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HomeMy WebLinkAbout97-03109 . ~ .j) oJ) 0- - cf] ( ~ j x , , * \,J, Sc.o-\-\ fS\i ~ ~ I Jr. Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : V :CIVIL ACTION - LAr{ ~NO. S \ 09 CIVIL :CUSTODY/VISI-TATION 19Cfl * fbrnela S, 81iS~ Defendant ORDER OF COURT AND NOW, this' (date) <;;,/lilcll , upon consideration of the attached complaint, it is hereby directed that the Barties and their respective counsel a pear before \ L \ . . the conciliator, at . tn ' on the au. day of ....l , 19Q-, ,at , P. M.-, for a PreheBring Cust dy 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 temporazy order. Either party may bring the child who is the subject of this custody action to the conference, but the child/children's attendance is not mandatozy. Failure to appear at the conference'may provide grounds for entry of a tempqra.ry or permanent order. , FOR THE COURT: By:'TIU.cJVl.n..O cI ~~f~ Custody conciliator~) 0 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO on TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, FOURTH FLOOR CARLISLE PA 17013 (717)240-6200 . RLED-OFFlCE OF n't: r~!'}TFONOTAAV 91 JUII I 9 l\H 10: 1.1 CU' ';'-.':' 'I .' j"' "'u~I'I'TY 1~:,..-\,:;.I'__"J' I J.... .'cI" FENi,'S'ILW,r fA . (,-/'14) d ~ff/J(47f.-~.~ ~ - It! . n 'fIi1u't. /1Ml,~ ~ dfI &- ' It? /jJ ~ .,4u ~ /'{.:i"3:l"r # . " (a) From January 1992 to October 1995, with Plaintiff and Defendant at 2973 Mourning Dove Circle, Stow, OH 44224; and (b) From October 1995 to present, with Plaintiff and Defendant at 145 Bryce Road, Camp Hill, PA 17011. The mother of the children is Defendant Pamela S. Bliss, residing at the above-indicated address. She is married to, but is or soon will be living separate from, the Plaintiff. The father of the children is Plaintiff W. Scott Bliss, Jr., residing at the above-indicated address. He is married to, but is or soon will be living separate from, the Defendant. 4. The relationship of the Plaintiff to the children is that of father. The Plaintiff currently resides with the following persons: Defendant Pamela S. Bliss and the parties' children, W. Scott Bliss, III, Hillary S. Bliss and Andrew L. Bliss. 5. The relationship of the Defendant to the children is that of mother. The Defendant currently resides with the following persons: Plaintiff W. Scott Bliss, Jr. and the parties' children, W. Scott Bliss, III, Hillary S. Bliss and Andrew L. Bliss. 6. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the children in this or another court. 2 Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because, inter ~, Plaintiff is ready, willing and able to provide a much more stable atmosphere for the children and the Defendant mother has, by her words and conduct over the last several months, attempted to influence the children against the Plaintiff and has attempted to use the children as a weapon in her dispute with the Plaintiff with regard to a divorce action Plaintiff has also commenced docketed to No, 97-1690, Cumberland County Court of Common Pleas. 8, Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children 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 children will be given notice of the pendency of this action and the right to intervene: NONE. liHEREFORE, Plaintiff requests the Court to grant primary physical custody of the parties' children to Plaintiff, subject to such periods of temporary custody and visitation with the Defendanb 3 f ~ ~ ,... :- 0 t::: .- .. ::; l.!) !;'jQ ..:z "'1,~ '. . 0 ~ Q ::z:: . ''''-:t ~ ...-<; 8~ 0- .",~ -,... c:-- - ~..,~'J \!) (0 Il.. ..1..... 1if -.. --, (f lS) Efll.! =-= 1......0 "j" ~- ~ :: u.. F -- -, ;-.: ;J 1i IL r- ;.:J 0 01 U .~ Cl!.. c) 8:00 p.m. If the children are not in school, these periods of partial custody shall be from 5:00 p.m. until 8:00 p.m. The parties both agree that it is in the best interest of the children that they spend these periods of partial custody and visitation with their Father. Both parties further agree that they will take whatever steps are necessary to ensure that the children spend this custodial time with their Father. 3. The parties shall alternate the major holidays, those holidays being defined as the Fourth of July, Labor Day, Thanksgiving, Easter, and Memorial Day. Should these holidays occur on a Friday or a Monday, or over the weekend, they shall include the entire weekend. 