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HomeMy WebLinkAbout97-00503 ~ o \. u ~ ~ \J \iJ ~ ~ ~ \. u f <:t. ,(j i , ! c<) i ~I t-ol <::tl .1 ~i , " .~ " '. ,./ .' DONALD S. CAMERON plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. CUSTODY\VISITATION : NO. '17- .~-D3 &;J jp- LISA R. CAMERON Defendant ORDER OF COURT AND NOW, 2. /.~ I q 1 , 1997, upon consideration of the attached Complaint, it is hereby directed that the parties and t~eir respective counsel appear before {1:( ~ L .r e. , the conciliator, at o 1 '1 (n 1-11 ~ t.. P 1\ on the \1' day of n~rl , 1997, at 1;00 p. 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 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: -/lt~~/! g?~(?~. Custody Conciliator "-r-~~J 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE , PA 17013 (717) 240-6200 DONALD S. CAMERON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: If'l_ _'JD 'i ~ U__- VS. LISA R. CAMERON, Defendant CIVIL ACTION - CUSTODY COMPLAINT FOR PARTIAL CUSTODY AND NOW comes your Plaintiff, DONALD S. CAMERON, by his attorney, Gregory J. Katshir, Esquire, with the following Complaint for Partial Custody, wherein it is averred as follows: 1. Your Plaintiff is this custody action is Donald S. Cameron, an adult individual residing at 805 5th Street, New CUmberland, County of Cumberland, Commonwealth of Pennsylvania, 17043. 2. Your Defendant in this custody action, is Lisa R. Cameron, an adult individual residing at 66 Spring Hill Road, North Andover, Commonwealth of Massachusetts. 3. Your Plaintiff, seeks partial custody of the minor child, NICHOLAS SCOTT CAMERON, age I, having been born on November 10, 1995. 4. The child was born out of wedlock, however, the parties married subsequent to the birth of the child. 5. The minor child is presently in the custody of his mother, LISA R. CAMERON, the Defendant in this action, who resides at 66 Spring Hill Road, North Andover, MA. 6. During the past five years, the child has resided with the following persons and at the following addresses: 1. From his birth on November 10, 1995 until August, 1996, the child resided at 805 5th street, New Cumberland, PA with Donald Cameron and Lisa Cameron. ii. From August, 1996 until the present, the child has resided at 66 Spring Hill Road, North Andover, MA with Lisa Cameron and Ruth and Paul st. Hilaire, the child's maternal grandparents. 7. The relationship of the Defendant in this custody action, to the minor child is that of the natural mother. Her current address is 66 Spring Hill Road, North Andover MA 01845. 8. The relationship of the Plaintiff in this custody action, to the minor child, is that of being the natural father. He currently resides at 805 5th Street, New Cumberland, Cumberland County, Commonwealth of Pennsylvania, 17070. Plaintiff is married to Defendant. 9. Your Plaintiff has no information concerning any custody proceeding that would involve the minor child, except for the instant action. Your Plaintiff has no information concerning any custody proceeding in any other jurisdiction or forum. 10. Yo~r Plaintiff does not know of any person, who is not a party to these proceedings, who would have physical custody or visitation rights with respect to the minor child. 11. Your Plaintiff has named each parent as a party to this action. The parental rights of each parent have not been terminated, and the natural mother is included as a party. 12. The best interests and permanent welfare of the minor child, would best be served by granting partial custody and shared r-J. l-1 '~ ';l ~ '! ;) o " '.., :;j.. '" ;:,.; " r ~ . ("; C':l r;: f..- <:.: IJlr '~ I: ;. ~ . C' J~ ~ ~L -..;: . ,=, (': , , , , ct:. ", , , J' :: , " ; :-!:....:. .... ~.... G ::5 c., t.) ......~ ~ o r- ~ l ~~ . " GREGORY J. KATSHIR . ~. Attorney at Law 900 Market Street Lemoyne, Pennsy' "'11I17043 (717) 763.8133 . Fu ) 763.9425 (<:\ leI) i ItUC~I",,'VI' ..../,/' OSJ . l' 1 t i' A. Parties. The following is a mutually acceptable agreement between Lisa R. St. Hilaire (Cameron) and Donald S. Cameron regarding how we will share parenting responsibilities for our child, Nicholas Scott Cameron. B. How Long ~his Agreement Lasts. We are entering into this agreement acknowledging that Nick will grow and mature in tne next few years, and that because of such, the terms of this agreement will be reviewed within a maximum of 4 years. C. Terms of -the Agreement. 1. Labeling the Custody Arrangement Lisa will have primary physical custody of Nick, and Don will have partial physical custody of Nick according to the agreed upon schedule. Lisa and Don will have joint legal custody of Nick. In the event Lisa dies, custody of Nick will be assumed by Don and his sister, Janet I. Kohles. 2. Where Our Child Will Live Nick will live with Lisa, and will spend time with Don according to the partial custody schedule. 