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HomeMy WebLinkAbout00-02266MAY 10 2000" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW ANGELA M. NICKLE, Plaintiff V. JASON S. NICKLE, SR, Defendant NO. 00-2266 Civil Term IN CUSTODY ORDER OF COURT AND NOW, this?day of 2000, upon consideration of the attached 3- Stipulation for Entry of a Custody Order IT IS HEREBY ORDERED AND DECREED that custody and partial custody with respect to the minor children: JASON NICKLE, born December 30, 1995; and BREONA NICKLE, born September 18, 1997, is awarded as follows: 1. The parents shall share legal custody of the minor children. All major decisions regarding the children, including medical, educational and religious matters, shall be discussed between the parents. 2. MOTHER shall have primary physical custody of the minor children. 3. FATHER shall have partial physical custody of the minor children on alternate weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m. 4. The following holidays shall be shared or alternated between, the parents each year; Memorial Day, the Fourth of July and Labor Day. The hours shall be from 10:00 am. until 6:00 p.m. unless otherwise agreed by the parents. In 2000 and in all even years thereafter, MOTHER shall have Memorial Day and Labor Day, and FATHER shall have the Fourth of July. In 2001 and in all odd years thereafter, FATHER shall have Memorial Day and Labor Day, and MOTHER shall have the Fourth of July. If possible, both parents shall have the opportunity to enjoy fireworks with the minor children during these holidays. 5. Thanksgiving shall be shared and alternated between the parents each year. The Thanksgiving holiday shall be divided into two (2) segments. Segment "A" shall be from the Wednesday before Thanksgiving at 5:00 p.m. until Thanksgiving Day at 5:00 p.m. Segment "B" shall be from Thanksgiving Day at 5:00 p.m. until the Friday after Thanksgiving at 5:00 p.m. In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 6. Easter shall be shared and alternated between the parents each year. In 2001 and in all odd years thereafter, FATHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and MOTHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. In 2002 and in all even years thereafter, MOTHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and FATHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. Christmas shall be shared and alternated between the parents each year. The Christmas holiday shall be divided into two (2) segments. Segment "A" shall be from noon on Christmas Eve until noon on Christmas Day. Segment "B" shall be from noon on Christmas Day until noon on December 26". In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 8. FATHER shall have the minor children on Father's Day and MOTHER shall have the minor children on Mother's Day. The hours shall be from 10:00 am. until 8:00 p.m. unless otherwise agreed by the parents. 9. Each parent shall have the minor children for two (2) weeks every year for summer vacation. These weeks need not be taken consecutively but should be taken in conjunction with that parent's alternate weekend. The parents shall give each other written notice of their chosen week(s) of summer custody by May 15`h of each year, if possible. In the event that both parents choose the same week(s) for summer custody, the parent who gives first notice shall prevail. 10. FATHER shall provide all transportation for custody transfers, or shall arrange transportation for the transfers by mutual agreement of the parents. 11. While in the presence of the children, neither parent shall make, or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the children should respect and love. 12. Each parent shall provide the other with a current telephone number and address. 13. Neither parent shall use illegal drugs nor shall they abuse alcohol in the presence of the children. MOTHER and FATHER shall ensure that the minor children not be in the presence of third parties who use illegal drugs or abuse alcohol. 14. Each parent shall have the opportunity to seethe minor children on their birthdays. The specific times shall be agreed upon between the parents. 15. The schedules for all holidays, vacations and special occasions shall take priority over the usual weekly schedule. 16. Both parents shall permit reasonable telephone access between the children and the other parent. The children shall be permitted reasonable telephone access to place calls to each of their parents while they are with the other. 17. By mutual consent of the parents, a revised schedule may be agreed upon between them for and in the best interests of the minor children, 18. This Order shall replace and supercede any and all prior Orders of Court or agreements between the parties. 19. This Order shall remain in full force and effect until further Order of Court. BY THE COURT: TpsE7 r`" nr;-almg? In Tee' rr _ y niy hand 'In and the seal of said Court at Carlisle, Pa. Thi ?G,2/aVyf .?1 .'.1.. tharotary, J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW ANGELA M. NICKLE, Plaintiff V. JASON S. NICKLE, SR., Defendant : NO. 00-2266 Civil Term IN CUSTODY STIPULATION FOR ENTRY OF CUSTODY ORDER The parties to this action, ANGELA M. NICKLE (hereinafter referred to as "MOTHER"), and JASON S. NICKLE, SR. (hereinafter referred to as "FATHER"), desiring to amicably settle and resolve all outstanding issues concerning custody and partial custody with respect to the minor children: JASON NICKLE, born December 30,1995; and BREONA NICKLE, born September 18, 1997, hereby stipulate and agree to the entry of an Order of Court awarding custody and partial custody of JASON and BREONA as follows: 1. The parents agree that they shall share legal custody of the minor children. All major decisions regarding the children, including medical, educational and religious matters, shall be discussed between the parents. 2. The parents agree that MOTHER shall have primary physical custody of the minor children. 3. The parents agree that FATHER shall have partial physical custody of the minor children on alternate weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m. 4. The parents agree that the following holidays shall be shared or alternated between them each year; Memorial Day, the Fourth of July and Labor Day. The hours shall be from 10:00 a.m. until 6:00 p.m. unless otherwise agreed by the parents. In 2000 and in all even years thereafter, MOTHER shall have Memorial Day and Labor Day, and FATHER shall have the Fourth of July. In 2001 and in all odd years thereafter, FATHER shall have Memorial Day and Labor Day, and MOTHER shall have the Fourth of July. If possible, both parents shall have the opportunity to enjoy fireworks with the minor children during these holidays. The parents agree to share and alternate Thanksgiving each year. The Thanksgiving holiday shall be divided into two (2) segments. Segment "A" shall be from the Wednesday before Thanksgiving at 5:00 p.m. until Thanksgiving Day at 5:00 p.m. Segment "B" shall be from Thanksgiving Day at 5:00 p.m. until the Friday after Thanksgiving at 5:00 p.m. In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 6. The parents agree to share and alternate Easter each year. In 2001 and in all odd years thereafter, FATHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and MOTHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. In 2002 and in all even years thereafter, MOTHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and FATHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. 7. The parents agree to share and alternate Christmas each year. The Christmas holiday shall be divided into two (2) segments. Segment "A" shall be from noon on Christmas Eve until noon on Christmas Day. Segment "B" shall be from noon on Christmas Day until noon on December 26`h. In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". The parents agree that FATHER shall have the minor children on Father's Day and MOTHER shall have the minor children on Mother's Day. The hours shall be from 10:00 a.m. until 8:00 p.m. unless otherwise agreed by the parents. 9. MOTHER and FATHER agree that each of them shall have the minor children for two (2) weeks every year for summer vacation. These weeks need not be taken consecutively but should be taken in conjunction with that parent's alternate weekend. The parents shall give each other written notice of their chosen week(s) of summer custody by May 15`h of each year, if possible. In the event that both parents choose the same week(s) for summer custody, the parent who gives first notice shall prevail. 10. FATHER agrees to provide all transportation for custody transfers, or to arrange transportation for the transfers by mutual agreement of the parents. 11. MOTHER and FATHER agree that while in the presence of the children, neither parent shall make, or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the children should respect and love. 12. Each parent agrees to provide the other with a current telephone number and address. 13. Both parents agree that neither shall use illegal drugs nor shall they abuse alcohol in the presence of the children. MOTHER and FATHER agree that the minor children shall not be in the presence of third parties who use illegal drugs or abuse alcohol. 14. Both parents agree that they shall each have the opportunity to see the minor children on their birthdays. The specific times shall be agreed upon between the parents. 15. MOTHER and FATHER agree that the schedules for all holidays, vacations and special occasions shall take priority over the usual weekly schedule. 16. Both parents agree to permit reasonable telephone access between the children and the other parent. The children shall be permitted reasonable telephone access to place calls to each of their parents while they are with the other. 