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Home My WebLink About00-02693 ." , -.,~ I KELLEY LYNN HUGHEY, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY ,PENNSYLVANIA * vs. * NO. 00-2693 Civil Term * GREGORY MILES HUGHEY, * CIVIL ACTION - LAW Defendant * IN DIVORCE CERTIFICATE OF SERVICE I, Emily A. Vislocky, Legal Assistant to Edward J. Weintraub, Esquire, hereby certify that on May 3, 2000 I served a true and correct copy of a Complaint in Divorce filed on May 2, 2000, upon Gregory Miles Hughey, Defendant, by depositing same, postage pre-paid, certified, restricted delivery, return receipt requested, in the United States Mail, Harrisburg, Pennsylvania, addressed as tollows: Gregory Hughey 431 W. Simpson Street Mechanicsburg, PA 17055 Date: 5/3100 ' .....;, ,,>~_c :.," ~' ~. ,""-> ~ lI;-iIt~lliIllff~'-""-"~>"'~'l:fiWllI<iIJJ 'OdJ'........... ~~ . ~. ~ "'~ ~ ~~"'"'-'" "8"-'= J ~ 0 Cl 0 C 0 'Tl s: :3: ,..; -OW ".. -r nlrn -< ~;~ :2:D , ZC: "rJ ' ~Z <..1' c::'( ..,--f. r<a -0 ~.~ >0 :3: :20 ? >c r-:? ~ ~ w >- {J1 :Q a ^O, - -'",-,--- -'<I I I , " KELLEY LYNN HUGHEY, Plaintiff. vs. * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY. PENNSYLVANIA C;~~( 'TVuj * * No. "0 - :2,ce'1 ~ * GREGORY MILES HUGHEY. Defendant. * CIVIL ACTION - LAW * CUSTODY ORDER OF COURT AND NOW, this lJ. day of ~, 2000, upon consideration of the attached complaint it is hereby directed that the parties and their respective counsel appear before \~\-\- i. ('~ \f~, Esquire, the Conciliator, at ~c..l.\~ 1"\, {_ "'---t- C~.r\m<:\-(.lI,~'t'ennsylvania, on . the.Q8+l-, day of .)..0.. I 2000, at q: .3D o'clock. (L.m., for a Pre-Hearing 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 a temporary order. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: BY_~^'~~ Custody Conciliator l;j YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR 1 COURTHOUSE SQUARE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 . I I. II I !:~ --. ~-- -. ~ 'W' F1LED-OFRCE OF TFE PROTHONOTARY 00 MAY -5 PM 2: 53 (': 11";B';:f'u' "[\1'1': (',OUNTY V,-'VI '--' ...., l.. ....J PENNSYl.:v."NIA 5-5,tJj W~M~~4 ~ fs,o?J }f~ A~ &;~' $oS-tM L~ ~ ~ ;t ~ ~ < " ~ t_~~ ". ~ ,~~l!!IIlIIIt .~,,,.,-.,=~, ,,'~ '" ,~i\l~~_1 r.....,~~ ~--~>"- ~ '";,;i;)..",,, " KELLEY LYNN HUGHEY, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY, PlENNSYLVANIA * vs. * NO. * GREGORY MILES HUGHEY, * CIVIL ACTION - LAW Defendant * IN DIVORCE NOTICE To DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Court House; 1 Court House Square, Carlisle, Pennsylvania, 17013-3387. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (71 7) 249-31 66 ""'" -~>,"~""'=~" -~ lMlli,^ KELLEY LYNN HUGHEY. Plaintiff * IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA NO. 6-t! - 2e. 93 Cu:.J. TL.U"'-' * * vs. * * GREGORY MILES HUGHEY. Defendant * CIVIL ACTION - LAW * IN DIVORCE COMPLAINT UNDER !i3301 OF THE DIVORCE CODE 1. Plaintiff is Kelley Hughey, who currently resides at 1017 Little Lake Drive, Virginia Beach, VA 23454. 2. Defendant is Gregory Hughey, who currently resides at 431 W. Simpson Street, Mechanicsburg, PA 17055. 3. Plaintiff was a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding her relocation to Virginia and the filing of this Complaint. Defendant is a resident of Pennsylvania. 4. The Parties were married on November 13, 1996. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. ~~ ''''In'''L 7. The Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I. REQUEST FOR A No-FAULT DIVORCE UNDER 93301 (c) OF THE DIVORCE CODE 8. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 9. The marriage of the parties is irretrievably broken. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, if both Parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301 (c) of the Divorce Code. COUNT II. REQUEST FOR A No-FAULT DIVORCE UNDER 93301 (d) OF THE DIVORCE CODE 11 . The prior paragraphs of this Complaint are incorporated herein by reference thereto. 