4, The parties shall share the Christmas holiday. Segment A shall be from Christmas Eve at 5:00 p.m. until Christmas Day at 5:00 p.m.; Segment B shall be from Christmas Day at 5:00 p,m. until December 26th at 5:00 p.m. Father shall have Segment A in 1998 and all even years thereafter and Segment B in 1999 and all odd years thereafter. Mother shall have Segment A in 1999 and all odd years thereafter and Segment B in 1998 and all even years thereafter. 5. The parties shall evenly share the remainder of the Christmas holiday which shall commence on December 26th and continue until January 1st each year, at times to be agreed upon by the parties. 6. Both parties shall be entitled to two uninterrupted non-consecutive weeks of vacation with the children. Both parties shall provide each other with thirty (30) days advance notice as to when they intend to exercise those two weeks of vacation, Father has already chosen the first week of August, 1998, Whoever provides the other with notice first shall be entitled to that particular week. 7. Father shall have the children on Father's Day and the Father's birthday, and Mother shall have the children on Mother's Day and the Mother's birthday. These periods of visitation shall be from 9:00 a.m. until 7:00 p,m. unless the parties otherwise agree. 8. The parties agree that they shall provide each other with reasonable telephone access and encourage the children to have telephone access with the other parcnt. 9. Such other times as the panies may agree. 10. The parties recognize that there ma)' be an on-going need for the minor children and the Father to engage themselves in counseling, 'The panies agree that they shall continue with those counseling sessions which have occurred with Dr. Delenne. Both panies shall endeavor to cooperate with each other to ensure that these sessions are completed when needed, 'nle cost of the counseling sessions shall be shared on a pro-raw basis in accordance with the parties' incomes. The panics agree that the pro-rata basis shall be 711% responsibility of Father and 22% responsibilit)' of Muther uf all)' costs atier appliclItioll of appropriate insurance. i;; 0'. P. -'1 ~~ .. --: LUQ - .-).~ (~t; - :.. ,1 ~:; -- :'-';;' f::i' ...;; &. ~., ~r.~ .. ,'" c.:, " -"'1 Uj" <'J ). , -I"~ -:; u:..; .;: ~} '~ lJ r:; ~ ...:.... II. ..... ..., (; _., 0' U . . III ~ :l IJ.I ~ :z I- CO "' 0 Q ::Jill;: rI ~~~al~ ! I-~~~ ~~ ~ < 0 ..:; ,;: ~M~~1;\5 ~ "' VI -:l "'" uJ~:rttz ,;~ UO~O~ Sfj :Zl:;O~li ~ IJ.I<Z2~ ~ ~ ~ el X III ~ - < ~ :t . , . . . . W. SCOTT BLISS, JR. . IN THE COURT OF COMMON PLEAS . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : v. . CIVIL ACTION - LAW . NO. 97-3109 PAMELA S. BLISS, . . Defendant . CUSTODY . PRAECIPE TO ENTER APPEARANCE TO: Prothonotary Cumberland County 1 Courthouse Square Carlisle, PA 17013 Please enter our appearance on behalf of the ,Defendant, Pamela S. Bliss in the above-captioned matter. WIX, WENGER & WEIDNER, a Profes onal Corporation . DATE: June 19, 1997 . W. SCOTT BLISS, JR. . IN THE COURT OF COMMON PLEAS . Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . v. . CIVIL ACTION - LAW . . NO. 97-3109 . . . PAMELA S. BLISS, . . Defendant . CUSTODY . CERTIFICATE OF SERVICE I hereby certify that the foregoing Praecipe To Enter Appearance was sent by first class, postage prepaid mail this day to the following: Bruce F. Bratton, Esquire Martsolf & Bratton 2515 North Front Street P.O. Box 12106 Harrisburg, Pennsylvania 17108-2106 (717) 236-4241 WIX, WENGER & WEIDNER, a profe~sional Corporation I I / / 7 n n ID #52653 a Street 17108-0845 June 19, 1997 W. SCOTT BLISS, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97-3109 v. PAMELA S. BLISS, Defendant CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF DAUPHIN AND NOW, this 18th day of June, 1997, personally appeared before me, a Notary Public in and for the State and County aforementioned, Bruce F. Bratton, Esquire, who, being duly sworn according to law, deposes and says that a copy of the Complaint for CUstody in the above-referenced custody action was served on the Defendant on June 14, 1997, by Certified Mail No. P 649 937 762, return receipt requested, restricted delivery, as evidenced by the return receipt card attached hereto and made a part hereof. ffJA+-, Bruce F. Bratton, Esquire Sworn to and subscribed to before me this~)Y4day of I. >...J ~- , 1997. ..1,/"7 ;::;//<;~~ <,' ? /).--:-.--<"!/,,- Notrry Pu~c / HOTAIllAL SeAL NANC'/ E, ROACH, Notary PublIc Horri.burg. Oauptlln County. PA My Commin.on e.pire. Jon. 29. 2001 I I - i . \" ( j ) ( ( ) .I . ~ ..:t (;. ..;l " j5: N ~~t" w9. (.) :;;; (J.....