17. Both parents agree that, by their mutual consent, a revised schedule maybe agreed upon between them for and in the best interests of the minor children, 18. The parents agree that this Agreement shall be submitted to the Court of Common Pleas of Cumberland County, Pennsylvania for approval and for entry of an Order awarding custody and partial custody as set forth herein, and the parents hereby request that this Honorable Court enter such an Order. IN WITNESS WHEREOF, the parties have executed this Stipulation for Entry of a Custody Order on the date indicated below. 5=17-0 v Date Witness SOYA NKLE, SR. Date Witness *ANGflA NICKLE X22 P7 ANGELA M. NICKLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW JASON S. NICKLE, SR., NO. 2000 - 2266 CIVIL Defendant IN CUSTODY COURT ORDER r AND NOW, this Y day of May, 2000, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. BY THE COURT, 01-/9 A 4 Hubert X. Gilroy, EsqUO6 Custody Conciliator - J1 ?wj -m IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW ANGELA M. NICKLE, Plaintiff V. NO. 00-2266 Civil Term JASON S. NICKLE, SR., Defendant IN CUSTODY ORDER OF COURT AND NOW, this a3fk day of , 2000, upon consideration of the attached Stipulation for Entry of a Custody Order, IT IS HEREBY ORDERED AND DECREED that custody and partial custody with respect to the minor children: JASON NICKLE, born December 30, 1995; and BREONA NICKLE, born September 18, 1997, is awarded as follows: 1. The parents shall share legal custody of the minor children. All major decisions regarding the children, including medical, educational and religious matters, shall be discussed between the parents. 2. MOTHER shall have primary physical custody of the minor children. 3. FATHER shall have partial physical custody of the minor children on alternate weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m. 4. The following holidays shall be shared or alternated between the parents each year; Memorial Day, the Fourth of July and Labor Day. The hours shall be from 10:00 a.m. until 6:00 p.m. unless otherwise agreed by the parents. In 2000 and in all even years thereafter, MOTHER shall have Memorial Day and Labor Day, and FATHER shall have the Fourth of July. In 2001 and in all odd years thereafter, FATHER shall have Memorial Day and Labor Day, and MOTHER shall have the Fourth of July. If possible, both parents shall have the opportunity to enj oy fireworks with the minor children during these holidays. 5. Thanksgiving shall be shared and alternated between the parents each year. The Thanksgiving holiday shall be divided into two (2) segments. Segment "A" shall be from the Wednesday before Thanksgiving at 5:00 p.m. until Thanksgiving Day at 5:00 p.m. Segment "B" shall be from Thanksgiving Day at 5:00 p.m. until the Friday after Thanksgiving at 5:00 p.m. In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 6. Easter shall be shared and alternated between the parents each year. In 2001 and in all odd years thereafter, FATHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and MOTHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. In 2002 and in all even years thereafter, MOTHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and FATHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. 7. Christmas shall be shared and alternated between the parents each year. The Christmas holiday shall be divided into two (2) segments. Segment "A" shall be from noon on Christmas Eve until noon on Christmas Day. Segment "B" shall be from noon on Christmas Day until noon on December 26`h In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 8. FATHER shall have the minor children on Father's Day and MOTHER shall have the minor children on Mother's Day. The hours shall be from 10:00 a.m. until 8:00 p.m. unless otherwise agreed by the parents. 9. Each parent shall have the minor children for two (2) weeks every year for summer vacation. These weeks need not be taken consecutively but should be taken in conjunction with that parent's alternate weekend. The parents shall give each other written notice of their chosen week(s) of summer custody by May 15th of each year, if possible. In the event that both parents choose the same week(s) for summer custody, the parent who gives first notice shall prevail. 10. FATHER shall provide all transportation for custody transfers, or shall arrange transportation for the transfers by mutual agreement of the parents. 11. While in the presence of the children, neither parent shall make, or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the children should respect and love. 12. Each parent shall provide the other with a current telephone number and address. 13. Neither parent shall use illegal drugs nor shall they abuse alcohol in the presence of the children. MOTHER and FATHER shall ensure that the minor children not be in the presence of third parties who use illegal drugs or abuse alcohol. 14. Each parent shall have the opportunity to seethe minor children on their birthdays. The specific times shall be agreed upon between the parents. 15. The schedules for all holidays, vacations and special occasions shall take priority over the usual weekly schedule. 16. Both parents shall permit reasonable telephone access between the children and the other parent. The children shall be permitted reasonable telephone access to place calls to each of their parents while they are with the other. 17. By mutual consent of the parents, a revised schedule maybe agreed upon between them for and in the best interests of the minor children, 18. This Order shall replace and supercede any and all prior Orders of Court or agreements between the parties. 19. This Order shall remain in full force and effect until further Order of Court. BY THE COURT: h`?Ji !ii? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW ANGELA M. NICKLE, Plaintiff V. JASON S. NICKLE, SR., Defendant NO. 00-2266 Civil Term IN CUSTODY STIPULATION FOR ENTRY OF CUSTODY ORDER The parties to this action, ANGELA M. NICKLE (hereinafter referred to as "MOTHER"), and JASON S. NICKLE, SR. (hereinafter referred to as "FATHER"), desiring to amicably settle and resolve all outstanding issues concerning custody and partial custody with respect to the minor children: JASON NICKLE, born December 30,1995; and BREONA NICKLE, born September 18, 1997, hereby stipulate and agree to the entry of an Order of Court awarding custody and partial custody of JASON and BREONA as follows: The parents agree that they shall share legal custody of the minor children. All major decisions regarding the children, including medical, educational and religious matters, shall be discussed between the parents. 2. The parents agree that MOTHER shall have primary physical custody of the minor children. 3. The parents agree that FATHER shall have partial physical custody of the minor children on alternate weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m. 4. The parents agree that the following holidays shall be shared or alternated between them each year; Memorial Day, the Fourth of July and Labor Day. The hours shall be from 10:00 a.m. until 6:00 p.m. unless otherwise agreed by the parents. In 2000 and in all even years thereafter, MOTHER shall have Memorial Day and Labor Day, and FATHER shall have the Fourth of July. In 2001 and in all odd years thereafter, FATHER shall have Memorial Day and Labor Day, and MOTHER shall have the Fourth of July. If possible, both parents shall have the opportunity to enj oy fireworks with the minor children during these holidays. The parents agree to share and alternate Thanksgiving each year. The Thanksgiving holiday shall be divided into two (2) segments. Segment "A" shall be from the Wednesday before Thanksgiving at 5:00 p.m. until Thanksgiving Day at 5:00 p.m. Segment "B" shall be from Thanksgiving Day at 5:00 p.m. until the Friday after Thanksgiving at 5:00 p.m. In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 6. The parents agree to share and alternate Easter each year. In 2001 and in all odd years thereafter, FATHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and MOTHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. In 2002 and in all even years thereafter, MOTHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and FATHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. The parents agree to share and alternate Christmas each year. The Christmas holiday shall be divided into two (2) segments. Segment "A" shall be from noon on Christmas Eve until noon on Christmas Day. Segment "B" shall be from noon on Christmas Day until noon on December 26th. In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". The parents agree that FATHER shall have the minor children on Father's Day and MOTHER shall have the minor children on Mother's Day. The hours shall be from 10:00 a.m. until 8:00 p.m. unless otherwise agreed by the parents. 9. MOTHER and FATHER agree that each of them shall have the minor children for two (2) weeks every year for summer vacation. These weeks need not be taken consecutively but should be taken in conjunction with that parent's alternate weekend. The parents shall give each other written notice of their chosen week(s) of summer custody by May 15" of each year, if possible. In the event that both parents choose the same week(s) for summer custody, the parent who gives first notice shall prevail. 10. FATHER agrees to provide all transportation for custody transfers, or to arrange transportation for the transfers by mutual agreement of the parents. 11. MOTHER and FATHER agree that while in the presence of the children, neither parent shall make, or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the children should respect and love. 12. Each parent agrees to provide the other with a current telephone number and address. 13. Both parents agree that neither shall use illegal drugs nor shall they abuse alcohol in the presence of the children. MOTHER and FATHER agree that the minor children shall not be in the presence of third parties who use illegal drugs or abuse alcohol. 14. Both parents agree that they shall each have the opportunity to see the minor children on their birthdays. The specific times shall be agreed upon between the parents. 15. MOTHER and FATHER agree that the schedules for all holidays, vacations and special occasions shall take priority over the usual weekly schedule. 