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HomeMy WebLinkAbout07-1038 Suzanne Spencer Abel, Esq. 22 East Street, #6 Mt. Holly Springs, PA 17065 (717) 829-3206 spencer abel_esq@fastmail.fm IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA G. RAY HOLSINGER, JR., Plaintiff AMY RUDY v Defendant No. 2007 - - CIVIL ACTION - LAW CUSTODY NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mfis adelante en las siguientes paginas, debe tomar acci6n dentro de los proximos veinte (20) dias despu6s de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falls de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier sums de dinero reclamada en la demanda o cualquier otra reclamacibn o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mss aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO IMMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Dauphin 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 at 717-255-2796. 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA G. RAY HOLSINGER, JR., ; Plaintiff No. 2007 - 1,3R v CIVIL ACTION - LAW AMY RUDY Defendant CUSTODY COMPLAINT FOR CUSTODY 1 2 3. The Plaintiff is G. Ray Holsinger, Jr., currently residing at 798 Creek Road, Carlisle, Cumberland County, Pennsylvania. The Defendant is Amy Rudy, currently residing at 6 Garden Lane, Hanover, York County, Pennsylvania. Plaintiff seeks custody of Makena Layne Holsinger, 4 years old (DOB 02/23/07), currently residing at 798 Creek Road, Carlisle, Cumberland County, PA. The child was not born out of wedlock. The child is presently in the custody of Ray Holsinger, who resides at 798 Creek Road, Carlisle, Cumberland County, Pennsylvania. During the past five (5) years, the child has resided with the following persons at the following addresses: Ray Holsinger and Amy (Holsinger) Rudy 12 Hope Terrace, Carlisle 02/2003 - 02/2005 Amy Rudy New Jersey 02/2005 - 06/2005 Amy Rudy Washington, D.C. 06/2005 - 06/2006 Ray Holsinger 1874 Douglas Drive, Carlisle, PA 06/2006 -11/2006 Ray Holsinger, Jr & Ray Holsinger, Sr. 798 Creek Road, Carlisle, PA 11/2006 - present 4. 5. 6. 7. 8. The mother of the child is Amy Rudy, currently residing 6 Garden Lane, Hanover, York County, Pennsylvania. She is divorced. The father of the child is Ray Holsinger, currently residing at 798 Creek Road, Carlisle, Cumberland County, Pennsylvania. He is divorced. The relationship of the Plaintiff to the child is that of father. Plaintiff currently resides with the following persons: G. Ray Holsinger, Sr., Plaintiffs father. The relationship of the Defendant to the child is that of mother. Defendant currently resides with the following persons: Jerry, Defendant's partner, Morgan, Defendant's 7 year old daughter, Amanda, Defendant's 1 year old daughter, and Rachel, Defendant's 2 month old daughter. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has not information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff knows of no person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff has consistently provided, and is better Page 2 situated to continue to provide, for the child's daily physical, social, emotional, and medical needs, and will continue to ensure the child maintains a close relationship with Defendant. 9. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child have been given notice of the pendency of this action and the right to intervene: NONE. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order granting him joint legal custody and primary physical custody of the child. Respectfully submitted, Spencer Abel Law Office SJae" Spen r Abel, sq. AID #202443 22 East Street, #6 Mt Holly Springs, PA 17065 (717) 323-0046 spencer abel_esq@fastmail.fm Counsel for Plaintiff, G. Ray Holsinger, Jr. Page 3 I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA G. RAYMOND HOLSINGER, JR., Plaintiff No. 2007 - v CIVIL ACTION - LAW AMY RUDY Defendant CUSTODY VERIFICATION I VERIFY that I have personal knowledge of all facts not of record set forth in the foregoing pleading, and that such statements 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.A. §4904 relating to unsworn falsification to authorities. Date: a - a a - 017 r y and Holsinger, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA G. RAY HOLSINGER, JR., Plaintiff No. 2007 - v AMY RUDY Defendant CIVIL ACTION - LAW CUSTODY CERTIFICATE OF SERVICE I certify that, concurrent with filing the foregoing Complaint for Custody, I am this day serving a copy of same by Certified, Return Receipt Requests, First Class U.S. Mail, to the following: Amy Rudy 6 Garden Lane Hanover, PA 17331 Date: uz nne p ncer Abel 2 ast Street, #6 Mt. Holly Springs, PA 17065 (717) 323-0046 spencer abet esq@fastmail.fm o „ `I7 { I , m LW ?? G. RAY HOLSINGER, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 07-1038 CIVIL ACTION LAW AMY RUDY DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, March 02, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, March 15, 2007 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. 