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HomeMy WebLinkAbout02-6187 SAIDIS SHUFF, FLOWER & LINDSAY ATTOP, I~Y$.AT*LAW 26 W. High Street Carlisle, PA MARSHA A. SADLER, Plaintiff, VS. RONALD L. SADLER, JR., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for the Plaintiff James D. Flower, Jr.,'h,F=Cquire ID # 27742 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA MARSHA A. SADLER, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. RONALD L. SADLER, JR., Defendant. D \ COMPLAINT MARSHA A. SADLER, Plaintiff, by her attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is MARSHA A. SADLER, who currently resides at 149 Cedar Street, Carlisle, Cumberland County, Pennsylvania, since October 1, 2002. 2. The Defendant is RONALD L. SADLER, JR., who currently resides at 931 North Middleton Road, Carlisle, Pennsylvania, since December 19, 1996. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on January 13, 1998, in Mount Holly Springs, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. SAIDIS SHUFF, FLOWER & LINDSAY AI'FORNEYS*AT.LAW 26 W. High Street Carlisle, PA 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. 8. Plaintiff requests the Court to enter a decree of divorce. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for the Plaintiff Date: ID # 27742 26 West High Street Carlisle, PA 17013 (717) 243-6222 3 SAIDIS SHUFF, FLOWER & LINDSAY ATrOP, I~YS.AT*LAW 26 W. High Street Carlisle, PA VERIFICATION I, MARSHA A. SADLER, hereby verify that the statements made in this Complaint 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. Section 4904, relating to unsworn falsification to authorities. Marsha A. Sadler Date: 4 MARSHA A. SADLER, Plaintiff, VS. RONALD L. SADLER, JR., Defendant. · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO.O~' d'/'~gVlL TERM IN CUSTODY PRAECIPE TO PROCEED IN FORMA PAUPERI,W To the Prothonotary: Kindly allow, MARSHA A. SADLER, the Plaintiff herein, to proceed in forma pauperis. I, JAMES D. FLOWER, JR., attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. SAIDIS SHUFF, FLOWER & LINDSAY .ATTORb~YS.AT.IAW 26 W. High Street Carlisle, PA SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for the Plaintiff James D. FIovCer, ~., Esquire ID Cf 27742 f~ 26 West High Street Carlisle, PA 17013 (717) 243-6222 MARSHA A. SADLER, Plaintiff, VS. RONALD L. SADLER, JR., Defendant. · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANI,~ · NO. CIVIL TERM · IN CUSTODY AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS SAIDIS SHUFF, FLOWER & LINDSAY ATrORNE~ 26 W. High Street Carlisle, PA 1. I am the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the actior or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: MARSHA A. SADLER Address: 149 Cedar Street, Carlisle, Pennsylvania 17013 (b) Social Security Number: 205-56-0224 If you are presently employed, state: Employer: Kelly Temporary Services Address: Carlisle PA Salary or wages per month: $132.00 gross/month Type of work: Telemarketing SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA If you are presently unemployed, state: Date of last employment: December 11,2002 Salary or wages per month: Type of work: Telemarketing (c) Other income within the past twelve months Business or profession: Other self-employment: Interest: Dividends: Pension and annuities: Social Security benefits: Support payments: Disability payments: Unemployment compensation and supplemental benefits: Workman's compensation: Public Assistance: Food stamps $435.00 / month Other: None (d) Other contributions to household support: Husband Name: If your husband/wife is employed, state: Employer: Salary or wages per month: $54.06 / week beginning November 23, 2002 SAIDIS SHIJFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA (f) (g) Type of work: Contributions from children: (e) Property owned: Cash: $5.00 Checking Account: $50.00 Savings Account: $15.00 Certificates of Deposit: Zero (0) Real Estate (including home): Zero (0) Motor vehicle: Make: Plymouth Voyager Cost: $10,200 Stocks; bonds: Other: Debts and obligations: Mortgage: Rent: $600.00 / month Loans: $155.00 / month Monthly Expenses: Persons dependent upon you for support: Husband Name: Children, if any: Name: Jacob Sadler Sarah Sadler Year: 1997 Amount owed: Approx. $6,000.00 Age: (22) months (8) years SAIDIS SHUFF, FLOWER & LINDSAY ATrORNEYS.AT"~-.-.-.-.-.-.~ 26 W. High Street Carlisle, PA 4. I understand that have a continuing obligation to inform the court of improvement in my financial c~rcumstances, which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: ,/'~-.,~'7'//_.) ,~ Marsha A. Sadler MARSHA A. SADLER PLAINTIFF go RONALD L. SADLER, JR. DEFENDANT IN THE COURT O17 COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ' N 02-6187 CIVIL ACTIO LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, January 09, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, January 29, 2003 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. All children age five or older may also be present at the conference.. Failure to apt>ear 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: Is~ ]acqueline M. Vern~, Esq. 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 JAN 31 MARSHA A. SADLER, Plaintiff VJ RONALD L. SADLER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-6187 CIVIL TERM : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this ~ rJ day of ~'F ~ ,o Z~ ,2003, upon consideration of the attached Custody Concilifiti~n Report, it'~s ordered and directed as follows: 1. The Mother, Marsha A. Sadler, and the Father, Ronald L. Sadler, Jr., shall have shared legal custody of Zachary Darwin Sadler, born July 18, 1990, Sarah Lynn Sadler, bom February 25, 1994 and Jacob Lee Sadler, bom February 9, 2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. Mother shall have primary physical custody of Sarah Lynn Sadler and Jacob Lee Sadler. 3. Father shall have primary physical custody of Zachary Darwin Sadler. 4. Both parents shall have periods of partial physical custody of the other child/children on an alternating weekend basis such that the children will spend every weekend together. Mother shall have the weekend of January 31, 2003. The times for the weekend shall be for Father from after school on Fridays~to Sundays at 6:30 p.m. The weekend times for Mother shall be from Friday at 6:00 p.m. to Sunday at 6:30 p.m. 5. The parties shall have such additional times with the children during the week as agreed by the parties. 6. The parties agree to cooperate in scheduling a doctor's appointment for Zachary to determine whether Zachary should go back on his medication. In the event that the doctor recommends that Zachary resume medication, then both parties agree to assure that Zachary takes his medication. 7. The parties agree to cooperate in the scheduling of counseling for the two older children to include family counseling if recommended by the Children's counselor. Both parties agree to sign releases so that both may receive information from the counselor and the counselor may speak to each parent concerning the Children. 8. Both parties agree to schedule and attend a Parent Works program suitable to their individual situation regarding Parenting, anger or separation. 9. Transportation shall be shared such that Father shall pick up the children from school on his Fridays. Mother shall pick up the Children on her Fridays and will always transport on Sundays. Transportation during the week shall be as agreed by the parties. 10. In the event either party wishes to leave the jurisdiction, they shall notify the other party and provide a telephone number and address where the Children can be reached. 11. Neither parent shall do or say or permit third parties to do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. 12. 