16. Both parents agree to permit reasonable telephone access between the children and the other parent. The children shall be permitted reasonable telephone access to place calls to each of their parents while they are with the other. 17. Both parents agree that, by their mutual consent, a revised schedule maybe agreed upon between them for and in the best interests of the minor children, 18. The parents agree that this Agreement shall be submitted to the Court of Common Pleas of Cumberland County, Pennsylvania for approval and for entry of an Order awarding custody and partial custody as set forth herein, and the parents hereby request that this Honorable Court enter such an Order. IN WITNESS WHEREOF, the parties have executed this Stipulation for Entry of a Custody Order on the date indicated below. e Date Witness 4 SICKLE, SR. -I -00 s 7 " A -b Date Witness ANGE AM. NICKLE .. c? ? 7n ?a ?p? IN'THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ' ANGELA M. NICKLE, Plaintiff V. NO. aaDD- aauu JASON S. NICKLE, SR. Defendant IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the p ies and their respective counsel a pear b ore Cn the Conciliator, at tLj on the day of 2000, at ?.m., for a Pre-Hearing Custody nference. 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. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent Order. BY THE COURT: C stody Conciliator L 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 FORTE BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact the office set forth above. 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. ?? - - - meNi?wbueNa?EZxveN?uwa. - ._ , ® - { ?' : , d? lLv?-y41A IN*THE'COORT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANGELA M. NICKLE, Plaintiff V. JASON S. NICKLE, SR., Defendant NO. 6-0 . d 2L IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, this day of 2000, comes the Plaintiff, ANGELA M. NICKLE, by and through her attorney, Maryann Murphy, Esquire, of Legal Services, Inc., and respectfully files this Complaint for Custody, and in support thereof avers as follows: 1. The Plaintiff is ANGELA M. NICKLE whose current address is 7 Pine Road, Apt. #506, Mt. Holly Springs. Cumberland County, Pennsylvania. 2. The Defendant is JASON S. NICKLE, SR. whose current address is 1066 Centerville Road, Newville, Cumberland County, Pennsylvania. 3. The Plaintiff seeks primary physical and shared legal custody of the following children: JASON NICKLE, born December 30, 1995 and BREONA NICKLE, born September 18, 1997 4'. The children were born out of wedlock. 5. Plaintiff currently resides with the minor children. 6. Defendant currently resides with his parents. 7. During the lifetime of the children, they have resided at the following addresses with the following persons: Time Address birth-3/96 10 Hollinger St, Mt. Holly Springs, PA 3/96-8/96 1066 Centerville Rd Newville, PA 8/96-10/99 7 Pine Road Mt. Holly Springs, PA 10/99-present 7 Pine Road Mt. Holly Springs, PA with Whom Plaintiff/Defendant Plaintiff's parents Plaintiff/Defendant Defendant's parents Plaintiff/Defendant Plaintiff 8. The father of the children is JASON S. NICKLE, SR. He is married to Plaintiff. 9. The mother of the children is ANGELA M. NICKLE. She is married to Defendant. 10. Plaintiff has not participated as a party or witness or in any other capacity, in other litigation concerning the custody of the children in this or any other Court, except as set forth above. 11. The Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth or ie any other State. 12. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children, or claims to have custody or visitation rights with respect to the children. 13. Each parent whose parental rights to the children have not been terminated, and the persons who have physical custody of the children, have been named as parties to this action. There are no other persons known to have or claim a right to custody or visitation of the children and therefore, no further notice of the pendency of this action and the right to intervene shall be given, other than to the parties named herein. 14. The best interest and permanent welfare of the minor children will be served by granting Plaintiff primary physical and shared legal custody of JASON and BREONA. , Plaintiff requests this Honorable Court to grant her primary physical and shared legal custody of the minor children. Respectfully submitted, Marya Murphy, Es uir Lki Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff VERIFICATION I, ANGELA M. NICKLE, verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. fi"A- /,A Nv ANGELA k. NICKLE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAN ANGELA M. NICKLE, Plaintiff V. JASON S. NICKLE, SR., Defendant NO. IN CUSTODY CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that on the day of 2000 I served a true and correct copy of the foregoing Complaint in Custody on the Defendant, JASON S. NICKLE, SR. at the address set forth below, by placing a copy of same in the United States mail, postage prepaid, certified/restricted delivery. Jason S. Nickle, Sr. 1066 Centerville Road Newville, PA 17241 Respectfully submitted, Maryann Murphy, Esquire Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 (717) 540-8600 I.D. # 61900 E`J c'r n 1 j rn I„ ,e :_z arn: (? Ga ? G °G tfi -< G ?nry Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ANGELA M. NICKLE, Plaintiff V. JASON S. NICKLE, SR., Defendant NO. a(DCC? -- IN CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, ANGELA M. NICKLE, Plaintiff, to proceed in forma a? nperis. I, Maryann Murphy, Esquire, of Legal Services, Inc., attorney for the party proceeding in ffn a au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. A 1#11m IAI 6 u kil J/ Maryanh Murphy, Esquir Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANGELA M. NICKLE, Plaintiff NO. o-v- a .24 G C'u t l v. JASON S. NICKLE, SR., Defendant IN CUSTODY AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am ANGELA M. NICKLE, Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: ANGELA M. NICKLE Address: 7 Pine Road, Apt. #506, Mr. Holly Springs, PA 17065 (b) Social Security Number: 201-64-4389 If you are presently employed, state Employer: Carlisle Hospital Address: Carlisle. PA Salary or wages per month: $1.481.00 Type of work: housekegper If you are presently unemployed, state N/A Date of last employment: N/A Salary or wages per month: N/A Type of work: (c) Other income within the past twelve months Business or profession: Other self-employment: -0- Interest: Dividends: Pension and annuities: Social Security benefits: Support payments: $200.00 Disability payments: Unemployment compensation and supplemental benefits: Workman's compensation: Public Assistance: Other: (d) Other contributions to household support (Wife)(Husband) Name: N/A (the parties are separated) If your (husband) (wife) is employed, state Employer: N/A . Salary or wages per month: N/A Type of work: N/A Contributions from children: (e) Property owned Cash: $5.00 Checking Account: $50.00 Savings Account: $50.00 Certificates of Deposit: Real Estate (including home): Motor vehicle: Make MercuKy Topaz Year 1991 Cost $800.00 Amount owed -0- Stocks; bonds: Other: (f) Debts and obligations Mortgage: -0- Rent: $219.00 Loans: Monthly Expenses: $1380.00 (g) Persons dependent upon you for support (Wife) (Husband) Name: N/A Children, if any: Name: Jason Age: Name: Breona Age: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: U ANGEL NICKLE , r Y ? 6b? IN THE COURT OF CONMON PLEAS OF CUKBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANGELA N. NICKLE, Plaintiff V. JASON S. NICKLE, SR., Defendant NO. &0 w ZL? l! ? TtH IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, this day of 0 2000, comes the I Plaintiff, ANGELA M. NICKLE, by and through her attorney, Maryann Murphy, Esquire, of Legal Services, Inc., and respectfully files this Complaint for Custody, and in support thereof avers as follows: 1. The Plaintiff is ANGELA M. NICKLE whose current address is 7 Pine Road, Apt. #506, Mt. Holly Springs. Cumberland County, Pennsylvania. 2. The Defendant is JASON S. NICKLE, SR. whose current address is 1066 Centerville Road, Newville, Cumberland County, Pennsylvania. 3. The Plaintiff seeks primary physical and shared legal custody of the following children: JASON NICKLE, born December 30, 1995 and BREONA NICKLE, born September 18, 1997 4. The children were born out of wedlock. 5. Plaintiff currently resides with the minor children. 6. Defendant currently resides with his parents. 7. During the lifetime of the children, they have resided at the following addresses with the following persons: Time Address birth-3/96 10 Hollinger St, Mt. Holly Springs, PA 3/96-8/96 1066 Centerville Rd Newville, PA 8/96-10/99 7 Pine Road Mt. Holly Springs, PA 10/99-present 7 Pine Road Mt. Holly Springs, PA With Whom Plaintiff/Defendant Plaintiff's parents Plaintiff/Defendant Defendant's parents Plaintiff/Defendant Plaintiff 8. The father of the children is JASON S. NICKLS, SR. He is married to Plaintiff. 9. The mother of the children is ANGELA N. NICKLS. She is married to Defendant. 10. Plaintiff has not participated as a party or witness or in any other capacity, in other litigation concerning the custody of the children in this or any other Court, except as set forth above. 11. The Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth or in any other State. 12. The Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children, or claims to have custody or visitation rights with respect to the children. 13. Each parent whose parental rights to the children have not been terminated, and the persons who have physical custody of the children, have been named as parties to this action. There are no other persons known to have or claim a right to custody or visitation of the children and therefore, no further notice of the pendency of this action and the right to intervene shall be given, other than to the parties named herein. 