-. C)~ fE~' li: ~~~ 1:""'\;:>, 0 ~:;/;; (:. N ._lX '-'- ":2 u:UI ~.: 1 L:..; r-: -, :(lu... -) ...... ...: () r- ;::J 0' U ~EP 0 9 1997 \ c:= ~. ;'u-:\:C1T:~:"T;':~'{ (J!1 1';'1 ,,') ("" "'. ,. i .n ,. ,. ./1.... I.; f" .-'. C[;'. _ ., ,., i;~\i;',_,::;.!..\,;;,~.;,~, I 1-?n,C)f &d. ~~~ii4 ~ . /'~'9r 71~ v?11~ & ~ D~ /3?-9r I~~-h... '7Jl.~~~. , ., ~ c:> r- ~~ u: Z >-o- M ,0, :::><( lU.-..1 oc. te':'> - -~ U"" f..~: 0... ~. ~,~ ~C o- r;.. ~ ~.... (/l ~". ~- ,)4 u:1.t,i -.. ilIT] ., ..::0:: r:. :11Q.. -, -; uo c:c :3 0 ", U , tllEO-OFFlCS or- 1\\'2. n:r:\HI',~~Oi/IP.'{ qB t\M~ '3 \ PH 2: 09 C\J'"'''' ' , ," '("'J""" Nl,:,':..n.J';".) \..J,j. 1,1\ Pr.N;,~~)"tt:\'; ~ .rA children and Father must be involved in counseling in order to effectuate a regular and consistent schedule. TIle minor children and the Father shall engage themselves in counseling so ns to work townrds a set schedule which should include a contact during the week nnd contact every other weekend at a minimum. The pnrties shall agree upon the counselor who should be involved with the children nnd Father. If the pnrties cnnnot otherwise agree, the counseling should be completed by Reigler Shienvold Associates. The children should be involved in atlenst four to six sessions with their Father between now nnd the next scheduled conciliation conference. Both pnrties will endeavor to cooperote with each other to ensure that these sessions are completed. The children are specifically instructed that they shall cooperote with aUending these sessions nnd pnrticipating in them ns well. The counseling sessions shall be shared on a pro-rota bnsis in accordnnce with the pnrties' incomes. The pnrties agree that that pro-rota bnsis shall be 78% responsibility of Father, nnd 22% responsibility of Mother of nny costs after application of appropriate insurance. 3. The pnrties shall engage in mediation with each other to help them work through these custodial issues. The pnrties shall agree upon nn appropriate mediator to help them work through these issues. If the pnrties cannot otherwise w. SCOTT BLISS, JR., Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97-3109 PAMELA S. BLISS, Defendant CUSTODY PLAINTIFF'S PETITION TO ENFORCE AND/OR FOR CONTEMPT 1. petitioner is W. Scott Bliss, Jr., Plaintiff in the above-captioned custody matter. 2. Respondent is Defendant Pamela S. Bliss, Defendant in the above-captioned custody matter. 3. As a result of conciliation conferences held in this matter, an Order was entered by agreement of the parties on June 5, 1998. A true and correct copy of the said custody Order establishing visitation schedules and rights of the petitioner is attached hereto and marked as Exhibit "A". 4. Despite Petitioner's requests that the said Order be complied with, the Respondent has failed and refused, and continues to fail and refuse, to abide by the terms of the Court Order, as a result of which the children of the parties, especially the parties' daughter, Hillary, has not been made available for the exercise of the father's visitation rights, including the following incidents and dates: (a) On the weekend of June 26-28, 1998, when the daughter was to be in the temporary custody or visitation of the father, Respondent interfered with father's visitation by scheduling activities which conflicted with father's time, resulting in father's having spent only the evening of June 26 with his daughter, Hillary. When the Petitioner objected, the Respondent accused him of being "an asshole". (b) On the evening of Wednesday, July 1, 1998, the daughter, Hillary, was not available when the Petitioner arrived to pick her up for an evening visit. (c) On Friday, July 10, 1998, when Petitioner appeared to pick up the children for a weekend visit during the weekend of July 10-12, the daughter, Hillary, was not available because, with her mother's approval, she left the area with friends and never appeared for any part of the weekend visitation. (d) On the evening of Wednesday, July 15, 1998, when Petitioner appeared at Respondent's home for his weekday evening visitation, the daughter, Hillary, was not available because, with the mother's approval, had been permitted to go to a movie and, therefore, be unavailable for the weekday evening visitation with her 2 father. When the father objected, Respondent mother said she will do everything possible to ensure that the Petitioner-father "will never see Hillary again". (el On the weekend of July 24-26, 1998, when the children were to be in the temporary custody or visitation of the father, Respondent interfered with father's visitation by scheduling activities which conflicted with father's time, resulting in father's having spent only disrupted time with his children. 