12. The marriage of the Parties is irretrievably broken. ~,-~ ~-'~~ - '", " 13. The parties are living separate and apart and at the appropriate time, Plaintiff will submit an affidavit alleging that the Parties have lived separate and apart for at least two years as specified in Section 3301 (d) of the Divorce Code. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301 (d) of the Divorce Code. COUNT III. REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER 93323, 93501, 93502 and 93503 OF THE DIVORCE CODE 14. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 15. Plaintiff requests the Court to equitably divide, distribute or assign the martial property between the parties without regard to marital misconduct in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff respectfully requests the Court to enter an order of equitable distribution of marital property pursuant to Sections 3323, 3501, 3502 and 3503 of the Divorce Code. COUNT IV. REQUEST FOR SPOUSAL SUPPORT AND/OR ALIMONY PENDENTE liTE AND ALIMONY UNDER 93701, 93702 and 93704 OF THE DIVORCE CODE 16. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 17. Plaintiff is unable to sustain herself during the course of litigation. """ -,"",,,,,,"-",' ',-=^ '. 18. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. 19. Plaintiff requests the Court to enter an award of spousal support and/or alimony pendente lite until final hearing and thereupon to enter an order of alimony in her favor pursuant to Sections 3704 of the Divorce Code. WHEREFORE, Plaintiff respectfully requests the Court to enter an award of spousal support and/or alimony pendente lite until final hearing and thereupon to enter an order of alimony in her favor pursuant to Sections 3701, 3702 and 3704 of the Divorce code. COUNT V. REQUEST FOR COUNSEL FEES, COSTS AND EXPENSES UNDER ~3702 OF THE DIVORCE CODE 20. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 21. Plaintiff has employed Edward J. Weintraub, Esquire, to represent her in this matrimonial cause. 22. Plaintiff is unable to pay her counsel fees, costs and expenses and Defendant is more than able to pay them. 23. Defendant is employed and has the ability to pay Plaintiff's counsel fees, costs and expenses. 24. Reserving the right to apply to the Court for temporary counsel fees, costs and expenses prior to final hearing, Plaintiff requests that, after final hearing, the Court order Defendant to pay Plaintiff's reasonable counsel fees, costs and expenses. ~I ' WHEREFORE, Plaintiff respectfully requests that, pursuant to Sections 3702 of the Divorce Code, the Court enter an order directing Defendant to pay Plaintiff's reasonable counsel fees, costs and expenses. COUNT VI. REQUEST FOR CONFIRMATION OF CUSTODY UNDER ~31 04(A)(2) AND 3323(B} OF THE DIVORCE CODE 25. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 26. The parties are the parents of the following unemancipated children who reside with Plaintiff: NAME AGE SEX DATE OF BIRTH Alyson Hughey 22 months Female May 1, 1998 April Hughey 11 months Female April 3, 1999 27. The children have resided with the parties and at the addresses herein indicated. FROM TO WITH WHOM ADDRESSES Birth February 29, 2000 Parents Mechanicsburg, PA February 29, 2000 Present Mother Virginia Beach, V A 28. Plaintiff has not participated in any other litigation concerning the children in this or any other state. " .' 29. There are no other proceedings pending involving custody of the children in this or any other state. 30. Plaintiff knows of no person not a party to these proceedings who has physical custody of the children or who claims to have custody, partial custody or visitation rights with respect to the children. 31. The best interests of the children will be served if custody of them is confirmed in Plaintiff. WHEREFORE, Plaintiff respectfully requests that, pursuant to S S 31 04(a)(2) and 3323{b) of the Divorce Code, the Court enter an Order confirming custody of the child\children in Plaintiff. COUNT VII. REQUEST FOR APPROVAL OF ANY SETTLEMENT AGREEMENT AND INCORPORATION THEREOF IN DIVORCE DECREE UNDER SECTION 3104 OF THE DIVORCE CODE 32. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 33. The public policy of the Commonwealth of Pennsylvania encourages parties to a marital dispute to negotiate a settlement of their differences. 34. While no settlement has been reached as of the date of the filing of this Complaint, Plaintiff is and has always been willing to negotiate a fair and reasonable settlement of all matters with Defendant. r" ~' '-IIltOl"" , . . 35. To the extent that a written settlement agreement might be entered into between the parties prior to the time of hearing on this Complaint, Plaintiff desires that such written agreement be approved by the Court and incorporated in any divorce decree which may be entered dissolving the marriage between the parties. WHEREFORE, if a written settlement agreement is reached between the Parties prior to the time of hearing on this Complaint, Plaintiff respectfully requests that, pursuant to Section 3104 of the Divorce code, the Court approve and incorporate such agreement in the final divorce decree. EDWARD J. WEINTRAUB, ESQUIRE 2650 North Third Street Harrisburg, PA 17110 (717) 238-2200 10#17441 ATTORNEY FOR PLAINTIFF Date: <.../1-00 . ' ,,' .,. " VERIFICATION I, Kelley Hughey, hereby swear and affirm that the facts contained in the foregoing Complaint for Divorce are true and correct and are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: o/! ~OO ,--" H. ";, '~I -"--~f~ ~ ','. ""'"'-l... l-.~. <' ';~ ?( ~ ~ \~ ~ \ f- "- ~~ OL,.....rt-> , '? \.I' ~t~R&~C3 ft. ~ , f tv ~ [ ~ \) P.... J-~r' -C. ~ "tq "' ~ .~ C <it, o 0 \ ~ 't - ..-... C',) (~,), \..; '':''J ~- c=-: o .", -, ~:~~ ' ~~' =,< f'~_) ;,.:. ,-"~ -<. 0'. -...... ".-1 ." ~! .... C~, . . ~ . .~ , , = ~"'ift KELLEY LYNN HUGHEY, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY,PENNSYLVANIA * vs. * NO. 00-2693 Civil Term * GREGORY MILES HUGHEY, * CIVIL ACTION - LAW Defendant * IN DIVORCE CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Edward J. Weintraub, Esquire, hereby certify that on May 8, 2000 I served a true and correct copy of the Order of Court filed on May 3, 2000, upon Gregory Miles Hughey, Defendant, by depositing same, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Gregory Hughey 431 W. Simpson Street Mechanicsburg, PA 17055 Date: ~ i1J~tA~f)~~ ~ Mis y D. Le man tiolfDl " i.lllllliiil" - ~ <~ .~., ~= '~'.-uiIil<' ~~ ~,O~ ,,,,,,--,~., ~-"'--'tl;'ii'R d'" "" ,~ " " ,., ..... ~~ "'"," (') 0 c> c 0 --n s: :x :c;:l ""Ot'V :t'" j:~'1;g iT1fll -< Z::n -iJf"n ZC :ocr' SQ~: (~Q r::O "0 ~.Ti <: P;:D ~O .~, ..... 4(") ,\>0 ~ ~rn c .. .. ::; W ~ -< ...l ". " - il1l1!l1~1l.\t~ ...~/ KELLEY LYNN HUGHEY, Plaintiff, * IN THE COURT OF COMMON PLEAS * CUMBERLANDCOUNTY, * PENNSYLVANIA * vs. * NO. 60 - ;;(C4 93 GREGORY MILES HUGHEY, Defendant. * * CIVIL ACTION - LAW CUSTODY * AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF DAUPHIN AND NOW, this 9th day of May, 2000 personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Misty D. Lehman, who being duly sworn according to law, deposes and says that she mailed a certified copy of a Complaint in Divorce by certified mail, restricted delivery, return receipt requested, to Gregory Hughey, 431 West Simpson Street, Mechanicsburg, PA 17055, and the same was received by him on May 6, 2000 as indicated by the return receipt card which is attached hereto. 'i5i'*'1!. 0J.-~ Misty D. Leh an Sworn tQ.RPd subscribed before me on this '-'t""'" day of m& , 2000. - \ NOTARIAL . EMILY A. FRITZ, NolaJy Public HarrisbUrg City, Dauphin County l.1y Commission Expires Dec. 4, 2000 .,.. . -"~ , , V,,",,".~'. 'ji! I ~ ~~S 1 amIlmr 2!fDr ad.ditfl,malJlerviees. lID -Complete items 3. 