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HomeMy WebLinkAbout97-02358 , SAMUEL G. MOORE, SR., Plaintiff : IN THE COURT OF C'a1to1ON PLEAS OF CUM8ERLAND COUNTY, PENNSYLVANIA . . vs. NO. 97-235S CIVIL TERN RHONDA S. GRIFFIE, CIVIL AcrION - LAW Defendant CUSTODY ",m OF CXXlRT .~ AND tDl, this r1-n- day of upon consideration of t~ Custody onclhation ordered and directed as follows: . . , 1997, Report, it is I. The Father, Samuel G. toIoore, Sr., and the Mother, Rhonda S. Griffie, shall have shared legal custody of Samuel G. Moore, Jr., born January 31, 1997. 2. The Father shall have custody of the Child from Friday between 3:00 and 4:00 p.m. until Tuesday at 6:00 a.m., begiMing Friday, June 13, 1997. The toIother shall have custody of the Child from Tuesday at 6:00 a.m. until Friday between 3:00 and 4:00 p.m. 3. Upon providing two weeks notice to the Father, the Mother shall be entitled to have custody of the Child for up to one full weekend every two months. The parties shall cooperate in scheduling a make-up period of custody for the Father as soon as possible. 4. The parties shall share or alternate custody of the Child on holidays as follows: A. Christmas: The Christmas holiday shall be divided into Segment A which shall run from 6:00 p.m. on Christmas Eve until 2:00 p.m. on Christmas Day, and Segment 8 which shall run from 2:00 p.m. on Christmas Day until December 26 at 9:00 a.m. The ~lother shall have custody of the Child during Segment A in odd numbered years and during Segment 8 in even numbered years. The Father shall have custody of the Child during Segment A in even numbered years and during Segment 8 in odd numbered years. 8. Easter/Thanksgiving: The ~lother shall have custody of the Child every year on Easter Sunday and Thanksgiving Day from 9:00 a.m. until 2:00 p.m. The Father shall have custody of the Child every year on Easter Sunday and Thanksgiving Day from 2:00 p.m. until S:OO p.m. c. Memorial Day/July 4th/Labor Day: The parties shall alternate custody of the Child on Memorial Day, July 4th and Laber Day begiMing with the Father having custody of the Child on July 4th in 1996. D. Mother's Day/Father's Day: The Mother shall have custody of the Child every year on Mother's Day and the Father SAMUEL G. MOORE, SR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : VB. . NO. 97-235S CIVIL TERM . : RHONDA S. GRIFFIE, . CIVIL ACTION - LAW . Defendant : CUSTODY aJSTOOY ~LIATIOO SlI1MARY REPalT IN ACXXlUlANCE WITH CUlBERLAND <XXNl'Y RULE OF CIVIL ~ 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 CURRENl'Ly IN CUS"IDOY OF Samuel G. Moore, Jr. January 31, 1997 Defendant/Mother 2. A Conciliation Conference was held on June 10, 1997, with the following individuals in attendance: The Father, Samuel G. Moore, Sr., with his counsel, Thomas D. Gould, Esquire, and the Mother, Rhonda S. Griffie, with her counsel, Joan Carey, Esquire. 3. The parties agreed JulV II /71 '7 Date to entry of an Order in the form as attached. (O~-/t,,,,d~ Dawn S. Sunday, ESqul e CUstody Conciliator , >.: ..:l' ?;: ~1' lJ. ,-, N :~j ,_0. n ~. ) ..:: UJ.. . 0'.' :r: '..J.., rt~. ..... ..... ~~; ....l...l ,'- r- "(II (1' "- ". 1,"- '!J" 1"::< u::. ~: \ ::..~ ' : 1 ~ lJ ,~ lL\. ,J....: ~ ....; I.!. r- ::; 0 C1' U f:i~ ~~~ ~~..,~ ~~51 ~. ~ ~ f:i~co~B ~~~~ S rt.... "'u :~g '. .. .... .... .... .u C . .... . III lJl'ii: .u ~ c ~ .8 tLI .... '" '" ~ ~ .... ~; g>< ~! B I II :1 =, ~ VI r: f' .::a ...:8 '9AJ:t!: " ,,;.I ~_ .. .. 1 1/)..... '8, 1;;\ r. .5 ~ . ,... e.o 1o?i 'Ii f :; 1l " 5' ~ c ~~_C._ .5 C ~ :: ~ ~ ~,~ ~ 11 '" . ~ . 0) :> . \.? . Ul i I , . . ~JU~ 1 ~ lS97 .. . , . SAMUEL G. MOORE, SR., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 97 - d358 CIVIL TERM CUSTODY RHONDA S. GRIFFIE, DEFENDANT ORDER OF COURT AND NOW, upon consideration of the attached custody complaint, it is hereby directed that the parties and their respective counsel appear before hI\~\1'\ S. ~C\(\\.I . Esauire, the Conciliator, at I 3.:l \..