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IN THE COURT OF ~OMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
IN THE MATTER OF PETITION
FOR CHANGE OF NAME OF
ANDREA JANE HARCLERODE
NO. 97-S6IS-CIVIL TERM
ANSWER TO OBJECTIONS TO PETITION FOR CHANGE OF NAME
~,
AND NOW,to wit, this ~ day of December, 1997, comes the
Petitioner, Susan L. Betsko, who on behalf of her minor child, Andrea Jane
Harclerode, and through their attorneys, The Law Omces of Niles S. Benn,
Esquire, by Martin Miller, Esquire, files the within A'1swer to Objections for
Change of Name and in support thereof avers as following:
I. Admilled.
2. Admilled.
3. Admilled. By way of further answer, the Custody Orders entered in
regard to this mailer speak for themselves. By way of further
answer, pursuant to a Marital SeUlement Agreement dated July 23,
1996, which was incorporated into a Divorce Decree on or about
August 6, 1996, the Petitioner and the Objector had shared legal
law OffiCII of
Nil.. S. 8.nn, elqulr.
P.O. BOl 5185
135 NMh George 51. I
SUlle 303 I
York, PA 1740S.5185 II
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and physical custody of the minor child at issue whereas the
Parties alternated weekly physical custody of the minor child.
VERIFICATION
I, Susan L. Betsko, verify thatlhe statements contained in the
foregoingAnswer to Objection to Petition For Change of Name are true and
correct to the best of my knowledge, infonnation, and belief. 1 understand that
false statements herein arc made subject to the penalties of 18 Pa. C. S. Section
4904, relating to unsworn falsification 10 authorities.
Date: 11/~/f1
//<fd,/
, Susan L, Betsko
law Offices or
Nil" S. B.nn, E.qulr.
P.O. Box 5185
'35 NMh Georg. Sl.
Suil. 303
York, PA 17405.5185
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
IN THE MA TIER OF PETITION
FOR CHANGE OF NAME OF
ANDREA JANE HARCLERODE
NO. 97-5615-CIVIL TERM
CERTIFICATE OF SERVICE
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I, Martin Miller, Esquire, do hereby certify that on the I q day of
December, 1997, I served a copy of the foregoing document by United States
Mail, First Class, postage pre-paid, 10:
Lori K. Serratelli, Esquire
SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C,
2080 Linglestown Road
Suite 20 I
Harrisburg, PAl 711 0
Respectfully submitted,
LAW OFFICES OF NILES S, BENN, ESQUIRE
Martin Miller, Esquire
Attorney 1.0, 1163021
Attorney for Petitioner
p, 0, Box 5185
135 North George Street, Suite 303
York, PA 17405-5185
(71 7)852-7020
Law Offices of
NUll S. B.nn, Elqulr.
po. Box 5'85
135 North George SI
Suite 303
Yor1c. PA 17405.5185
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Pka'. ~lIkT.d all Ord:, .,,( 1!llIt II.iI,...I'\(llrI ?,~. 1(11)7, OIltlrnll1!l f1arcl~rOll~'s
oblrgillilln II. I'Ol~ 1l1,""~'i Iii P.IIII""~r. S,'Sill11. Ikls"o. lor Ih~ suppon of
AIIII"a Jail" Ilarcklo.k Sad ""I'(I"rI ()rd~r \las '.lIhs~qU~ll1l) Illodili~d b)
Old~r or ('Ollt! dill~" hal~ ,111. 11N7. alld ,\I'll'''' ;6. ")IJ7. A copy ofth~
tlm:..: ()I'lkr~ ,HI,: UII;u.:lh.:d III.:r,,'llI alllllll~lIrporah.'d h..:r~ill by refcn:ncc as
bh,bll "I)". 1\luhil .". alld hlll~1I "1'". res(l'~llId~
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hOld a .:Itlhl. '\I)ssa .1",1111"11;,,1.... III .I,,';~ph B.'140 ,'n A"!lustl;. 11)97. and
,h; \\alllS ..\'lllre;\ I.. h~ar Ih.: ""11\ 11.:111, AI) ssa Ilhlltl B~I>"o or any other
dllldr~n hll'll \lf1h":lr lIlaln;lg~" :\lolI:o'..:r, P..:t1til)lh.:r a\l.:rs Ihal there arc
ceria ill p~~,,'lhlh.gIC.d ;I~h;1I11~1:Jl'S tLl p~l!l1illing Ih,: flaml: changt:, Also. there
\\ill hI.' a cUI\Slsh"Il~~ Ilf 1l;II1U: U"il." II1lh~ Iktsk\l f,lIIl1l~.
III 1)~li'I,,"..r hdi~\~,. all<l Ih~r~I"J'~ .II,'rS,II'i1t illS III Ih.. hl'sl inl~r~sls of
And'''';l lallI.' II.lldt..:llhk III lIa\l..' her Ihllih: ~'hangl'\1 (0 r\ndn:a Jane
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law Onices of
NU" 8. Benn, elqulre
P.O. Bo> S185
'35 North George 51.
Sulle 303
York. PA 17405.5185
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Th",'I'\: ;u..' !III ,1l1dgl."nH.:uh ,If d..I:r..:...s 111' h\~ chara~t.'r pI' r...:cord against
-\lId,,'" Ja,L' Il.lr..k... 'lk
\aw Ome.. 0'
s. Blnn, Elqulro II
P.O. BOl 5'85 I
North alorge 51.
SUllO 303 !
. PA 17405.5'85 .
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VERIFICATION
.,
I. Susan L [)~lsko. verify thatlhe statements contained in the foregoing
Petition For Chan!!~ OfNam~ are true and correct to the best of my knowledge.
information and belief (understand that talse statements herein are made subject to
the penalties of I B [In. C.S. 4904. relatin!! to unsworn falsification to authorities.
