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HomeMy WebLinkAbout00-03670 ~ ~,~'~ ~ JUN 1 9 zoooW Plaintiff :IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~NO. 00-.)(-76 c3~n'l ~ :CHILD CUSTODY RHEA A. METZ vs. FRANCIS C. METZ, Defendant ORDER. OF COURT AND NOW, thiS;22'7~ay of J'ZA c.. i 2000, the attached STIPULATION is hereby approved and made an Order of this Court. Dated: ~~JJ t-J.3-00 ~P \' AlNn , ,,":, !i",r:!d , ;:-'\);';) f- ~. .' i v ,-,,"ji' CO ,r".. , ::D !" ,,' i",~ ;_:j l-, ,"' . RHEA A. METZ, Plaintiff : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA ;NO. ()1J. 3(,,70 ~ I.u.--- vs. FRANCIS C. METZ, Defendant :IN CUSTODY AGREEMENT AND STIPULATION - AND NOW, this I) day 2000, RHEA A. METZ (hereinafter referred to as and FRANCIS C. METZ (hereinafter referred to as "Father") agree as follows: WHEREAS, Mother and Father are the parents of SAMUEL METZ, born December 10, 1999; WHEREAS, Mother and Father live separate and apart and are desirous of entering into an Agreement and Stipulation concerning the custody of their son: NOW THEREFORE, each party intending to be legally bound agrees as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of Samuel Metz, born December 10, 1999. The parties agree that major decisions concerning their child, including, but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall ~ ;-- ~- . '''';-' notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. 2. Physical custody of the child will be shared equally between the parties on the following schedule: a. Father will have custody of the child one weekend from Friday at noon until Monday at noon and on the next weekend from Friday at noon until Sunday at noon and every week from Tuesday at noon until Wednesday at noon. The pickup and delivery time may be adjusted in the future to acconnnodate the parent's respective work schedule. b. Mother will have custody the balance of the times. 3. The parents will alternate the following major holidays: Memorial Day, Fourth of July, Labor Day, and Thanksgiving. The custodial period shall run from 9:00 a.m. to 8:00 p.m. Father will have custody every Easter and Christmas and Mother will have custody every Passover and Hanukkah. This , custodial period shall run from noon the day before and end two days later at sun down. 4. Father shall have custody on Fathers's Day from 9:00 a.m. to 8:00 p.m. and Mother shall have custody on Mother's Day from 9:00 a.m. to 8:00 p.m. 5. The holiday schedule shall take precedence over the regular custody schedule. 6. Pick up and delivery of the minor child will occur at Friendly's in Camp Hill, PA. 7: During any period of custody or visitation the parties to this order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this prohibition. 8. Both parents are entitled to one (1) week of uninterrupted custody during the year. It is understood that a week in defined as seven (7) days which must include the parent's regularly scheduled custodial weekend. Each parent shall provide the other with thirty (30) days notice of his/her intention to exercise the extended custody period. 9. Neither parent shall permanently relocate if the relocation would necessitate a change in the visitation schedule or if the relocation would exceed a fifty (50) mile radius without a minimum notice of sixty (60) days to the other parent. The sixty (60) day notice is designed to afford the parents an opportunity to renegotiate the custodial arrangements or to have the matter listed . ~- , ~" ""lii~ " . for a Court hearing. 