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: /s/ Hubert X, Giko Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,,bl 4v ro 4,4 GQ C :I d S- UW LODZ APR 2 6 200?? G. RAY HOLSINGER, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW AMY RUDY, NO. 07-1038 Defendant. IN CUSTODY COURT ORDER AND NOW, this c re day of , 2007, upon consideration of the attached Custody Conciliation report, it is ordered a directed as follows: 1. The father, G. Ray Holsinger, Jr., and the mother, Amy Rudy, shall enjoy shared legal and shared physical custody of Makena Layne Holsinger, born February 23, 2003. 2. Physical custody shall be handled on a week on/week off basis with the parties exchanging custody on Friday evening at 5:00 p.m. The exchange shall take place at the maternal grandmother's home, and the father will either deliver the child to the maternal grandmother's home or pick the child up at the maternal grandmother's home at the specified time. 3. The parties may modify or alter this custody schedule as they agree. Absent an agreement, the schedule will control. 4. In the event either party desires to modify this Order, legal counsel for the parties may contact the Custody Conciliator directly to schedule a Custody Conference which may be by telephone. 5. Neither parent shall smoke in the home or in the car when they have custody of the minor child nor shall they allow other people to smoke in enclosed places with the minor child. 6. Both parents shall enjoy reasonable telephone contact with the minor child when the child is in the custody of the other parent. 7. The parties shall share or alternate holidays pursuant to a schedule agreed upon by the parties. Additionally, both parties shall be able to enjoy a two week summer vacation with the minor child. .---s,. BY Judge cc: Elizabeth B. Stone, Esquire Suzanne Spencer Abel, Esquire A oI o 7 I-),.- R LE- 1) - OF THE PP 'F-?TA?Y 2007 APR 30 Ali 11' 54- Pt f 1y G. RAY HOLSINGER, JR., Plaintiff, V. AMY RUDY, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-1038 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child is the subject of this litigation is as follows: Makena Layne Holsinger, born February 23, 2003. 2. A Conciliation Conference was held on April 24, 2007, with the following individuals in attendance: The mother, Amy Rudy, with her counsel, Elizabeth B. Stone, Esquire, and the father, G. Ray Holsinger, Jr., with his counsel, Suzanne Spencer Abel, Esquire. 3. Based upon the recommendation of the Conciliator, the parties agreed to the entry of an Order in the form as attached. Date: April 25, 2007 A.ubert Gi oy, Esquire Custody C ciliator fl\cust\RUDY,AMY-petformodification G. RAY HOLSINGER, JR. Plaintiff/Respondent v. AMY RUDY, Defendant/Petitioner :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :IN CUSTODY :NO. 07-1038 PETITION FOR MODIFICATION FOR CUSTODY 1. Your petitioner is AMY RUDY,(hereinafter referred to as "Mother"), an adult individual, residing at 6 Garden Lane, Hanover, Pennsylvania. 2. The Respondent is G. RAY HOLSINGER, JR., (hereinafter referred to as "Father"), an adult individual, residing at 798 Creek Road, Carlisle, Pennsylvania. 3. Mother and Father share both legal and physical custody of their daughter, MAKENA LAYNE HOLSINGER, who is four years and 11 months of age having been born on February 23, 2003. The parties share custody equally by rotating their daughter on Friday nights on a week on/week off basis pursuant to a Court Order dated April 30, 2007. 4. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) The child has resided with the mother since birth who has provided a continuous loving relationship with the child; -1- (b) The mother is able to provide a stable home and family type environment for the child allowing the child opportunity to spend agreed upon time with the child's father. (c) The mother and her husband are raising their three other minor daughters, all of whom are half-siblings of the subject minor child. The children love each other and miss one other when there are prolonged periods of time between visitations. (d) The minor child is scheduled to be registered for kindergarten this summer, 2008, and Mother would like her to be in the same school district as her other children are and will be. (e) Mother believes that the minor child is being emotionally blackmailed by her father who has convinced this four year old that he NEEDS her to survive and without her, he will die. Mother believes this to be emotional abuse upon this small child. (f) Mother believes that Father is now unstable. Mother reports that Father calls this small child sometimes twice a day which is not