5. The Respondent-mother's attitude and behavior has been and continues to be one designed to interfere with the Petitioner- father's access to his children, maintenance of an open relationship with his children and encouragement of contact with and visits between Petitioner-father and his children, all with the intent of using the children as a weapon and in an effort to destroy or interfere with the development of a normal father-child relationship between the Petitioner-father and his children, especially the daughter, Hillary. WHEREFORE, Petitioner respectfully requests that a hearing be held in this matter as soon as is practicable and that, after hearing, this Honorable Court enter an Order: (al Holding the Respondent in contempt for willful violation of and interference with the Order dated June 5, 1998; 3 (bl Awarding primary physical custody of the parties' minor children to the petitioner subject to such reasonable periods of temporary custody and visitation by the Respondent as the Court deems to be appropriate under all of the circumstances; (c) Awarding the Petitioner-father his reasonable attorneys' fees; and (dl Granting such other relief as this Honorable Court deems to be just and appropriate under all of the circumstances. Respectfully submitted, Date 1 Arf- f~ By Bruce F. Bratton, Esquire Pa. Attorney I.D. No. 23949 2515 North Front Street P. O. Box 12106 Harrisburg, PA 17108-2106 (717) 236-4241 Attorneys for Plaintiff 4 8:00 p.m. If the children are not In school, these periods of partial custody shall be from 5:00 p,m. until 8:00 p.m: The parties both agree that it is in the best interest of the children that they spend these periods of partial custody and visitation with their Father. Both parties further agree that they willtnke whatever steps are necessary to ensure that the children spend this custodial time with their Father. 3. The parties shall alternate the major holidays, those holidays being defined as the Fourth of July, Labor Day, Thanksgiving, Easter, and Memorial Day. Should these holidays occur on a Friday or a Monday, or over the weekend, they shall include the entire weekend. 4. The parties shall share the Christmas holiday, Segment A shall be from Christmas Eve at 5:00 p,m. until Christmas Day at 5:00 p,m.; Segment B shall be from Christmas Day at 5:00 p.m. until December 26th at 5:00 p,m. Father shall have Segment A in 1998 and all even years thereafter and Segment B in 1999 and all odd years thereafter. Mother shall have Segment A in 1999 and all odd years thereafter and Segment B in 1998 and all even years thereafter, 5, The parties shall evenly share the remainder of the Christmas holiday which shall commence on December 26th and continue until ];muary I st each year, at times to be agreed upon b)' th~ parties, 6, Both parties shall be entitled to two uninterrupted non-consecutive weeks of vacation with the children. Uoth parties shall provide each olher with 5. The PlaintilT's position on custody is as follows: Mother has interfered with the custodial situation primarily as it relates to Hillary. Father believes that the Mother has interfered with his custodial schedule by allowing or permitting Hillary to schedule activities that conflict with his time. Father believes this is an on-going pattcrn and is concerned that his custodial rights will be interfered with on a regular basis. 6. The Defendant's position on custody is as follows: Mother believes that the Father does not recognize the needs of thcir teenage children in that they havc rcgular activities that are planned. These include activities with school, jobs, and activitics with fricnds. Mother dcnies that she has purposely schcdulcd thcse activitics on Fathcr's weekends but believes that Father needs to be more flexible with the scheduling to accommodate his teenage children. 7. Need for separate counsel to represent child(ren): Neither party requested, 8. Need for independent psychological evaluation or counseling: None requested and the Conciliator does not believe any is necessary. 9. A hearing in this matter will take two hours. 