10. Both parents shall refrain from making derogatory comments about the other parent in the presence of the child and to the extent possible shall prevent third parties from making such comments in the presence of the child. Esquire ~eJt~Me~ ~~ -Iii "~ .li:JJilij~i1-_.A'llI&. ',;,........,"""'.."-'.........iI- ~ -~'~"~~i~~/iIrill1~~<' ~~~ ~ N I " ~ * CV I ,..__W , ,~_. ,_~" -" ~ "~ . -~ - -," ,_~ n ~ ~ 1- 0-- L.:. ~~"'" ~ ~ ~ 8' &' ~ . d ~ t ~"~.. o c s: ~fF 7-,; zf~ 0d,~": r:: (:0) -;c- zc> ..,-C'J ;Pc'" '.7 :::; -< -~'lir<l!l!lJiWJ'~' ~ ~~ ~ ~'j , , I ! . o o ~- -II (J, 'fTl{;) :--;~? ~ :~: 'b ----. "Tj " () ;;::::;;:Pl '-~) =;;1 5:J -< -'C; t..J :.11 0"> '~, "'~"" ~ . - ,e"w IY:' < RHEA A. METZ PLAINTIFF V. FRANCIS C. METZ DEFENDANT IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 00-3670 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, April 27, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa F. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, FA 17011 on Tuesday, May 29, 2001 at 9:15 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 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. 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 honrs prior to scheduled hearing. FOR THE COURT, By: Isl Melissa P. Greevy. Esq.tzfJ 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 infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 - ~ "' '~--~~ ,,< , -T\ ->":FI"E ~-j! [" ,"Ul ;1..,_ . ' ,~:'~~., ""I V)"chfl\/ ...-. "~I ,~~ ,~'" ~Ti"j' ,\,; Ihl1 Gi- !.l:_ :; ,-,-" '--- " O! ~PR 27 Ff\ I: 54 CUivl8ERLt~~[) COUN1Y PENNSYLVANIA M-.t'~~ %4#~~ ~~~~~.~~ tfd).C?/ t~ ~ 1i ~~ '1',;l7.()( Vo>?t'/ , - ,-..n, 1 __~i '"' llle/!J~" "I!IlMJ\'1 T ~~,~"' -. ~,,"'!J: _ 1/ll,L ,~!~\ljll~_\1"~~~i'r'.~'l'~~f"'W'i!F~~'I~~I!ffi~'lfl'i'fflI$I~'!ii!l-.~,_~ ~ """I __Jill ,.- ~i&l RHEA A. METZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-3670 CIVIL TERM v. FRANCIS C. METZ, CHILD CUSTODY Defendant ORDEROFCOURT , AND NOW, this _ day of April, 200 I, upon consideration of the attached Defendant's Petition for Modification of Custody Order, it is hereby directed that the parties and their respective counsel, appear before ,the conciliator, on the _ day of ,2001, 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 atthe conference may provide grounds for the entry of a temporary or permanent Order. BY THE COURT: Dated: 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 THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue Carlisle, Pennsylvania 17013-3387 PHONE: (717)249-3166 Document #: 203382.1 ~" ' RHEA A. METZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-3670 CIVIL TERM v. FRANCIS C. METZ, CHILD CUSTODY Defendant DEFENDANT'S PETITION FOR MODIFICATION OF CUSTODY ORDER 1. The Petitioner is Francis C. Metz, residing at 210 Holiday Avenue, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. The Respondent is Rhea A. Metz , residing at 215 Herr Street, Harrisburg, Dauphin County, Pennsylvania. 3. Petitioner seeks custody of the following child: Name Present Residence Age Samuel Francis George Metz Shared Custody Between Plaintiff and Defendant 1 year 4 months (D.O.B. 12/10/99) The child was not born out of wedlock. The child is present in the custody of Petitioner and Respondent pursuantto Order of this Court dated June 22, 2000, approving a Stipulation of Custody. The mother of the child is Rhea A. Metz, currently residing at 215 Herr Street, Harrisburg, Dauphin County, Pennsylvania. She is divorced. The father of the child is Francis G. Metz, currently residing at 210 Holiday Avenue, Mechanicsburg, Cumberland County, Pennsylvania. He is divorced. Document #: 203382.1 '= 4. The relationship of Petitioner to the child is that of natural father. The Petitioner currently resides with the following persons: none. 5. The relationship of