Date:
'I
fol/o! q 7-
~/4 A,-(b,
~ei;j;
10/00/00
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IN 'mE COURT OF COMMON PLEAS OF YORK COUNTY. PENNSYLVANIA
JEFFREY A. HARa..ERODE,
Plaind1f
No. 96-SU-01BOl!-02C
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Civil Action. Law \0 ~
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SUSAN L. HARCLERODE BETSKO,
Defendant
APPEARANCES:
Susan A. Doctor, Esquire
for the P1aind1f (father)
Michelle Pokri1ka, EsquiIc
for the Defendant (mother)
ORDER
Both parties and their respective counsel appeared at the conciliation conference
scheduled for Wednesday, October 2, 1996, before Conciliator, Dorothy Livaditis. It Is
noted that this action was initlally commenced by the filing of a custody complaint in
Cumberland County, Pennsylllania, by the mother. COUIlSel advised the conciliator that the
parties amicably agreed to the withdrawal of that complaint and the action being heard in
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the jurisdiction of York County, Pennsylllania. Thereafter, Jeffrey A. Harclerode, the father
of the minor cbfid, Andrea Jane Harclerode, born October 27, 1993, filed a cllBtody action
in the York County Court of Common Pleas seeking majority physical custody of his
daughter, The mother then filed a counter-claim also seeking majority physical custody of
the child. It is further noted that these parties entered Into a Marital SettlemeIlt Agreement
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OIl or about July 23, 1996, a copy of which is attached to Plaintifrs complaint und, therefore,
Exhibit "A"
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a part of the recoed. Furthermore, there have been some issues raised by both panies that
they have not' been tully complying with the terms and conditioWl of the custody
arrangement set forth in that agreement,
At the conciliation conference, each party indicated his or her present desire to
continue to pursue majority physical custody of !he chUd. As a result, it is Ordered and
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Directed that these parties undergo Court-ordered medlatlon with Dr, Stanley Schneider,
(717) 732-2917, Both panies were provided wi'{1 written instructioWl as to how to contact
Dr. Schneider to pUmle this medlatlon. It is the Court's desire that in addltion to the usual
medJation issues addressed, Dr. Schneider attempt to address with these parties the issue
of communication between them as to any problems or difficulties arising regarding the
custody of this child.
It is hoped that these parties. will be able to reach an agreement regarding the
custody issues through Court-ordered mediation. However. in the event that they are unable
to do so, counsel for Zhe parties are reseIVed thirty days after the completion of mediation,
to agree upon an independent evaluator to complete psychological evaluatloWl of the parents
and their spouses if this matter is to proceed to a full hearing, If the parties cannot agree
to an Independent evaluator within that thirty day period, either party may request
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psychological evaluatlOWl to be completed at his or her own full expense and each party and
their respective spouse are directed to cooperate with these evaluatioWl, Furthermore. the
panies must also attend and complete the Kids First Custody Workshop on or before
December 6, 1996, Since both parties reside in the northern part of York County.
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Pennsylvania, it will be acceptable for either or both of them to attend the 1nnerworJcs
Custody Worbliop 3powored by the Dauphin County Couns. In either caae, each parent,
upon completion, mll3t file a Certificate of Completion either of the Kids First Custody
Workshop or the Innerworks Clutody Workshop with the Prothonotary's Office of York
County on or before December 6, 1996. The parties arc reminded that they arc under
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Court Order to complete both the mediation and the custody worJcsbop and their failure to
do so may result in their being brought before the Court and appropriate sanctions being
entered.
Furthermore,
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in the event that mediation is unsuccessful, upon completion of
mediation, the custody worJcsbop and the psychological evaluations, if requested, counsel
shall then contact the Court to schedule a pre bearing conference so that this matter may
proceed to a final hearing,
In the interim, it is Ordered and Directed that the custocrJ provilJions as set fonh in
the Marriage Settlement Agreement dated July 23, 1996, and incorporated into the Divorce
Decree and Order of Court on or about August 6. 1996, shall remain in full force aDd effect
and shall govern until further Order of Coun. That Agreement and Order provided for
shared legal and physical custody of the child which shall continue,
It was acknowledged by the father at the conciliation conference that he has not been
regularly exercising his CWItody righu on Wednesd}y evening3 pursuant to the agreement of
the partles. He has voiced some concCIIlIi about providing continuity for the child and
further indicated that he has not made a final decision as to whether he wishes to continue
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his custody rights on Wednesday evenings or to waive them. The mother, however, clearly
stated that she wishes to continue exerciJing her rights on Wednesday evenings while the
faeber has physical custody of their daughter, It is directed that the father make a deciaion,
at least for the time being. as to whether or not he intends to QCI'CUc his CUStody rigbtl on
Wednesday evenings. In fairness to the mo!her, she should be given advanced notice as to
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!he father's intentioDS. It has been sugge3tcd and is now directed tbat once he rcachc:s a
decision, which should be done in me vel)' immediate future. hc should advise me mother
accordingly. 'Ibis Order is not terminating the father's custody rights on Wednesday
evenings, but It is specilically directing him to advise the mother of his prc:sent intcntiol18,
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and, in the future, If he changes his mind, he sbould at least give the mother notice no later
than !he time that custody Is transferred to the mother on Friday evenings as to what his
Intentions are as to the upcoming Wednesday evening. ObviOUllly, for both parties, this is
not addressing any emergency situatiom which might prevent either of them from exercising
their custody rights on Wednesday evenings.
A copy of this Order shall be provided to both counsel 50 they may forward a copy
to their respective client. A copy shall also be forwarded to Stanley Schneider who shall be
conducting the Court.ordered mediation. Additionally, counsel arc requested to provide a
copy to the selected evaluator should evaluations later be requested.
Date: ~.A 't' JCtlJ t..
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BY TIm COURT:
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IN THE COURT OF COMMON PLEAS OF YORK COUNI'Y. PENNSYLVANIA
Jet t HEY A. HARCLERODE.
! I PlaintlIf
No. 96-SU-01800-02C
vs.
CIVIL ACTION - u..w
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CUSTODY ACTION
II SUSAN L. HARCLERODE.
Defendant
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, . and Agreement of the parties. it is hereby ORDERED. ADJUDGED. and DECREED. as
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AND NOW. TO WIT. this ~ day of ~ C~~...... . 1996. pursuant to the Stipulation
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; . follows:
1. The parties are the parents of the following minor child. TO WIT:
Name
Present Address
Birth DCU
Andrea Jane Harclerode 1751 Weatherbum ,Drive
New Cumberland. PA
October 27. 1993
2, 'Legal Custody" as that term is defined in the "Pennsylvania Domestic Relations
· : Code". 23 Pa. C.SA Section 530 I ~~. is to be shared by the parties,
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! 3. "Majority Physical Custody" of the child as that term Is defined in the
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! aforementioned Act. shall be granted to the mother.