48, and ,~b. I .Print your name and address on the reverse of this tonn 80 that we can return this card to you. > -.Attach this tonn to the front of the mailpieC8, or on the back if space does not I' permit. at -Write-Return Receipt Requested- on the mailpiece below t~e article number. ! _The Retum Receipt will show to whom the article was delivered and the date e delivered. e ... ~ ii E 8 3. Article Addressed to: I_wish", reselva tile following saMess (for an extra fee): ,. 0 Addressee's Address t 2. ~eStrlcted Delivery ~ Consult posbnaster for fee. -t 4a. Article Number .I I~ 10"'7 4b. SelVles Type J o Registered ;gLCertlfIeEI o Express Mail 0 Insured f o Return Recelptfor Merohandise 0 COD . Date of Delivery i I t ~ oW ~~~~ ..- 4~1 IJJ. SVvLpWl1 ~ f'1wJrz' . P A- e's Addre.. (Only if requestslJ' e paid) ~ " =- .!!! 1"$ FolIiII + i~lIlIlIil!illlMill~PIloll'-~~"Ii~il;!otb:;K~'{ """"~~&';~;;,i~;&,-'lil;jjjl..'$;;iWjil1iilk..llfiidlillillii."! ". ,""u" w~~,~ " ,,,,,..., ,."""""', ,~.,- ~,' ",- (~~~~iliiIi!lli!Il!"_" o c ;? -~-~ ,-,OJ rnrn ;:;;:0 tss:.: -<2 r::O ~- )>~ Z~.I :i;O C ~ ,. - .' ''" ~ ~" " ~~) 1'., Co ;-\ r, " ~l;~~ -'i )c. :!:l -<. . , '0 '<'. '; " 00- ...~ ~""r__ , "- '.',-,., ,--,: ,. 0 ," , 4 ::1 JUl 3 1 2000~ KELLEY LYNN HUGHEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 2000-2693 CIVIL TERM GREGORY MILES HUGHEY, Defendant : CIVIL ACTION - LAW : CUSTODY COURT ORDER r~ AND NOW, the :)S day of July, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. Hubert X. Gilroy, Es Custody Conciliato 1'1'':'''; ~11~ , '~ "'...0... _~ ...,c, ,~, .~ ~- -,'. <'- j"" c C:~ ~0 f:~~ ~ ~ Q~, ,~:,') &.~ :: 22("',' ...:::,: ;1::'" ,_~,j; i~.:~, - - ~.~ =,;~) .-<- =< :") :-tJ M< <"':j ': " < ;t""'i , " , ,.' KELLEY LYNN HUGHEY, * IN THE COURT OF COMMON PLEAS Plaintiff. * CUMBERLANDCOUNTY,PENNSYL VANIA * ~Wm V5. * NO. CO - ;).l.D<l ~ * GREGORY MILES HUGHEY, * CIVIL ACTION - LAW Defendant. * CUSTODY STIPULA nON FOR AN AGREED ORDER OF CUSTODY AND NOW, the parties, by and through their attorneys, stipulate and agree as follows: I. LEGAL CUSTODY 1 . The parties hereby agree to share legal custody of their minor children, Alyson Briana Hughey born Mary 1, 1998, and April Lynn Hughey born April 3, 1999. All decisions affecting the children's growth and development including, but not limited to: choice of camp, if any; choice of day care provider; medical and dental treatment; psychotherapy, psychoanalysis, or like treatment; decisions relating to actual or potential litigation involving the children, directly or as beneficiary, other than custody litigation; education, both secular and religious; scholastic athletic pursuits and other extracurricular activities; shall be considered major decisions and shall be made by the parents jointly, after discussion and consultation with each other and with a view towards obtaining and following a harmonious policy in the children's best interest. 2. Each party agrees to keep the other informed of the progress of the children's education and social adjustments. Each party agrees not to impair the other party's right to shared legal or physical custody of the children. Each party agrees to give support to the other in the role as parent and to take into account the consensus of the other for the physical and emotional well-being of the children. 3. 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 ""'!i>,,",,,=~,. __. ~. . . .. ~~ - . ~~._-., . express duty of each parent to uphold the other parent as one whom the children should respect and love. 4. It shall be the obligation of each parent to make the children available to the other in accordance with the physical custody schedule and to encourage her to participate in the plan hereby agreed and ordered. 5. Each parent shall have the duty to notify the other of any event or activity that could reasonably be expected to be of significant concern to the other parent. 