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Home My WebLink About97-04413 ..Q :s ~ t:j i i '1 , '> ! '.. ~ .( ~ i , I ':"'- I '$ j .. J ~ . I ; ~) ~I. ~l ! I \ . j i f / .' ./ , , I l! ., " II ~:!i II ~~ I ~ Ii E' "'.a ~ S ... .. 'j ~~3oJ f 'I ..a: = . "',... ... ~~ ;:: n. l:- '..-4 ii = =..,. .;; -< ~ I ~~ gj~ .ittii.:~ <II ~ 0.00 ~~ ... .. .> t lW tt 'M . '! ~! ~1i.t~1 ~~el'l8 II !!l = ... _ c_ > ~ sj!~; M ~ ~ ~~~ e ,- ~ do III t I I la . :I! . . ~M" W oJ >0\ M ! i :!UQ I . .. ..., ~"""",,","""'" '""~~~_'_'~'_' ...._.,. _..____.....M~__._. ....~ r~~~EP 2 i mi - JAMESON E. CHRISTOPHER, Plaintiff : IN THE OOURT DE' COlllON PLEAS OF : CUMBERLAND COONTY, PENNSYLVANIA . . vs. : NO. 97-4413 CIVIL TERM . . RACHAEL L. STAUB, Defendant : CIVIL ACTION - LAW : IN CUsroDY OODER OF cnm AND 1Of, this 30" day of S!l!I'~ , 1997, upon consideration of the attached CUstody Corlciliation Report, it is ordered and directed as follows: 1. 'l.11e Father, Jameson E. Christopher, and the Mother, Rachael L. Staub, shall have shared legal custody of Jameson E. Olristopher, II, bom April 5, 1996. 2. '!'he parties shall share physical custody of the Child in accordance with the following schedule: A. 'l.11e Father shall have custody of the Child on alternating weekends, begiMing Septenber 26, 1997, fran Friday at 4:00 p.m. until Sunday at 7:00 p.m. B. During alternating weeks when the Father works the 3:00 p.m. until 11:00 p.m. shift, the Father shall have <UStody of the Child on Tuesday and Thursday momings fran 8:00 a.m. until 12:00 noon. OUring alternatingweeks when the Father works the 7:00 a.m. until 3:00 p.m. shift, the Father shall have custody of the Child on Mondays fran 3:00 p.m. until 5:00 p.m., and Wednesdays fran 4:00 p.m. until 8:00 p.m. C. '!'he Mother shall have custody of the Child at all other times. 3. '!'he parties shall share or alternate having custody of the Child on holidays as follows: A. Olriatmas: '!'he Christmas holiday shall be divided into Segment A, which shall run fran Christmas Eve at 12:00 neon mtil Christmas Day at 12:00 noon. and Segment a. which shall run fran Christmas Day at 12:00 neon until Dee_bee 26 at 12:00 noon. The Father shall have custody of the Child QJring Segment A in odd nlr.tlertld yeara and QJring Se9nnt 8 in even rutleAd years. '!'he Mother shall have custody of the Child during Se9nnt A in even nl.lltlKed years and dul'ing SeoSl!IMlt a 1/\ odd l\Ul!t)ertld years. B. ~tving: The Mother shall have custody of the ChUd on '1'hanU9iving Oay fran 8:00 a.lI1. until 9:00 p.lI!. in odd ~ yeau and the FatMr shall have CUStody of the Child ,.. 0' :;- ...... ..:l \.: .... ,- u:~ .. - - ~s, .+~ t\ c'- ; . t.." 8, ~':1: t' ~' ("': E' t '.~ ......- ;i,.t... ,. u~ ~ \r a on Thanksgiving Day frOln 8:00 a.n. until 8:00 p.m. in even numbered years. The parties agree that the Mother may have custody of the Child in 1997 from the Monday before Thanksgiving until the Tuesday following Thanksgiving for purposes of taking the Child to visit relatives over the holidily. The Mother shall cooperate with the Father in scheduling make-up periods of custody for all regular periods of custody which the Father will miss, either the week prior to or the week