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4. The father. Jeffrey A. Harclerode. shall have the right to 'Partial Physical
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! i Custody" and shall exercise that right in the follOwing manner:
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a, Every other Friday at 4:00 p.m. until the following Wednesday at 8:00 am.
/9:00 a.m. with drop-off to be at the day care center. Mother will then
maintain custody from Wednesday at 8:00 a.m. /9:00 a.m. until the second
Friday thereafter at 4:00 p.m. This schedule shall begin with the mother
Exhibit "B"
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having custody from Wednesday. October 9. 1996 until Friday. October 18.
. 1996 and the father having custody from Friday. October 18. 1996 at 4:00
p.m. until Wednesday. October 23. 1996 at 8:00 a.m, /9:00 a.m, and
alternating therea!ter;
b, On alternate holidays. beginning New Years Day. The holidays are: New
Years Day. Memoria! Day. Fourth of July. Labor Day and Thanksgiving Day.
Such custody shall begin qt 9:00 a.m, and end at 8:00 p.m.;
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c.
The Christmas Eve and Christmas Day holidays shall be as mutually
agreed upon by the parties. In the event that the parties cannot reach an
amicable agreement as to these holidays. the following schedule shall
apply:
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In even numbered years. father shall have partial physical custody
from 12:00 noon on Christmas Eve until 12:00 noon on Christmas Day.
This provision supersedes all others.
In odd numbered years. father shall have partial physical custody
from 12:00 noon on Christmas Day until 12:00 noon on December
26th. This provision supersedes all others.
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d. During the summer, each parent shall be entitled to a two (2) week period
of uninterrupted custody. said period may be consecutive. Each parent
shall notify the other. in writing. sixty (60l days in advance. of his or her plan
to exercise this two (2) week perioa. In the event of a conflict the parent to
first notify the o.ther shall prevail.
e.
Father shall have right of custody on every Father's Day from 9:00 a.m. until
8:00 p.m. with Mother having that same right every Mother's Day from 9:00
a.m. until 8:00 p.m. This provision supersedes all others.
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, i 5. Medical CarelI'reatment. Both mother and father shall be immediately
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! ! informed as to the medical care and treatment of the child.
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j : permanent. of either parent. that parent must immediately inform the other of hisiher new
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! ! address and telephone number.
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6.
Relocation. Upon the knowledge of pending relocation, temporary or
7. Seat Belts and Child Restraint Seats. Both parties shall utilize child restraint
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seats and seat belts when transporting the child by automobile,
8. Telephone Contact. The parties agree that the child Is to have liberal rights of
telephone contact with the non-custodial parent, no matter who Is exercising h1s/her right
to physical custody.
I 9. Transportatton. Unless otherwise'agreed upon between the parties. the father
I shall be primarily responsible for providing transportation in the exercise of his custody
ri ht ,'ll~S Mo4\<<r r€.IIlC,,\<J "\01."(, 1"<t~, /I. +t.I(IO) "";\.( "~Q;lJS ~.'" Oill~hv'3lA
-t~n ~~I" /t...<l i=A~1" ~;\1 S~o1.Y( tvA"spodl\nc'o '-)(,","'u (i",..+<t1 to 91l~ <l"c.\ {oIls (I.,. 'I"
.III "AI ~1'dI).
Ie, Lecol Residency. The legal residency of the aforementioned child. not
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: I withstanding where the child may live at various times. shall be the same as that of
. : mother,
11. The mother and father agree that they are voluntarily entering into this
Agreement with full knowledge and wish for the Court to adopt It as a Court Order,
IT IS SO ORDERED.
. BY~m1fl:r~ I \. n Q
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,-- -Penny L. Blackwell. Judge HOY 0 1 1996
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We have read and consent to::> entry of the foregoing Order,
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'vKt1~;$2i~~
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Susan L. Harc1erode-Betsko
law OHless 01
. Nil.. 8. 8-."", ..qul... .
PO. 8o,,-~1B~
1:3~ NCI"'th George Screee. Sule. :303
York. Pennayivlll'll. 1740!5-~1ae
(717) B52-7020 · F.." (717) Be2-B787
100 HEREBY CERTIFY THAT THIS IS A TRUE;
COIIRECT COPY Of THE ORIGINAL OOCUME
ALEO OF AI:,^,"LI -
BY
IN THE COURT OF COMMON PLEAS
OF YORK COUNTY, PENNSYLVANIA
JEFFREY A. HARCLERODE
NO.
96-SU-01S00-02C
v.
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SUSAN L. BETSKO
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CIVIL ACTION_7~LA~
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AND HOH, TO HIT,
ORDER or COURT
this o?/~day of
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?r7- : ,i;
Stipulation of Jeffrey
1997, pursuant to the Agreement and
A. Harclerode and Susan L. Betsko, is hereby ORDERED that
the undersigned Jeffrey A. Harclerode and Susan L. Betsko,
Father and Mother, respectively of Andrea Jane Harclerode,
born October 27, 1993, the subject of the above referenced
custody proceeding, hereby agree ~hat the best interest and
welfare of Andrea Jane Harclerode would be served by
amending the Consent Order entered on the 19th of October
1996 as follows:
1. During such times as Susan L. Betsko is on
"maternity leave", the minor child will remain with her
rather than the previously agreed upon daycare provider.
Mother shall be utilized as the daycare provider during such
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time as Father is working. Father shall be responsible for
dropping off and picking up the minor child before and after
. om... af
. 8.nn. EaqulrI "
I. Sa. 5185
,nh George SI.
iUII. 303 I
A '7405.5185
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his scheduled work.
Exhibit "e"
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B.nn, !Iqul..
. Box 5185
,"" George 51.
/ulll 303
" lU05.5185 I
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lYelendanl
PAGE TWO
DRO No, ~
Dlll:..el No, 423 SA I 'Ii} I
ORDER OF COURT
...