}-~\- Hnlfl '-')~ ) \1('c I'Irlfll ( \h,r9 , PA on the 10 day of J\.Jne , 1997, at 1:):CO .e..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. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. For the Court, r).jf\\\Ji\ sA, ~11!ll~ lu:;'\(K\~1 (CJ'\U\,o~<Y rlP,) , 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 COORT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA l70l3 (717) 240-6200 " , , AlED-OFFlCE OF TI'F ('~~Ti.l.'~"')" , " . ,,\R'( 9HI~Y /2 Pil 3: :n CU"I1' ., IV,r-/." .' "') ",:..1.;., - ,~. (_ ''''J\;'y 1",o-t.1\'('\'lll"'" "j 1.... 'I "-.II .1'J1.'!\ f-/~ ';'7 dd. @f2/- /?~ ~a* ~ f-/;J f) '71t"tc:e ~~lr;:t ~. 5'/,) ,;'/ ~ /IVt./!/ ~ ,,4 ~.,..1""~ The mother of the child is Rhonda S. Griffie, who is believed to be temporarily residing at 4903 Kunkle Lane, Mechanicsburg, Pennsylvania. She is married. The father of the child is Samuel G. Moore, Sr., currently residing at 707 Hertzler Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. He io not married. 4. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: Person Relationshi~ Robert & Shirley Moore Parents 5. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: Name Relationshin Samuel G. Moore, Jr. Son 6. Neither party has participated as a part or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: A. Plaintiff can provide a better environment for raising his son. B. Plaintiff can provide a stable loving home. C. Plaintiff will foster a better relationship between the child's parents. D. Plaintiff will place the interests of the child before his own. 8. 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. WHEREFORE, Plaintiff requests this Honorable Court to grant him joint Legal and Primary physical custody of his son subject to liberal partial custody to Defendant. Respectfully submitted, ~tA4\l). ~ Thomas D. Gould, Esquire I.D.# 3650S 2 E. Main Street Shiremanstown, PA 17011 (717) 731-1461 Fax 761-1974 I verify that the statements made in the Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 1S Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: )-. ,( - 9-( ~. ~ )lJ ...:::)n 1I I I 'l '( '>' {('['ore :Sr: Samuel Moore, Sr. t it; \II - R ,.. ~ C 1'- If) r':> u(', 9 ,'-: Q r- . Je~ .5 ( ..- ',)::"1 fEe, trI ("i~ -'. ~, .' ~;~ ~, U "'" ~[I" .. . ~ ::.j 0 '\1 1:\ lO '- :.'U) !() -' ,{ I J-' ,j (L:U,' l>- f,. ~j. -..! r':: "'" . t'\l) It} ...' :".:,1.. -. tii r- :.i u\ U ,'17IfJlJmJ (P. ~%flld AITomu:v A1 LAW i~r '''AIN~-'Tr?[I:' ';HlfiI:MA~V,10Wt;l PI\. ,'lOll "'17-7]1-14(.1 ~ :=: i5 ~~ ~ ~ ~ < w < ..I W a. iD ... 0: i v G'i < ... ~ .. >- 1Il 0 w z '" z :( ... " ~ 0: 1Il . 0 >: z " < ... w >: " ~ ~ N W < 0: ~ J: ~ 1Il '. . , ,:J:llPV Mi., \.. ,- :<. (;; ic, \.:.-. ."- s1 ':~d. t:)::;: ;..J :'l:. d.~ '.")? . ~ .:0 -i..n ('~1 "1:'< ._, c." .~~Im " \.>-, 'Vo- ..... -' C,) ? , - , ('':J lJ ~:'I l.t, - SAMUEL G, MOORE, SR" Plaintiff/Respondent APR 11 2002 I) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA j 07 . . . . v, NO, 97-2358 Civil Tenn RHONDA S. FERNENGEL Defendant/Petitioner CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this day of ,2002, 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 , 2002, 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 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 pennanent order. FOR THE COURT: By: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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 2 Liberty A venue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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, SAMUEL G. MOORE, SR., Plaintiff IN THE OOURT OF CXX1l-lQN PLEAS OF : CUMSERLAND COUNTY, PENNSYLVANIA . . . . vs. : NO. 97-2358 CIVIL TERM : RHONDA S. GRIFFIE, CIVIL ACTION - LAW Defendant : CUSTODY ~ER OF <XXlRT ~ AND tDl, this /1-n- day of upon consideration of t~ custody oncll1ation ordered and directed as follows: , 1997, Report, it is 1. The Father, Samuel G. Moore, Sr., and the Mother, Rhonda S. Griffie, shall have shared legal custody of Samuel G. Moore, Jr., born January 31, 1997. 