14. The best interest and permanent welfare of the minor children will be served by granting Plaintiff primary physical and shared legal custody of JASON and HREONA. WHEREFORE, Plaintiff requests this Honorable Court to grant her primary physical and shared legal custody of the minor children. Respectfully submitted, V Maryagn Murphy, Es(kuir Legal Services, Inc. v 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff VERIFICATION I, ANGELA N. NICKLE, verify that the statements made in the foregoing Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. 11t A) c b ANGELA k. NICKLE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAM ANGELA M. NICKLE, Plaintiff V. JASON S. NICKLE, SR., Defendant NO. IN CUSTODY CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that on the day of 2000 I served a true and correct copy of the foregoing Complaint in Custody on the Defendant, JASON S. NICKLE, SR. at the address set forth below, by placing a copy of same in the United States Mail, postage prepaid, certified/restricted delivery. Jason S. Nickle, Sr. 1066 Centerville Road Newville, PA 17241 Respectfully submitted, Maryann Nurphy, Esquir Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 (717) 540-8600 I.D. # 61900 ;?_ ?;- :; ??,; ?, ?" _i - __, .. _. .:'. ' i'. .?, ? ? ': ' C, W 6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANGELA M. NICKLE, Plaintiff V. JASON S. NICKLE, SR. Defendant NO. 0????1` ??? IN CUSTODY ORDER OF COURT AND NOW, upon consideration of the hereby directed that the P,r ies and app ear J7 ore - - of 2000, at Custody nference. At such Conference, resolve the issues in dispute; or if thi to define and narrow the issues to be enter into a temporary order. Failure t vide rounds for entry of a tempo attached Complaint, it is their respective counsel the Conciliator, at on the +4,-% day fl.m., for a Pre-Hearing an effort will be made to s cannot be accomplished, heard by the Court and to o appear at the Conference may pro g rary or permanent order. BY THE COURT: C stody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland county is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact the office set forth above. 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. Oo-?j.Jc? 'C' r. C r',{? r? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANGELA M. NICKLE, Plaintiff NO. aC?Ot? aa? ?p V. JASON S. NICKLE, SR., Defendant IN CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, ANGELA M. NICKLE, Plaintiff, to proceed in forma au eris. I, Maryann Murphy, Esquire, of Legal Services, Inc., attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Marya Murphy, Esquir Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. k 61900 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANGELA M. NICKLE, Plaintiff NO. o-v. a?44 ?w l 1 V. JASON S. NICKLE, SR., Defendant IN CUSTODY AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am ANGELA M. NICKLE, Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: ANGELA M. NICKLE Address: _7 Pine Road. Ant. #506. Mr. Holly Spines PA 17065 (b) Social Security Number: 201-64-4389 If you are presently employed, state Employer: Carlisle Hospital Address: Carlisle. PA Salary or wages per month: $1.481.00 Type of work:_ housekeeper If you are presently unemployed, state N/A Date of last employment: N/A Salary or wages per month: N/A _ Type of work: (c) Other income within the past twelve months Business or profession:. Other self-employment: Interest: Dividends: Pension and annuities: _ Social Security benefits: Support payments: $200.00 Disability payments: Unemployment compensation and supplemental benefits: Workman's compensation: Public Assistance: Other: (d) Other contributions to household support (Wife)(Husband) Name: N/A (the parties are separated) If your (husband) (wife) is employed, state Employer: Salary or wages per month: N/A Type of work: N/A Contributions from children: (e) Property owned Cash: $5.00 Checking Account: $50.00 Savings Account: $50.00 Certificates of Deposit: Real Estate (including home): Motor vehicle: Make Mercury Topaz Year 1991 Cost $800.00 Amount owed -0- Stocks; bonds: Other: (f) Debts and obligations Mortgage: Rent: $219.00 Loans: Monthly Expenses: $1380.00 (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: Jason Age: Name: Breona Age: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 P.I. C.S. 4904, relating to unworn falsification to authorities. Date: -?? ANGELk . NICKLE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW ANGELA M. NICKLE, Plaintiff V. JASON S. NICKLE, SR., Defendant NO. 00-2266 Civil Term IN CUSTODY ORDER OF COURT AND NOW, this ;3P' day of 44**r 2000, upon consideration of the attached Stipulation for Entry of a Custody Order, IT IS HEREBY ORDERED AND DECREED that custody and partial custody with respect to the minor children: JASON NICKLE, born December 30,1995; and BREONA NICKLE, born September 18, 1997, is awarded as follows: I. The parents shall share legal custody of the minor children. All major decisions regarding the children, including medical, educational and religious matters, shall be discussed between the parents. 2. MOTHER shall have primary physical custody of the minor children. 3. FATHER shall have partial physical custody of the minor children on alternate weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m. 4. The following holidays shall be shared or alternated between the parents each year; Memorial Day, the Fourth of July and Labor Day. The hours shall be from 10:00 a.m. until 6:00 p.m. unless otherwise agreed by the parents. In 2000 and in all even years thereafter, MOTHER shall have Memorial Day and Labor Day, and FATHER shall have the Fourth of July. In 2001 and in all odd years thereafter, FATHER shall have Memorial Day and Labor Day, and MOTHER shall have the Fourth of July. If possible, both parents shall have the opportunity to enjoy fireworks with the minor children during these holidays. 5. Thanksgiving shall be shared and alternated between the parents each year. The Thanksgiving holiday shall be divided into two (2) segments. Segment "A" shall be from the Wednesday before Thanksgiving at 5:00 p.m. until Thanksgiving Day at 5:00 p.m. Segment "B" shall be from Thanksgiving Day at 5:00 p.m. until the Friday after Thanksgiving at 5:00 p.m. In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 6. Easter shall be shared and alternated between the parents each year. In 2001 and in all odd years thereafter, FATHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and MOTHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. In 2002 and in all even years thereafter, MOTHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and FATHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. 7. Christmas shall be shared and alternated between the parents each year. The Christmas holiday shall be divided into two (2) segments. Segment "A" shall be from noon on Christmas Eve until noon on Christmas Day. Segment "B" shall be from noon on Christmas Day until noon on December 26". In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B" 8. FATHER shall have the minor children on Father's Day and MOTHER shall have the minor children on Mother's Day. The hours shall be from 10:00 a.m. until 8:00 p.m. unless otherwise agreed by the parents. 9. Each parent shall have the minor children for two (2) weeks every year for summer vacation. These weeks need not be taken consecutively but should be taken in conjunction with that parent's alternate weekend. The parents shall give each other written notice of their chosen week(s) of summer custody by May 15'h of each year, if possible. In the event that both parents choose the same week(s) for summer custody, the parent who gives first notice shall prevail. 10. FATHER shall provide all transportation for custody transfers, or shall arrange transportation for the transfers by mutual agreement of the parents. 11. While in the presence of the children, neither parent shall make, or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express dub/ of each parent to uphold the other parent as one whom the children should respect and love. 12. Each parent shall provide the other with a current telephone number and address. 13. Neither parent shall use illegal drugs nor shall they abuse alcohol in the presence of the children. MOTHER and FATHER shall ensure that the minor children not be in the presence of third parties who use illegal drugs or abuse alcohol. 14. Each parent shall have the opportunity to see the minor children on their birthdays. The specific times shall be agreed upon between the parents. 15. The schedules for all holidays, vacations and special occasions shall take priority over the usual weekly schedule. 16. Both parents shall permit reasonable telephone access between the children and the other parent. The children shall be permitted reasonable telephone access to place calls to each of their parents while they are with the other. 17. By mutual consent of the parents, a revised schedule maybe agreed upon between them for and in the best interests of the minor children, 18. This Order shall replace and supercede any and all prior Orders of Court or agreements between the parties. 19. This Order shall remain in full force and effect until further Order of Court. BY THE COURT: J too RKS -? G;;y .-; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW ANGELA M. NICKLE, Plaintiff V. JASON S. NICKLE, SR., Defendant : NO. 00-2266 Civil Term IN CUSTODY STIPULATION FOR ENTRY OF CUSTODY ORDER The parties to this action, ANGELA M. NICKLE (hereinafter referred to as "MOTHER"), and JASON S. NICKLE, SR. (hereinafter referred to as "FATHER"), desiring to amicably settle and resolve all outstanding issues concerning custody and partial custody with respect to the minor children: JASON NICKLE, born December 30,1995; and BREONA NICKLE, born September 18, 1997, hereby stipulate and agree to the entry of an Order of Court awarding custody and partial custody of JASON and BREONA as follows: The parents agree that they shall share legal custody of the minor children. All major decisions regarding the children, including medical, educational and religious matters, shall be discussed between the parents. 