Respondentto the child is that of natural mother. The Respondent currently resides with the following persons: Doug Hilbert, Doug Hilbert's wife, Doug Hilbert's two teenage children at 98 Lone Oak Drive, Marysville, Pa. 6. The parties previously reached a Stipulated Agreement regarding custody to the above term and number and said Agreement was approved by this Court in an Order dated June 22, 2000. A copy of said Order and Stipulation is attached hereto, marked as Exhibit "A", and incorporated herein by reference. Petitioner has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth or any other state. Petitioner does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respectto the child. 7. The best interest and permanent welfare of the child will be served by granting primary legal and physical custody to Petitioner with limited visitation to Respondent for the following reasons: (a) Since the Stipulated Agreement was entered into, Respondent has not exercised her designated time with the child and Petitioner has had the child approximately seventy- five (75%) percent of the time. (b) Respondent has been under psychological and/or psychiatric care for mental and emotional problems. Respondent has threatened and/or attempted suicide on a number of -2- Document #: 203382,] . ;0'= ~'" occasions. Respondent recently threatened suicide when Petitioner objected to Respondent's living arrangements with her boyfriend and her boyfriend's wife and children. ( c) Respondent has demonstrated instability by making repeated harassing phone calls to Petitioner and his family threatening harm to herself. (d) Respondent has threatened to commit suicide either in the presence of the child or to include the child in such activity. (e) Respondenthas been engaged in a meretricious relationship with a married man, Doug Hilbert, whom she met during mental health treatment at Holy Spirit Hospital. Respondenthas been living with Doug Hilbert and his wife and their two teenage children in the same household. Respondent has been sharing a bedroom with Mr. Hilbert while his wife sleeps in an adjoining bedroom all in the same house with Doug Hilbert's two teenage children. (f) Petitioner has objected to Respondent exposing the child to her immoral and harrnfulliving arrangement. Respondent has refused to refrain from exposing the child to these harmful living arrangements and, in fact, intends to move permanently from 215 Herr Street into her boyfriend's home with the other members of his family still present. (g) Respondenthas demonstrated emotional instability and has failed to provide a stable, moral environment for the minor child. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: - 3 - Document #: 203382.1 ~ , . " "^" '" ',[, Name Address Basis of Claim None WHEREFORE, Petitionerrespectfullyrequests that this Court grant primary legal and physical custody to him with restricted visitation to Respondent. Respectfully submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By ~'6?~ ~ R. Hildabrand, Esquire Attorney LD. No. 30102 P.O. Box 5300 3211 North Front Street Harrisburg, P A 17110-0300 (717) 238-8187 Attorneys for Defendant Dated: 117/01 -4- Document #: 203382.1 ~. ,.' ~~<~'lIiL"" JUN 1 9 2001lJT 1 RHEA A. . METZ Plaintiff .' : IN THE COURT OF COMMON' PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. :NO. 00- 2(.. 70 . : CHILD CUSTODY (?t"Ot'('T~ FRANCIS C. METZ, Defendant ORDER AND NOW, thi~ day of . 2000, the attached STIPULATION is hereby approved an Order of this Court. ;/ Dated, Id I -LfJ.,1P L J, l 4f- Jl /i~U:: r'~--", f- In T(~s;imo:~v :'~~-~:,,~t "'I<C',\~ ,~':"':-"~-;7:) .. '.' "4' ~'_.1. le::: :., ,--1 .:-r.a J ;,\ ':.,::;:,' of~. 