10. Other matters or comments: This is a case that has come a long way from its inception with this Conciliator. The unfortunate aspcct of the case is that the parties are seemingly unable to communicate to this day. TIle allegations raised by each party clearly indicate that the parties have an inability to communicate in that they cannot adjust these schedules to the needs of their teenage children. On the one hand, Father does not seem to understand or recognize that the children have regular activities that may conflict with his time, Given the history of the case, it is understandable that Father wants to make sure that he has as v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97-3109 W. SCOTT BLISS, JR., Plaintiff PAMELA S. BLISS, Defendant CUSTODY STIPULATION It is hereby stipulated and agreed by and between the parties to the above-captioned matter and their respective counsel as follows: 1. The parties jointly request that the hearing on the Plaintiff's petition for contempt which had been scheduled for December 14, 1998 be postponed to a date to be selected by the Court no earlier than April 1, 1999 and request that the said hearing be rescheduled for the month of April, 1999 if possible. 2. Defendant Mother and the parties' children, Scott, Hillary and Andrew, shall be required to attend a counseling session at the office of Jose A. Delerme, M.A., currently scheduled for January 8, 1999. 3. The children shall attend additional counseling sessions along with the Plaintiff Father currently scheduled for January 21, February 4, February 18, March 4 and March 18, 1999. 4. Jose A. Delerme, M.A. shall report directly to the Court, and, concurrently, notify the parties and their counsel, of the >- co ~ ~ .::J f-': ... w~; N :;J.... O...-..~ U~' fFl" -~ .}.Z 1._'" LL. ~- :.1... C')c ,...:!~... "'(;5 @t ..:r ' . :~Z ~~I~ :>- n:% .1. ..~ : l,'UJ i~" X UJll. ~ 0'\ .'- ::l 0- U father's home at 4705-A Charles Road, Mechanicsburg, PA 17055, and the minor child, Hillary S. Bliss, has likewise been residing with her father at her father's home at 4705-A Charles Road, Mechanicsburg, PA 17055 approximately half of the time. The eldest child, W. Scott Bliss, III, has attained the age of majority and is attending college at Purdue University in West Lafayette, Indiana. 6. The relationship of the Plaintiff/Petitioner to the children is that of father. The Plaintiff/Petitioner currently resides with the minor children, Hillary S. Bliss and Andrew L. Bliss. 7. The relationship of the Defendant/Respondent to the children is that of mother. Plaintiff/Petitioner believes the Defendant/Respondent currently resides alone. 8. Plaintiff/Petitioner has not participated as a party or witness, or in another capacity, in any other litigation concerning the custody of the children in this or in any other court except for the instant proceedings. Furthermore, Plaintiff/Petitioner has no information regarding any custody proceeding concerning the children pending in any other court of this Commonwealth or in any other jurisdiction. 9. Plaintiff/Petitioner does not know of any person not a party to these proceedings who has physical custody of the children or who claims to have custody or visitaticn rights with respect to the children. 10. The best interest and permanent welfare of the children will be served by granting the relief requested because the 2 children have developed a close bond with their father, the Petitioner, and have expressed an interest in and determination to reside primarily in the home of the Plaintiff/Petitioner who is full well ready, willing and able to provide for their daily physical, educational, medical, social and psychological welfare, or to reside with each parent on a more or less shared basis. 11. Each parent whose parental rights to the children have not been terminated and all persons who have physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff/Petitioner respectfully requests your Honorable Court to modify the existing Custody Order so that the Plaintiff/Petitioner be granted primary physical custody of the parties' minor child, Andrew L. Bliss, with such periods of temporary custody or visitation granted to the Defendant/Respondent as the Court deems to be appropriate, and that the parties share equally the custody of Hillary S. Bliss. Respectfully submitted, Date J~ JelL 0 J V By B uce F. rat n, Esquire Pa. Attorney I.D. No. 23949 2515 North Front Street P. O. Box 12106 Harrisburg, PA 17108-2106 (717) 236-4241 Attorneys for Plaintiff 3 8:00 p.m. If the children are not in school.thcse periods of partial eustody shall be from 5:00 p.m. until 8:00 p.m: The pnrties both agree that it is in the bcst interest of the children lhatlhey spend these periods of partial custody and visitation with their Father. Iloth parties further agree that they will take whatever steps are necessary to ensure that the children spend this custodial time with their Father. 