ifll11ediately following the Mother's extended period of custody for the Thanksgiving holidily. C. Alternating Holidays: The parties shall alternate having custody of the Child on the fOllOWing holidays, begiMing with the Mother having custody of the Child on New Years Day in 1998: New Years Oily, Easter Sunday, Memorial Day, July 4th and Labor Day. The period of custody on the foregoing holidays shall be from 8:00 a.m. until 8:00 p.m. D. Mother's Day/Father's Day: The Mother shall have custody of the Child every year on Mother's Day fran 8:00 a.m. until 8:00 p.m. and the Father shall have custody of the Child every year on Father's Day fran 8:00 a.m. until 8:00 p.m. 4. In the event a conflict arises between the regular custody schedule and the holiday custody schedule, the holiday custody arrangements set forth in this Order shall take precedence. 5. Each party shall be entitled to have custody of the Child for two nonCOr\$ecutive one week periods anytime during the year upon providing sixty (60) days advance notice to the other party. Extended periods of custody under this paragraph shall not be scheduled (unless mutually agreed otherwise) to interfere with the holiday cuotody schedule. 6. All exchanges of custody under this Order shall take place at the paternal grandnotlmr's residence. 7. This Order is entered pursuant to an agreP.ment of the parties at a Custody Concili<ltion Conference. The partil!s /<laY modify thP. provisions of this Order by mutual agreement. In the abeence of mutual agreement, the terr.. of this Order shall control. BY 'nIe <n.JRT, _;S~,.t" II- J. , CCI John H. 8roujoa, tBquiro - Cow,.,.l for Father _ ~.,~ 1t'j,/f'l I'Iareua A. l'IClQ\ight. Ill. F.aquiro - CCun."\l>1 for Mothec .,J 1':J. JAMESON E. C1IRISTOPHER , IN THE COURT OF <XX1MON PLEAS OF plaintiff . ClJlIIBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. 97-4413 CIVIL TERM . . . RACHAEL L. STAUB, . CIVIL ACTION - LAW . Defendant . IN cusrooy . PRIeR JUDGE: Kevin A. Hess am'lOOY <XH:ILIATIOO &MARY REPCRl' IN ACXDUWa "rm cumfm.AND <XUn'Y RlU CR CIVIL ~ ""'~ 1915.3-8, the undersigned CUstody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DM'B CR 8IR'l'II <1RU!B1'LY IN cum:or CR Jameson E. Christopher, II April 5, 1996 Defendant/Mother 2. A Conciliation Conference was held on Septeutler 23, 1997, with the following individuals in attendance: The Father, Jameson E. Christopher, with his counsel, John H. Broujos, Esquire, and the Mother, Rac:hael L. Staub, with her counsel, Marcus A. McKnight, III, Esquire. ~....J"'l Dee 3. The partiea agree to entry of an OI:der in the for:m as attached. t:~..~ DaWn S. S y, &!Iqu nl CUstody CalcUiator ,J'f /9'17 . JAMESON E, CHRISTOPHER, PLAIl"lTlff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA \'. 97-4413 CIVIL TERM RACHEL L. STAUB. DEFENDANT CIVIL ACTION - LAW IN CUSTODY CUSTODY PRE-TRIAL MEMORANDUM OF DEFENDANT. RACHEL L. ST AVB AND NOW. this 26th day of March. 1999, comes the Defendant, Rachel L. Staub. by and through her attorneys, IRWIN. McKNIGHT & HUGHES, and makes the following Custody Memorandum: I. FACTS The Defendant is Rachel L. Staub who has enjoyed primary custody of Jameson E, Christopher, II, since his hinh on April 5. 