'r! r '.' ,.a~;t. "........ , .:~i-.: ,,-our" -~~. - J . Ie. ,I, "'.' , 3:~~f I-rothomt3J" , . ' r - - " 'mil, ~ J lJ Ii I '1 :J- ()7i7> I , ',- RHEA A: METZ : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, I;'ENNSYLVANIA Plaintiff vs. :NO. tJ6-3b?O C'~/~ FRANCIS C. METZ, Defendant :CHILD CUSTODY ORDER OF COURT AND NOW, this;J.:;l. day of ~ , 2000, the attached STIPULATION is hereby approved and made an Order of this Court. Dated: J. ;sf w~ OM, 9-'- -r~VM -r~ ~ ". /" trO , ~c- !J:3'~o:f ~ .LN> - 8n ~~I p~ -~-~M,> '~ RHEA A. METZ, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : vs. :No. FRANCIS C. METZ, Defendant : IN CUSTODY AGREEMENT AND STIPULATION AND NOW, this day , 2000, RHEA A. METZ (hereinafter referred to as "Mother") and FRANCIS .C. METZ (hereinafter referred to as "Father") agree as follows: WHEREAS, Mother and Father are the parents of SAMUEL METZ, born December 10, 1999; WHEREAS, Mother and Father live separate and apart and are desirous of entering into an Agreement and Stipulation concerning the custody of their son: NOW THEREFORE, each party intending to be legally bound agrees as follows: 1. It is the intention of the parties and the parties agree that they will share joint legal custody of Samuel Metz, born December 10, 1999. The parties agree that major decisions concerning their child, including, but not necessarily limited to, the child's health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the child's best interest. Each party agrees not to impair the other party's rights to shared legal custody of the child. Each party agrees not to attempt to alienate the affections of the child from the other party. Each party shall ,,~,;;- notify the other of any activity or circumstance concerning their child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having'physical custody of the child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. 2. Physical custody of the child will be shared equally between the parties on the following schedule: C',. Fclther ~rillhavec'ustody of \;!'l€' child :lne weekend from Friday at noon until Monday at noon and on the next weekend from Friday at noon until Sunday at noon and every week from Tuesday at noon until Wednesday at noon. The pickup and delivery time may be adjusted in the future to accommodate the parent's respective work schedule. b. Mother will have custody the balance of the times. 3. The parents will alternate the following major holidays: Memorial Day, Fourth of July, Labor Day, and Thanksgiving. The custodial period shall run from 9:00 a.m. to 8:00 p.m. Father will have custody every Easter and Christmas and Mother will have custody every Passover and Hanukkah. This ~~ N'. ~" ~j L .~, liJ,j,a^1 "" . custodial period shall run from noon the day before and end two days later at sun down. 4 . Father shall have custody on Fathers's Day from 9:00 a.m. to 8:00 p.m. and Mother shall have custody on Mother's Day from 9:00 a.m. to 8:00 p.m. 5. The holiday schedule shall take precedence over the regular custody schedule. 6. Pick up and delivery of the minor child will occur at Friendly's in Camp Hill, PA. 7. During any period of custody or visitation the parties to this order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this prohibition. 8. Both parents are entitled to one (I) week of uninterrupted custody during the year. It is understood that a week in defined as seven (7) days which must include the parent's regularly scheduled custodial weekend. Each parent shall provide the other with thirty (30) days notice of his/her intention to exercise the extended custody period. 