2. The Father shall have custody of the Child from Friday between 3:00 and 4:00 p.m. until Tuesday at 6:00 a.m., beginning Friday, June 13, 1997. The Mother shall have custody of the Child from Tuesday at 6:00 a.m. until Friday between 3:00 and 4:00 p.m. 3. Upon providing two weeks notice to the Father, the Mother shall be entitled to have custody of the Child for up to one full weekend every two months. The parties shall cooperate in scheduling a make-up period of custody for the Father as soon as possible. 4. The parties shall share or alternate custody of the Child on holidays as follows: A. Christmas: The Christmas holiday shall be divided into Segment A which shall run from 6:00 p.m. on Christmas Eve until 2:00 p.m. on Christmas Day, and Segment B which shall run frem 2:00 p.m. on Christmas Day until DecerrOer 26 at 9:00 a.m. The Mother shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years. The Father shall have custody of the Child during segment A in even numbered years and during Segment B in odd numbered years. B. Easter/Thanksgiving: The Mother shall have custody of the Child every year on Easter Sunday and Thanksgiving Day from 9:00 a.m. until 2:00 p.m. The Father shall have custody of the Child every year on Easter Sunday and Thanksgiving Day from 2:00 p.m. until 8:00 p.m. C. Memorial Day/July 4th/Labor Day: The parties shall alternate custody of the Child on Memorial Day, July 4th and Labor Day beginning with the Father having custody of the Child on July 4th in 1996. D. Mother's Day/Father's Day: The Mother shall have custody of the Child every year on Mother's Day and the Father I 'f shall have custody of the Child every year on Father's Day. 5. Each party shall be entitled to have custody of the Child for one week of vacation (including two weekenas) each year, upon providing at least two weeks advance notice to the other party. 6. If either party requires childcare for the Child for an overnight period or longer during his or her period of custody, that party shall first contact the other party to give the right of first refusal to provide the necessary childcare. 7. The parties shall share the responsibility to provide transportation for exchanges of custody. 8. Each party shall notify the other of all medical care the Child receives while in his or her care. Each party shall notify the other inmediately of any medical emergencies which arise while the Child is in that party's care. 9. Each party shall notify the other party promptly of any changes in his or her current telephone number or address. 10. The parties realize that their Child's well being is paramount to any differences they may have between themselves. Therefore, the parties agree that neither party shall do 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. 11. 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 agreement. In the absence of mutual agreement, the terms of this Order shall control. J. . 4i.1 t/lt/f?, <V /J'>>A <t. ,,.6. -p, cc: Thomas D. Gould, Esquire - Counsel ther Joan Carey, Esquire - Counsel for Mother - T RUE COpy FROM RECORD 10 Tasllmony Whereof, I here unto set my hand ':!d the seal 01 said c~rl al Carlisle. ,~;.:Z. ; \)1. Ij'It- day ~~ - ;r: I ~/lA-ll ~-I. P -' I ProUhonotarv >- tJ" r: I~ . ~ ..... I'; : ., r-, ~)< lJJ:. ,- 7' Cl' L".; -. ( ." !, -I. "- r~)~ l;~:. '.:'" ~;- -==, "1, 'I) :::; ('''': "- i__ ~ ~-" ~;~~ I." '" ... (" :5 0 0 U SAMUEL G. MOORE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 97-2358 CIVIL ACTION LAW RHONDA S. FERNENGEL, (fornlerly Griffie), Defendant IN CUSTODY PRIOR JUDGE: George E. Hoffer CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent infonnation concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Samuel G. Moore, Jr. January 31, 1997 Father/Mother 2. A Conciliation Conference was held on May 14, 2002, with the following individuals in attendance: The Father, Samuel G. Moore, Sr., with his counsel, Thomas D. Gould, Esquire, and the Mother, Rhonda S. Femengel (fonncrly Griffie), with her counsel, Megan Malone and Lucy Johnston- Walsh, Esquire. 