. the Court does hereby order the Defendant to pay the Office of Domestic Relatioll5 the
$ r.w=k for the support of onc...chil.d as allocated on page
one effective tJiiS'"order to cotitlnue unllIl'iirtlier Order of the Court.
Payment to commence y e Dele tin e amount of the order (or cl1l!nge) until the aWlU'ded wage
attachment is deducted DY e employer. The f.\ai,uti~efendant Ilffl 10 orovide IieaIth insurance that is available
Cor the dlUd hereinvolvcd at reasonable cost. Both parnes are reqwred to comply with all Policies and Procedures
of Domesllc Relations including ~rting changes of address, emplo~ent, lriSUrance cove~elcost or CUSlOllv nf
children, in writing or person, withm seven (7) days of the cf!ange. Willful failure to inform Domestic Relations of
this ~uired information may result in the Court adjudging the party in contempt p1lml8DI to Rule 1910.21
punishable by one or more of the following: .jail, fine or PJ:Obatlon. Income win De attached unless the obUsor is
not thl!t}' days in arrears I\IIl1 good cause exists not to altlii:h Q.t a written agreement is reaclted between the P.JU1ies
providinS for an alternative arrangement, this second option applying to non-welfare cases only. Any past Que
support IS a judgment by oJlC!!ltion of law, Cases with qualified IUI'ClIr! will be submitted to thC IRS 1Dtm:ept
program. PUrsuant to 23 Pa.C,S,A. 4308,. noncustodial jlarent's state lottery winnings may be intercepted for
payment of back support, Pursuant to 23 Pa.C.S.A. 4352(a), both parties are entitleil to mtuest a 1'eV1ew at least
once every 3 years from the date of the most recent order or modification upon the tiling ora petition to modify,
Thete 13 a S,20 per week service charge that must be paid by the Defendant. .
Arrears are 145.00 owed to ll.llIintiff.as of~
Pa~ents on lIITlllII'S shall be "'1iiIIie1oUowing pnority, _ __
Slllll per w=k.. on support arrears account number ~
$_ per _ on birtli expenses account number . .,'
S_ per _ on HLA blood test account number _
S_ per _ on account number . .
S pl!r _ on account number '
If at any rime after the entry of this order, the total sUPPQrt lIITlllII'S exceed ~, the amars payment on the case
shall automatically increase to Sl,ll.Oll per ~ to continue until full paynieiitOi allamars or further order of
court, A wage attachment in the Increased amount sball automatically Issue without further notice, Arrears
paymentlisled above are minimum p~ents required by this Order of Court. . -
Fonnula Income Amount Defendant Formula Income Amount Plaintiff~.
Guideline Amnllnl ofSuPP<'rt SNfA ( ase NLA Additiolull WA). .
Medical Split. ifapplicable ~% Defendant; ~% Plaintiff, which IJertains to unreimbursed reasonable and
nccess!uy medical services as defined by the P A statewide guidelii1e for the children incurred on or after &hnl.ll1Y
S. 1997. This matter is to be handled directly between the parties unless default occurs at which point enfon:ement
action may be pursued through York Domesltc Relations in accordance with the procedures in place for same.
~~~~~~a;~~~~n~~lWI~ ~~~I~~~nii~cS~~:~ n~~~~:~~:l~op~~~~~c~~O:~
lP"dehn~ amnllnt of support.
pc: Plaintifl; Anv, L. Serratelli
Defendant; Ally, M. Pokritla
JTS
I7p'E COURT. ·
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Judge
Dale Mailed 4/22197 Workcr ITS P&P ene, P JD JBoth XX/No_
Exhibit "0"
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j,)SAN L BETSKO
'Iainti"
I
COURT OF COMMON PLEAS
YORK COUNTY
DOMESTIC RELATIONS SECTION
;FFREY A HARCLERODE
'efendant
No. 423 Support Action 1997
Action in Support
DRO No. 62350
..
ORDER OF COURT
AND NOW, JULY 30. 1997. verification having been presented to the Domestic Relations Section and to the Court that OlL
JL Y 17 1997 the olaintiffs attomev advised York Domestic Relations that the oarties had reached an aoreement for the
lDoort of the child ANDREA J HARCLERODE /DOB 10/27/931 and orovided a coov of that aore!!ment It is reco';;~~nded
larder be entered in accordance with this information
IT IS HEREBY ORDERED that the SUDoort order in the above entitled case be modified effeclive FEBRUARY 22 1997 to
11.00 oer week which is 534 50 Der week Dr $150 00 oer month in base suooort olus $56 50 Der week reoresentino y" of the
,ild care exoenses for Andrea) olus $5.00 oer week on arrears oer t~e aoreement of the oarties Given this order arrears
~ $1 52450 as of Auoust 2 1997 In accordance with the aoreement dunno such times as the minor child is not enrolled in
'vcare due to the olaintiffs exoected maternity leave the davcare exoenses reoresentino the sum of 556 50 oer week shall be
:sDended This action mav be taken bv soecial court order wilhout a conference effective the date said child care exoense
luld cease The olaintiff is advised to notify York Domes~c Relations of the exact date oavment of child care ceases within
ven davs of its occurrence All existino suooort orovisions oertainino to Andrea unchanoed herein remain in full force and
'ect The defendant's waoe attachment shall be increased accordinolv This order resolves the Petition for Amendment
bmitted on Mav 23 1997 therefore the conference scheduled for Seotember 3 1997 before Conference Officer Jennifer
'Ibv Is herebv canceled Payment under this order is to be made to Domestic Relations Section, P.O. Box 1502. York, PA
405 and is to commence immediately in the amount of the order (or change) until the awarded wage attachment Is deducted
the employer. Both parties are required to comply with all Policies and Procedures of Domestic Relations. Parties ara under
I continuing obligation to inform the Domestic Relations Section and all oth~r parties in writing within seven (7) days of any
Iterial change in circumstances relevant to the level of support or the administration of the support order, including. but not
ited to. loss or change of income or employment and change of personal address or change of address of any child receiving
Jport. Willful failure to inform Domestic Relations of this required information may result in the Court adjudging the party in
1tempt pursuant to Rules 1910.21-1 through 1910.21-7 punishable by one or more of the following: jail, fine or probation. At
, time a defendant Is not paying the order due to medical problems and/or insufficient income, the monthly reportingIJob
Irch requirements of York DomestIc Relations must be followed. Income will be attached unless the obligor is nOllhirty days
Irrears il!lIt good cause exists not to attach QLa wntten agreement is reached between the parties providing for an alternative
engement. this second optior> applying to non-welfare cases only. Any past dUl! support is a judgment by operation of law.