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 consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for Thursda A ril 24 2003 at 9:30 a.m. BY THE COURT~//~ cc: James D. Flower, Jr., Esquire, Counsel for Mother Ronald L. Sadler, pro se 931 North Middleton Rd. Carlisle, PA 17013 MARSHA A. SADLER, Plaintiff Ve RONALD L. SADLER, JR., Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 2002-6187 CIVIL TERM : : CIVIL ACTION -iLAW : : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, thc undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME Zachary Darwin Sadler Sarah Lynn Sadler Jacob Lee Sadler DATE OF BIRTH CURRENTLY IN CUSTODY OF July 18, 1990 Father February 25, 1994 Mother February 9, 2001 Mother 2. A Conciliation Conference was held in this matter on January 29, 2003, with the following individuals in attendance: The Mother, Marsha A. Sadler, with her counsel, James D. Flower, Jr., Esquire, and the Father, Ronald L. Sadler, Jr., pro se. 3. The parties agreed to entry of an Order in the form as attached. Date mey, Esquire Custody Conciliator RONALD L. SAOt-ER, JR., dant ~ .. bet 3~, 2002- · , as tired on De~m ' . - { 3301 {c~ o~ t~e ONo~ce co6e ~ n an~ nineW . ~ r. omp~tnt in ONo~ce unOe~ .... ~ant ~s it~etfie~ab~ broke .... ues~ · -~ oi p~nt~ .~"~.~o~tnt .... o~ notice u, ,, MARSHA A. SADLER, Plaintiff, vs. RONALD L. SADLER, JR., Defendant. iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-6187 CIVIL AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301 (c) of the Divorce Code was filed on December 31, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit 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 ~.C.S. 4904 relating to unsworn falsification to authorities. Marsha A. Sadler, Plaintiff Date: SAIDIS SHUFF, FLOWER & LINDSAY ATro~S*AT.LAW 26 W. High Street Carlisle, PA WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit 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. 4904 relating to unsworn falsification to authorities. Marsha A. Sadler,~Plaintiff Date: SAIDIS SHUFF, FLOWER & LINDSAY A~rOPd~S.AT.LAW 26 W. High Street Carlisle, PA Ir' ---I" Postage I'~ Ce~ified Fee Return Receipt Fee (Endorsement Required) C:3 Restricted Delivery Fee r-'l (Endorsement Required) t,--I Total Postage & Fees r-'-i · Complete items 1, 2, and 3. Also complete Item 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 mail or on the front if space permits 1. Article Addressed to: / [] Addresese Pr/nted Name) J C. Date of Delive~ I ~,~LIs'de~tve~ address different from item 17 [] Yes i~_'~YE,,S, enter delivery address below: [] No ~ertified Mail [] Express Mail ~.{~] Registered ~etum Receipt for Merchandtes [] Insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) E~es (Transfer from service label) PS Form 3811, August 2001 Domestic R®tum Receipt 102ses-02-~-oe3s H106,1b'7 REV. Cumberland DI CE OR ANN E ' (CHECK ONE) STATE FILE NU~i.~ ~TAT'E FILE DATE HUSBAND --------- Ron'' (~u)---'----- (t.,0 · n,v= ....... -----_ ttonam L. Sa s. a~ ~ ~ dler, Jr: - ~~d~eton Ro~ C~lisle . Flo~ Mill - Packer~oader McLm ' Marsha A S ~lso~, Lot ~26 C~lisle mberl~d p~' ~ nu~ C Pe~ 24. ~TURE OF ~I~NG CL~ MARSHA A. SADLER, Plaintiff Ve RONALD L. SADLER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-6187 CIVIL TERM : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this ~2~t, day of U/t ~9 ~ ,2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The prior Order of Court dated February 3, 2002 shall remain in full force and effect with the following modifications: 2. Paragraph 4 is amended to provide for the children to be returned at 6:00 p.m. on Sundays. 3. Paragraph 5 is deleted and replaced with the ibllowing: Father shall have physical custody of Sarah and Jacob every Wednesday from after school/daycare until 8:30 p.m. Mother shall have physical custody of Zachary every Wednesday from after school to 8:30 p.m. 4. Paragraph 6 is deleted and replaced with the following: Mother agrees to provide Father with a copy of the Gateway insurance card. Upon receipt of the insurance card and confirmation that the prescription is still valid, Father will pick up Zachary's prescription. Both parties agree to assure that Zachary takes his medication as prescribed. 5. Paragraph 7 is deleted and replaced with the following: It is acknowledged that Mother has initiated counseling for Sarah at the Stevens Center. Father shall initiate (call for intake) counseling for Zachary at the Stevens Center within seven days from receipt of the Gateway insurance card with. a goal toward family counseling with both children and parents. Both parties agree to sign releases so that both may receive information from the counselor and the counselor may speak to each parent concerning both children. 6. Paragraph 8 is deleted in its entirety. 7. Paragraph 9 is deleted and replaced with the following: Transportation shall be shared. Except when the parties pick up the children from school or daycare, they shall exchange the children at the Carlisle Borough Police Department parking lot. Order. The parties agree to strictly abide by and enforce Paragraph 11 of the prior o parties. Neither parent will permit physical discipline of the children by third 10. Neither party will drink and drive with the children in the vehicle nor permit third parties to drink and drive with the children in the vehicle. 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 consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for Thursday, August 7, 2003 at 8:30 a.m. Jo cc: James D. Flower, Jr., Esquire, Counsel for Mother Marylou Matas, Esquire, Counsel for Father ~ ~ o</3- o~3 MARSHA A. SADLER, Plaintiff Vo RONALD L. SADLER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 2002-6187 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J 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 information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Zachary Darwin Sadler July 18, 1990 Father Sarah Lynn Sadler February 25, 1994 Mother Jacob Lee Sadler February 9, 2001 Mother 2. A Conciliation Conference was held in this matter on May 8, 2003, with the following individuals in attendance: The Mother, Marsha A. Sadler, with her counsel, James D. Flower, Jr., Esquire, and the Father, Ronald L. Sadler, Jr., with his counsel Marylou Matas, Esquire. 3. A prior Order of Court was entered by the Honorable J. Wesley Oler, Jr. dated February 3, 2003 providing for shared legal custody and Mother having primary physical custody of the two younger children and Father having primary physical custody of the older child, with the parties having alternating weekends so that all three children will be together on weekends. 4. The parties agreed to entry of an Order in the form as attached. Date .i iea o y,Esquire Q SAIDIS SHUFF, FLOWER & LINDSAY ATrORI~YS.AT.LAW 26 W. High Street Carlisle, PA MARSHA A. SADLER, Plaintiff, VS. RONALD L. SADLER, JR., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-6187 CIVIL AFFIDAVIT OF (;;ONSENT 1. A Complaint in Divorce under § 3301 (c) of the Divorce Code was filed on December 31,2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit 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. 4904 relating to unsworn falsification to authorities. Ronald L. Sadler, Jr., Defendant Date: WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER {}3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit 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. 