3. The parties agreed to entry of an Order in the fonn as attached. DATE ~ 1,5"; JOJJ- f],~tLdt7'7 Dawn S. Sunday, Custody Conciliator ~;:j ~~j >< t;j ~~tl .... ~~ ~ ,., :g i~~~ .... r:s~.s-O .... -:~ ~~ ,~ ~ ~.:I g~ . c e>:.... ~,fl <iI=''''~ U) III <iI-C o-i . ~I . 'l' ';J e.O ~~58 'll. g! r~ !;>(<Bi~~.E ~ == eo,.... 11'I E ~ u '" C ~ ,_ ~~~~ =.s~ g r.. '=mVl"'''' . . , i ~.. M ~ t.? U)~ ~ r.J ~~~ I I~ ~ 0\ . . MAY::: U LUU, i) '. , - r ,~, t', ,- " I.. I:: '.' " '. .).:;. tl ':-,' 1 ~:j ':1 if I I,' / ,-- ' - L IJ'fi L: ,:lll. " ~..: " , "1 ::..) _:.J (.) SAMUEL G. MOORE PLAINTIFF IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 97-2358 CIVIL ACTION LAW RHONDA S, FERN ENGEL DEFENDANT IN CUSTODY ORDER OF COllin AND NOW, Thursday, Oclober 16,2003 , upon considcration of the attached Complaint, it is hereby directcd Ihal parties and their respeelive counsel appear helllre Dawn S, Sunday, Esq. , the conciliator. at 39 West MaIn Slreel, Mechanlcsburg, PA 17055 on Thursday, November 13, 2003 at 10:00 AM for a Pre-Hearing Custody Conference. At such cOlllerence, all ef/{lrt will be mJde to resolve the issues in dispute: or if this cannot be aecomplished, to define and narrow Ihe issues to be heard by the court, and to enter into a temporary order. All children aAe five or older mJY also be present althe conference. Failure 10 appear at the eonfercnce may provide grounds for cntry of a temporary or permanent order. The court hereby directs tbe parties to furnlsb any and nUexisting Protection from Abuse orders, Special Relief orders, and Custody orders to tbe conciliator 48 hours prior to scheduled hearlug. FOR TIlE COURT. By: /s/ DawlI S. Sill/day. Esq. CUSlody Conciliator The Court of Common Pleas ofCumberlJnd County is required by IJW to comply with the Americans with Disabilites Act of 1990. For informalion about accessible facilities nnd reasonable accommodations available to disabled individuals baving business before the court, please eontJet our ollice. All arrangements must be made atleJsl 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or bearing. YOU SHOULD TAKE TIllS PAPER TO YOUR ATroRNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland Counly Bar Association 32 Soulh Bedford Slreet Carlisle, Pennsylv'lI1in 17013 Telepholle (717) 249-3166 OCT 1 3 2003 \; 5 SAMUEL G. MOORE, PlainlitTIRespondent : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN CUSTODY RIIONDA S. FERN ENGEL, Defendant/Petitioner : NO. 97 - 2358 CIVIL TERM ORDER OF COURT AND NOW, this day of ,2003, upon consideration oflhe attached complaint, it is hereby directed that the parties and lheir respective counsel appear before, , the conciliator, at , on lhe day of ,2001, at m., for a Pre-Hearing Custody Conference. At such conference, an errort 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 penn anent order. FOR THE COURT: By: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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 32 South Bedford Street Carlisle, P A 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabililies Act of 1990. For information about accessible facilities and reasonable accommodations available to disnbled individunls having business before the court, plense contnct our office. All nrrnngements must be made utleast 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. SAMUEL G, MOORE, PlaintiITIRespondent v. : IN TilE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LA W : IN CUSTODY RIIONDA S. FEI?NENGEL, Defendant/Petitioner : NO. 97 - 2358 CIVIL TERM PETITION TO MOmFY CUSTODY ORDER Rhonda S. Fernengel, formerly Rhonda Griffie, by her a\lorneys, the Family Law Clinic, respectfully represents the following in support of her petition: I. Defendant/Petitioner is Rhonda S. Fernengel (hereinafter "Mother"), who resides at 50 Short Lane, Shippensubrg, PA, 17257. 