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During the past five years the children have resided with
the following persons and at the following addresses: From May,
1992, until May, 1993, with Plaintiff and Defendant in Newville,
Pennsylvania; from May, 1993, until May, 1994, with Plaintiff and
Defendant on Queen Avenue, Enola, Pennsylvania; from May, 1994,
until November, 1995, with Plaintiff and Defendant on Belle Vista
Drive, Marysville, Pennsylvania; from November, 1995, until
August, 1996, with Plaintiff and Defendant at 133 S Enola Drive,
Enola, Pennsylvania; from August, 1996, until the present with
Defendant at 423 Sioux Drive, Mechanicsburg, Pennsylvania,
The mother of the children is DENISE L. SUCCA, who currently
resides at 423 Sioux Drive, Mechanicsburg, Pennsylvania, She is
married,
The father of AUSTIN LUKE SUCCA is KENNETH A. SUCCA, who
currently resides at 26 Stephen Road, Apartment 6-L, Camp Hill,
Pennsylvania, KENNETH A. SUCCA is the step-father of KRISTINA
RENEE BAER. He is married,
4, The relationship of the Plaintiff to the children is
that of mother. The Plaintiff currently resides with the
children.
5, The relationship of the Defendant to the children is
that of father and step-father. He currently resides with his
girlfriend, Linda Ettinger.
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KENNETH A. SUCCA, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 97-2699 CIVIL TERM
.
.
DENISE L. SUCCA and STEVE HOFFMAN, : CIVIL ACTION - LAW
Defendants : IN DIVORCE/CUSTODY
l'~~axm
AND NGl, this day of
upon consideration of the attached custody
ordered and directed as follows:
1997,
it is
1. The Father, Kermeth A. Succa, and the Mother, Denise L.
Succa, shall have shared legal custody of Austin Luke Succa, born March 25,
1994.
2. The ~Iother shall have prilll3ry physical custody of Austin Luke
Succa, subject to periods of partial custody with the Father as follows:
a. On Sunday, July 6, 1997, at 11:00 a.m. until 5:00 p.m.:
b. From Saturday, July 19, 1997 at 9:00 a.m. until Sunday, July
20, 1997 at 5:00 p.m.
c. Thereafter, on alternating weekends from Friday after work
until Sunday at 5:00 p.m.
d. Every Wednesday evening, begirming July 9, 1997, from after
work until the following Thursday morning, when the Father
shall return Austin to daycare. If the Father is unable to
take the Child to daycare on Thursday morning, custody of
Austin shall be returned to the Mother on Wednesday evening
at 8:00 p.m.
e. For one uninterrupted week in 1997 and five (5) additional
nonconsecutive days in 1997, upon providing thirty (30) days
advance notice to the Mother. The Father's five (5)
nonconsecutive days may be added at the begirming and/or end
of the Father's regular periods of weekend custody. In
subsequent years, the Father shall have extended periods of
custody as arranged by mutual agreement of the parties. The
parties agree that it is their intention in subsequent years
to increase the Father's extended periods of custody to two
nonconsecutive weeks.
f. At such other times as arranged by mutual agreement of the
parties.
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3. The parties shall share or alternate custody of Austin Luke
Succa on holidays as follows:
a. Christmas: The parties shall share custody of the Child over
the Christmas holiday as arranged by mutual agreement.
b. Easter: The ~lother shall have custody of the Child every
year over the Easter holiday fran Saturday at 5:00 p.m.
through Easter Sunday.
c. Labor Day: The Father shall have custody of the Child every
year over the Labor Day holiday beginning on Sunday at 5:00
p.m. through Labor Day, Monday.
d. Alternating holidays:
1. The Father shall have custody of the Child in odd
numbered years on New Years Day and Thanksgiving and, in even
nl.lllbered years on Memorial Day and July 4th.
2. The Mother shall have custody of the Child in odd
numbered years on July 4th and Memodal Day and, in even
numbered years, on Thanksgiving and New Years Day.
3. The times for exchanges of custody under this provision
shall be arranged by mutual agreement of the parties.
c. Mother's Day/Father's Day: The Mother shall have custody of
the Child in every year on Mother's Day fran 10:00 a.m. until
5:00 p.m. and the Father shall have custody of the Child in
every year on Father's Day from 10:00 a.m. until 5:00 p.m.
d. Child's birthday: The party who does not otherwise have
custody of Austln on Memorial Day weekend shall have custody
of the Child on his birthday, even if the Child I s birthday
falls during the Memorial Day weekend.
4. In the event either party requires childcare for Austin by a
person who is not a relative for a period in excess of twenty-four (24)
hours during his or her period of custody, the party requiring childcare
shall offer the other party the opportunity to provide the care before
contacting unrelated caregivers.
5. The party receiving custody of Austin shall provide
transportation for the exchange of custody, with the exception of Thursday
morning, when the Father shall transport the Child to daycare.
6. The parties agree that the Father shall have reasonable
periods of custody with his stepdaughter, Kristina Renee Saer, as arranged
by mutual agreement and in consultation with Kristina.
7. Neither party shall imbibe alcoholic beverages for a period
of twelve (12) hours prior to, or during periods of custody with the
Children. In addition, neither party shall smoke in the presence of the
KENNETH A. SUCCA, . IN THE COURT OF CCWlON PLEAS OF
.
Plaintiff . CU~IBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . NO. 97-2699 CIVIL TERM
.
.
.
DENISE L. SUCCA and STEVE HOFF~lAN, . CIVIL AcrION - LAW
.
Defendants . IN DIVORCE/CUS'IODY
.
aJS'lOOY ~LIATIOO SlftWri REPOOT
IN ACXXlUlANCE WITH CDUlERLl\ND <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:
NAIlE
DATE OF BIRTII
CURREmi,Y IN aJS'lOOY OF
Austin Luke Succa
March 25, 1994
Defendant/Mother
2. A COnciliation COnference was held in this matter on July 2, 1997,
with the following individuals in attendance: The Father, Kenneth A.
Succa, with his counsel, Charles E. Petrie, Esquire and the Mother, Denise
L. Succa, with her counsel, Johnna S. Deily, Esquire.
3. It should be noted that Steve Hoffman was also joined as a
Defendant in the Father's Petition. Steve Hoffman is the biological Father
of the Father's step-child, Kristina Renee Baer, born September 14, 1982.
According to the Mother, Steve Hoffman has had no contact with Kristina for
fourteen (14) years. Steve Hoffman did not appear at the Conference.
Custody of Kristina was not an issue at the COnference and is only relevant
to this action to the extent that the parties have agreed that the Father,
Kenneth A. Succa, may have reasonable partial custody of Kristina as
arranged by mutual agreement with the Mother and with consultation with
Kristina.
4. The parties agree to entry of an Order in the form as attached.
~ ,~/997
Date
O~~ay
Dawn S. Sunday, EsquIre
Custody Conciliator