2. The parents agree that MOTHER shall have primary physical custody of the minor children. 3. The parents agree that FATHER shall have partial physical custody of the minor children on alternate weekends from Friday at 5:00 P.M. until Sunday at 5:00 p.m. 4. The parents agree that the following holidays shall be shared or alternated between them each year; Memorial Day, the Fourth of July and Labor Day. The hours shall be from 10:00 a.m. until 6:00 p.m. unless otherwise agreed by the parents. In 2000 and in all even years thereafter, MOTHER shall have Memorial Day and Labor Day, and FATHER shall have the Fourth of July. In 2001 and in all odd years thereafter, FATHER shall have Memorial Day and Labor Day, and MOTHER shall have the Fourth of July. If possible, both parents shall have the opportunity to enjoy fireworks with the minor children during these holidays. The parents agree to share and alternate Thanksgiving each year. The Thanksgiving holiday shall be divided into two (2) segments. Segment "A" shall be from the Wednesday before Thanksgiving at 5:00 p.m. until Thanksgiving Day at 5:00 p.m. Segment "B" shall be from Thanksgiving Day at 5:00 p.m. until the Friday after Thanksgiving at 5:00 p.m. In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 6. The parents agree to share and alternate Easter each year. In 2001 and in all odd years thereafter, FATHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and MOTHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. In 2002 and in all even years thereafter, MOTHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before: Easter, and FATHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. 7. The parents agree to share and alternate Christmas each year. The Christmas holiday shall be divided into two (2) segments. Segment "A" shall be from noon on Christmas Eve until noon on Christmas Day. Segment "B" shall be from noon on Christmas Day until noon on December 26th. In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 8. The parents agree that FATHER shall have the minor children on Father's Day and MOTHER shall have the minor children on Mother's Day. The hours shall be from 10:00 a.m. until 8:00 p.m. unless otherwise agreed by the parents. 9. MOTHER and FATHER agree that each of them shall have the minor children for two (2) weeks every year for summer vacation. These weeks need not be taken consecutively but should be taken in conjunction with that parent's alternate weekend. The parents shall give each other written notice of their chosen week(s) of summer custody by May 15`h of each year, if possible. In the event that both parents choose the same week(s) for summer custody, the parent who gives first notice shall prevail. 10. FATHER agrees to provide all transportation for custody transfers, or to arrange transportation for the transfers by mutual agreement of the parents. 11. MOTHER and FATHER agree that while in the presence of the children, neither parent shall make, or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the children should respect and love. 12. Each parent agrees to provide the other with a current telephone number and address. 13. Both parents agree that neither shall use illegal drugs nor shall they abuse alcohol in the presence of the children. MOTHER and FATHER agree that the minor children shall not be in the presence of third parties who use illegal drugs or abuse alcohol. 14. Both parents agree that they shall each have the opportunity to seethe minor children on their birthdays. The specific times shall be agreed upon between the parents. 15. MOTHER and FATHER agree that the schedules for all holidays, vacations and special occasions shall take priority over the usual weekly schedule. 16. Both parents agree to permit reasonable telephone access between the children and the other parent. The children shall be permitted reasonable telephone access to place calls to each of their parents while they are with the other. 17. Both parents agree that, by their mutual consent, a revised schedule maybe agreed upon between them for and in the best interests of the minor children, 18. The parents agree that this Agreement shall be submitted to the Court of Common Pleas of Cumberland County, Pennsylvania for approval and for entry of an Order awarding custody and partial custody as set forth herein, and the parents hereby request that this Honorable Court enter such an Order. IN WITNESS WHEREOF, the parties have executed this Stipulation for Entry of a Custody Order on the date indicated below. 5-17?Da v \ ? . Date Witness SON S. NICKLE, SR. Date Witness ANGE A M. NICKLE C? c , ?? _ - _? ?? -n _ _ ;?*? ? ? .? r" ?4 _) 'i, ?? f?1 .J Z CJ1 MAX & L 2000' ANGELA M. NICKLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW JASON S. NICKLE, SR., : NO. 2000 - 2266 CIVIL Defendant : IN CUSTODY COURT ORDER AND NOW, this I Y? day of May, 2000, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. BY THE COURT, 9_Jx Hubert X. Gilroy, Esgw Custody Conciliator <.) '-? O c o -,? -; •-, ?? -!n i.) ice) ".? ;'may m .? L!7 _? tD j ANGELA M. NICKLE, Plaintiff V. JASON S. NICKLE, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-2266 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW comes Petitioner, Jason Nickle, by and through his attorney, Mark F. Bayley, Esquire, and in support of the within petition avers as follows: 1. Jason Nickle, Petitioner, (hereinafter referred to as "Father"), is the Defendant in the above caption-matter, and is an adult currently residing at 1849 Walnut Bottom Rd., Newville, Pennsylvania 17241. 2. Angela M. Nickle, k/n/a, Angela M. Keiter, Respondent, (hereinafter referred to as "Mother"), is the Plaintiff in the above-captioned matter, and is an adult currently residing at 1 Mountain View Terrace, Newville, Pennsylvania 17241. 3. The parties are the natural parents of: Jason Scott Nickle (date of birth 12/30/1995). Breonna Mae Nickle (date of birth 9/18/1997). 4. A previous Order was entered on May 23, 2000 (a copy is attached as Exhibit 5. Said Order was based upon a written stipulation signed by the parties on May 17, 2000. 6. Said Order became obsolete shortly after it was entered and the parties have made alternative arrangements for custody over the years. 7. Father now wishes to obtain an Order which better reflects the current circumstances. WHEREFORE, Petitioner requests this Honorable Court to schedule a custody conciliation conference. Date. Respectfully submitted, BAYLEY & MANGAN UkAF? Mark F. Bayley, Esqu' 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 MAY 19 2000V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW ANGELA M. NICKLE, Plaintiff NO. 00-2266 Civil Term V. JASON S. NICKLE, SR., Defendant IN CUSTODY ORDER OF COURT AND NOW, this day of -M (1i 1 , 2000, upon consideration of the attached 13 Stipulation for Entry of a Custody Order, IT IS HEREBY ORDERED AND DECREED that custody and partial custody with respect to the minor children: JASON NICKLE, born December 30,1995; and BREONA NICKLE, born September 18, 1997, is awarded as follows: 1. The parents shall share legal custody of the minor children. All major decisions regarding the children, including medical, educational and religious matters, shall be discussed between the parents. 2. MOTHER shall have primary physical custody of the minor children. 3. FATHER shall have partial physical custody of the minor children on alternate weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m. 4. The following holidays shall be shared or alternated between: the parents each year; Memorial Day, the Fourth of July and Labor Day. The hours shall be from 10:00 am. until 6:00 p.m. unless otherwise agreed by the parents. In 2000 and in all even years thereafter, MOTHER shall have Memorial Day and Labor Day, and FATHER shall have the Fourth of July. In 2001 and in all odd years thereafter, FATHER shall have Memorial Day and Labor Day, and MOTHER shall have the Fourth of July. If possible, both parents shall have the opportunity to enjoy fireworks with the minor children during these holidays. 5. Thanksgiving shall be shared and alternated between the parents each year. The Thanksgiving holiday shall be divided into two (2) segments. Segment "A" shall be from the Wednesday before Thanksgiving at 5:00 p.m. until Thanksgiving Day at 5:00 p.m. Segment "B" shall be from Thanksgiving Day at 5:00 p.m. until the Friday after Thanksgiving at 5:00 p.m. In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 6. Easter shall be shared and alternated between the parents each year. In 2001 and in all odd years thereafter, FATHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and MOTHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. In 2002 and in all even years thereafter, MOTHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and FATHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. 7. Christmas shall be shared and alternated between the parents each year. The Christmas holiday shall be divided into two (2) segments. Segment "A" shall be from noon on Christmas Eve until noon on Christmas Day. Segment "B" shall be from noon on Christmas Day until noon on December 26". In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 8. FATHER shall have the minor children on Father's Day and MOTHER shall have the minor children on Mother's Day. The hours shall be from 10:00 a.m. until 8:00 p.m. unless otherwise agreed by the parents. 9. Each parent shall have the minor children for two (2) weeks every year for summer vacation. These weeks need not be taken consecutively but should be taken in conjunction with that parent's alternate weekend. The parents shall give each other written notice of their chosen week(s) of summer custody by May 15`h of each year, if possible. In the event that both parents choose the same week(s) for summer custody, the parent who gives first notice shall prevail. 10. FATHER shall provide all transportation for custody transfers, or shall arrange transportation for the transfers by mutual agreement of the parents. 