3. The parties shall alternate the major holidays, those holidays being defined as the Fourth of July, Labor Day, 11lRnksllivinll. Easter, and Memorial Dny. Should these holidays occur on a Friday ur a Monday, or over lhe weckend, they shall include the entire weekend. 4. 11le parties shall sharc the Christmas huliday. SCllmcnt ^ shall be from Christmas Eve nt 5:00 p.m. until Christmas Day at 5:00 p.m.; Scltmentll shall be from Christmas Day at 5:00 p.m. until Deeemher 26th at 5:00 p.m. Father shall hnve Segment ^ in 1998 and all even years lhereafier and Segmentll in 1999 and all odd years thereafier. Mother shall have Sellment ^ in 1999 nnd all odd yenrs therenfier nnd Segment 13 in 1998 and nil even years therenfier. 5. The pnrties shnll evenly share the remainder of the Christmns holiday which shall commence on Decemher 26th and continue until Janunry 1st each year, nttimes to be allrecd upon h> the parties. 6. noth partics shall be entitled to two uninterrupted non-consecutive weeks of vacation with the children. nuth parties shall provide each other with thirty (30) days advance notice as to when they intend to exercise those two weeks of vacation. Father has already chosen the first week of August, 1998.-Whoever provides the other with notice first shall be entitled to that pnrticular week. 7. Father shall have the children on Father's Day and the Father's birthday, and Mother shall have the children on Mother's Day and the Mother's birthday. These periods of visitation shall be from 9:00 a.m. until 7:00 p.m. unless the parties otherwise agree. 8. The parties agree that they shall provide each other with reasonable telephone access and encourage the children to have telcphonc access with the othcr parent. 9. Such other timcs as the parties may agree. 10. The parties recognize thatthcre may be an on-going necd for the minor children and tho Father to engage themselves in counseling. Thc parties agree that they shall continue with those counseling sessions which have occurred with Dr. Delemie. Both parties shall endeavor to cooperate with each other to ensure that these sessions are completed when needcd. 11le cost of the counscling sessions shall be shared on a pro-rata basis in accordance with the parties' incomcs. The parties agrce that the pro-rata basis shall bc 78% responsibility of Father and 22% responsibility of Mother of any costs afier application of appropriate insurance. :' C' =t .~,- l!j ~ ~ ~ :: ~ : ... .....-- ~ ,.... , ~ " 0 C'( c- ...... ...... . ..... , s -u . ~ ~ ~ u " ,," 'oJ . s~p i~l W. SCOTT BLISS, JR. Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97-3109 CIVIL TERM PAMELA S. BLISS, Defendant CUSTODY ORDER AND NOW, this L.:~ II day of ~, 2001, upon consideration of the within Stipulation, it is hereby ORDERED AND DECREED that such Stipulation is hereby adopted as the Custody Order of this Court, modifying and replacing the Order of June 5, 1998, as provided in such J. ~ C~OI~\ Q 10' -01 ~ ~ -{ ,./ '.',- c:- ('" . .-li C :, .... I (. ; ~' t I I" .,: :OJ ;} : ~~ -0 :.: to) .. ;0..) v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97-3109 CIVIL TERM W. SCOTT BLISS, JR. Plaintiff PAMELA S. BLISS, Defendant CUSTODY STIPULATION The parties to this custody action hereby stipulate and agree as follows: 1. The Custody Order dated June 5, 1998 shall be modified so as' to provide for custody and visitation as hereinafter described. 2. The parties desire that the Court enter an Order incorporating the terms of this Stipulation as a Custody Order in this matter. 3. As to the parties' minor son, Andrew L. Bliss, the parties shall continue to share legal custody of such child; Father shall enjoy primary physical custody of Andrew L. Bliss, subject to the following periods of temporary custody or visitation to be exercised by Mother: (a) On alternating weekends from Friday evening at 5:00 p.m. until Sunday evening at 5:00 p.m.; (b) Thursday evenings each week from 5:00 p.m. to 8 :00 p.m.; 4. As to the parties' daughter, Hillary S. Bliss, the parties shall continue to share legal custody of such child; Mother shall enjoy primary physical custody of Hillary S. Bliss, during the school year, subject to the following periods of temporary custody or visitation to be excercised by Father: