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HomeMy WebLinkAbout00-03571 " .,;' "- ~~'ltf7 '1IIli!m<-;, . SCOTI D. BOLDEN PLAINTIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KELLI A. JOHNSON 2000-3571 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 19th day of June ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawu S. Sunday, Esq. . the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on the 23rd day of August , 2000, aU,OO PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Isl Dawn S. Sundar. Esq. tj 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 ATIORNEY AT ONCE. IF YOU DO NOT HA VB AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . ,..~ -~,.~~,~..- . :', /~;";:~'\':;~':?; >yN . ,'. {:\\} '2. i.} \" ',-', 'c. \) :1' .... . ...cJ"0\T{ ,..,.,-" \ \~)\ \,)' CU;J\~~)~~Si\)II\\~\~' ~dtJdJ M-~~~4 df~ ?-'dtJ-a; ~~. - ~.0d#. t~~1J ~ ~ ~ 4#~ . . . , " ~" ~_,' _ ,'_ ".~ h~"1!IIil!'~~m' ~!,QIM;J,il!!f!!ll'l!"M "" ":-".l".__,:c"'~"!! ~ . -" ~" .j1ll:'j~,~, SCOTT D. BOLDEN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. No. CO -. .3$71 Ciu\'l'-r~ KELLI A. JOHNSON Defendant CIVIL ACTION -- LAW ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at on the day of , 2000, at .m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issue[ in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, by: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 2 LffiERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ~~~ill1d"r;' SCOTT D. BOLDEN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff vs. N 00- 357/ ~ I...u-- o. KELLI A. JOHNSON Defendant CIVIL ACTION -- LAW PETITION FOR CUSTODY AND COMES NOW, SCOTT D. BOLDEN, by his attorney, Timothy 1. Colgan, Esq., and files the following Petition: I. Petitioner, SCOTT D. BOLDEN, resides at 607 Herrin Lane, Enola, Cumberland County, Peunsylvania since October 1998. 2. Respondent, KELLI A. JOHNSON, resides at 111 Fairview Drive, Camp Hill, Cumberland County, Pennsylvania since 1992. 3. The parties are the natural parents of one minor child, Trevor Scott Bolden, d.o.b. 10/18/96. 4. The child was born out of wedlock. 5. The child is presently in the care and custody of the Respondent. 6. There is no court order establishing custody and visitation. 7. Petitioner has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 8. Petitioner 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. .' , ,... 9. The best interest and permanent welfare of the children will be served by granting the relief requested herein. WHEREFORE, Petitioner requests the Court enter an Order granting him shared physical custody of the minor child. Dated: '/60/_ ~ , ResPTlly submitted, I~~ Timothy 1. , squire WILEY, LENOX & COLGAN, P.C. 1 South Baltimore Street Dillsburg, PA 17019 (717) 432-9666 I.D.#77944 S:ICLIENTSICOLGANlBOLDEN.SCT\COMPLAIN. WPD "' ~ - ~"~"~~-'"- VERIFICATION I, SCOTT BOLDEN, veriJy that the statements made in this document are true and correct to the best of my knowledge, information, and belief. 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: 5- Jo-()O ~-d6fJ,~ SC TT BOLDEN Plaintiff ,L .1 ~ ~i~m'-, . SCOTT D. BOLDEN PLAINTIFF V. KELL! A. JOHNSON DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 00-3571 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, Angnst 06, 2001 , upon consideration ofthe attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, September 05, 2001 , the conciliator, at 11:00 a.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Dawn S. Sunday. Esq.f/J 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . .. OF r__~lLrf,r~:I:<~njCE . ,"iU'iOT.I\RY 01 AUG - 1 p" . . rl 2:" I .; , CUMB1:0, !."" ;:ll;'_.I".\!'~LJ C''"' , PENNSYLVAN~UNTY <{-7tl/ M!dff~ -t4 &j.... <{-).C)! ~ ~ 70 -I..H- ffNJ/ 1''l'J' ",.;A.- p 4~'} . .:..~ .,....- -" ~,"~ ~ ~",.~-~ .. '=<"''"'f'.:.""~,,, .__.0..'_'' ("d!tl__,"o__JHq!l!llll .' - - .............itii<. '~Lj '7 ? