. 4. The parties shall alternate having custody of the Child on holidays as follows: A. In even numbered years, the Father shall have custody of the Child on Memorial Day, Labor Day, and Christmas and the Mother shall have custody on Easter, July 4th, and Thanksgiving. In odd numbered years, the Father shall have custody of the Child on Easter, July 4th, and Thanksgiving, and the Mother shall have custody on Memorial Day, Labor Day, and Christmas. The party who has custody of the Child over the weekend following Thanksgiving under the regular custody schedule shall begin the weekend period of custody on the day after Thanksgiving at 12:00 noon unless the parties agree otherwise. B. The Mother shall have custody of the Child every year on Mother I s Day and the Father shall have custody of the Child every year on Father I s Day. C. All holiday custody periods under this provJ.sJ.on shall run from 7:00 p.m. on the evening before the holiday until 7:00 p.m. on the holiday. D. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 5. Each party shall be entitled to have custody of the Child for 2 uninterrupted weeks (to be scheduled non-consecutively unless otherwise agreed between the parties) during the summer school break upon providing at least 30 days advance notice to the other party. Neither party shall schedule his or her periods of custody under this provision to interfere with the other party's period of holiday custody. '-"'- ~, ~ ..~..=<.." ~ 6. This order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this order by mutual consent. In the absence of mutual consent, the terms of this order shall control. BY THE CDURT, cc: Mary A. Etter Dissinger, Esquire - Counsel for Father Maria P. COgnetti, Esquire - Counsel for Mother _1, .~~ " , J. ~ ~~ " RONALD 1.. SHUI.DA, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 00-1803 CIVIL TERM . . . JENNIFER A. VALENTINE, : CIVIL ACTION - LAW Defendant : IN CUSroDY PRIOR.JUDGE: Kevin A. Hess CUS'l'ODY CCtlCILIATICJ\/ SUIIIMARY REPORT IN ACCORDANCE WITH CUMBERLAND COONTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Chase R. Shulda September 23, 1994 Mother 2. A Custody Conciliation Conference was held on August 29, 2000, with the following individuals in attendance: The Father, Ronald L. Shulda, Jr., with his counsel, Mary A. Etter Dissinger, Esquire, and the Mother, Jennifer A. Valentine, with her counsel, Maria P. Cognetti, Esquire. 3. The parties agreed to entry of an Order in the form as attached. /J-v rdJl- , ? ~ deJ7p) Date Da~~ Custody Conciliator ,'" ./ ~~