4904 relating to unsworn falsification to authorities. ~Jr., Defendant Date: ~_18/~3 IN THE COURT OF CC~4ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARSHA A. SADLER, NO. 02-6187 CIVIL Plaintiff, vs. RONALD L. SADLER, JR. , Defendant. PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following informationl to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c) ~Xkd~ of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: January 3~ 2003~ by certified mail, return receipt requested~ deliver to addressee only 3. Complete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff April 7~ 2003 by the defendant May 8, 2003 B. (1) Date of execution of the plaintiff's affidavit requJn-~ed by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: None 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(1)(i) of the Divorce Code ~/Jam~s D' Flower, Jr., Esquire IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF ~~ PENNA. MARS~A A. SADLER Plaintiff, VERSUS RONALD L. SADLER, JR. Defendant. NO. 02-6187 CIVIL DECREE IN DIVORCE AND NOW, DBCREED THAT AND June /3~ , 2003 MARSHA A. SADLER RONALD L. SADLER, JR. , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YEt BEEN ENTERED; None MARSHA A. SADLER, Plaintiff VS. RONALD L. SADLER, JR., Defendant 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-6187 CIVIL TERM CIVIL ACTION - LAW : 1N CUSTODY PETITION FOR CONTEMPT OF CUSTODY Your Petitioner is the above named Defendant, Ronald L. Sadler, Jr., an adult individual currently residing at 931 North Middleton Road, Carlisle, Cumberland County, Pennsylvania. 2. Your Respondent is the above named Plaintiff, Marsha A. Sadler, an adult individual currently residing at 149 Cedar Street, Carlisle, Cumberland County, Pennsylvania. o The pmties are the natural parents of three children, namely, Zachary Darwin Sadler, bom July 18, 1990, Sarah Lyn Sadler, bom February 25, 1994, and Jacob Lee Sadler, bom February 9, 2001. The parties are subject to an Order of Court, dated May 12, 2003, a copy of said Order being attached hereto and incorporated herein by reference as Exhibit "A", and an Order of Court, dated February 3, 2002, a copy of said Order being attached hereto and incorporated herein by reference as Exhibit "B." 5. Since the entry of the aforesaid Orders, the children have continued to reside in Cumberland County thus providing this Court with ongoing jurisdiction. Since the entry of the aforesaid Orders, the child, Zachary, has continued to reside primarily with Petitioner and the children, Sarah ami Jacob, have continued to reside primarily with Respondent. Since the entry of the aforesaid Orders, Respondent repeatedly has failed to share transportation in that she has refused to meet Petitioner at the Carlisle Borough Police Department parking lot for custody exchanges. On or about May 1, 2003, Respondent did not appear at the Carlisle Borough Police Department for the scheduled custody exchange, foming Petitioner to drive the children to her home. On or about June 4, 2003, Respondent did not appear at the Carlisle Borough Police Department for the scheduled custody exchange, forcing Petitioner to drive the children to her home. 10. On or about June 15, 2003, Respondent did not appear at the Carlisle Borough Police Department for the scheduled custody exchange, forcing Petitioner to drive the children to her home. 11. In June 2003, Respondent directed third parties to take the minor child, Zachary, to Petitioner's home, while Petitioner waited at the designated exchange point. 12. Since the entry of the aforesaid Orders, Respondent has failed to strictly abide by and enforce paragraph 11 of the February 3, 2002, Order in that Respondent has said and has permitted third parties to do or so say things which may estrange the children from Petitioner, injure the opinion of the children as to Petitioner, and hamper the free and natural development of the children's love and respect for Petitioner. 13. Respondent and her live-in boyfriend repeatedly refer to Petitioner as "fat bastard" in front of the children. 14. On or about July 6, 2003, Respondent's boyfriend refcrred to Petitioner as "fat bastard", yelled obscenities, and threatened to "blow his head off", while referring to Petitioner, during a telephone conversation between Petitioner and the minor child, Zachary, while he was in Respondent's custody. 15. Respondent's boyfriend repeatedly uses racial slurs when referring to Petitioner in front of the children. 16. Respondent's boyfriend repeatedly has threatened to harm the life of the children and Petitioner in front of the children. 17. Since the entry of the aforesaid Orders, Respondent has permitted physical discipline of the children by a third party, specifically allowing her live-in boyfriend to physically discipline the children, Zachary and Sarah. 18. The minor child, Sarah, reported to Petitioner that Respondent's boyfriend paddled her on or about late May, 2003. 19. Since the entry of the aforesaid Orders, Respondent l~tas permitted a third party to drink and drive with the children in the vehicle. 20. Since the entry of the aforesaid Orders, Respondent has removed the oldest child, Zachary, from Petitioner's primary physical custody and refused to return him to Petitioner. 21. On July 1, 2003, Respondent picked up the minor child, Zachary, from Petitioner's residence and restrained him to her physical custody through Sunday, July 6, 2003, without Petitioner's permission, at which time Petitioner was able to regain custody of the child. 22. Petitioner was obligated to secure counsel to prepare and file the enclosed Petition for Contempt and has incurred attorney's fees and costs in doing so. 23. It is the in the best interest and permanent welfare of the children to provide Petitioner with additional periods of physical custody of the children to make up the time periods he has lost due to Respondent's contempt. 24. It is in the best interest and permanent welfare of the children to Order Respondent to attend and complete anger management and parenting classes. 25. It is in the best interest and permanent welfare of the children to Order Respondent to restrict contact between her boyfriend, Sam, and the children. 26. It is in the best interest and permanent welfare of the children to find Respondent in contempt of the Orders dated May 12, 2003 and February 3, 2002, and to hold Respondent responsible for Petitioner's attorney's fees, and costs accrued in this matter. WHEREFORE, Petitioner requests your Honorable Court to schedule a Custody Conciliation Conference, at which time an Order should be entered providing him with the following: A. Additional periods of physical custody of the children; B. A finding of contempt against Respondent of the Orders of Court; C. Imposing costs and fees upon Respondent; D. Ordering Respondent to attend anger management and parenting classes; and E. Restricting contact between Respondent's boyfriend and the children. Respectfully submitted, mar~atas, Esq~re GRIFFI,F~-& ASSOCIATES 200 N. Hanover Street Carlisle, PA 17013 (717) 243-5551 I verify that the statements made in this Complaint are trae and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. i~NALD L. S~DLER, JR.~ flAY 0 § 2003 MARSHA A. SADLER, Plaintiff RONALD L. SADLER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-6187 CIVIL TERM : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, tiffs f,2 - day of )]4.~- consideration of the attached Custody Conciliation Report, folIows: ,2003, upon it is ordered and directed as 1. The prior Order of Court dated February 3, 2002 shall remain in full force and effect with the following modifications: 2. Paragraph 4 is amended to provide for the children to be returned at 6:00 p.m. on Sundays. 3. Paragraph 5 is deleted and replaced with the following: Father shall have physical custody of Sarah and Jacob every Wednesday from after school/daycare until 8:30 p.m. Mother shall have physical custody of Zachary every Wednesday from after school to 8:30 p.m. 4. Paragraph 6 is deleted and replaced with the following: Mother agrees to provide Father with a copy of the Gateway insurance card. Crpon receipt of the insurance card and confirmation that the prescription is still valid, Father will pick up Zachary's prescription. Both parties agree to assure that Zachary takes ibis medication as prescribed. 