2. PlaintiITIRespondent is Samuel G. Moore (hereinafter "Father"). who resides at 707 Hertzler Road, Mechanicsburg. PA, 17055. 3. Mother and Father arc the natural parents of one child, Samuel Moore, Jr., born January 31, 1997. 4. On June 17, 1997, this honorable Court entered an initial Order for custody of the minor child (Exhibit A, A\lached). 5. On May 21, 2002, a modified Order for custody was established (Exhibit B, A\lached). 6. The current custody Order provides that Father has physical custody of the child from Friday morning before school until Tuesday at 4:00pm or immediately after school if Mother is not working, Mother has physical custody of the child from Tuesday though Friday morning before school. During the summer, Father has cllstody of the child from Friday at 10:00 a.m. until Tuesday at 10:00 a,l11.. and Mother has cllstody of child frol11 Tuesday at 10:00 a,m, until Friday at 10:00 a.l11. each week, Mother and Father share or alternate custody on holidays. 7. The May 21, 2002 Order of Court should be modified beeause: a. The parties arc no longer following the May 21, 2002 Order, but have established a temporary arrangement where Mother sees the child on the weekends. This arrangement is not in the child's best interest because Mother will soon begin to work double shifts at her place of employment on the weekends and can not spend adequate time with the child. b. The current Order was entered when the child was beginning kindergarten. The child is now in first grade and attends school for a full day. c. The current Order grants periods of partial custody to the parents on a rotating schedule during the week that is burdensome to the child now that the child's school schedule has changed. d. Mother believes and therefore avers that it is in the child's best interest to spend more time with his half sister, Sequoia Femengel, age five. e. Mother can provide the child with a healthy and safe home environment and can make arrangements for the child to attend school in Shippensburg, where she lives. f. Mother believes and therefore avers that it would be in the child's best interest to modify the current custody order so that she would have custody of the child each week from Monday after school until Friday after school, and Father would have custody of the child each week from Friday after school until Monday before school. When a school holiday falls on a Monday, Fathrr would have custody of the child until Monday at 7:00 p.m. All other provisions of the May 21, 2002 Order of Court should remain in effect. WHEREFORE, Petitioner asks that the Court modify the existing Order for Custody and grant mother physical custody of the child during the school week, because such an arrangement SAMUEL G. MOORE, SR., Plaintiff IN THE COURT OF COOl-IQN PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 97-2358 CIVIL TERM . . RHONDA S. GRIFFIE, CIVIL ACTION - LAW Defendant CUSTODY ~ER OF CXXJRT ~ AND NGI, this 11~ day of upon consideration of t~ custody onclllation ordered and directed as follows: , 1997, Report, it is I. The Father, Samuel G. Moore, Sr., and the Mother, Rhonda S. Griffie, shall have shared legal custody of Samuel G. Moore, Jr., born January 3l, 1997. 2. The Father shall have custody of the Child from Friday between 3:00 and 4:00 p.m. until Tuesday at 6:00 a.m., beginning Friday, June 13, 1997. The Mother shall have custody of the Child from Tuesday at 6:00 a.m. until Friday between 3:00 and 4:00 p.m. 3. Upon providing two weeks notice to the Father, the Mother shall be entitled to have custody of the Child for up to one full weekend every two months. The parties shall cooperate in scheduling a make-up period of custody for the Father as soon as possible. 