ses with qualified arrear~. including medical accounts, will be submitted to the IRS intercept program. Pursuant to 23
C.S.A 4308, noncustodial parent's state lottery winnings may be Intercepted for payment of back support. Pursuant to 23
C.S.A 4352(a), both parties are entitled to request a review at least once every 3 years from the date of the most recent
er or modification upon the filing of a pelition to modify Pursuant to 23 Pa.C.S.A 4309. names of obligors delinquent mora
n 30 days may be published in general or special Circulation newspapers in the county. Pursuant to state and federal law,
nes and account balances of obligors delinquent more than 60 days shall be provided to consumer reporting agencies upon
ues! There is a 5.20 per week service charge that must be paid by the Delendan!
. Plaintiff: Defendant: L Serratelli Esq - Deft.: M Miller Esq - Plntf
Tlyzl
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Exhibit "E"
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CO U R T 0 F COM M 0 N P LEA S, YORK COUNTY PENNSYLVANIA
DOMESTIC RELATIONS SECTION
ifjs9n ,. Betsko
alnul
No. ill Support Action 21
Action in Support
DRO No. n2J..5.ll
DPW No. ~
JefflfY A. Harclerode
De endant
, ..
ORDER OF COURT
AND NOW,
and to the Court that
been presented to the Domestic Relalions Section
. . . .
.
IT IS HEREBY ORDERED that
.,. w
Payment under this order is to be made to Domestic Relations Section. P.O. Box 1502. York. PA 17405
ani! is to commence immediately in the amount of the order (or change) until the awarded wage attachment
is deducted by the employer. The total amount ordered for arrears it to continue ill eITect until all accounts
are current. All payments are credited to current support obligations first, with any I!ayment in excess to be
applied to arrearages. BOlh parties are to comply wIth all Policies and Procedures of Domestic Relations.
Parties are under the continuing obligation to Inform the Domestic Relations Section and all other parties in
writing. within seven (7) days of any material change in circumstances relevant to the level of support or the
administration of the support order. includinJ1. but not limited to, loss or change of income or employment
and change of I'ersonal aadress or chan!le of address of any child receiving support. Willful failure to
inform Domestic I<elations of this reqUired information may result in the Court adjudging the party in _
contemptl'ursuantto Rules 1910.21-1 IhrollL!h 1910.21-7 punishable by one or more of the following: jai I.
line or probatiun. Income will be attached unless the ubligor is not thirty (30) days in arrears and good
cause exists Ilutto allach w: a \Hillen aL!reement is reached between the parties providing for an alternative
arrangement. this second option apl!lviiig to nun-\\e1fare cases onl\. An\' past aue suppurt is a judgment 1'1)
operation oflaw. Cases With quafified arrears will be submined to' the I~S intercepl program. Pursuant to
23 Pa.C.S.A. 4308. noncustodllll parent's slale lonery winnings may be inlercepted for pavment of back
suppon. Pursuant to 23 Pa.C.S.A. 4352(a). both parties are entitled to request a revic\\ at least once every
three (3) vears from the dale of the most recent order or modilication upon the filing of a petition to modil\'.
There is a $.20 per week service charge on support orders which must be paid by the defendant. .
By the Court.
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1'(' Platnlit't'. 0\11\ \1. ....Iilh:r
Dekndanl: ..Jim l.. K. Serratelll
JTS .
Judg\'
Date Mailed 8/26/97
Wurker JTS P&P enc. P _'D_/Both_ 'Nu .1li
Exhibit "r"
JAH-23-98 09:21 PM JEFF HARCLERODE
717 432 7937
P.0"
December 11, 1996
JefT,
I am proposing to you a polentially more agreeable tUTInsement that is clearly in the best illierost
of Andie. I al1l tOlally 8Ilainst Andie further developinll psycholollical and emotional problO,tns
that are becoming apparenl 10 us. You must understand Ihal the prcscnl arrangement is clearly. .
having detrimental afTecb on Andie. You must pul aside any feelings of pride and consider whal .
is best for Andie. .
There con he one unified flll1\ily. There can be dinners, eveningl, events and holidays shared al
Sue's hou.e or some olher location like an amusemenl park, boll pork, city park or restaurant, for
e"Dlnple. We can all be one family. Of course, there is 10 be some give and take.
We can go on as it is now. Miscrable. We are not pleased with alot of thin liS and it will nol be
repealed again here because you have already heard it from Sue. We slrong'y recommend that
you yIeld full cu.~ody to us llS h is in Audie'. be>! inlc..e... We ..bo want you 10 maintain positiv.'
conlacl wilh Andie thaI is mutually beneficial between you and Andie.
In principle, this is the proposal as follows:
.~
. Visitation rights on a1lernating weekends
. RJght 10 visil Andie al Sue's home on a weekday nighl on an alternating week basis
. Rig,hllo shan: birthduys and holidays al Sue's home
. These righls exlend 10 Donnll, of course
. Allow Sue and Joe to "isit Andie at your home once evei)' three monlhs
. You accept role a.~ Uncle
. Donna accepls role as Aunl
. Financial responsibility for Andie's day core and schooling will be reduced 10 25%
. You relinquish parental rights
If you agree 10 ac<:epllh.se lenns, we can hove one big family that can do things logether.. We ,
want 10 e"ereise control over her development. At Ihe same time, we are welcoming you intO our
house to spend lime with Andie and even hove dinner with uS if you would like. (fwe canlll..
aeccpl our rolos within this big fDlllily, we con cr~.lo a less confusing ond contentious climate for'
Andie who is al\.r all way 100 young to be stressed out over all of this. She does not deserVe it.
1 om Irying to promo'" a bellcr environment here for all of us involved. Please note .vcn thouGh
We ask you to relinquish your parental rights, you will not lose your visitation rights as desCribed
above. Call Sue either way by this Saturday if you want 10 opl for Ih. one big family approach or
if you want 10 mainlain the division and ils delrimental eITecls.