9. Neither parent shall permanently relocate if the relocation would necessitate a change in the visitation schedule or if the relocation would exceed a fifty (50) mile radius without a minimum notice of sixty (60) days to the other parent. The sixty (60) day notice is designed to afford the parents an opportunity to renegotiate the custodial arrangements or to have the matter listed , . , 'Hz, '- . ' for a Court hearing. 10. Both parents shall refrain from making derogatory conunents about the other parent in the presence of the child and to the extent possible sha,::. prevent third parties from making such conunents in the presence of the child. n~~.1'\~ Rhea A. Metz Carol Lindsey, Esquire Francis C.' Metz ~ I '. -- ~ ~"'."" VERIFICATION I verify that the statements made in the foregoing Defendant's Petition for Modification of Custody Order 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. Dated: 0/11 l/0 / , I Francis G. Metz Document #: 203382.1 " J' CERTIFICATE OF SERVICE AND NOW, this 12 day of April, 2001 I, Karl R. Hildabrand, Esquire, of Metzger, Wickersham, Knauss & Erb, P.C., attorneys for Defendant, Francis C. Metz, hereby certifY that I served a copy of Defendant's Petition for Modification of Custody Order this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Judith A. Calkin, Esquire 2201 North Second Street Harrisburg, P A 17110 Y;:;R~~ Karl R. Hildabrand --P Document #: 203382.1 ,r I I, , , , , Plaintiff , IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNrr, PENNSYLVANIA NO. 00-3670 CIVIL TE~ CHILD CUSTODY RHEA A. MErZ, v. FRANCIS C. METZ, Defendant / ~' ORDER OF COURT I AND NOW, this ~ day of M '? 1 ,2001, the Order elf this Court dated June 22, 2000, is hereby modified and amended to include the Stipulation of the parties ! appended hereto. In all other respects the previous Order of this Court shall ~ontinue to remain in full force and effect. BY THE COURT: J. ( cc: Karl R. Hildabrand, Esquire, Attorney for Defendant, Francis G. Metz I Judith A. Calkin, Esquire, Attorney for Plaintiff, Rhea A. Metz ' ~ Doc;um~'1r #: 204284.1 I Ij't"'\i"l i Al'.n.'..}./~k::::'JIHd 1 J ,) Ii ) I " '!'-)I ,-." /- I ,.~, \,-~', / ;'~..:-:!8/1n'1 ~- ~ c: OJ :" "J . , (- I"Ic TI/ I Ii'..! '0' Ii fIT1 ;' I },I:JV'" .'. ' I J.~.:.:;',~(/:,L, :~:,":"i,~,' -- -10: .:i.._iJ:L~1(j -C:j: - --,' I -,' , .... , iLl -^~ ~, l "i 41 L~~ '" .. Plaintiff , I i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA i , NO. 00-3670 CIVIL TERM RHEA A. METZ. v. FRANCIS C. MErZ, cmLD CUSTODY Defendant STIPULATION TO MODIFY CUSTODY ORDER 1. On June 22, 2000, an Order was issued by Judge Dler approving the Agreement and Stipulation of the parties regarding custody" The parties desire to modify and am~d the Stipulation to include the following provision: "During the times of Plaintiff Rhea A. Metz' s ~hysical custody i with the minor child, she agrees that she will not take the child to the home of her boyfriend, Doug Hilbert, as long as Doug Hilbert's wife continues to reside in said residence." 2. Defendant, Francis G. Metz, intends to continue to pursue his Petition for , I Modification of Custody Order filed on or about April 18, 2001, and the entry oftllis Stipulation shall in no way prevent or affect the continuation of that proceeding. ~~,~' Rhea A. Metz ! I ~b ,n~ f..T~-<sL1 I Francis G. Metz ' Itness ALo~;~ ~ Witness / DOG14ment #: 20428./, I , ~ il~~ "" Plaintiff J/JN 11 2001~ IN THE COURT OF COMMON PLt=AS OF CUMBERLAND COUNTY, PENNSYLVANIA RHEA A. METZ, vs. NO. 00-3670 FRANCIS C. METZ, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this 29th day of May, 2001, the Conciliator, having been advised by counsel for the Plaintiff that the parties have reached an agreement, hereby relinquishes jurisdiction of the above-referenced custody matter. FOR THE COURT, Melissa Peel Greevy, Esquire Custody Conciliator ~ I, ~c~ 1~;\,_fD,-D~':F;C: !t:,ji"',lOTARY o i JUtl j ['.ii iD: h 0 cur"'-I' ',-,v'Ut~1Y . V~I....(~~ ,~( L\,\il ill I ,l".I... ,.~.' ,'>I..... \.... '-' PEN~JSYLVANIA ,'" .~~-~~=-> 0 11" _ "'~_,,"' - iFl~r.~~~J!llm~~ ~"~ ~ ~_ ~.~'=~T-~'-'-"''''--"'''--~''-'---'''" ""''''.T<' i . "'~,- .... JUN 2 72001tP RHEA A. METZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-3670 CIVIL TERM FRANCIS C. METZ, CHILD CUSTODY Defendant ORDER OF COURT AND NOW, this 4~ay of -----J' \.J DC' , 200 I, the Order of this Court dated June 22,2000, and the Order of May 13,2001, (which modified and amended the June 22, 2000, Order) are hereby modified and amended further to include the Stipulation of the parties appended hereto. Said Stipulation is approved and issued as an Order of this Court. In all other respects the previous Orders of this Court shall continue to remain in full force and effect. BY THE COURT: J.~ ~~ G .,_0\ cc: Judith A. Calkin, Esquire, Attorney for Plaintiff, Rhea A. Metz Karl R. Hildabrand, Esquire, Attorney for Defendant, Francis G. Metz Document #: 206957.1 . """,,,.,'~ .... " ,.. "'..,~ """',~'~~ ~~ 11'1, 0\ '" ,J,~~ " , ",,',DV ;,.]\,11\1 I"', '1\ 'I: \ G "'U'd-I'I C"" ...",. !:', I" , ..." iJVI: -,:_- I'~ 1 " - 1 '-' .~, U ';';;~,; 1'''''1\ "~hili\ n:J'-, j ~~) 1 ....-J" .J ('J~Jll!f\l'M'lJJ!; ,/' -,' ., 1!?'l':~!~~'ll!!l~'ll''1!i1!lij!I3''l''<!!t~"~,~'1" <~.,~~li'!'2m;l:,:I!l,~tI,.,~" [, ~Ij ,,-'" ~~" ''''''' ,. RHEA A. METZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-3670 CIVIL TERM FRANCIS C. METZ, CHILD CUSTODY Defendant STIPULATION TO MODIFY CUSTODY ORDER I. On June 22, 2000, an Order was issued by Judge Oler approving the Agreement and Stipulation of the parties regarding custody. 2, On May 13, 200 I, an Order was issued by Judge Oler modifYing and amending the June 22, 2000, Order in part and reaffrrmingthe Order in part, 3. Defendant, Francis G. Metz, filed a Petition for Modification of Custody Order on or about April 18, 2001. 4, By agreement and stipulation, the parties have reached agreement regarding the Petition for Modification of Custody Order. 5. The parties agree and stipulate to the following terms: (a) The parties will share joint physical and legal custody of the minor child, Samuel Metz, born December 10, 1999. (b) The minor child shall be in the physical custody of the mother, Rhea A. Metz, from each Tuesday at noon until Friday of that week at noon at which time the child shall be returned to the father, Francis G. Metz. Document #: 206957.1 '-""'..~.. ,~,~ , ,< ~ .~ ( c) The remaining provisions of the previously issued Custody Orders dated June 22, 2000, and May 13,2001, to the extent not inconsistent with the agreement and stipulation set forth herein, shall remain in full force and effect. 6. Both parties further agree that they will cooperate with one another to facilitate the implementation of the agreements, stipulations, and Orders in effect to develop and foster a good relationship between Samuel and both parents. 7. It is agreed between the parties that the minor child will be kept, while in the custody of each parent, in a smoke-free environment. ~ca: /! ~ itness ~Y?c&~ p Witness is r ('j'- 0 I c~~~~ FrancisG. Metz r - 2- Document #: 2069571 ~~lr, ~ ~~~L' l.ilM~~liliiIi1l-!!-_reh..K"Shi;~i&i,ilWlIif UIi...:........ ~-,~.' -, ~~ ," , ~ ~-- - ~~, ,...... ,~"' ~- ~w" " 0 c:' () C n ~', <- -or).:.: r-- nln, '-,..- z:r ,""":- 7C r~' (1)< c,,-,., -<.. < C;:c -CJ J::;r~ 5;Ci r:Y ('-<; C ::--\ Z r:- ~j -:: .z:- -< ~~ " ,,-,~ -. ~