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SCOTT D. BOLDEN, * Plaintiff * * VS. * * KELLI A. JOHNSON, * Defendant * NO. 00-3571 CIVIL TERM CIVIL ACTION LAW - CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached petition, it is hereby directed that the parties and their respective counsel appear before the conciliator, at on the day of ,2---, at .m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entIy of a temporary or permanent order. FOR THE COURT, by: Custody Conciliator The Court of Common Pleas ofCumberIand County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference or hearing. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 2 LmERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 't ",;,,-. iiIb~ }Ri'~_t; ';;:0 :> IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SCOTT D. BOLDEN, * Plaintiff * * vs. * * KELLI A. JOHNSON, * Defendant * NO. 00-3571 CIVIL TERM CIVIL ACTION LAW - CUSTODY PETITION FOR MODIFICATION OF CUSTODY AND NOW, this 2> f"d..-.. day of Ju , 2001, comes the Plaintiff, Scott D. Bolden, by and through his attorney, T othy J. Colgan, Esquire, of Wiley, Lenox, Colgan & Marzzacco, P.C., and files the instant Petition or Modification of Custody, and in support thereof, avers as follows: 1. The Petition of Scott D. Bolden, Petitioner herein, respectfully represents that on September 6, 2000, an Order of Court was entered by the Honorable J. Wesley Oler, Jr., upon an agreement of the parties granting the Petitioner minority physical custody of the minor child, Trevor Scott Bolden born October 18, 1996. A true and correct copy of said Order is attached hereto, marked Exhibit "A" and made a part hereof by reference thereto. 2. This Order should be modified be.cause the Petitioner and natural father, Scott D. Bolden, believes and therefore avers that an Order of primary physical custody in favor of Petitioner is in the best interest of the minor child. Date: 1/25! () I Res~tfully submitted, r~~ Timothy 1. uire WILEY, LENOX, COLGAN & MARZZACCO, P.C. 1 South Baltimore Street Dillsburg, PA 17019 (717) 432-9666 I.D.#77944 .' , -'" -~''''~''''-- , t ' ~ . SCOTT D. BOLDEN, : IN THE COURT OF OOMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-3571 CIVIL TERM . . KELLI A. JOHNSON, . CIVIL ACTION - LAW . Defendant : IN CUSTODY ORDER OF COURT AND N(Xoq, this )0 -th. day of ~ consideration of the attached Custody Cone liation Report, and directed as follows: , 2000, upon it is ordered 1. The Father, Scott D. Bolden, and the Mother, Kelli A. Johnson, shall have shared legal custody of Trevor Scott Bolden, born October 18, 1996. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child on alternating weekends from Saturday at 3:00 p.m. through Sunday at 8:00 p.m., beginning Saturday, August 26, 2000. In addition, the Father shall have custody every week from Tuesday at 3:00 p.m. through Wednesday at 8:00 p"';m. 4. The parties shall share oriG.ternate having custody of the Child on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 3:00 p.m. through Christmas Day at 3:00 p.m., and Segment B, which shall run from Christmas Day at 3:00 p.m. through December 26 at 3:00 p.m. The Mother shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. The Father shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years. B. NEW YEARS: The New Years holiday shall be divided into Segment A, which shall run from New Years Eve at. 3:00 p.m~ through New Years Day at 3:00 p.m., and Segment .B, which shall run from New Years Day at 3:00 p.m. through January 2 at 3:00 p.m. The Father shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years. The Mother shall have custody of the Child during Segment A in even numbered years and during Segment B EXHIBIT "A" . ~ . "'".' .. in odd numbered years. entire New Years holiday year as New Years Day. For purposes of this provision, the shall be deemed to fall in the same C. TBlINKSGIVING: The Thanksgiving holiday shall be divided into Segment A, which shall run from the Wednesday before Thanksgiving at 3:00 p.m. through Thanksgiving Day at 3:00 p.m., and Segment B, which shall run from Thanksgiving Day at 3:00 p.m. through the following Friday at 3:00 p.m. The Father shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. The Mother shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years. D. ElISTE:R: The party .who has custody under the regular custody schedule on Easter SUnday shall have custody of the Child on the holiday. E. MEMORIAL DAY/JULY 4TH/l:.ABCR DAY: The. Father shall have custody of the Child on Memorial Day and Labor Day in even numbered years and on JUly 4th in odd numbered years. The Mother shall have custody of the Child on Memorial Day and Labor Day in odd numbered years and on July 4th in even numbered years. The period of custody on the holiday shall run from 8:00 p.m. the day before the holiday through the holiday at 8:00 p.m., with the exception of July 4th on which the period of custody shall run until after the fireworks. F. 1v.rt:flsK'S DAY/FATHER'S DAY: The Mother shall have custody of the Child every year on Mother's Day from the Saturday before Mother's Day at 3:00 p.m. through Sunday at 8:00 p.m. The Father shall have custody of the Child every year on Father's Day from the Saturday before Father's Day at 3:00 p.m. through Sunday at 8:00 p.m. G. ~ TRICK-<:l.R-TREAT NIGHT: Each party shall be entitled to have custody of the Child for Trick-or-Treat night each year, if scheduled on separate nights in their respective communities. The specific times for exchanges of custody under this provision shall be arranged by agreement of the parties. B. CHILD'S BlRI.'BIlAY: Each parent shall be entitled to have a period of custody on the Child's birthday each year with the times to be arranged by agreement of the parties. I. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. J _ In the event the Father's period of holiday custody falls immediately preceding or following his regular period of custody, the Father's period of regular/holiday custody shall run continuously. ,"",,'-, ~ 5. Each party shall be entitled to have custody of the Child for up to three non-consecutive weeks each summer upon providing at least 30 days advance notice to the other party. The party providing notice first shall be entitled to preference on his or her selection of vacation dates under this provision. ... 6. In the event either party intends to remove the Child from his or her residence fot: an overnight period or longer, that party shall provide advance notice to the other party along with the address and telephone numbers where the Child can be contacted. 7. The Father shall ensure that the Child has no access or exposure to firearms during his periods of custody. The Father shall not take the Child hunting until the Child has taken and passed the Hunter Safety Course at the appropriate age, 8. . Neither party shall do or say anything which may estrange the Child frexn the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall take all reasonable steps to ensure that third parties having contact with the Child comply with this provision. 9. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE CXJURT, cc: Timothy J. COlgan, Esquire - Counsel for Father Robert L. O'Brien, Esquire - Counsel for Mother TRUE COr'Y FROl'1i RECORD In T 0stimony vvnE"'''8Gf I 1\ -'_>;,t;, l.,r,-i'o ~c,t m)' .hand ,_. ',. ''''' v " .,},'" I J Bnd the seal of said Court at r. riisi , Pa. . .\, ffJ- otnonotary ~ ., - SCOIT D. BOLDEN, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : VS. . NO. 00-3571 CIVIL TERM . . . KELLI A. JOHNSON, . CIVIL ACTION - LAW . Defendant : IN CUSTODY Cu;:,'.!.UlJX CCI!lCILIATlOO SOMMARY REPORT IN ACCXIIDANCE WITH CUMBERLAND CXXJNTY RIlLE OF CIVIL PROCEOORE 1915.3-8, the undersigned Custody Conciliator submits the fOllowing report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH a:lRREN.rLY IN CUSTODY OF Trevor Scott BOlden October 18, 1996 Mother 2. A Conciliation COnference was held on August 24, 2000, with the following individuals in attendance: The Father, Scott D. Bolden, with his counsel, Timothy J. COlgan, Esquire, and the Mother, Kelli A. Johnson, with her counsel, Robert L. O'Brien, Esquire. 3. The parties agreed to entry of an Order in the form as attached. fJv~t- &'7 ~ Date . c~,~~ Dawn S. Sunday, Esquir Custody COnciliator c' I. I. e '-'iil~ '-w>, VERIFICATION I, SCOTT D. BOLDEN, verify that the statements made in this doclllUent are true and correct to the best of my knowledge, information, and belief. 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: 1~/B ~u ( ~~.~ SCOTT D. B LDEN ,- "'~"""""" ,~ -~''"' ,.",,,'-. , '~_"""~k_;~;'''--'''<"f'~'~':J~!i:~_t~llIil'#Jl ,-~, d 'iIbIIIiliI'~V , .~" ~ Iiiii~ M.: 0 ~ (") c 9, ~ c: ~ [9 :;::: ;po .,..j -aU] c.-.: ;-':~#- mm <7) Z::D i5~ ZS;: , ........ . 8 ~'-' f"-.) ........ ~ C:G ..... "'0 ",'--r, "- ~J2i [9 :zO ~~ & ~ ~8 Y: (S,n ~ -~ Z ::> ~ =< (n '-< ~ ~ J " '^'-", SCOTT D. BOLEN Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW KBLLI A JOHNSON Defendant : NO. 00-3571 Civil Term : CUSTODY PRAECIPE TO ENTER AN APPEARANCE To the Prothonotary: Please enter the appearance ofthe Family Law Clinic on behalf of Kelli A Johnson, the Defendant, in the above captioned matter. .~ u11L R BRAD BALABAN Certified Legal Intern r ~ HOMAS M. PLACE ROBERT R. RAINS TERI L. HENNlNG Supervising Attorneys Date: September 5, 2001 FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2963 ~~i!iilli'i~#li,ll<"- lIlIi-.riIIiC!lii.iff' ~-, -"~'~!J'ffi:leii!<iOi;MU",_;;J,"*,d_ ~rnt "' .- ~ - .,., 1IIII:Il:~'~ ...i:illi o c ~- -o0:J rnr\- 7~~::" C!I~;:., r::c) ."-. 1-';> ...-, ~.g :z; :-~ C;J iI') ;:"",4 ':J L'-' ,.. I I I ~ :J1 CO . -..~ - '" SCOTT D. BOLEN Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW KELLI A. JOHNSON Defendant : NO. 00-3571 Civil Term : CUSTODY CERTIFICATE OF SERVICE I, R Brad Balaban, Family Law Clinic, hereby certify that I am serving a true and correct copy of the Praecipe to Enter Appearance on Timothy 1. Colgan, Esq., at 1 South Baltimore Street, Dillsburg, PA, 17019, by depositing a copy of the same in the United States mail, first class, postage prepaid, this 5th day of September, 2001. Date: September 5, 2001 ~1f R BRAD BALABAN Certified Legal Intem FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2963 1iI'.<"~ .L~"~j .' ii! '0' ~rI'l,.H;!.i$"'.tlM~'MOO ~. .~" ..i>,,,." 1*- '->"~,. ^-~ , ~"_. ""."". .. 0 C) C --T~ ~ U') -rJ c.:'::: ,,, rn L[ , "c::J L Z t_ w .. C/ i -- c' [2 c" :p " . Z f-'. s> ". I'.) '.......-: c:: 7 ::;::: ~ :n ~ CO ~ -, ,."J" ,,- -'1IIiIld - l'" ~ , , ~ SCOTT D. BOLDEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-3571 CIVIL ACTION LAW KELLI A. JOHNSON, Defendant IN CUSTODY ORDER OF COURT AND NOW, this 7 It, day of 030 L....s ,2001, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of this Court dated September 6, 2000 shall continue in effect as modified by this Order. 2. The parties shall submit themselves, their minor Child, and any other individuals deemed necessary by the evaluator to a comprehensive child-parent evaluation (at least through Phase I) to be performed by Georgi Anderson, LCSW, ACSW, RPT-S. The purpose of the evaluation shall be to assist the parties in establishing ongoing custody arrangements which would best serve the interests of the Child. The parties shall sign any authorizations deemed necessary by the evaluator in order to obtain additional information pertaining to either the parties or the Child. The parties shall share the costs of the evaluation, up to a total of $1125.00, with the Mother being responsible for 35% and the Father being responsible for 65% of the costs. In the event the Father is required to pay more than his 65% share in order to prevent delay in completing the evaluation, the Father may enforce his right to reimbursement of the Mother's share through the Court. The Father also reserves the right to seek an additional allocation of the evaluation costs from the Court, 3. The Father shall have partial physical custody of the Child on alternating weekends from Saturday at 3:00 p.m. through Sunday at 8:00 p.m., beginning Saturday, September 29, 2001. In addition, the Father shall have custody every week on Tuesdays from 3:00 p.m. through 8:00 p.m. '" ~. =--~- Di [(I-9 " -~ ~". ._~-" . "~ ~" r:;, t.:: II ,~ ,,'-- CUL'ib;:~i"~:L"~:, (;C)j\JTY PENNSYLV/\NU\ ".. "'>''''-~,"",-'' .. , .!lt~iil~'f~JiI",JJijll ~-,,''"'''' - ",~~'11'9< J,~, I'"'-'~ ~ '0!