Sincerely,
Joe
EXH1BIT
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IN TIlE COURT OF COMMON PLEAS OF YORK COUNTY. PENNSYLVANIA
.1E.F'FREY A. HARCLERODE,
Plailld1f
No. 96-SU~1800-O:ZC
VI,
ova ActiOD . Law
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SUSAN L. HARa.ERODE DETSKO.
Defendant
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APPEARANCES:
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Susan A. Doctor, Esquire
Cor the Plaintiff (father)
MicheDe Pokri1ka, Esquire
Cor the DefendaDt (mother)
ORP~R
Both parties and their respective counsel appeared at the conciUatloD conferencc
acbeduled for Wednesday. October 2, 1996, before Conciliator, Dorothy Livadids, It is
DOted that this actIon wu initially commenced by the ftIlng at a custody complaint in
Cumberland County, PennsyJvlUl.ill, by the mother, Counsel advised the conciliator that the
parties amicably agreed to the withdrawal of that complaint and the ac:tlon being heard In
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the Jurisdiction of York County. Pennsylvania. Thereafter, Jeffrey A Harclerode, the father
of the minor child, Andrea Jane Harclerode, born October 27, 1993, filed n custody action
in the York County CDun ot Common Pleas 5eeldng majority physical custody of his
daughter, The mother then ftled a counter.claim also seeking majority physical custody of
the chIld. It is further noted that these panics enlered Into a Marital Settlemeut Agreement
.
on or abo:Jt July 23, 1996, a copy otwhlch b DttlIched to Plain~s complaint and, therefore,
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I part of the record, Furthennore, there have been some issues raised by both parties that
they have nOlO been fully complying with !he terms and conditioo:l of the custody
arrangement set forth in that agreement,
At !he conciliation conference, each party indicated his or her present desire to
continue to pursue majority ph}'3ical cwtody of !he child. As a result, it is Otdered and
...-
Directed that !hese parties undergo Court-ordered mediation with Dr, Stanley Schneider,
(717) 732.2917. Both parties were provided wire written instrnctiOo:l as to how to contact
Dr. Schneidet to pursue this mediation. It is the Court's desire that in addition to the usua1
mediation Issues addressed, Dr. Schneider attempt to address with these parties the Issue
of communication between them as to any problems or difficulties arising regarding the
custody of this child.
It is hoped that !hese parties. will be able to reach an agreement regarding the
custody Issues through Court-ordered mediation. However, in !he event that they are unable
to do so, cO\1DSel for the parties are reserved thirty days after the completion of mediation,
to agree upon an independent evaluator to complete psychological evaluations of the parents
and their spouses if this matter is to proceed to a full hearing, If !he parties cannot agree
to an independent evaluator within that thirty clay period, either party may request
\
psychological evaluations to be completed at his or her own full expense and each party and
their respective spouse arc directed to cooperate with these evaluatioo:l, Furthermore, the
parties must also attend and complete the Kids First Custody Workshop on or before
December 6, 1996, Since both parties reside in the northern part of York County,
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Pennsylvania, it will be aCC4ptable (or ellJler or both ot them to attend the Inne.rworlc.s
Custody WorJahop sponsored by the Dauphin County Couns. In eilhcr ClUe, each parent.
upon completion, mU3t file a CertIficate ot Completion either of the KIds First Custody
Workshop or the lnnerworu CU3tody Worlahop with the Prothonotary's Office of York
County on or before December ~,1996. The part1cs are reminded that they arc under
..,.
Court ardor to comple[e both the mediation and the CUlItody worlc.shop and their failure to
do 10 may reault in their belna brollBht before the Court and appropriate sanctions being
entered.
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Furthermore, In the avent that media lion Is IlIlSUCce$sful, upon completion of
mediation, the CUltody workJbop and tho psychological evaluations, if requested, counsel
&haJ1 then contlct the Coun 10 schedule II prehewg conference so that this matter may
proceed to a i1nal bOllnol.
In the interim, It II Ordored and Directed that the custody provi3loIlS lIS set forth In
tho Murial" Settlement AllI'eement dated 1uly 23,1996, and incorporated into the Divorce
Decree and ardor of Court on or about Augwt 6. 1996, sbalI remain in full force and effect
and mall lovom untJI Author Order of Coun. That Agreement and Order provided for
shared lelal and physical cWltody of tho child which shall continue,
It wu acJmowledled by the tathcr at the conciliation conference that he has not been
regularly exerclllnl hi. custody riih13 on Wedoesda\ avening3 pursuant to the agreement of
the partIel, He I1lU voiced some concerns about providing continuity for the chlJd and
further indicated that be bas not made a final decision as to whether he wilIhes to continue
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his custody rights on Wednesday evenings or to waive them, The mother, however, clearly
stated that she wishes to continue exercising her rights on Wednesday evenings while the
father has physical custody of their daughter. It is directed that the father make a decision,
at least for the time beinJl, as to whether or not he intends to exercise his custody rights on
Wednesday evenings, In fairness to the mother, she should be given advanced 1I0tice as to
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the father's intentions. It has be~n suggested 8IId is now directed that once he reaches a
decision, which should be done In the very immediate future, he should advise the mother
accordingly, This Order is not terminating the father's custody rights on Wednesday
evenings. but it is specifica1ly directing him to advise the mother of his present intentions,
,
and, in the future, if he changes his mind, he should at least give the mother notice no later
than the time that custody is transferred to the mother on Friday evenings as to what his
Intentions are as to the upcoming Wednesday evening. Obviously, for both panles, this is
not addressing any emergency situations which might prevent either of them from exercising
their custody rights on Wednesday evenings,
A copy of this Order shall be provided to both counsel so they may fOIWard a copy
to their respective client. A copy sbalJ also be forwarded to Stanley Schneider who sbalJ be
conducting the Court-ordered mediation. Additionally, counsel are requested to provide a
copy to the selected evaluator should evaluations later be requested,
Date: ~ 't'. I~
BY TIm COURT:
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having custody from Wednesday. October 9. 1996 untU Friday. October 18.