5. Paragraph 7 is deleted and replaced with the ~bllowing: It is ackmowledged that Mother has initiated counseling for Sarah at the Stevens Center. Father shall initiate (call for intake) counseling for Zachary a'I the Stevens Center within seven days from receipt of the Gateway insurance card with a goal toward fmnily counseling with both children and parents. Both parties agree to sign releases so that both may receive information from the counselor and the counselor may speak to each parent concerning both children. 6. Paragraph 8 is deleted in its entirety. 7. Paragraph 9 is deleted and replaced with the following: Transportation shall be shared. Except when the parties pick up the childrert from school or daycare, they shall exchange the children at the Carlisle Borough Police Depa~1ment parking lot. Order. The parties agree to strictly abide by and enforce Paragraph 11 oftbe prior parties. Neither parent will permit physical discipline of the children by third 10. Neither party will drink and drive with the children in the vehicle nor permit third parties to drink and drive with the children in the vehicle. 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 consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for Thursday. August 7. 2003 at 8:30 a.m. BY THE COURT, ~/ / , / J. cc: James D. Flower, Jr., Esquire, Com~sel for Mother Marylou Matas, Esquire, Counsel for Father MARSHA A. SADLER, Plaintiff V. RONALD L. SADLER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2002-6187 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J 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 information concerning the Chilqren who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY 1N CUSTODY OF Zachary Darwin Sadler Sarah Lynn Sadler Jacob Lee Sadler July 18, 1990 February 25, 1994 February 9, 2001 Father Mother Mother 2. A Conciliation Conference was held in this matter on May 8, 2003, with the following individuals in attendance: The Mother, Marsha A. Sadler, with her counsel, James D. Flower, Jr., Esquire, and the Father, Ronald L. Sad]er, Jr., with his counsel Marylou Matas, Esquire. 3. A prior Order of Court was entered by the Honorable J. Wesley Oler, Jr. dated February 3, 2003 providing for shared legal custody and Mother having primary physical custody of the tx,co younger children and Father having primary physical custody of the older child, with the parties having alternating weekends so that all tkree children will be together on weekends. 4. The parties agreed to entry Of an Order in the form as attached. Date J~cq~line M. Vemey, Esquire Custody Conciliator · . JAN 31 ~DO3 ~ MARSHA A. SADLER, l'laintiff RONALD L. SADLER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-6187 CIVIL TERM : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this .$.,d.. day of .f~ ,2003. upon consideration of the attached Custody Conciliation R/eport, it is ordered and directed as follows: 1. The Mother, Marsha A. Sadler, and the Father, Ronald L. Sadler, Jr., shall have shared legal custody of Zachary Darwin Sadler, bom July 18, 1990, Sarah Lynn Sadler, born February 25, 1994 and Jacob Lee Sadler, born February 9, 2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including,. but not limited to, all decisions regarding their health, education and 'religion. 2. Mother shall have primaW physical custody of Sarah Lynn Sadler and Jacob Lee Sadler. 3. Father shall have primat'y physical custody of Zachary Darwin Sadler. 4. Both parents shall have periods of partial physical custody of the other child/children on att alternating weekend basis such that the children will spend every weekend together. Mother shall have the weekend of January 31,2003. The times for the weekend shall be for Father fi'om after school on Fridays to Sundays at 6:30 p.m. The weekend times for Mother shall be from Friday at 6:00 p.m. to Sunday at 6:30 p.m. 5. The parties shall have such additional times with the children during the week as agreed by the parties. ~' 6. The parties agree to cooperate in scheduling a doctor's appointment tbr Zachary to determine whether Zachary should go back on his raedication. In the event that the doctor recommends that Zachary resume medication, then both parties agree to assure that Zachary takes his medication. The parties agree to cooperate in the scheduling of counseling ibc the two older children to include family counseling if recommended by the Children's counselor. Both parties agree to sign releases so that both may receive infiormation from tim ct)unsclor and thc couaselor may speak to each parent concerning the Children. 8. Both parties agree to schedule and attend a Parent Works program suitable to their individual situation regarding parenting, anger or separation. 9. Transportation shall be shared such that Father shall pick up tile children fi'Oln school on his Fridays. Mother shall pick up the Children oil her Fridays and xvill always transport on Sundays. Transportation during the week :shall be as agreed by the parties. 10. in the event either party wishes to leave the jurisdiction, they shall notify the other party and provide a telephone number and address where the Children can be reached. 11. Neither parent shall do or say or permit third pa:tties to do or say anything which may estrange the Children fi'om the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect lbr the other parent. l 2. 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 consent. In the absence of mutual consent, the temps of this Order shall control. Another Conciliation Conference is scheduled for Thursday, April 24. 2003 at 9:30 a.m. BY THE COURT, / / r / cc: James D. Flower, Jr., Esquire, Counsel for Mother Ronald L. Sadler, pro se 931 North Middleton Rd. Carlisle, PA 17013 MARSIIA A. SADLER, Plaintiff Mo RONALD L. SADLER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 2002-6187 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY I'RIOR JUDGE: None 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 information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Zad~ary Darwin Sadler Sarah Lynn Sadler Jacob Lee Sadler July 18,1990 February 25, 1994 February 9,2001 Father Mother Mother 2. A Conciliation Conference was held in this matter on January 29, 2003, with the following individuals in attendance: The Mother, Marsha A. Sadler, with her counsel, James D. Flower, Jr., Esquire, and the .Father, Ronald L. Sadler, Jr., pro se. 3. The parties agreed to entry of an Order in the form as attached. Date ~cq~line M. Verney, Esquire Custody Conciliator MARSHA A. SADLER, Plaintiff VS. RONALD L. SADLER, JR., Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-6187 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CERTIFICATE OF SERVICE I, Marylou Matas, Esquire, hereby certify that I did, the 16th day of July, 2003, cause a copy of Defendant's Petition for Contempt to be served upon Plaintiff's attorney of record by facsimile and first class mail, postage prepaid at the following addresses: James D. Flower, Jr., Esquire.. 26 West High Street Carlisle, PA 17013 Facsimile # (717) 243-6486 DAVE: "]//~ / 0~,~ Mar~loff~atas, Esquire Attorn~ffr Defendant GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243 -5551 (800)347-5552 MARSHA A. SADLER PLAIN~FF V. RONALDL. SADLER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-6187 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, July 18, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before _Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, July 17, 2003 at 9:30 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 del'me 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 l~resent at the conference. Failure to al:r~ear 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 hearinl~. FOR THE COURT, By: /s/ facqueline M. Verney. Esq. 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 hear/ng. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATI'ORNEY 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 MARSHA A. SADLER, Plaintiff V. RONALD L. SADLER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002-6187 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this ~. { $~ day of ~ ~ { "~ consideration of the attached Custody Conciliation Report, follows: ,2003, upon it is ordered and directed as 1. A Hearing is scheduled in Court Room No. /t , of the Cumberland County Court House, on the ~j day of O-~f~/~, ,2003, at ~ o clock, ~ . M., at which tinge testimony will betaken. For purposes of this Hearing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least ten days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the prior Orders of Court dated May 12, 2003 and February 3, 2002 shall remain in full force and effect with the following additions: 3. Both parties shall explore the possibility of a custody evaluation and cooperate with scheduling and attending appointments if one is initiated. 4. Both parties shall obtain anger management counseling. 5. Father shall cooperate with and not interfere with Zachary's counseling. If requested, both parties shall participate in Zachary's and Sarah's counseling. house. Father shall not have in his possession a gun when or if he is at Mother's 7. All custody exchanges shall occur within 30 minutes of the designated time. Neither party need to wait longer than 30 minutes of the designated exchange time. In the event that custody is not exchanged due to a party's tardiness, said times shall be made up by the parties. 8. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, J~esl~y Oler, ~, . cc:~es D. Flower, Jr., Esquire, counsel for Mother .~ylou Matas, Esquire, counsel for Father MARSHA A. SADLER, Plaintiff V. RONALD L. SADLER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2002-6187 CIVIL TERM ._ : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. 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 information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Zachary Darwin Sadler Sarah Lynn Sadler Jacob Lee Sadler July 18, 1990 February 25, 1994 February 9, 2001 Father Mother Mother 2. A Conciliation Conference was held July 17, 2003 with the following individuals in attendance: The Mother, Marsha A. Sadler, with her counsel, James D. Flower, Jr., Esquire, and the Father, Ronald L. Sadler, Jr., with his counsel, Marylou Matas, Esquire. 3. The Honorable J. Wesley Oler, Jr. previously entered Orders of Court on February 3, 2002 and May 12, 2003. The parties share legal custody of the Children. Mother has primary physical custody of Sarah and Jacob; Father has primary physical custody of Zachary. The parties have alternating weekends wherein they have all three Children at the same time. 4. Father filed a Contempt Petition on July 16, 2003. Mother intends to file a Contempt Petition shortly. Her allegations of contempt were considered at the conciliation conference. None of the Contempt issues were resolved at the conference and should be heard by the Court. 5. Mother's position on custody is as follows: Mother seeks shared legal and primary physical custody of all three Children. Mother asserts that the Children have friends in the neighborhood at her home. She maintains that while Zachary is at his Father's he has no playmates. While Father is working, Zachary is alone. Zachary has been diagnosed with depression and is prescribed medication. Because there has been a lapse in insurance, Father has not purchased the prescribed medication for Zachary. There ahs been problems with the transfer of custody. Mother claims Father has a loaded gun in the car when custody transfers occur. Mother is willing to cooperate with a custody evaluation but has limited or no funds to pay for an evaluation. 6. Father's position on custody is as follows: Father seeks shared legal custody and primary physical custody of all three Children. Father asserts several violations of the Court Orders: Mother's boyfriend has physically disciplined Sarah in violation of the Court Order. Father maintains that Mother and third parties disparage Father to the children, calling him names. Father claims that Mother took Zachary for a week in violation of the Court Order. Father further acknowledges problems with the transfer of custody citing Mother as the problem. Father is willing to cooperate with a custody evaluation, but has limited or no funds to pay for the evaluation. 7. The Conciliator asks the Court to consider paying for a custody evaluation or a portion thereof. 8. The Conciliator recommends an Order in the form as attached scheduling a Heating and maintaining the status quo with additional protective provisions. It is expected that the Hearing will require one day. Date ffacqu~ine M. Vemey, Esquire Custody Conciliator MARSHA A. SADLER, Plaintiff VS. RONALD L. SADLER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-6187 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY PETITION TO WITHDRAW AS COUNSEL AND NOW, comes Petitioner, Marylou Matas, Esquire, and the law finn of Griffie & Associates and petitions the Court as follows: 1. Your Petitioner is counsel of record in the above-captioned action for Defendant, Ronald L. Sadler, Jr. 2. Your Respondent is Ronald L. Sadler, Jr., an adult individual currently residing at 931 North Middleton Road, Carlisle, Cumberland County, Pennsylvania. 3. The above-named Plaintiff, Marsha A. Sadler, is represented by James D. Sadler, Jr., Esquire. 4. A hearing is scheduled for October 9, 2003, at 9:30 a.m., in Courtroom No. 1 of the Cumberland County Courthouse. 5. Since Petitioner received notice of the hearing, she has been unable to secure any type of response from Respondent relative to the need to provide an appropriate retainer for these proceedings and relative to information needed to be provided in order to prepare the required Pre-Thai Memorandum in this matter. 6. Respondent has been advised that if the required retainer is not paid and information is not provided to prepare the Pre-Trial Statement, Petitioner would not be able to provide additional services in this matter. 7. Despite providing Respondent with advance notice of his need to respond to Petitioner and his responsibility in these proceedings, Respondent has failed and refused to provide the required retainer and the necessary information to proceed in this matter. 8. Petitioner is unable to take any additional action to proceed on behalf of the Respondent due to his failure to provide information and the required retainer to Petitioner. WHEREFORE, Petitioner requests your Honorable Court to enter a Rule upon the Respondent, Ronald L. Sadler, Jr., to Show Cause, if any he has, as to why Petitioner should not be permitted to withdraw as counsel in the above-captioned matter. Respectfully submitted, Date Marylo(~vlatas, Esquire GRIFFiE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document am true and correct. I understand that false statements heroin are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsifications to authorities. Maryi'oa ~atas, Esquire MARSHA A. SADLER, Plaintiff VS. RONALD L. SADLER, JR., Defendant : IN THE COURT ,OF COMMON PLEAS OF flCT 0 2 7003 : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-6187 ,CIVIL TERM : CIVIL ACTION -- LAW : : IN CUSTODY ORDER OF COURT AND, RULE TO SHOW CAUSE AND NOW, this [~¢day of ~')[~"~z~ ['*t'~ 2003, upon presentation and consideration of the within Petition, a Rule is hereby issued upon the Respondent, Ronald L. Sadler, Jr., to Show Cause, if any he has, as to why Petitioner., Marylou Matas, Esquire, and the law firm of Griffie & Associates should not be permitted to withdraw as counsel in the above- captioned matter. Rule returnable 143 days after service by first-class mail, postage prepaid upon Respondent at his last known address. Cc; ~lou Matas, Esquire ~onald Petitioner~Attorney for Defendant L. Sadler Respondent ~aames D. Flower, Jr., Esquire Attorney for Plaintiff By the Court, MARSHA A. SADLER, Plaintiff, VS. RONALD L. SADLER, JR., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-6187 CIVIL IN CUSTODY PETITION FOR CONTEMPT SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA AND NOW, comes Petitioner, MARSHA A. SADLER, through her attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, and represents the following: 1. Petitioner is MARSHA A. SADLER, an adult individual, residing at 74 Betty Nelson Court, Lot 126, Carlisle, Pennsylvania 17013. 