reasonable. Mother believes that this is an intentional interruption of her time with her daughter as this child never gets time to assimilate into her mother's house without the father's intensive, intrusive and incessant interference. (g) Mother believes that the child should live primarily 1with her during the school because she can provide a stable healthy and clean environment within which to raise young girls without the -2- influence of unhealthy environment such as is prevalent in father's home life. (h) Mother asserts that Father lives in the basement of the child's paternal grandfather, grandfather's girlfriend and several of her children from prior relationships. (i) Mother does not believe that it is healthy for her daughter to live in a basement and share both a bed and a bedroom with her Father when she could live above-ground with her sisters, Mother and step-father safely in Hanover. (j) Mother has watched her daughter suffer for the last year during this rotation of physical custody and is distressed about her daughter's well-being. 5. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 7. Petitioner has no information of a custody proceeding concerning the child 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 child or claims to have custody or visitation rights with respect to the child. -3- WHEREFORE, your Petitioner requests this Honorable Court to grant primary physical custody of the minor child to her, and grant any and all such other relief as this Court deems just and proper. Dated: 1-? YADY STONE LaFAVER & SHEKLETSKI E1'eth tone, Esquire upreme t I.D. #60251 414 Br' Street, P.O. Box E New C erland, PA 17070 Te one: (717) 774-7435 torneys for Petitioner -4- ,v r Qra 1 ..? C> ? W ff fl G. RAY HOLSINGER, JR. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2007-1038 CIVIL ACTION LAW AMY RUDY DEFENDANT . IN CUSTODY ORDER OF COURT AND NOW, Tuesday, January 29, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, February 29, 2008 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custodv orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, Esq. jgNj _ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 t AWNN3d s I .E wd R Nvr oooz ,1'dl 'i 40 03 U t I 11 1 fl\div\RUDY,AMY-affofservice G. RAY HOLSINGER, JR. AN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent :CUMBERLAND COUNTY, PENNSYLVANIA V. :CIVIL ACTION -LAW :IN CUSTODY AMY RUDY, Defendant/Petitioner :NO. 07-1038 AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND SS: I, Elizabeth B. Stone, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify that I served the Petition for Modification for Custody in the above captioned matter on the Plain- tiff/Respondent, G. RAY HOLSINGER, JR., at 7988 Creek Road, Carlisle, Pennsylvania 17015, by United States certified mail, postage prepaid, restricted delivery, on January 31, 2008, as evidenced by the attached certified mail return recei SWORN TO AND SCRIBED ay of -'. 2008. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL KATHLEEN KEIM, Notary Public New Cumberland Boro., Cumberland Co. My Commission Expires Dec. 5, 2010 411116 m Ln m -D L2 rq Postage ) $ C3 - Er Certified Fee Return Receipt Fee (Endorsement Required) a m s O Restricted Delivery Fee C3 (Endorsement Required) Total Postage & Fees O ru ru m Ir Er C3 r- 0 ¦ Complete items 1, 2, and 3. Aiso complete - Nom 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 ressed to: _ . ?'SIVL?Ji ???1.e i QR ti?? 1? A. Signature I 13 C. Date of Daiivwy (Q - KQ 1WO(S; NgdL J ( - 1 51 -0 D. Is del?ry address difIlerent from Item ? ? Yes If YES, enter delivery address below: ? No 3. Type 10 Certified Mail ? )bqxws Mail ? Registered EW Return Receipt for Menchwullse ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number ._1 a-?. 0-? cal CQ 3 53 ()iarasfb? from service Asby P$ Form 3811, February =4 Domestic Return Receipt 10259&42-W1540 4 l y CIO LIAR S 8 2008 G. RAY HOLSINGER, JR. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW AMY RUDY, NO. 2007-1038 Defendant IN CUSTODY COURT ORDER AND NOW, this day of 2008, upon consideration of the attached Custody Conciliation Report, it is ordered +d' d as follows: 1. A hearing is scheduled in Court Room No. 2 of the Cumberland County Courthouse on the 7``' day of August, 2008 at 8:45 a.m. At this hearing, the mother shall be the moving party and shall proceed initially with testimony. Counsel for the parties shall file with the Court and opposing counsel a memorandum setting forth the history of custody in this case, the issues currently before the Court, a summary of each parties position on these issues, a list of witnesses who will be called to testify on behalf of each party and a summary of the anticipated testimony of each witness. This memorandum shall be filed at least five days prior to the mentioned hearing date. 2. The parties and their attorneys shall also meet again with the Custody Conciliator on June 5, 2008 at 8:30 a.m. for a Custody Conciliation Conference at the Cumberland County Courthouse. In the event the parties are able to reach an agreement at this conference, the Conciliator may notify the Court that the hearing scheduled above may be cancelled. 