. 1996 and the father having custody from Friday, October 18, 1996 at 4:00
p.m. until Wednesday, October 23. 1996 at 8:00 a,m. /9:00 a,m. and
alternating thereafter;
b,
On alternate holidays, beglnnlng New Years Day. The holidays are: New
Years Day, Memorial Day. Fourth of July, Labor Day and Thanksgiving Day,
Such custody shall begin qt.9:00 a,m. and end at 8:00 p.m.:
The Christmas Eve and Christmas Day holidays shall be as mutually
agreed upon by the parties, In the event that the parties cannot reach an
ainiccble agreement as to these holidays. the following schedule shall
apply:
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In even numbered years. father shall have partial physical custody
from 12:00 noon on Christmas Eve until 12:00 noon on Christmas Day.
This provision supersedes all others,
In odd numbered years, father shall have partial physical custody
from 12:00 noon on Christmas Day until 12:00 noon on December
26th. This provision supersedes all others,
"
d, During the swnmer. each parent shall be entitled to a two (2) week period
of uninterrupted custody, said period may be consecutive, Each parent
shall notify the other. in writing. sixty (60) days in advance, of his or her plan
to exercise this two (2) week perioeL In the event of a conflict the parent to
first notify the o.ther shall prevail,
,
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Father shall have right of custody on every Father's Day from 9:00 a,m, until
8:00 p.m. with Mother having that sarne right every Mother's Day from 9:00
a,m. untU 8:00 p,m, This provision supersedes all others,
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: ! informed as to the medical care and treatment of the child.
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5. ~edical CarelT'reatment. Both mother and father shall be immediately
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II 6. Relocation. Upon the knowledge of pending relocation, temporary or
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; : permanent. of either parent. that parent must immediately inform the other of hls/her new
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:: address and telephone number.
7. Seat Belts and Child Restraint Sp.ats. Both parties shall utilize child restraint
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8. Teleohone Contact. The parties agree that the child Is to have ltberal rights of
11. The mother and father agree that they are voluntarily entering Into this
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i Agreement with full knowledge and wish for the Court to adopt It as a Court Order.
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IT IS SO ORDERED,
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. BY~emflT.:...,:::::. I ~. n Q
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,~ -Penny L. Blackwell. Judge "0 V .0 1 1996
seats and seat belts when transporting the child byautomobtle,
telephone contact with the non-custodtal parent. no matter who Is exercising his/her right
to physical custody.
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I 9, Transportation. Unless otherwise agreed upon between the parties. the Cather
I shall be primarily responsible' for provtding transportation In the exerclse of his custody
rt h "~S~ Mo-i4r re.IIlC<\l<.i ",orL~4.1oi A tt'I(IC) ",;\.t. ,..a:d;lIS~,,,, Oil\~l;v'j;PA
+~n t~~l'" It\\<.l 'Fa.~V" \Vi\l S~"'Y'( -tI'-A"~p6...tl\hc.. L)l.p.c.nLJl. Ii^,"~~ +0 91l.~ ll~cl {ells "";~"
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I C !U. LeQal Residency. The legal residency of the aforementioned child, not
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! I withstanding where the child may live at various times. shall be the same as that of
.: mother.
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We have read and consel1t to entry of the foregoing Order.
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. J!:ftfrey KHarclerode
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Susan L. Harclerode-Betsko
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FI.a. BcJC- !:51Be
1:;15 NOM:h Georg. Scr.et;, Suit.a 303
York, PennttylvlIIrQI 1740S-e1Be
[717) 85:2-70:20 · F.... [717) fl~:;;! El7S7
I DO HEREBY camFY THAT THIS IS A TRUE.
COfIRECT COPY 01' 'OlE ORIGINAL DOCUMI
fILED OP Ac"""","1.I
BY
IN THE COURT OF COMMON PLEAS
OF YORK COUNTY, PENNSYLVANIA
= PflIT/ONER'S
I,. EX.HIBIT
JEFFREY A. HARCLERODE
NO.
96-SU-01800-02C
v.
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AND NOW. TO WIT,
1997, pursuant to the
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Agreement and Stipulation of Jeffrey
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CIVIL ACTION.-'LAR:
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SUSAN L. BETSKO
.'
A. Harclerode and Susan L. Betsko, is hereby ORDERED that
the undersigned Jeffrey A. Harclerode and Susan L. Betsko,
Father ~nd Mother, respectively of Andrea Jane Harclerode,
born October 27, 1993, the subject of the above referenced
custody proceeding, hereby agree ~hat the best interest and
welfare of Andrea Jane Harclerode would be served by
amending the Consent Order entered on ~he 19th of October
1996 as follows:
10' I
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5185 I
.org. 51. .
03
JOS.SI8S
1. During such times as Susan L. Betsko is on
"maternity leave", the minor child will remain with her
rather than the previously agreed upon daycare provider.
Mother shall be utilized as the daycare provider during such
.
time as Father is working. Father shall be responsible for
dropping off and picking up the minor child before and after
his scheduled work.
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2. In all other respects, the Order entered on the
19th of October 1996 shall remain in full force and effect.
BY THE COURT,
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IN THE COURT OF COMMON PLEAS
OF YORK COUNTY, PENNSYLVANIA
v.
I NO. 96-SU-01BOO-02C
I
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I CIVIL ACTION - LAW
JEFFREY A. HARCLERODE
..'
SUSAN L. BETSKO
AGREEMENT AND STIPULATION FOR ORDER OF COURT
TO THE HONORABLE PENNY L. BLACKWELL,
JUDGE, COURT OF COMMON PLEASI
Susan L. Betsko and her counsel, The Law Offices of
Niles S. Benn, Esquire,.py Hartin Hiller, Esquire, and
Jeffrey A. Harclerode and his counsel, Lori K. Serratelli,
Esquire, do hereby stipulate and agree that this Honorable
Court, before whom this matter has been assigned, may enter
the Order of Court attached hereto.
S&J$/
HARTIN HILLER, ESQUIRE
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-stfSAN L. BETSKO
LORI K. SERRATELLI, ESQUIRE
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A. HARCLERODE
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11303
1U05.5185
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COURT OF COMMON PLEAS
YORK COUNTY
DOMESTIC RELATIONS SECTION
~ PETITIONER'S
· EXHIBIT
r-::-
.REV A HARCLERODE
,"dant
No. 423 Support Action 1997
Action in Support
DRO No. 62350
......
