HomeMy WebLinkAbout00-03571
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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
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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
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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.
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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/_
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ResPTlly submitted,
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Timothy 1. , squire
WILEY, LENOX & COLGAN, P.C.
1 South Baltimore Street
Dillsburg, PA 17019
(717) 432-9666
I.D.#77944
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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
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SC TT BOLDEN
Plaintiff
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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
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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
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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,
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Timothy 1. uire
WILEY, LENOX, COLGAN
& MARZZACCO, P.C.
1 South Baltimore Street
Dillsburg, PA 17019
(717) 432-9666
I.D.#77944
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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"
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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.
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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
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Bnd the seal of said Court at r. riisi , Pa.
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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.
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Date .
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Dawn S. Sunday, Esquir
Custody COnciliator
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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 (
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SCOTT D. B LDEN
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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.
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R BRAD BALABAN
Certified Legal Intern r
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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
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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
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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.
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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
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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
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EXHIBIT "A"
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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
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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.
-
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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
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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
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Dawn S. Sunday, Esquir
custody Conciliator
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IN THE COURT OF COMMONPLF;AS
CUMBERLAND COUNTY, PENNSYLVANIA..
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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
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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
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