~'J "I ~~ . ,-,', ...... .~ '" ~~ _.- / .. SCOTT D. BOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO, 00-3571 CIVIL ACTION LAW KELLI A. JOHNSON, Defendant : IN CUSTODY PRIOR JUDGE: J. Wesley OIer, Jr. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Trevor Scott Bolden October 18, 1996 Mother 2. A Conciliation Conference was held on September 26, 2001, with the following individuals in attendance: The Mother, Kelli A. Jolmson, with her counsel, R. Brad Balaban and Robert R. Rains, Esquire, and the Father's counsel, Timothy J. Colgan, Esquire. The Father, Scott D. Bolden, participated in the Conference by telephone. Date 3. The parties agreed to entry of an Order in the form as attached. ;;Cf~ d-J-.'Joo/ a,,~dO Dawn S. Sunday, Esquire Custody Conciliator -"'-~'"~.~ <-,~. . '~ ~"" - l:':",_ j ~ 4. Within 60 days of receipt of the evaluator's written custody recommendations counsel for either party may contact the Conciliator to schedule an additional Custody Conciliation Conference, if necessary. BY THE COURT, J. W J. . cc: Timothy J. Colgan, Esquire - Counsel for Father t(J~ R. Brad Balaban and Robert R. Rains, Esquire - Counsel for Mother "~ . ~~ ". .~<, . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SCOTT D. BOLDEN, Plaintiff * * * vs. * No. 2000-3571 CIVIL ACTION-LAW * KELLI A. JOHNSON, Defendant * * AFFIDAVIT OF SERVICE I, Michele A. Reneker, being duly sworn, deposes and says that she is an adult and that she served the Petition for Custody with regard to the above-referenced matter to the defendant's last known address by both regular mail and certified mail on July 6, 2000. The certified mail return receipt card, form PS 3811 and PS 3800, dated June 22, 2000 are attached hereto, marked Exhibit "A" and made a part hereof by reference thereto. THE WILEY GROUP By: 7llui/k C Buh-( Michele A. Reneker One South Baltimore Street Dillsburg,PA 17019 (717) 432-9666 Date: July 18, 2000 , I~ L~_J_~ ~~ ~ , - t .. Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the maiipiece, or on the front if space permits. 1. Article Addressed to: c. Si9nature "1/. O' I X Ie -( 1\ i0C fA,<,-,~-'I. D. Is delivery address different from item 1? If YES, enter delivery address below: o Agent Ol>.dd_ DYes jil(NO ,Gel r. f\ JD hV1 SoD", \\ \ FA-ll Vf.vJ ~,>I'{" &Mf H.ll pA /')0/ / 3. ~Service Type ;~Certjfjed Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail D C.O,D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. ArticleNumberi(Cp.pyfrom~f,Vic9Iabel);:;' ! ii;' ii' p, FQI'!T138111, J'!iy,111119. ! 'I'",;',', ------,- - - ----,-- ~-- ------ PP\Tl~1e; Retum Receipt 102595-99-M-17a9 _, '.',C ; - - --" --~----- r"- t:I r"- .JI t:I r"- ..D .JI Postage $ Certified Fee II"' Return Receipt Fee C (Endorsement Required) o Restricted Delivery Fee I:J (Endorsement Required) Total Postage & Fees $ t:I ru N Name (Please PrInt Clearly) (To be completed by mailer) m ..t:~!Jj__..6..:...Jp..~~~.'?~__.._____.______..________._ ..' D"'" Strset, 'Apt. No.; or PO Box No. ...___.....m..n_.... lJ'" l'( F""iYv;ew'(::w;"'e ::2 ii~~-Zi,;~4--.._;-:;:._..I.:;;-;-;-.--._.._..---------._....--.-----.._..