2. Respondent is RONALD L. SADLER, JR., an adult individual, residing at 931 North Middleton Road, Carlisle, Pennsylvania 17013. 3. The parties are the parents of three children, ZACHARY DARWIN SADLER, born July 18, 1990; SARAH LYNN SADLER, born February 25, 1994; and JACOB LEE SADLER, born February 9, 2001. 4. The parties are subject to an Order of Court dated May 12, 2003, a copy of which is attached hereto as Exhibit "A", and an Order of Court dated February 3, 2003, a copy of which is attached hereto as Exhibit "B". 5. The parties and the children all continue to reside in Cumberland County, Pennsylvania. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA 6. Since the entry of the aforesaid Orders, Respondent has had primary physical custody of ZACHARY DARWIN SADLER, and Petitioner has primary physical custody of SARAH LYNN SADLER and JACOB LEE SADLER. 7. Since the entry of the aforesaid Orders, Respondent has been in violation of those Orders for the following reasons: The aforesaid Orders provided that both parties would agree to assure that ZACHARY DARWIN SADLER takes his medication, and that Respondent would initiate counseling for ZACHARY at The Stevens Center, within seven days following receipt of insurance cards. Respondent has failed to follow through with counseling for ZACHARY at The Stevens Center, and has failed to provide him with medication. Furthermore, Respondent continues to denigrate Petitioner in the presence of the children. 8. This custody action is scheduled before the Honorable J. Wesley Oler at 9:30 a.m., on October 9, 2003, and Petitioner requests that the Petition be heard at that time. WHEREFORE, Petitioner requests that Respondent be found to be in contempt of Court for the foregoing violation of the applicable Court Orders. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff Date: /~- ~-(~ 3 James D. Flower, Jr. (/' 26 West High Street ',/ Carlisle, PA 17013 (717) 243-6222 I.D. No. 27742 MAY 1 2003 MAY ()g MARSHA A. SADLER, Plaintiff RONALD L. SADLER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-6187 CIVIL TERM : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this /~ day of ~ consideration of the attached Custody Conciliation Report, follows: ,2003, upon it is ordered and directed as 1. The prior Order of Court dated February 3, 2002 shall remain in full force and effect with the following modifications: 2. Paragraph 4 is amended to provide for the children to be returned at 6:00 p.m. on Sundays. 3. Paragraph 5 is deleted and replaced with the following: Father shall have physical custody of Sarah and Jacob every Wednesday from after school/daycare until 8:30 p.m. Mother shall have physical custody of Zachary every Wednesday from after school to 8:30 p.m. 4. Paragraph 6 is deleted and replaced with the following: Mother agrees to provide Father with a copy of the Gateway insurance card. Upon receipt of the insurance card and confirmation that the prescription is still valid, Father will pick up Zachary's prescription. Both parties agree to assure that Zachary takes his medication as prescribed. 5. Paragraph 7 is deleted and replaced with the following: It is acknowledged that Mother has initiated counseling for Sarah at the Stevens Center. Father shall initiate (call for intake) counseling for Zachary at the Stevens Center within seven days from receipt of the Gateway insurance card with a goal toward family counseling with both children and parents. Both parties agree to sign releases so that both may receive information from the counselor and the counselor may speak to each parent concerning both children. 6. Paragraph 8 is deleted in its entirety. 7. Paragraph 9 is deleted and replaced with the following: Transportation shall be shared. Except when the parties pick up the children from school or daycare, the3' shall exchange the children at the Carlisle Borough Police Department parking lot. Order. The parties agree to strictly abide by and enforce Paragraph 11 of the prior parties. Neither parent will permit physical discipline of the children by third 10. Neither party will drink and drive with the children in the vehicle nor permit third parties to drink and drive with the children in the vehicle. 1 I. 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 consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for Thursday. Aueust 7. 2003 at 8:30 a.m. BYTHECOURT, cc: James D. Flower, Jr., Esquire, Counsel for Mother Marylou Matas, Esquire, Counsel for Father lrRUE COPY FROM RECORO In Tc~t!rn0ny whereof, I here ur, to en~ ~.h~ s~al of ~aid Court at C~i~, MARSHA A. SADLER, Plaintiff V. RONALD L. SADLER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2002-6187 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J 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 information conceming the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Zachary Darwin Sadler Sarah Lynn Sadler Jacob Lee Sadler July 18, 1990 February 25, 1994 February 9, 2001 Father Mother Mother 2. A Conciliation Conference was held in this matter on May 8, 2003, with the following individuals in attendance: The Mother, Marsha A. Sadler, ~Sth her counsel, James D. Flower, Jr., Esquire, and the Father, Ronald L. Sadler, Jr., with his counsel Marylou Matas, Esquire. 3. A prior Order of Court was entered by the Honorable J. Wesley Oler, Jr. dated February 3, 2003 providing for shared legal custody and Mother having primary physical custody of the two younger children and Father having primary physical custody of the older child, with the parties having alternating weekends so that all three children will be together on weekends. 4. The parties agreed to entry of an Order in the form as attached. Date Custody Conciliator MARSHA A. SADLER, l'hfintiff RONALD L. SADLLR, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL\:ANIA : NO. 2002-6187 CIVIL TERM : CIVIL ACTION- LAW : IN CUSTODY ORDER OF COURT AND NOW, this ~2.~4 day of .ff..og~ .... , ,2003. upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Marsha A. Sadler, and the Father, Ronald L. S'adl er, Jr., shall have shared legal custody of Zachary Darwin Sadler, born July 18, 1990, Sarah Lynn Sadler, born February 25, 1994 and Jacob Lee Sadler, born February 9, 2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including; but not limited to, all decisions regarding their health, education and religion. 2. Mother shall have primary physical custody of Sarah Lynn Sadler and Jacob Lee Sadler. 3. Father shall have primary physical custody of Zachary Darwin Sadler. 4. Both parents shall have periods of partial physical custody of the other child/chilch'en on an alternating weekend basis such that the children will spend every weekend together. Mother shall have the weekend of January 31, 2003. The times for the weekend shall be for Father fi'om after school on Fridays to Sundays at 6:30 p.m. The weekend times for Mother shall be from Friday at 6:00 p.m. to Sunday at 6:30 p.m. 5. The parties shall have such additional times with the children during the week as agreed by the parties. 6. The parties agree to cooperate in scheduling a doctor's appointmem for Zachary to determine whether Zachary should go back on his medication. In the event that the doctor recommends that Zachary resume medication, then both parties agree to assure that Zachary takes his medication. 