1996. Despite problems with the child's father, Jameson E, Christopher, the Defendant has agreed to prO\ide significant time to the Plaintiff with his son. From the beginning of the custody litigation. the Plaintiff has made clear his desire to reduce or eliminate his child support obligation for the child. He is therefore seeking to have an equal custody schedule wilh the Defendant. Rachel Staub. A Conciliation Conference was held on January 5, 1999. The Court had previously entffed an Order in referetK-': to th4: abm c-caplioned matter on $cptember 30, 1997, pro\iding for th4: J\Vties to have dw-al ph)skal ~u,tody of the Child although the actual custody schedule rnl\ioJcd "lfth4: Plainti 11' II' ha\ c phy~cal CUSI.'lly of the Child during the majority of the time, The Plainulllilcd the Petllkm 10 ''''ll,I)' the Sq>!ember -'0, I CW1 Onkf and seeks equally shared ph)5l\:al ~-ustl'll)' llf a week tlt\ ,,~-\ "IT N.\is The partin "ere not able to reach an ~~II~t. The PliAinllll RKhd I ~\;\uh, ~ t" l:'Itahlish that. still nmh to rnwide the -tM'lllrc """'''''<;II') ,,, cn,urt lh.al tho: ,hIM " ~n."ful in rn'l'3fat1\~ for hUi lIttendma t\:~>l. II. LIST OF WITNESSES I. RACHEL L,STAUB Mother of Jameson E. Christopher. II 521.C South West Street Will testify as to the her relationship Carlisle. PA 7103 betwccn her and her child and her ability to parent and eare for the child, 2. MARGIE GROVE Defendant's mother R. D. #1, Box 310 Will testify as to the relationship between New B1oomlield. PA 17068 mother and child. 3. LELAND SCOTT. II Grandfather of Nathaniel, Jameson's brother 4591 lareh Drive Will testify as to the relationship between Harrisburg, PA 171M mother and child. 4. PATSY SWART Friend of defendant 2208 Cirele Drive Will testify as to the relationship betwccn Carlisle. PA 17103 mother and child. S. BETTE ALSPAUGH Grandparents of defendant LARRY ALSPAUGH Will testify as to the relationship between 744 West Penn Street mother and child. Carlisle, PA 17013 6. REBEKAH CHRISTOPHER Sister of defendant and sister-in-law of plaintiff 1885 Aeronca Street Will testify as to the relationship between Carlisle. PA 17013 mother, child and the contact between the rather and Jameson. 7. LELAND SCOTT,IlI Father of Nathaniel, tbe brother of Jameson 314 Lexington Street Will testify as to the n:lationship between York.PA 11403 motl1cr and child, II. CRAIG HARRIS Assistant Pastor of Grace Baptist OlUttb 117 West North Stred Will testify lqAlding the relationship ~'eCfl Carlisle. P A 11013 mother and child. l l.MI t'lRoll 01 Jacqueline M. Verney ,p 4 H"",-"1\.U ~t . I: Altrttt. .. P\Hi II t',"',lO}:-\ .,. . U.' t!"lh ,... t<st. -, JAMESON E. CHRISTOPHER, Plaintiff : IN THE CXXlRT OF cnlMCN PLEAS OF : CUt1BERLANO COUN'l'Y, PENNSYLVANIA . . V8. : NO. 97-4413 CIVIL TERM RACHAEL L. STAUB, Defendant . . : CIVIL ACTlOO - LAW : IN CUS'roOY aulI!R (p cnm AlIID tof, this 30r day of So ":-k:" upon consideration of the attached CUstcxly ~iliation ordered and directed 88 follows: 1. '!'he Father, Jameson E. Christopher, and the Mother, Rachael L. Staub, shall have shared legal custody of Jameson E. OlristqXler, II, bom Apdl 5, 1996. , 1997, Report, it is 2. '!he partiu shall share physical custody of