3. Partial Custody Schedule Visits: Don will spend time with Nick every third weekend (defined as being from 11:30 a.m. on Friday until 7:00 p.m. on Sunday), unless otherwise mutually agreed upon. Before Nick is 5 years old, these visits will be at Nick and Lisa's home. Don will be permitted to take Nick out for day excursions, with the restriction that while Nick is nursing, the excursions allow for Nick's nursing schedule. Holidays: Before Nick is 5 years old, he will have the opportunity to spend a day with Don at Lisa and Nick's home on or around the following holidays: Easter, Thanksgiving, Christmas. If the holidays coincide with Don's regular weekend visits, then no additional visit will be necessary. Vacations: During the summer of 2000, before Nick turns 5, he will spend one one week vacation with Don. Consideration will be given to Nick's maturity level and needs in determining when it is appropriate for Nick to stay overnight with Don, and also in determining acceptable distances and methods for travel. If this agreement has not been reviewed within 4 years, the 2 following partial custody schedule modifications will be in effect: Visi~s: After Nick is 5 years old, he may spend every third weekend at Don's home. Holidays: After Nick is 5 years old, he will alternate the following holidays between Lisa's and Don's homes: Easter, Thanksgiving, and Christmas. Holiday visits will be arranged to meet Nick's best interests and will be scheduled as mutually agreed upon. Vaca~ions: After Nick is 5 years old, he will spend two one week vacations during the summer with Don, unless otherwise mutually agreed upon. When Nick is older, he will have the opportunity to extend his summer vacations with Don to a total of four weeks, should Nick so desire. These summer vacations will be scheduled by January 1st of that year. 4, ~anspor~ing Hic~t Transportation of Nick between his parent's households will be mutually agreed upon with both parents assuming some of the responsibility for transporting Nick. 5. MBin~aining Contac~ When Hick is wi~h ~he O~her Paren~ Nick will be given the opportunity to contact either parent when he is with the other. 6. Insurance We will both obtain medical, dental, and vision care insurance coverage for Nick if it is available through an employer at low or no cost. Don will pay uncovered medical expenses until Nick's 10th birthday, unless Lisa obtains full-time employment (or part-time employment with equivalent full-time benefits) prior to that time. In that case, both parents will share costs of uncovered medical, dental, and vision care expenses by evenly splitting them. After Nick's 10th birthday, both parents will share costs of uncovered medical, dental, and vision care expenses by evenly splitting them. Don will obtain life insurance of at least $120,000 with Nick as the named beneficiary, and Lisa as the trustee. The policy will be maintained until Nick is 18 years old. 7. Medical, Dental, and Vision Care 3 Lisa will choose care providers for Nick, as appropriate, and will share this information with Don. Lisa will share any medical records for Nick that she has with Don. Lisa will provide written instructions on any special care that Nick needs when he is with Don. In the event neither parent is capable of making medical decisions for Nick, decision making power is granted to Ruth C. St. Hilaire. 8. Medical Emergencies If Nick requires emergency medical attention, the parent on hand will notify the other parent as soon as possible. If Nick needs emergency medical treatment and the parent on hand is incapable of making decisions, the other parent will be contacted. If the other parent is not immediately available, emergency contacts will be contacted and granted decision making authority. Each parent will carry a card listing emergency contact numbers, including nearby relatives. Each parent will carry a card indicating that Nick needs protection from bacterial endocarditis because of pulmonary stenosis. 9. Education Lisa will choose appropriate schooling for Nick. Lisa will send Don copies of Nick's school records within 30 days of receiving them. Medical emergencies arising at school will be handled as indicated in #8 of this agreement. Lisa will keep Don informed about Nick's progress in school and participation in school related activities. 10. Consistency in Raising Nick We will attempt to abide by the same discipline standards. If either of us has a discipline issue with Nick, that parent will explain the issue to the other parent so we can be consistent with our discipline. 11. Disparaging Remarks We will each refrain from making disparaging remarks about the other, his/her partner, and his/her chosen life directly to Nick or within Nick's hearing. 12. Undermining the Parent-Child Relationship We will encourage and support Nick in maintaining a good relationship with the other parent. If either of us feels that the other is undermining our relationship with Nick, we will discuss the matter and try to reach an agreement. 13, When Parents Have New Partners Nick will always know that we are his parents, regardless of his attachment to a parent's new partner. 14. Moving/Vacations Each parent will give the other at least 30 days notice of a change of residence, unless circumstances prevent such notice. Each parent will give the other at least 14 days notice of a planned vacation. Signed Date . , II/jar;' (Cameron) ~'2J.. S (~- Donald S. Cameron 5/1/1i-L . \1....\'> ~Jz'iJ!ft /~/:'tJv~7 '" [)" C..-. ?;h Fr; ~/71t " , , 4 >- .:S {":: c: C .~ .' \;. if, !.~ C' ;..;.. W.. ):~ ('>. -.' C ::'i ''i~ ',' I, y[ -- ,n (0 0' ',/. LL..:I- , .,, _..Il, )- ~-,t~ It: , ..':: Uu... r- :A.:. ,.I.: u' r- ;,) 0 C1' U GREGORY J. KATSHIR Attorney al Law 900 Markel Slreel Lemoyne. Pennsylvania 17043 (717) 763-8133. Fax (717) 763.9425 ~MAY 1 9 1991