7. The parties agree to cooperate in the scheduling of counseling lbr the two older children to include family counseling if recommended by the Children's counselor. b~th pardcs agrcc to sign releases so that both may receive iafom~ation l¥om thc counsck}r amd thc counst:lor may speak to each parent concerning the Children. Both parties agree to schedule and attend a Parent Works program suitable to their indMdual situation regarding parenting, anger or separation. 9. Transportation shall be shared such that Father shall pick up the children from school on his Fridays. Mother shall pick up the Children on her Fridays and will always transport on Sundays. Transportation during the week shall be as agreed by the parties. 10. in the event either party wishes to leave the jurisdiction, they shall notify the other party and provide a telephone number and address where the Children can be reached. 11. Neither parch; shall do or say or permit third pm'ties to do or say anything which may estrange the Clxildren from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural developmeat of the Children's love and respect for the other parent. 12. 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 consent. In the absence of mutual consent, the tern'ts of this Order shall con~rol. Another Conciliation Conference is scheduled for Thursday. ACril 24. 2003 at 9:30 a.m. BY THE COURT, cc: James D. Flower, Jr., Esquire, Core, scl for Mother Ronald L. Sadler, pro se 931 No;da Middleton Rd. Carlisle, PA 17013 MARSIIA A. SADLER, l'laintiff V. RONALD L. SADLER, JR., Defendant I'I{IOR JUDGE: None IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2002-6187 CIVIL TERM CIVIL ACT1ON - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 19I 5.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURP~ENTLY IN CUSTODY OF Zachary Darwin Sadler Sarah Lynn Sadler Jacob Lee Sadler July 18, 1990 February 25, 1994 February 9, 2001 Father Mother Mother 2. A Conciliation Conference was held in this matter on January 29, 2003, with the following individuals in attendance: The Mother, Marsha A. Sadler, with her counsel, James D. Flower, Jr., Esquire, and the Father, Ronald L. Sadler, Jr., pro se. 3. The parties agreed to entry of an Order in the form as attached. Date bficq~line M. Vemey, Esquire Custody Conciliator MARSHA A. SADLER, Plaintiff, VS. RONALD L. SADLER, JR., Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-6187 CIVIL IN CUSTODY PETITION FOR CONTEMPT SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA AND NOW, comes Petitioner, MARSHA A. SADLER, through her attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, and represents the following: 1. Petitioner is MARSHA A. SADLER, an adult individual, residing at 74 Betty Nelson Court, Lot 126, Carlisle, Pennsylvania 17013. 2. Respondent is RONALD L. SADLER, JR., an adult individual, residing at 931 North Middleton Road, Carlisle, Pennsylvania 17013. 3. The parties are the parents of three children, ZACHARY DARWIN SADLER, born July 18, 1990; SARAH LYNN SADLER, born February 25, 1994; and JACOB LEE SADLER, born February 9, 2001. 4. The parties are subject to an Order of Court dated May 12, 2003, a copy of which is attached hereto as Exhibit "A", and an Order of Court dated February 3, 2003, a copy of which is attached hereto as Exhibit "B". 5. The parties and the children all continue to reside in Cumberland County, Pennsylvania. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA 6. Since the entry of the aforesaid Orders, Respondent has had primary physical custody of ZACHARY DARWIN SADLER, and Petitioner has primary physical custody of SARAH LYNN SADLER and JACOB LEE SADLER. 7. Since the entry of the aforesaid Orders, Respondent has been in violation of those Orders for the following reasons: The aforesaid Orders provided that both parties would agree to assure that ZACHARY DARWIN SADLER takes his medication, and that Respondent would initiate counseling for ZACHARY at The Stevens Center, within seven days following receipt of insurance cards. Respondent has failed to follow through with counseling for ZACHARY at The Stevens Center, and has failed to provide him with medication. Furthermore, Respondent continues to denigrate Petitioner in the presence of the children. 8. This custody action is scheduled before the Honorable J. Wesley Oler at 9:30 a.m., on October 9, 2003, and Petitioner requests that the Petition be heard at that time. WHEREFORE, Petitioner requests that Respondent be found to be in contempt of Court for the foregoing violation of the applicable Court Orders. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff James D. Flower, Jr. // 26 West High Street ~-/,- Carlisle, PA 17013 (717) 243-6222 I.D. No. 27742 VERIFICATION I, MARSHA A. SADLER, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Marsha A. Sadler Date: /~2/'-//~ ~ SAIDIS SHUFF, FLOWER & LINDSAY MAY 1 2003 l'lAY O § 2D03 MARSHA A. SADLER, Plaintiff RONALD L. SADLER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-6187 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, thxs /,2 - day m D~ .v,~fi ,200.~, upon of the attached Custody Conciliation Report, it is ordered and directed as consideration follows: 1. The prior Order of Court dated February 3, 2002 shall remain in full force and effect with the fullowing modifications: 2. Paragraph 4 is amended to provide for the children to be returned at 6:00 p.m. on Sundays. 3. Paragraph 5 is deleted and replaced with the following: Father shall have physical custody of Sarah and Jacob every Wednesday from after school/daycare until 8:30 p.m. Mother shall have physical custody of Zachary every Wednesday from after school to 8:30 p.m. 4. Paragraph 6 is deleted and replaced with the following: Mother agrees to provide Father with a copy of the Gateway insurance card. Upon receipt of the insurance card and confirmation that the prescription is still valid, Father will pick up Zachary's prescription. Both parties agree to assure that Zachary takes his medication as prescribed. 5. Paragraph 7 is deleted and replaced with the following: It is ac 'knowledged that Mother has initiated counseling for Sarah at the Stevens Center. Father shall initiate (call for intake) counseling for Zachary at the Stevens Center within seven days from receipt of the Gateway insurance card with a goal toward family counseling with both children and parents. Both parties agree to sign releases so that both may receive information from the counselor and the counselor may speak to each parent concerning both children. 6. Paragraph 8 is deleted in its entirety. 7. Paragraph 9 is deleted and replaced with the following: Transportation shall be shared. Except when the parties pick up the children from school or daycare, they shall exchange the children at the Carlisle Borough Police Department parking lot. Order. The parties agree to strictly abide by and enforce Paragraph 11 of the prior parties. Neither parent will permit physical discipline of the children by third 10. Neither party will drink and drive with the children in the vehicle nor permit third parties to drink and drive Mth the children in the vehicle. 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 consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for Thursday. August 7. 2003 at 8:30 a.m. BY THE COURT, cc: James D. Flower, Jr., Esquire, Counsel for Mother Marylou Matas, Esquire, Counsel for Father lrRUE COPY FROM RECORD In Tc~!!mony wheraoI, I hare ur, to.~ r~ I~.