6. The parents shall communicate directly with one another concerning any parenting issue requiring consultation and agreement and regarding any proposed modifications to the physical custody schedule, which may from time to time become necessary, and shall specifically not use the children as a messenger. Furthermore, neither parent shall discuss with the children any proposed changes to the physical custody schedule, or any other issue requiring consultation and agre.ement, prior to discussing the matter and reaching an agreement with the other parent. 7. With regard to any emergency decisions which must be made, the parent with whom the children are physically residing at the time shall be permitted to make the decision necessitated by the emergency without consulting the other parent in advance. However, that parent shall inform the other of the emergency and consult with him/her as soon as possible. Day-to-day decisions of a routine nature shall be the responsibility of the parent having physical custody at the time. 8. Each parent shall be entitled to complete and full information from any doctor, dentist, teacher or authority and have copies of any reports given to them as a parent. Such documents include, but are not limited to, medical reports, academic and school report cards, birth certificates, etc. Both parents may and are encouraged to attend school conferences and activities. The Mother's name shall be listed with the school as the parent to be contacted in the event of an emergency and to be notified regarding school events. However, it will be Mother's primary responsibility to provide Father with copies of report cards and all notifications of major school events. 2 _/ -,'l-~- ""'""'0:"'" ~ -~ 11;~;:C . 9. Neither parent shall schedule activities or appointments for the children which would require their attendance or participation at said activity or appointment during a time when she is scheduled to be in the physical custody of the other parent without that parent's express prior approval. 10. The parties hereby acknowledge that they have discussed and jointly made the following decisions: a. The parties agree that Princess Ann Family Practice, Virginia Beach, Virginia, will continue to be the children's pediatrician and accordingly, will provide medical treatment to the children when necessary. b. The parties acknowledge that the children's legal name are Alyson Briana Hughey and April Lynn Hughey and that they shall be known by these names for all purposes. The parties agree that they will instruct their respective families and friends that the children should not be referred to by any other name. II PHYSICAL CUSTODY The parents shall share physical custody of the children. Mother shall have primary physical custody. Father shall have partial custody as periodically determined by mutual agreement. Failing mutual agreement to the contrary, the following schedule shall apply: 1. Alternating weekend with Father from Friday at 6:00 p.m. to Sunday at 6:00 p.m. One of these weekends will be with the children in Virginia Beach, VA; the other will be in Mechanicsburg, PA. The parties will designate a half-way point and will share transportation for all alternating weekend visits. 2. Thanksgiving from the preceding Wednesday at 3:00 p.m. until Thursday at 6:00 p.m. with Father in 2000 and in even numbered 3 -;"~~ .~~-~~ " ~ ~- ~~' ~~, '"" - years thereafter, with the parties to share transportation by exchanging custody at a half-way point designated by them. 3. The Christmas holiday shall be from December 24, 2000 at 12:00 noon until December 26, 2000 at 6:00 p.m. The New Years holiday shall be from December 30, 2000 at 12:00 noon until January 1, 2000 at 6:00 p.m. Mother shall have Christmas in 2000; Father shall have the New Years holiday in 2000 and the two holidays shall be reversed and alternated thereafter. 