11. While in the presence of the children, neither parent shall make, or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the children should respect and love. 12. Each parent shall provide the other with a current telephone number and address. 13. Neither parent shall use illegal drugs nor shall they abuse alcohol in the presence of the children. MOTHER and FATHER shall ensure that the minor children not be in the presence of third parties who use illegal drugs or abuse alcohol. 14. Each parent shall have the opportunity to see the minor children on their birthdays. The specific times shall be agreed upon between the parents. 15. The schedules for all holidays, vacations and special occasions shall take priority over the usual weekly schedule. 16. Both parents shall permit reasonable telephone access between the children and the other parent. The children shall be permitted reasonable telephone access to place calls to each of their parents while they are with the other. 17. By mutual consent of the parents, a revised schedule maybe agreed upon between them for and in the best interests of the minor children, 18. This Order shall replace and supercede any and all prior Orders of Court or agreements between the parties. 19. This Order shall remain in full force and effect until further Order of Court. BY THE COURT: TP ' ray hand In t-''-- and the seal of said Court at Carlisle, Pa. ... ay y f. •, Thi a AA thonotary, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW ANGELA M. NICKLE, Plaintiff V. JASON S. NICKLE, SR., Defendant IN CUSTODY STIPULATION FOR ENTRY OF CUSTODY ORDER The parties to this action, ANGELA M. NICKLE (hereinafter referred to as "MOTHER"), and JASON S. NICKLE, SR (hereinafter referred to as "FATHER"), desiring to amicably settle and resolve all outstanding issues concerning custody and partial custody with respect to the minor children: JASON NICKLE, born December 30,1995; and BREONA NICKLE, born September 18, 1997, hereby stipulate and agree to the entry of an Order of Court awarding custody and partial custody of JASON and BREONA as follows: 1. The parents agree that they shall share legal custody of the minor children. All major decisions regarding the children, including medical, educational and religious matters, shall be discussed between the parents. 2. The parents agree that MOTHER shall have primary physical custody of the minor children. NO. 00-2266 Civil Term 3. The parents agree that FATHER shall have partial physical custody of the minor children on alternate weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m. 4. The parents agree that the following holidays shall be shared or alternated between them each year; Memorial Day, the Fourth of July and Labor Day. The hours shall be from 10:00 a.m. until 6:00 p.m. unless otherwise agreed by the parents. In 2000 and in all even years thereafter, MOTHER shall have Memorial Day and Labor Day, and FATHER shall have the Fourth of July. In 2001 and in all odd years thereafter, FATHER shall have Memorial Day and Labor Day, and MOTHER shall have the Fourth of July. If possible, both parents shall have the opportunity to enjoy fireworks with the minor children during these holidays. 5. The parents agree to share. and alternate Thanksgiving each year. The Thanksgiving holiday shall be divided into two (2) segments. Segment "A" shall be from the Wednesday before Thanksgiving at 5:00 p.m. until Thanksgiving Day at 5:00 p.m. Segment "B" shall be from Thanksgiving Day at 5:00 p.m. until the Friday after Thanksgiving at 5:00 p.m. In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment B". 6. The parents agree to share and alternate Easter each year. In 2001 and in all odd years thereafter, FATHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and MOTHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. In 2002 and in all even years thereafter, MOTHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and FATHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. 7. The parents agree to share and alternate Christmas each year. The Christmas holiday shall be divided into two (2) segments. Segment "A" shall be from noon on Christmas Eve until noon on Christmas Day. Segment "B" shall be from noon on Christmas Day until noon on December 200. In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 8. The parents agree that FATHER shall have the minor children on Father's Day and MOTHER shall have the minor children on Mother's Day. The hours shall be from 10:00 a.m. until 8:00 p.m. unless otherwise agreed by the parents. 9. MOTHER and FATHER agree that each of them shall have the minor children for two (2) weeks every year for summer vacation. These weeks need not be taken consecutively but should be taken in conjunction with that parent's alternate weekend. The parents shall give each other written notice of their chosen week(s) of summer custody by May 15`h of each year, if possible. In the event that both parents choose the same week(s) for summer custody, the parent who gives first notice shall prevail. 10. FATHER agrees to provide all transportation for custody transfers, or to arrange transportation for the transfers by mutual agreement of the parents. 11. MOTHER and FATHER agree that while in the presence of the children, neither parent shall make, or permit any other person to make, any remarks or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the children should respect and love. 12. Each parent agrees to provide the other with a current telephone number and address. 13. Both parents agree that neither shall use illegal drugs nor shall they abuse alcohol in the presence of the children. MOTHER and FATHER agree that the minor children shall not be in the presence of third parties who use illegal drugs or abuse alcohol. 14. Both parents agree that they shall each have the opportunity to see the minor children on their birthdays. The specific times shall be agreed upon between the parents. 15. MOTHER and FATHER agree that the schedules for all holidays, vacations and special occasions shall take priority over the usual weekly schedule. 16. Both parents agree to permit reasonable telephone access between the children and the other parent. The children shall be permitted reasonable telephone access to place calls to each of their parents while they are with the other. 17. Both parents agree that, by their mutual consent, a revised schedule maybe agreed upon between them for and in the best interests of the minor children, 18. The parents agree that this Agreement shall be submitted to the Court of Common Pleas of Cumberland County, Pennsylvania for approval and for entry of an Order awarding custody and partial custody as set forth herein, and the parents hereby request that this Honorable Court enter such an Order. IN WITNESS WHEREOF, the parties have executed this Stipulation for Entry of a Custody Order on the date indicated below. 5=17- Date Witness SON S. NICKLE, SR. S-i uAAA 0- Date Witness WGAICKLE X22 ANGELA M. NICKLE, Plaintiff v JASON S. NICKLE, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 - 2266 CIVIL IN CUSTODY COURT ORDER k AND NOW, this Y day of May, 2000, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. BY THE COURT, 4J)6 1 - - Hubert X. Gilroy, Esq Custody Conciliator _- r\3 --7!T3 trG f ANGELA M. NICKLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 00-2266 CIVIL TERM JASON S. NICKLE, SR., : CIVIL ACTION - LAW Defendant IN CUSTODY ATTORNEY VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney for Defendant in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: r .-- () ( UV41--i Mark F. Bayley, Esquire ANGELA M. NICKLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 00-2266 CIVIL TERM JASON S. NICKLE SR., : CIVIL ACTION - LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Defendant do hereby certify that I this day served a copy of the foregoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Angela Keiter 1 Mountain View Terrace Newville, PA 17241 Mark F. Bayley, Esquire ?y rz? ?V Q ? N j ! C? i tl , +a4? - ANGELA M. NICKLE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2000-2266 CIVIL ACTION LAW JASON S. NICKLE, SR. IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, November 06, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, December 11, 2008 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 define and narrow the issues to be heard by the court, and to enter into a temporary order. 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/ Hubert X. Gilroy, Es q. 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 vw * -,Ok-r 1 z :C W8 4- AON 89OZ 1?8't?1Uly : i -OW .]Hi :10 l5O- f a/ -5®- °l-J/ 50-1-IA ANGELA M. NICKLE, n/k/a : IN THE COURT OF COMMON PLEAS OF ANGELA KEITER, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Petitioner V. : NO. 2000-2266 CIVIL ACTION LAW JASON S. NICKLE, Defendant/Respondent : IN CUSTODY PETITION TO MODIFY CUSTODY ORDER AND NOW, this 9th day of December, 2008, the following Petition to Modify Custody Order by Petitioner, Angela M. Keiter, by and through her attorney, Brian O. Williams, and respectfully requests this Honorable Court grant a Modification of Custody, and in support thereof, the following is averred: 1. Petitioner is ANGELA M. KEITER, an adult individual currently residing at 1 Mountain View Terrace, Newville, Cumberland County, Pennsylvania 17241. 2. Respondent is JASON S. NICKLE, SR., an adult individual currently residing at 1849 Walnut Bottom Road, Newville, Cumberland County, Pennsylvania 17241. 3. Respondent filed a Petition to Modify Custody with the Court of Common Pleas of Cumberland County on November 3, 2008. 4. The Petitioner is the natural mother of subject minor children, Jason Scott Nickle, age 12. DOB 12/30/1995 and Breonna Mae Nickle, age 11, DOB 09/18/1997. 5. Petitioner currently resides with her husband, Anthony Keiter and has primary physica: custody of the subject minor children Jason Scott Nickle and Breonna Mae Nickle. 6. The Respondent is the natural father of the subject matter children. 7. Respondent currently resides with his girlfriend, and her three children in her apartment. 