the Olild in ac:oardance with the following schedule: A. '!'he Father shall have custody of the Olild CXl alternating weekends, begiming Septerrtler 26, 1997, fran Friday at 4:00 p.m. until SUnday at 7:00 p.m. B. Durilg alternating week.s when the Father \/OrIes the 3:00 p.m. until 11:00 p.m. ahUt, the Father shall have CIlStcx!y of the Olild on Tuesday and '1'hur8day mornings fran 8:00 a.lll. until 12:00 noon. During alternatingweeka when the Father works the 7:00 a.lll. until 3:00 p.m. ehift, the Father ahall have custody of the Olild CXl Mandaya fran 3:00 p.m. until 5:00 1'.11I., and w.e.i.....&.ys fran 4:00 p.m. until 8:00 p.m. C. '!he Mother shall have custcxly of the Olild at all other tinte. 3. 'DIe ptrtiee ahall share 01:' alternate having custcx!y of the Olild CXl holidaya u tollows: A. Olrtatmu: The Olrisbnu holiday shall be divided into s.; .....t A, which ahall run fran OlristIIIUI Eve at 12:00 noon until Olrtabnu OIly at 12:00 noon, and SegIIlent B, which shall run ttan Olristmu Dey at 12:00 noon until ~ 26 at 12:00 noon. 'ftIe rather aha11 have CIlStCIdy of the Olild durin;, SeqII~'t A in ocli nlEbtuod )'lMr'II and durin;, S. ~ -'\t B in .... 1UI'bet.d)'lMr'll. 'DIe Mother 1ba11 have euatody of the Olild during 5el .t A in ;tven ~ YMl'a lIl1d duri~ SllW \t B in ocli 0I.IItlend )'Mrs. B. ~h~: The ~ ....11 haft custcx!y of the OlUd CXl '1'tIInUglvin;, DIy ftan 8:00 a.lI. untU 8:00 1'.11I. in ocli f\l;;<<ed Y'lUlI lIl1d the hthtt: 8hIIll have c:uatod>{ of the auld f .... , il on Thanksgiving Daly from 8:00 a.l:1. until 8:00 p.m. in even nlllbered years. The parties agree that the Mother may have custody of the Child in 1997 from the Monday before Thanksgiving until the Tuesday fOllowing Tr ,'KBgiving for purposes of taking the Child to visit relatives over the holiday. The Mother shall COOperate ....ith the Father in scheduling make-up periods of custody for all regular periods of custody which the Father ....ill miss, either the week prior to or the week imnediately following the Mother's extended period of custody for the Thanksgiving holiday. C. Alternating Holidays: The parties shall alternate having custody of the ChIld on the follOWing holidays, beqiMing ....ith the Mother having custody of the Child on New Years Day in 1998: New Years Oay, Easter Sunday, Memorial Oay, July 4th and Labor Day. The period of custody on the foregoing holidays shall be fran 8:00 a.m. until 8:00 p.m. D. Mother's DaY/Father's Daly: The I'Iother Ilhall have custody of the Child every year on Mother's Daly fran 8:00 a.m. until 8:00 p.m. and the Father shall have custody of the Child every year on Father's Day fran 8:00 a.m. until 8:00 p.m. 4. In the event a oonflict arises between the regular custody schedule and the holiday custody schedule, the holiday custody arrangements set forth in this Order Mall take pr<<:edt:..c:e. 5. Each party shall be entitled to have custody of the Child for two IlOllCOnsecutive one week periods anytime during the year upon pC'OViding sixty (60) days advance notice to the other party. Extended periods of custody lXlder this paragraph Mall not Ix! scheduled (unless IIaltually agreed otherwise) to interfere with the holiday custody schedule. 