3. Pending further Order of this Court, the parties shall continue with the 50/50 custody arrangement consistent with the status quo of custody in this case. cc: "Elizabeth Barron Stone, Esquire ""Carol J. Lindsay, Esquire 'Cal Its /niag L, y/a/o8 ? ?= ' ; tt.- ?, -: ...- t?rr, ? '- a?x «V' ? l1M1„t ?lt-- tt +?.????. ? __ ?-- ?' _? ?-- c? G ?-' G. RAY HOLSINGER, JR., Plaintiff v AMY RUDY, Defendant Prior Judge: Edgar B. Bayley IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007-1038 IN CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Makena Layne Holsinger, born February 23, 2003. 2. A Conciliation Conference was held on February 29, 2008, with the following individuals in attendance: The mother, Amy Rudy, with her counsel, Elizabeth Barron Stone, Esquire, and the father, G. Ray Holsinger, Jr., with his counsel, Carol J. Lindsay, Esquire. 3. The parties have generally been working out a 50/50 custody arrangement over the past few years. However, the mother is currently living in Hanover and she may be trying to sell her home to relocate to the Mechanicsburg area. The father lives in Carlisle, but he may be willing to move to Mechanicsburg. In the event there are no moves, some type of different custody arrangement needs to be worked out because the child will be starting school relatively soon. 4. The parties are in agreement to have a hearing scheduled but to also have another Custody Conciliation scheduled in June in the hopes that matters can be worked out prior to a hearing. 5. The Conciliator recommends an Order in the form as attached. Date: ? -a 6-0 Hubert X. G' oy, Esquire Custody C nciliator ' 0 91006 G. RAY HOLSINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW AMY RUDY, NO. 2007-1038 Defendant IN CUSTODY COURT ORDER AND NOW, this day of June, 2008, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. z?4 Hubert X. Gilr , Esquire Custody Co liator N Ci Q C -n C7 Cz'? C..._ flit"-: C ?T?^ >`. r . { rn T,- i .I G. RAY HOLSINGER, JR., Plaintiff V. AMY RUDY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-1038 IN CUSTODY STIPULATION OF THE PARTIES The parties hereto stipulate as follows: 1. They are the parents of a daughter, Makena Layne Holsinger, born February 23, 2003. 2. Amy Rudy, hereinafter "Mother', resides in Hanover, Pennsylvania and G. Ray Holsinger, Jr., hereinafter "Father", resides in Carlisle, Pennsylvania. 3. Makena will be attending kindergarten in the school year commencing August 2008. 4. Since at least March 2007, the parties have shared custody of Makena on a week on, week off basis. 5. In order to preserve continuation of an equal sharing of the custodial time and the active involvement of both parents in her rearing, Father will relocate to Hanover, Pennsylvania so that Makena can attend Park Hills Elementary School in the Southwestern School District. 6. The parties will continue to equally share custody of Makena on a week on, week off basis and will schedule any vacations which they wish to take with the child during their week of custody. 7. Makena will attend before and after school care and daycare at a daycare provider agreeable to the parties. 11 8. The party who registers Makena for school will see to it that the school provides all notices to the other party and, further, if either party receives notice of any school related or extracurricular event, he or she will immediately notify the other of that event. 9. Mother represents that she has no intention of moving from the Hanover area for a period of at least three years. 10. In the event that at any time, Mother petitions the Court for a relocation, and Father remains resident in Hanover, PA., the Court will give favorable consideration at any hearing on that issue to Father's willingness to relocate to Hanover in order to preserve the shared custody arrangement, so long as Father remains residing in Hanover. 11. The parties intend to amend this Stipulation with the details of a holiday schedule. 12. The terms of this Stipulation shall be entered as an Order of Court. Witness: 08- 9- OCAV -1 G. Ray o in er, r. N Q9V 16 e I (W UAdy C=Ng cza o'• AUG 0 7 2008 mA G. RAY HOLSINGER, JR., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-1038 AMY RUDY, Defendant IN CUSTODY ORDER OF COURT AND NOW, this r ( day of ?4 f? `7 ,008, upon consideration of the within Stipulation, the terms thereof are hereby made an Order of Court. , J. FLOWER & LINDSAY ATIOWN15 AT.uw 26 West High Street Carlisle, PA r UJI - r cn ? i J + ¢ r o o a °