~M a~,, tha s~al of said Co, ri at C~L, te, Pa, MARSHA A. SADLER, Plaintiff V. RONALD L. SADLER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : 2002-6187 CIVIL TER3I _. : CIVIL ACTION - LAW : : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J 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 information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Zachary Darwin Sadler Sarah Lynn Sadler Jacob Lee Sadler July 18, 1990 Febmary 25, 1994 February 9, 2001 Father Mother Mother 2. A Conciliation Conference was held in this matter on May 8, 2003, with the following individuals in attendance: The Mother, Marsha A. Sadler, with her counsel, James D. Flower, Jr., Esquire, and the Father, Ronald L. Sadler, Jr., with his counsel Marylou Matas, Esquire. 3. A prior Order of Court was entered by the Honorable J. Wesley Oler, Jr. dated February 3, 2003 providing for shared legal custody and Mother having primary physical custody of the two younger children and Father having primary physical custody of the older child, with the parties having alternating weekends so that all three children will be together on weekends. 4. The parties agreed to entry of an Order in the form as attached. Date (~eline M. Vemey, Esquire Custody Conciliator MARSI IA A. SADLER, l'laintiff I,IONALD L. SADLER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-6187 CIVIL TERM CIVIL ACTION - LAW 1N CUSTODY ORDER OF COURT AND NOW, tt~s ~Y~oC da), of ff'~ , _00~, upon consideration of the attached Custody Conciliation iZeport, it is ordered and directed as l'ollows: I. The Mother, Marsha A. Sadler, and the Father, Ronald L. Sadler, Jr., shall have shared legal custody of Zachary Darwin Sadler, bom July 18, 1990, Sarah Lynn Sadler, bom February 25, 1994 and Jacob Lee Sadler, bom February 9, 2001. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including; but not limited to, all decisions regarding their health, education and 'religion. 2. Mother shall have primmT physical custody of Sarah Lyrm Sadler and Jacob Lee Sadler. 3. Father shall have primary physical custody of Zachary Darwin Sadler. 4. Both parents shall have periods of partial physical custody of the other child/children on an alternating weekend basis such that the children will spend every weekend together. Mother shall have the weekend of January 31,2003. The iimes lbr the weekend shall be for Father from after school on Fridays to Sundays at 6:30 p.m. The weekend times for Mother shall be from Friday at 6:00 p.m. to Sunday at 6:30 p.m. 5. The pm'ties shall have such additional times with tile children during the week as agreed by the parties. ~' 6. The parties agree to cooperate in scheduling a doctor's appointment Zachary to detemline whether Zachary should go back on his medication. In the event that the doctor recommends that Zachary resume medication, then both parties agree to assure that Zachary takes his medication. 7. Tile parties agree to cooperate in the scheduling, of counselin=,,, ibr the two older children to include family counseling if recommended by the Children's counselor. t3uth parties a~vce to sign releases so that both may receive information from the cmlnsel{~r and thc go~.ll~s~,lor may speak to each parent concerning the Children. g. Both parties agree lo schedule and attend a Parent Works program suitable to their individual situation regarding parenting, anger or separation. 9. Transportation shall be shared such that Father shall pick up the children fi'om school on his Fridays. Mother shall pick up the Children on her Fridays and xxill always transport on Sundays. Transportation during the week shall be as agreed by the parties. I 0. In tile event either party wishes to leave the jurisdiction, tile), shall notify thc other party and provide a telephone number and address where the Children can be reached. 11, Neither parent shall do or say or permit third pm'ties to do or say anything which may estrange the Clfildren from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. 12. This Order is entered pursum~t to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. Inthe absence of mutual consent, the temps of this Order shall comrol. Another Conciliation Conference is scheduled for Thursday. Al~ril 24.2003 at 9:30 a.m. BY THE COURT, cc: James D. Flower, Jr., Esquire, Counsel for Mother Ronald L. Sadler, pro se 931 North Middleton Rd. Carlisle, PA 17013 MAI{SI IA A. SADLER, l'l:tin tilt V. RONALD L. SADLER, JR., Defendant PI~,IOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2002-6187 CIVIL TERM : : CIVIL ACTION- LAW : : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following rcport: 1. The pertinent infonuation concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Zachary Darwin Sadler Sarah Lynn Sadler Jacob Lee Sadler July 18, 1990 February 25, 1994 February 9, 2001 Fatber Mother Mother 2. A Conciliation Conference was held in this matter on January 29, 2003, with tbe tbllowing individuals in attendance: The Mother, Marsba A. Sadler, with her counsel, .lames D. Flower, Jr., Esquire, and the.Father, Ronald L. Sadler, Jr., pro se. 3. The parties agreed to entry of an Order in the form as attacbed. Date £ ~cq~line M. Verney, Esquire Custody Conciliator MARSHA A. SADLER, Plaintiff RONALD L. SADLER, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY : : No. 02-6187 CIVIL TERM ORDER OF COURT AND NOW, this 9th day of October, 2003, upon consideration of Plaintiff's complaint for custody, Defendant's petition for contempt, and Plaintiff's petition for contempt, and pursuant to an agreer~ent reached in open court between the parties in the presence respective counsel, James D. Flower, Jr., of Plaintiff, and Marylou Matas, Esquire, Defendant, it is ordered and directed as 1. Plaintiff and Defendant withdraw their respective petitions for contempt. 2. The prior Orders 3, 2003, May 12, 2003, and July 21, full force and effect with the following additions: of their Esquire, on behalf on behalf of follows: of Court dated February 2003, shall remain in a. Father shall move forward with all good faith efforts to provide counseling for Zachary. b. Father shall provide documentation within seven days to his counsel of his efforts to provide this counseling. c. Father shall guarantee that Zachary receives Paxil and Ritalin, as prescribed by his physician, at all times. d. Father shall provide copies of all prescription receipts to prove that he obtain such medication. e. Father shall make all good faith efforts to arrange family counseling to include mother and Zachary. f. Father shall sign releases for mother to have access to all medical documents and access to any counselors. g. Father shall provide medications prescribed for Zachary at all times to mother when mother has custody of Zachary. h. The Wednesday evening partial periods of custody are modified so that father agrees to insure that Sara has completed any homework before he returns her to mother's custody at the designated ordered time. i. Both parties agree to keep open j o communication regarding any medical needs of the children, especially in the events of any illness or emergency medical need. The parties agree to share holidays as follows: Easter shall be alternated from 9:00 a.m. to 7:00 p.m., with mother exercising custody of Easter in 2004 and all even numbered years. Thanksgiving shall be alternated from 9:00 a.m. to 7:00 p.m., with mother exercising custody in 2003 and all. odd numbered years. Christmas shall be divided into two periods. Period A shall be from Christmas Eve at 2:00 p.m. until Christmas Day at noon. Period B shall be from ,Christmas Day at noon to the day after at noon. Father shall exercise custody of the children in period A for 2003 and all odd numbered years. Mother shall exercise custody of the children for period A in 2004 and all even numbered years. The parties agree to hames D. Flower, Jr., For the Plaintiff ~arylou Matas, Esquire For the Defendant wcy alternate trick-or-treat evening, with mother exercising trick-or-treat evening in 2003. Father agrees that when he exercises custody of the children on trick-or-treat evening, he shall have them returned to the designated exchange point at 9:00 p.m. Esquire By the Court, iey Ol~Jr.; J.~'~