4. With respect to President's Day, Memorial Day, Labor Day, Martin Luther King Day, Columbus Day, Veterans Day, all of which occur on Monday, may be tacked onto the preceding weekend, at the option of the custodial parent, extending the weekend until Monday at 6:00 p.m. 5. Up to fourteen (14) days vacation with Father between Memorial Day and Labor Day to be exercised in two blocks of seven (7) days each. The parties shall share transportation equally to implement Father's vacation visits. Vacation periods shall be designated by written notice to the other parent at the end of the school year. 6. Father's Day weekend from 7:00 p.m. Friday until 8:00 p.m. Sunday with Father every year. 7. Mother's Day weekend from 7:00 p.m. Friday until 8:00 p.m. Sunday with Mother every year. 8. July 3rd at 6:00 p.m. until July 4th at 10:00 p.m. with Mother in even years and with Father in odd years. 9. Each parent shall have physical custody of the children for attendance at family funerals, near death situations and at weddings with reasonable notice to the other parent. III. RELOCATION 4 - =. -_.-, .. JJi\!h"""" - " . , ' , ., The parties have negotiated the custody and partial custody portions of this Agreement based upon existing circumstances, and in particular, based upon Wife's current residence in Virginia Beach, Va and Husband's current residence in Cumberland County, Pennsylvania. If either parent desires to establish a residence more than fifty (50) miles from his or her present residence, he or she shall give the other parent at least ninety (90) days' written notice in advance of the proposed move, in order to give the parties the opportunity to confer, prior to the relocation, and to establish a mutually satisfactory arrangement as to custody and partial custody in light of the changed circumstances. In the event that the parties are unable to reach an agreement, then the Court of Common Please of Cumberland County shall retain jurisdiction until September 2001, and thereafter, the Court of Common Pleas Virginia Beach, VA of shall have exclusive jurisdiction to fashion an appropriate custody order. IV. TELEPHONE PRIVILEGES The parties agree that there shall be reasonable telephone access between the children and both parents. The parents are encouraged to place telephone calls to the children between 6:00 p.m. and 8:00 p.m. so as not to interfere with dinner or bedtime. The children shall be permitted free access to place calls to their parents at shall be entered as an Order of the Court. Edwar J. eintraub, Esquire Attorney for Plaintiff -=:t>~U/ ,j. /11A Attorney for Defenaa t // -,-' /,.' i BY THE COURT: J. ~bl ]QiJ Date: 5 . fr: o. ~ '<C -" I-" wO -~ (~.J<C (')2 J'-7 ~~? :::'i.iC o:? ~E "'- r-,::'~ '--':::...J c';.. :z>- UjO:: -~(/) ~1! -~z S2 (""'z GJLlj !-- ~ :Do... "'" .2 LL. 0 a ::J c:> U " - II_.~ ~~=~,. . .~,~ ~...,..,~-~",!I!I. .. ~ '.-- ~ o~- rr,;!LtL1_ii,-__, I, / "............, I~',"/"o- " ,"'- -, ~'''I' Ive '_,,"_i"';, ('on "'c',\lOI~;"'Y Vv i1 lie^'" '"., Ib~ /Ft4 Ci I,,, lir) 10: I VJ~'7j_~r,--,"'-. , /-<.J i'!../> "/' " PGVtV:s;;2.~ COUrv'h, MA 'f -. ~~ ~.-~" ,!'!,.'''''........- _~~~_,"I!8Il1~~~_ .-~~-c~ ,,~"^~. _, ~ p ~ ~ .... . I><> 1 ~. ,_, ,_",.,)1111'81' ~U\L",: KELLEY ILYNN HUGHEY, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY,PENNSYR.VANIA * vs. * NO. 00-2693 Civil Term * GREGORY MILES HUGHEY, * CIVIL ACTION - LAW Defendant * IN DIVORCE CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Edward J. Weintraub, Esquire, hereby certify that on August 21, 2000, I served a true and correct copy of the Order approving the Stipulation for Agreed Order of Custody filed on August 16, 2000, upon Doug Miller, Esquire, counsel for Defendant, by depositing same, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Douglas Miller, Esquire Irwin McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 Date: '6 - J.\ -DO ffi~,~ Misty D. Le man ~ -~'""'""~~~~lIiillltBl .-. _...""''''"'''''"'''''~~ '1liIlIllIlI~ ~~- ~ " (') C z -of}::' rnr, Z::CJ :Z:C ~~ !<CJ ~(') -0 >c ~ ~,~~- -~-~. -." - Cl o ~ "" r".) <-'" ~. .:-1::: -~; tJ, ,- -0 :>:: ~~~<::~,?, _.1_ --n ';;:20 /~rn ~ > ::0 '< r:-? N .- IT