6. All exchanges of custody under this Order shall take place at the patemal 9randDol:h&r's residence. 7. 'Ihi.s Order is entt!l'1ld pursuant to an ag~t of the parti.. at a Cuatody CalcUlation Cllnfennce. The parties llliIy Ill:ldify the pC'OV Wens at thi. 0n:Jer by IlIJtual agreCll\orJ1t. In the abeence of IlIJtual agAemlnt, the tem. of this order shall control. c:c: BY THE: cnJRT, ...;jf- ...;1 ;,L J. John H. Ilnlujoa. t:8q\.Ilre - Couneel{OI: Father _ e:,.~.,T'-:~N""', I'IIrc:ue A. ~lgt1t. III, t:8q\.Ilnt - ~l for Motbtr ...4 fIl II ~:!i '" 4.1 I ~~~ J ! I ~ I ~i~~ 4.1 ... I f~3g~ II . ... II ~I i ~~5~1 ~ , 4.1 ,-,~ ~ ~ ~ . ii . - . ~~~~ ~ ~>< ......if ~~ Ul!. ~ '~i!l ~ , ;i .! r . . 01'" III ~ 0 i ~ 8 I i!l .. ;.11\ . JAlt" . JAMESON E. CHRISroPHER, . IN THE OJURT OF CXMolON PLEAS OF . Plaintiff/petitioner . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. . NO. 97-4413 CIVIL TERM . RACHAEL L. STAUB, . CIVIL ACTION - LAW . Defendant/Respondent : IN CUSTODY CJIDIlR OF cnm AND NCW, this ;V",r' day of")rl.ll({{ 2<1' , 1999, upon consideratioo of the attached Custody conohiatioo Report, it is ordered and directed as follows: A Hearing is scheduled in Court Room . <-j of the Ctmtlerland County Court House, on the ).;;. t day of , ~) ~' , 1999, at ," ('(J , o'cloclt, ~.m. The Father shall deemed to be the moving party for the purpose of this Hearing and shall proceed initially with testimony. COUnsel for the parties shall file with the Court and opposing counsel a Memorandun setting forth each party's positioo 00 custody, a list of witnesses who will be expected to testify at the Hearing and a 8UI11l1l!ry of the testimony of each witness. These Memoranda shall be filed at least ten (10) days prior to the Hearing date. BY THE CClIRT, //4- J. ee: Jacqueline It. verney. f:aqUi~ . ccunsel fO\': f'athet _ ~.,,,,,,,,:"A.lI.1~ /.", Marcus A. Mc:Itnfght, Eaqufnt - ccunsel fO\': It:)ther ~ ..J 7' JAMESON E. CHRISTOPHER. : IN TilE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNlY,PENNSYLV ANIA V. : CIVIL ACTION . LAW . . RACHEL L STAUB, nefendantIRespondent : NO. 97-4413 . . : IN CUSTODY PROPOSED CllSTODY ORDER OF PLAINTIFF JAMESON E. (;HRISTOPHEB Father makes the following akemate proposals to the Court for c:onsideratiou of a custody order. Father intends to commence taking the child to his church regularly on the weekends that he has custody IUd thus objeas to Mother having the thild every Sunday morning to take to thurch, I. The panies shall have shared legal custody of their minor SOIl, Jameson E. Christopher, II, bom April,. 1996, 2, The panies shan share physical custody of the child on the foUowina schedule: .. The panics shan alternate wee1ends such that Father "i1Iu,,'c thote wccbads "hen Mother \\OI'b, from Fridly at .4;00 P,IIl to Monday UlItiJ appnnirnately 3;00 P,IIl "iIen Father worts the 3-11 shift aud UIltiJ =-,..,~ lppl:O'*mateJy 7;00 a.1Il wtlal Father "wU the 7.) shift, The child is to he rct1InIed either to tile beb>'1llter's or to McllIler depta lilt. 011 Mother', \VOlt defile. b. Oa \\teb Wi FIldler \\OIl., 7.00 . Dl to 300 P Ill, flldler _II ha,,~ the ,.... r ~. _ .tw, ,,\ 1':; .. 1"- c;W.-.r ~1l It).. J r ' t..l) J Oli P III ..,11 , "--I.,. n '. .. At