4. The parties shall share or alternate custody of the Child on hOlidays as follows: A. Christmas: The Christmas holiday shall be divided into Segment A which shall run from 6:00 p.m. on Christmas Eve until 2:00 p.m. on Christmas Day, and Segment B which shall run from 2:00 p.m. on Christmas Day until December 26 at 9:00 a.m. The Mother shall have custody of the Child during Segment A in odd numbered years and during Segment B in even numbered years. The Father shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. B. Easter/Thanksgiving: The Mother shall have custody of the Child every year on Eastet" Sunday and Thanksgiving Day from 9:00 a.m. until 2:00 p.m. The Father shall have custody of the Child every year on Easter Sunday and Thanksgiving Day from 2:00 p.m. until 8:00 p.m. C. ~lemorial Day/July 4th/Labor Day: The parties shall alternate custody of the Child on ~lemorial Day, July 4th and Labor Day beginning with the Father having custody of the Child on July 4th in 1996. D. Mother's Day/Father's Day: The ~Iother shall have custody of the Child every year on ~lother' s Day and the Father Extllblt A shall have custody of the Child ever:y year on Father's Day. 5. Each party shall be entitled to have custody of the Child for one week of vacation (including two weekends) each year, upon providing at least two weeks advance noticE to the other party. 6. If either party requires childcare for the Child for an overnight period or longer during his or her period of custody, that party shall first contact the other party to give the right of first refusal to provide the necessar:y childcare. 7. The parties shall share the responsibility to provide transportation for exchanges of custody. S. Each party shall notify the other of all medical care the Child receives while in his or her care. Each party shall notify the other immediately of any medical emergencies which arise while the Child is in that party's care. 9. Each party shall notify the other party promptly of any changes in his or her current telephone number or address. 10. The parties realize that their Child's well being is paramount to any differences they may have between themselves. Therefore, the parties agree that neither party shall do 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. ll. 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 agreement. In the absence of mutual agreement, the terms of this Order shall control. cc: . ' ~ A '-<<v fhlAld'lq; t/!t;/f1, ..1, (', J. Thomas D. Gould, Esquire - Counsel ther Joan Carey, Esquire - Counsel for Mother 1 AUE COpy FROM RECORD In Tazthlll)ny wl1er:loi, 1 tlero Ullto set my hand ':~d 01e seal of saId C0fl al Carllslo, '~;.;l. i ilia /fl/.- rJJ.y q) '"L/"'''7 - :h I ,L./u... () })! I OJ J r/...f"'~ " I I ProthOllotary SAMUEL G. MOORE, SR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. 97-2358 CIVIL ACTION LAW RHONDA S. FERNENGEL, (fonnedy Griffie), Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 21M day of~ .2002, upon consideration of the attached Custody Conciliation Rep rt, it is ordered JOd directed as follows: I. The prior Order of this Court dated June 17, 1997 shall continue in effect as modified by this Order. 2. Paragraph 2 oflhcJune 17, 1997 Order is deleted and replaced with the following provision: SCHOOL YEAR: A. During the school year, the Father shall have custody of the Child from Friday morning before school through Tuesday at 4:00 p,m. (or immediately aner school if the Mother is not working) and the Mother shall have custody from Tuesday through Friday morning before school. The parties agree that the Child shall be enrolled in the Mechanicsburg School District for the beginning of the 2002-2003 school year. The Father shall be responsible to trJOsfer the Child to JOd from school during his periods of custody. On days when the Mother WOlks during her periods of custody, the partics shall exchange custody of the Child before and aner school at the Eat N Park restaurant in Carlisle. During days when the Mother