8. A previous Order was entered on May 23, 2000 (attached as Exhibit "1"). 9. Said order was based upon a written stipulation signed by the parties on May 17, 2000. 10. Said Order became obsolete shortly after it was entered and the parties have made alternative arrangements for custody over the years. 11. The subject children stay at the paternal grandmother's house instead of at the respondent's residence every other weekend. 12. The Respondent occasionally visits with the subject children at the paternal grandmother's home for short periods of time. 13. Respondent has never consulted with Petitioner or shown an interest regarding decision making issues affecting the children's health and welfare. 14. In September of this year, Respondent pulled the daughter Beonna out of her elementary school and registered her in a different elementary school without notice or consultation with the Petitioner. 15. Respondent has not paid any child support since Petitioner withdrew the support order last year. 16. The Respondent was arrested in August of this year for assaulting his girlfriend with sentencing pending. 17. The Respondent has a history of alcohol abuse and engaging in criminal behavior, which creates an unstable environment for the children. 18. The Respondent's current residence is unstable and not a safe environment for the subject children to stay overnight. 19. Respondent rarely requests to see the children on birthdays or Holidays. Recently, the Respondent chose not telephone the children or request time with them this past Thanksgiving. 20. Petitioner has not participated as a party or witness, or in another capacity in other litigation concerning the custody of the children in this or another court. Petitioner hasno information of a custody proceeding concerning the children pending in a court of this Commonwealth. 21. Petitioner does not know of a person not a party to the proceeding who has physical custody of the children, or claims to have custody or visitation rights with respect to the l children. 22. 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 Petition. 23. The best interest and permanent welfare of the children will be served by ordering Respondent to: a. Enroll in and complete an alcohol treatment program; and b. Enroll in anger management class. 24. Petitioner respectfully requests to modify the Current Order and award sole legal custody of the subject matter children to Petitioner, while providing supervised partial physical custody of the children to the Respondent. WHEREFORE, the Petitioner, Angela M. Keiter, respectfully requests that This Honorable) Court grants his request to schedule a Custody Conciliation in this matter followed by granting) sole legal custody of the minor children to Petitioner. Dated: I d Respectfully Submitted, Brian O. Williams, Esquire Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 (717)245-9688 CERTIFICATE OF SERVICE I, Brian O. Williams, Esquire hereby certify that I served a true and correct copy of the Petition to Modify Custody by first class, postage pre-paid and depositing same in the United States Mail, first class, postage pre-paid on the `7'/( day of ACe,?SPr , 2008, from Carlisle, Pennsylvania, addressed as follows: Mark F. Bayley, Esquire Bayley & Mangan Law Offices 17 West South Street Carlisle, PA 17013 TURO LAW OFFICES Brian O. Williams, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Supreme Court I.D. No. 209610 VERIFICATION I verify that the statements made in the foregoing Potition to Modify Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date Angela Ke' . N . MgT19 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW ANGELA M. MCKLE, Plaintiff : NO. W2266 Civil Term JASON S. NICKLE, SR, IN CUSTODY Defendant ORDER OF COURT AND NOW, this of 2000, upon consideration of tine auwJwd S i 3 Stipuiation for Entry of a Custody Order, IT IS Y ORDERED AND DECREED that i custody and partial custody with respect to the minor children: JASON NICNIX born December 30,1995; and BREONA MC102, born Sepunker 19, 1997, is awarded as follows: The pffab shall share legal custody of the minor cb tdrm All major decisions regsr+dmg the children, including modicd, edwaftonal and religious mMxs, shall be discussed between the parents. 2. MOTHER shall have primary physical custody of the mirror children, 3. FATHER shall have partial physical custody of the minor children on alternate weekends from Friday at 5:00 p.m. until Sunday at 5:00 p.m. 4. The following holidays shall be shared or alternated between; the F w e nts each yew, Memorial Day, the Fourth of July and Labor Day. The hours shall be from 10:00 a.m. until 6:00 p.m. unless otherwise agreed by the parents. EXHIBIT ..-fr'? <.. e,?i . ?` ;"x?jJ?.C.n du, tisi.' i "`?? . ?'?'?`?' S r ? t ? t.tq?y 'A.? A.rk7l,?. r?? 7? l?:s ?? a , r, '?a F'.. it*1Qdf?''??S ?fri...fT, ,'.f }'. C?*.?t€k:i 1??l??i; (£: ?l?t 1? l•.'.?ia? d!? ? .)' *,>lr ??P'g .Y. 'w:3'},I In 2000 and in all even years thereafter, MOTHER shall have Manorial Day and Labor Day, and FATHER shall have the Fourth of Judy. In 2001 and in all odd years thereafter, FATHER shall have Memorial Day and Labor Day, and MOTHER shall have the Fourth of July. If possible, bath parents shall have the opporwnity to enjoy &eworks with the minor children during these holidays. 5. Thanksgiving strait be shared and alternated between the pavem each year. The Thanksgiving holiday shall be divided into two (2) segments. Segment "A" shall be fiom the Wednesday before Thanksgiving at 5:00 p.m. until Thanksgiving Day at 5:00 pm. Segment "B" shall be from Thanksgiving Day at 5;00 p.m. until the Friday after Thanksgiving at 5:00 p.m. In 2000 and in all even years dumfter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment -B-- 6. Easter shall be shared and alternated between the parents each year. In 2001 and in all odd years thereafter, FATHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5.00 p.m. the Saturday before Easter, and MOTHER shall have from 5:00 p.m. the Saturday before Easter urM 5:00 pan. on Easter Sunday. In 2002 and in all even years thereafter, MOTHER shall have the minor children from 5:00 p.m. the Friday before Easter until 5:00 pm. the Saturday before Easter, and FATTER shall have from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Easter Sunday. 7. Christmas shall be shared and alternated between the parents each year. The Christmas ,.?.._....,,? . ?.,_?:.,,b.,. holiday shall be divided into two (2) segments. Segment "A" shall be from noon on avist aus Eve until noon on Christmas Day. Segment "B" shall be fiom noon on Christmas, Day until noon on December 2&- In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 8. FATHER shall have the minor children on Father's Day and MOTHER shall have the minorchildren on Mother's Day. Thehorns shall be from 10:00 a.m. until 9:00 p.n. unlessotherwise agreed by the parents. 9. Each parent shall have the minor children for two (2) weeks every year for summer vacation These weeks need not be taken consecutively but should be taken in conju neon with that parent's alternate weekend. The parents shall give each other written notice of their chosen week(s) of summer custody by May 15* of each year, if possible. In the event that both parents choose the same week(s) for summer custody, the parent who gives first notice shall prevail. 10. FATHER shall provide all transportation for custody transfers, or shall arrange transportation for the transfers by mutual agreement of the parents. I I . While in the presence of the children, neither parent shall make, or permit any other i person to make, any remarks or do anything which could in any way be construed as derogatory or i uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the children should respect and love. „i;t +t. .. ,.4x'A t pl,.'o??;'` ? ¢4kA)?e .?i, ?',i., .:r ? .,..(s , ??i`???`, ..J?J? "?&'"+? a?, '6.i; ,,.. i.t,? q' s. ,. , M.?_. .. ..,,;. ., w. .w,,?s,=:x _,>v. .. ,ter-%r!?fw a- .?KS?,?-.,.-.,a+, ., .?z ..»a y?.,, nk „,?,„?rr. _. 12. Each parent shall provide the other with a can v t tekghone number and address. 13. Neither parent shall use illegal drugs nor shall they abuse ak:olrol in the presence of the children. MOTHER and FATHER shall ensure that the minor children not be in the presence of thW pasties who use illegal drugs or abuse alcohol. 14. Each parent shall have the opportunity to seethe minor children on their birthdays. The specific times shall be agreed upon between the parents. 15. The schedules for all holidays, vacations and special occasions diall take priority over the usual weekly schedule. 16. Both parents shall permit reasonable telephone access between the children and the other parent. The children shall be penw ed reasonable telephone access to place calls to each of their parents while they are with the other. 17. By mutual consent of the parents, a revised schedule may be agreed upon between than for and in the best interests of the minor children, 18. This Order shall replace and supercede any and all prior Orders of Court or agreements between the parties. 19. This Order shall remain in full force and effect until further Order of Court. BY THE COURT: In Twt.m any r.ttAtcf, ! li.r4 u-ito S-:-, ray hand and the seat of said Court Ja/t/?Carlisle, Pa. AOM 4% A .9;, rA A a - - W.-.Al W -- 7 tidLa U41i I JA P ,. a: .. - - f # ?, ;,.,.. x,.ry., ,,.:. . r..,.... .. .-. ozJYtn , rr .ia. N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW ANGELA W NICKLE, Piaiaw V. JASON S. NICKLE, SR., Defendant : NO. 08-2266 Civil Term IN CUSTODY The parties to this action, ANGELA M. MC= OadnaRer referted to as "MOTHER"}, and JASON S. MCKLE, SR. (hereinafter referred to as `FATHER"), desiring to tumicably settle and resolve all outstanding issues concerning custody and partial custody with respect to the minor children: JASON NICKLE, born December 30,1995; and BREONA NICKLE, born Seprocmber 18, 1997, hereby stipulate and agree to the entry of an Order of Court awarding custody and partial custody of JASON and BREONA as follows: 1. The parents agree that they shall share legal custody of the minor children. All major decisions regarding the children, including medical, educational and religious matters, shall be discussed between the parents. 