- EXHIBIT "A" . '. -" ~'~ '-1{",- , v SCOTT D. BOLDEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. : NO. 00-3571 CIVIL TERM : KELLI A. JOHNSON, : CIVIL ACTION - LAW Defendant . IN CUSTODY . OODER OF <XllJRT AND ~, this l, tL day of ~ (' ~t -r L 0- consideration of the attached Custody Concil:J:ation Report, and directed as follows: , 2000, upon it is ordered 1. The Father, Scott D. Bolden, and the Mother, Kelli A. Johnson, shall have shared legal custody of Trevor Scott Bolden, born October 18, 1996. Each parent shall have an equal right, to be exercised jointly with the otheJ:' parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child on alternating weekends from Saturday at 3:00 p.m. through SUnday at 8:00 p.m., beginning Saturday, August 26, 2000. In addition, the Father shall have custody every week from Tuesday at 3:00 p.m. through Wednesday at 8:00 p.m. 4. The parties shall share or alternate having custody of the Child on holidays as follows: A. CIllUS'JW\S: The Christmas holiday shall be divided into Segment A, which shall run fran Christmas Eve at 3:00 p.m. through Christmas Day at 3:00 p.m., and Segment B, which shall run fran Christmas Day at 3:00 p.m. through December 26 at 3:00 p.m. The Mother shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. The Father shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years. B. NEW YEARS: The New Years holiday shall be divided into Segment A, which shall run fran New Years Eve at 3:00 p.m. through New Years Day at 3:00 p.m., and Segment B, which shall run from New Years Day at 3:00 p.m. through January 2 at 3:00 p.m. The Father shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years. The Mother shall have custody of the Child during Segment A in even numbered years and during Segment B ::,!l - .' MM.Il'!fl,,< On (""i-f" <"'v ,'.I~ '.-' f._, . '!: ~,:;~ '-,"j CUilr<:-:,:, .' ".D"-;'i1~n\D {),.-:" Jori'" , E;\jj\IC::\'I'1 'A -~. uI\ I v .u ..../i"1NA 'f --.e_,,,- , . .:rrr~_I,,~~. ~F~~~1$WlflI!!'~,~~..." "~,~i!ij,_~1!1!~:1_ _",~~,,,,,~~ '! ."'~-'~ . ,,~ --~ml- in odd numbered years. entire New Years holiday year as New Years Day. For purposes of this provJ.sJ.on, the shall be deemed to fall in the same C. TBANKSGlVING: The Thanksgiving holiday shall be divided into Segment A, which shall run from the Wednesday before Thanksgiving at 3:00 p.m. through Thanksgiving Day at 3:00 p.m., and Segment B, which shall run from Thanksgiving Day at 3:00 p.m. through the following Friday at 3:00 p.m. The Father shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. The Mother shall have custody of the Child during Segment A in odd numbered years and during segment B in even numbered years. D. FASTER: The party who has custody under the regular custody schedule on Easter sunday shall have custody of the Child on the holiday. E. MEMOOIAL DAY/JULY 4TH/I.ABCR DAY: The Father shall have custody of the Child dn Memorial Day and Labor Day in even numbered years and on July 4th in odd numbered years. The Mother shall have custody of the Child on Memorial Day and Labor Day in odd numbered years and on July 4th in even numbered years. The period of custody on the holiday shall run from 8:00 p.m. the day before the holiday through the holiday at 8:00 p.m., with the exception of July 4th on which the period of custody shall run until after the fireworks. F. IO.rHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Child every year on Mother's Day from the Saturday before Mother's Day at 3:00 p.m. through Sunday at 8:00 p.m. The Father shall have custody of the Child every year on Father's Day from the Saturday before Father's Day at 3:00 p.m. through sunday at 8:00 p.m. G. BAI.J:.amEN TRICK-oR-'l'REAT NIGHT: Each party shall be entitled to have custody of the Child for Trick-or-Treat night each year, if scheduled on separate nights in their respective communities. The specific times for exchanges of custody under this provision shall be arranged by agreement of the parties. H. CHILD'S BIRTHDAY: Each parent shall be entitled to have a period of custody on the Child's birthday each year with the times to be arranged by agreement of the parties. I. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. J. In the event the Father I s period of holiday custody falls immediately preceding or following his regular period of custody, the Father's period of regular/holiday custody shall run continuously. - .; '~~ "" .", 5. Each party shall be entitled to have custody of the Child for up to three non-consecutive weeks each summer upon providing at least 30 days advance notice to the other party. The party providing notice first shall be entitled to preference on his or her selection of vacation dates under this provision. 6. In the event either party intends to remove the Child from his or her residence for an overnight period or longer, that party shall provide advance notice to the other party along with the address and telephone numbers where the Child can be contacted. 7. The Father shall ensure that the Child has no access or exposure to firearms during his periods of custody. The Father shall not take the Child hunting until the Child has taken and passed the Hunter Safety Course at the appropriate age. 8. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall take all reasonable steps to ensure that third parties having contact with the Child comply with this provision. 9. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, cc: Timothy J. Colgan, Esquire - Counsel for Father Robert L. O'Brien, Esquire - Counsel for Mother ,J~~ L~ 9-1-00 ~i~ ~- - u*'- . ~~ I. . ~- ~" '.:. SCO'l'l' D. BOLDEN, . IN THE OOURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. 00-3571 CIVIL TERM . . . KELLI A. JOHNSON, : CIVIL ACTION - LAW Defendant : IN CUSTODY CUSTODY (XlqCII,IATIGI SUMMARY REPCRT IN ACCDIDANCE WITH CUMBERLAND CXXIN'lY RULE OF CIVIL PROCIIDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Trevor Scott Bolden October 18, 1996 Mother 2, A Conciliation Conference was held on August 24, 2000, with the following individuals in attendance: The Father, Scott D. Bolden, with his counsel, Timothy J. Colgan, Esquire, and the Mother, Kelli A. Johnson, with her counsel, Robert L. O'Brien, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date A~f .;J 1; aobD tC{.~~ Dawn S. Sunday, Esquir custody Conciliator ~"..u< Ei , ,. '~, __ ~ c' "'-r- ., ;-," ' , IN THE COURT OF COMMONPLF;AS CUMBERLAND COUNTY, PENNSYLVANIA.. ,;7,," ,~, /,,~ ' -', " SCOTT D. BOLDEN, Plaintiff * * * vs. * No. 2000-3571 CIVIL ACTION-LAW * KELLI A. JOHNSON, Defendant * * AFFIDAVIT OF SERVICE I, Michele A. Reneker, being duly sworn, deposes and says that she is an adult and that she served the Petition for Modification of Custody with regard to the above-referenced matter to the defendant's last known address by both regular mail and certified mail onAugust 18, 2001. The certified mail return receipt card, form PS 381 I dated August 18, 2001 is attached hereto, marked Exhibit "A" and made a part hereof by reference thereto. Date: August 22, 2001 WILEY, LENpX, COLGAN ~C. CO, P.C. By: ~IrC~.. ...../( Michele A. Reneker One South Baltimore Street Dillsburg,PA 17019 (717) 432-9666 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF ~ On this, the 22nd day of August, 200 I, before me, a notary public, personally appeared Michele A. Reneker, known to me or satisfactorily proven to be the whose name is subscribed to the Within AffidaVit and acknowledged that she executed the same for the purposes therein contained. WITNESS, my hand and notarial seal the day and year aforesaid. : SS Notanal Seal S. Dawn Gladfelter. No~ Public DlIIsburg BOlO, York COunty My Commissfon Expires May 11, 2005 Member, Pennsy!vantaAssocialionofNola/jes S~~UlfJO ;1) tl 4!J,d:t;u NOT YP LIC My Commission Expires: Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. :1- .Article Addressed to: l~ e7l II. Jo/ulS&1 U~~ftj{j~// -=-===- =--=----'---~ 3~S !Vice Type Certified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) Ves /~ 102595.00.M-0952 .11" .c. .c;~.. ~ .<...~~t7~' -- ~ . ~f..w.'J!illi~J~~~N~ilii~~iI;~J~'~.~~~' 'lli,~ ~~ ','. .~--., ~ ~~ c. I" :- !I ,,, _,0 > =~~ ~ - ~" "'-'~ .- . ~',,~~"-' llIlMIt.Lti.l'~ ~ '" "_.~-. .,,", ."'''' 0 \'-,p' 0 C ..,-,,,.. "TI "lJ(" "" ,,~- pi' '.:5 , ~8 ::t >c t.; z :;;I (~