is not working during her periods of custody, the parties shall exchange custody at a half way point between their residences before and aner school. The purpose of the exchanges during the Mother's weekly period~ of custody from Tuesday through Friday is to enable the Father to share in transporting thJ Child to and from school. SUMMER 8REAK: B, During the summer school vacntion each year, the Father shall have custody of the Child from Fridny at 10:00 n.m. through Tuesday at 10:00 a.m. and the Mother shall have custody from Tuesdny nt 10:00 n.m. through Friday at 10:00 a,l11. each week. exhibit B L. " l >.. C, , .. , I . '. , : , , '. ,- -. "I " . I .~ " . , ,':'" C- , , f' . :,; I .' .:,., U SAMUEL G. MOORE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 97-2358 CIVIL ACTION LAW RHONDA S. FERNENGEL Defendant IN CUSTODY ORDER OF COURT AND NOW, this ;1.1' day of AJ~ , 2003, upon consideration of the attached Custody Coneiliation Report, it is ordered and directed as follows: I. The prior Orders ofthis Court dated June 17, 1997, and May 21, 2002 are vacated and replaced with this Order. 2. The Father, Samuel G. Moore, Sr, and the Mother, Rhonda S. Fernengel, shall have shared legal custody of Samuel G. Moore, Jr., born January 31, 1997. 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 gcneral well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the tenns of this paragraph eaeh parent shall be entitled to all reeords and infonnation pertaining to the Child including, but not limited to, school and medical records and infonnation. The parties shall cooperate in exchanging all school infonnation including calendars, report cards and any other significant infonnation pertaining to the Child. 3. The parties shall share having physical custody of the Child during the 2003 -2004 school year, with the Father having custody from Monday morning before school through Friday afternoon and the Mother having custody from Friday after work through Monday morning before school. The parties shall cooperate in adjusting the arrangements so that the Mother has mid-week periods of custody with the Child and the Father has periods of week end custody when the Mother is working. 4. The parties agree to contact the appropriate elementary school in the Mother's school district to obtain infonnation on the curriculum for the Child in order to decide where the Child should be enrolled for the 2004-2005 school year. The parties agree thatthc parent who does not have custody of the Child on weekdays during the sehool year shall havc custody cvery weekend, The parties agree to cooperate in resolving the custodial arrangcmcnts for thc 2004 - 2005 school year by May I, 2004. 5. During the summer school break cach year, thc Father shall have custody of the Child from Friday at 10:00 am through Tucsday at 10:00 am and the Mother shall have custody from Tuesday at 10:00 am through Friday at 10:00 am each week. SAMUEL G. MOORE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 97-2358 CIVIL ACTION LAW RHONDA S. FERN ENGEL Defendant IN CUSTODY Prior Judge: Kevin A. Hess 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 infornlation concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Samuel G. Moore Jr. January 31,1997 Father / Mother 2. A Conciliation Conference was held on November 13, 2003, with the following individuals in attendance: The Father, Samuel G. Moore, with his counsel, Thomas D. Gould, Esquire, and the Mother, Rhonda S. Fernengel, and her counsel, Heather Fine, and Anne MacDonald- Fox, Esquire. 3. The parties agreed to entry of an Order in the fonn as attached. IU(1~t.1 ( 1, ;:>0,.3 Date Da\~ Custody Conciliator ;i ~ ~ "" ~ l1. ~ ~~ M~.s-O I:> ur-- ~ ~ .... +J ;.g.:1~- .... 'i II ~; tBl=,,,,~ ~p; J . tBl 'ijl .~ to I~ t;o(tBi:'::E,g . 5 fW... In &Jl1. ~ E: '" u ~ '" = ~.- ;:.13~ ~ ~; m ~ ~ ~mlJl~~ , . 8 ~ tIl ~ ~ 8 M N Z r.!. 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