2. The parents agree that MOTHER shell have primary physical custody of the minor children. 3. The pan m agree that FATHER shall have partial physical custody of the minor ?.., _. :, c <. _ ,. t . . ?.. ? . ?;???r .??3 t ? s ? ,? children on alternate wedcends firm Friday at 5:00 pm. until Sunday at 5:00 pm. 4. The parents agree that the following holidays shall be shared or alterhmted between them each year, Memorial Day, the Fourth of July and Labor Day. The hours shall be fi+orn 10:00 a.m. until 6:00 pm. unless otherwise agreed by the parents. In 2000 and in all even years tom, MOTHER shall have Memorial Day and Labor Day, and FATHER shall have the Fourth of July. In 2001 and in all odd years thereafter, FATHER shalt have Memorial Day and Labor Day, and MOTHER shalt have the Fourth of July. If possible, both parents shall havethe opportunity to enjoy fireworks with the minor children during these holidays. 5. The parents agree to share. and alternate Thanksgiving each year. The Thanksgiving holiday shall be divided into two (2) segments. Segment "A" shall be from the Wednesday before Thanksgiving at 5:00 p.m. until Thanksgiving Day at 5:00 p.m. Segment "B" shall be from Thanksgiving Day at 5:00 p.m. until the Friday after Thanksgiving at 5:00 p.m. In 2000 and in all even years thweafter, MOTHER shall have Segment "A" and FATHER shall have Segment "B". In 2001 and in all odd years dweafter, FATTIER shall have Segment "A" and MOTHER shall have Segment "B". 6. The patents agree to share and alternate Easter each year. In 2001 and in all odd years thereafter, FATHER shall have the minor children from 5:00 .i p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and MOTHER shall have J 1 5 >p .v 4 _wvv??NFr.. :...?., r?. .wef y.c a,^? -'4 ___ 7?- from 5:00 p.m. the Saturday before Easter until 5:00 p.m. on Faster Sunday. In 2002 and in all even years thereafter, MOTHER shall have the minor cbildreo from 5:00 p.m. the Friday before Easter until 5:00 p.m. the Saturday before Easter, and FATHER shall have from 5:00 p.m. the Saturday before Easter until 5:00 pm. on Easter Sunday. 7. IU parents agree to share and alternate Christmas each year. The Cbrisinin holiday shall be divided into two (2) segments. Segment "A" shall be from noon on Christmas Eve until noon on Christmas Day. Segment "B" shall be from noon on Christmas Day until noon on December 26*. In 2000 and in all even years thereafter, MOTHER shall have Segment "A" and FATHER shall have ScgmW "B". In 2001 and in all odd years thereafter, FATHER shall have Segment "A" and MOTHER shall have Segment "B". 8. The parents agree that FATHER shall have the minor children on Father's Day and MOTHER shall have the minor children on Mother's Day. The hours shall be from 10:00 a.m. until 8:00 pm unless otherwise agreed by the parents. 9. MOTHER and FATHER agree that each ofthem shall have the minorchildren for two (2) weeks every year for summer vacation. These weeks need not be taken consecutively but should be taken in conjunction with that parent's alternate weekend. The pax elm shall give each other written notice of their chosen week(s) of summer custody by May 15th of each year, if possible. In the event that both parents choose the same week(s) for summer custody, the patent who gives first notice shall prevail. 10. FATHER agrees to provide all traasp '-- .on for custody transfers, or to AfTS nge tv ortation for the transfers by maW agreexn a of the pumb. 11. MOTHER and FATHER agree that wbibe in the presence of the "dr % treidw parent shall make, or permit any other person to make, any rarmeaU or do anything which could in any way be construed as derogatory or uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the children should respect and love. 12. Each parent agrees to provide the other with a current telephone number and address. 13. Both parents agree that neither shall use illegal drugs nor shaU they abuse alcohol in the presence of the children. MOTHER and FATHER agree that the minor children shall not be in the presence of third parties who use illegal drugs or abuse alcohol. 14. Both paw agree that they shall each have the opportunity to we the minor children on their birthdays. The specific times shall be agreed upon between the parents. 15. MOTHER and FATHER agree that the schedules for ail holidays, vacations and special occasions shall take priority over the usual weekly schedule. 16. Both parents agree to permit reasonable telephone ass between the children and the other parent. The children shall be permitted nusonable telephone access to place calls to each of their parents while they are with the other. 17. Both parents agree that, by their mutual consent, a revised schedule may be agreed upon betw= them for and in the best interests of the minor children, 18. The parents agree that this Agt+eer wnt shall be submittedto the Court ofCommon Pleas ofCumberiand County, Pennsylvania for approval and for entry of an Order awarding custody and eJ`d .4h x' i.$?K ?{'} AIi?A{lla .a? .: .? ?ia ?a. ?? 2f. partial custody as set forth heaein, and the paoents hereby request that this Honorable Court eater such an Order. IN w T1VmW HMMoF, the parties have executed this Stipulation for Entry of a Custody Order on the elate indicated below. Date VIL N 3. NICKLE, 3R. r? Date Witness ANC M. NICKLE was ANGELA M. NICKLE, : IN THE COURT OF COQ FLEAS OF Plainoaff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW JASON S. NICKIA SR, NO. 2000 - 2266 CIVIL Ddmdaut : IN CUSTODY It AND NOW, this -1.1 r day of May, 2000, the Cwmliator being advised. the the parties haws reached m agreement, the ConcalieW rcliugWAm jw6dicdm BY THE COURT, 4JIV-11j- 1-11,13WIcir Custody Corr mator Ap i P L h ?J M`'r r - 'L7 ""- rn ANGELA M. NICKLE A/K/A ANGELA IN THE COURT OF COMMON PLEAS OF KEITER PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2000-2266 CIVIL ACTION LAW JASON S. NICKLE IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Thursday, December 11, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, January 09, 2009 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 define and narrow the issues to be heard by the court, and to enter into a temporary order. 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/ Hubert X. Gilroy, Es q. ,ION 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 g??' -Y cl? uf.F ,l f? v+ x6v DEC 16 2008 4 ANGELA M. NICKLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW JASON S. NICKLE,SR., NO. 2000-2266 Defendant IN CUSTODY PRIOR JUDGE: The Honorable Edward E. Guido COURT ORDER AND NOW, this f ? day of December , 2008, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this Court's prior Order of May 23, 2000, is vacated and replaced with the following Order: 1. The mother, Angela M. Nickle, and the father, Jason S. Nickle, Sr., shall enjoy shared legal custody of Jason Nickle, born December 30, 1995, and Breonna Mae Nickle, born September 18, 1997. 2. The Mother shall enjoy primary physical custody of the minor children. 3. The Father shall enjoy liberal periods of temporary physical custody of the minor children to include, at a minimum, alternating weekends and after school until Wednesday morning when the Father shall deliver the children to school. 4. The parties shall work between themselves to achieve a custody arrangement that recognizes the children want to be with their maternal grandmother for time on certain weekends. Additionally, the parties shall try to communicate with each other in an effort to achieve a custody arrangement that reflects the desires of the children subject, however, to the understanding that Mother needs meaningful custody time with the minor children and Father needs meaningful custody time with the minor children. I 5. For Christmas 2008, Mother shall have custody on Christmas Eve and Christmas Day through approximately noon. Father shall have custody from Christmas Day at approximately noon until approximately 2:00 p.m. on December 26. 6. Neither party shall consume alcohol or be under the influence of alcohol when they have custody' of the minor children. 7. The parties shall meet again for a custody conciliation on Thursday, February 26, 2009, at 8:30 a.m. In the event there are any major issues that develop between the date of this Order and the next scheduled custody conciliation conference, legal counsel for the parties may contact the Custody Conciliator directly to schedule an emergency conciliation conference. Judge Edward E. Guido cc: ark F. Bayley, Esquire Brian O. Williams, Esquire l0P 41,s /ri:.t LECL 2,181 0? 91.0! WV 91 030 $OOZ AdViQ titUHiC,l W 3HI ?O I M ANGELA M. NICKLE, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JASON S. NICKLE,SR., NO. 2000-2266 Defendant IN CUSTODY PRIOR JUDGE: The Honorable Edward E. Guido CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the children who are the subject of this litigation is as follows: Jason Scott Nickle, born December 30, 1995, and Breonna Mae Nickle, born September 18, 1997. 2. A Conciliation Conference was held on December 11, 2008, with the following individuals in attendance: The mother, Angela M. Nickle, who appeared with her counsel, Brian O. Williams, Esquire, and the father, Jason S. Nickle, Sr., with his counsel, Mark F. Bayley, Esquire. 3. The parties agree to the entry of an Order in the form as attached. Date: December /2- , 2008 I-IYbert X. 911roy, Esquire Custody onciliator ANGELA M. NICKLE, IN THE COURT OF COMMON PLEAS t`rF 2 2009, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW JASON S. NICKLE,SR., NO. 2000-2266 Defendant IN CUSTODY PRIOR JUDGE: The Honorable Edward E. Guido COURT ORDER v` AND NOW, this -?? day of February, 2009, the Conciliator initiating a Custody Conciliation Conference on February 26, 2009, at 8:30 a.m. consistent with the prior Order of Court and only the Attorneys being in attendance, the Conciliator relinquishes jurisdiction. ??? ? 1 ? ? i '"" :`5.1 ?.Y ,'„t