ORDER OF COURT
,ND NOW, JULY 30, 1997, verification having been presented to the Domestic Relations Section and to the Court that oc....
'17 19971he olaintiffs attorne'l2dvised York Domeslic Relations that the oarties had reached an aoreement ~~=e
~rt of the child ANDREA J HARCLERODE IDOB 101271931 and orovided a coov of that aoreeme~t It i~ ;~~o nded
der be entered in accordance wilh this information
r IS HEREBY ORDERED that the suooort order in the above entitled case be modified effective f'EBRUARY 22 1997 to
'0 oer week which is 534 50 oer week or 5150 00 oer month in base suooort olus S56 50 oer week reoresentino % ~f the
care exoenses for Andrea) olus 55 00 oer week on arrears oer Ihe aoreement of the oarties Given this order a;r~~~s
1 524 50 as of Auoust 2 1997 In accordance with the aoreement durino such times as the minor child Is not enr~II~~ in
Ire due to the olaintiffs exoected maternitv leave. the davcare excenses. reoresentlno the sum of 556 50 oer week shall be
,"ded This action mav be taken bv soeclal court order wilhout a conference effective the date said child care exoens!l
cease The olaintiff is advised to noti'" York Domestic Relations of the exact date oavment of child care ceases within
I davs of its occurrence All existino suooort orovisions oertainino to Andrea unchanoed herein remain in full force and
-!he defendant's waoe attachment shall be increased accordinolv This order resolves the Petition for Amendment
tted on Mav 23 1997 therefore Ihe conference scheduled for Seolember 3 1997 before Conference Officer Jennifer
Is hereby canceled Payment under this order is to be made 10 Domestic Relations Section, P.O. Box 1502, York. PA
and Is to commence immediately in the amount of the order (or change) until the awarded wage attachment Is deducted
. employer. Both parties are required to comply with all Policies and Procedures of Comestic Relations. Parties are under
ntlnuing obligation to inform the Domestic Relallons Section and all othfilr parties In writing within seven (7) days of any
al change In circumstances relevant to the level of support or the administration of the support order, Including, but not
to, loss or change of income or employment and change of personal address or change of address of any child receiving
/1. Willful failure to inform Domestic Relations of this required Information may result In the Court adjudging the party In
npt pursuant to Rules 1910.21-1 through 1910.21-7 punishable by one or more of the following: Jail, fine or probation. At
1e a defendant is not paying the order due to medical problems andlor Insufficient income, the monthly reportlng~ob
requirements of York Domestic Relations must be followed. Income will be attached unless the obligor Is not thirty days
Brs ill!.d. good cause exists not to attach Qt.a written agreement is reached between the parties providing for an altemative
ement. this second option appiying to non-welfare cases only. Any past due support Is a Judgment by operation of law.
with qualified arrears, including medical accounts, will be submitted to the IRS intercept program. Pursuant to 23
1.A. 4306, noncustodial parent's state lottery winnings may be intercepted for payment of back support. Pursuant to 23
i.A. 4352(a), both parties are enlitled to request a review at least once every 3 years from the date of the most recent
ir modification upon the filing of a pelilion to modify Pursuant to 23 Pa.C.S.A. 4309, names of obligors delinquent more
) days may be published in general or special circulation newspapers in the county. Pursuant to state and federal law,
and account balances of obligors delinquent more than 60 days shall be provided to consumer reporting agencies upon
t. There is a 520 per week service charge that must be paid by the Defendant.
Ilntiff: Defendant: L Serralelli ESQ. Deft.: M Miller Esq. . Plntt
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 1997-05615 P
COMMONWEALTH OF PENNSYLVANIA;
COUNTY OF CUMBERLAND
I
IN RE HARCLERODE ANDREA JANE
VS.
SERVE HARCLERODE
R, Thomas Kline , Sheriff, who being duly sworn according
to law, says, that he made a diligent search and inquiry for the within
named defendant, to witl HARCLERODE JEFFREY
but was unable to locate
Him
in his bailiwick. He therefore
deputized the sheriff of YORK COUNTY
to serve the within ORDER OF COURT
County, Pennsylvania,
the attached return from
YORK COUNTY
Count).,
receipt of
Pennsylvania.
On December
8th. 1997
, this office was in
Sheriff's CostSI
Docketing
Out of County
Surcharge
YORK COUNTY
18,00
9,00
2,00
43,25
5/~,~O NILES BENN
12/08/1997
So answers:
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RJ' I homas l'ilJ.ne, ~herJ..t1
Sworn and subscribed to before me
this ll!:c day of ,,,' ,,,,,t~_
19..2..:1_ A, D.
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c~', )~Ld.~,- 1lY.-r.
I'rothonotar'y
In The Court of Common Pleas of Cumberland County, Pennsylvania
IN RE, In the Matter of Petition for Change of
Name of Andrea Jane Harclerode
VS.
SERVE, Jeffrey A. Harclerode
No.
97-~615 Civil
19_
Now, Nav. 3,
York
19~,1 SHERIFF OF CUMBERLAND COUNTY, PA do hereby deputize the Sberlffof
County 10 exeeule Ihls Writ, Ihls deputallon being made atlbe request ond risk of the Plalnllff,
~(" -~~
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Sheriff of Cumberland Counly, Po.
Affidavit of Service
Now,
wllhln
Noverrber 13 1997
Order of Court, Petition for Chanqe of Name,
P i\I, served Ihe
,01 6: 33 o'doek
Amended Petition
upon .1effrp.y A H;t f"l ..rod..
01 1940 Old York Rd., Dillsburg,
by hondlng 10 Jeffrev A. Harclerooe
oltesled copy of Ihe original Order of Court,
him Ihe contents Ihereof,
PA 17019
Petition for Chan~ of Name,
Fullt::uclt::d ~1 t:.1011
a Irue and
and mode known 10
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So answers,
, el-1t<n~ t<(/--J~
~ Sheriff of York County, Po.
Royce Eeaverson, Deputy Sheriff
COSTS
Sworn ond suhscrlbed hefore
me this day of
SERVICE
MILEAGE
AFFIDA \lIT
s
-ft.'r/:.:j,l J (;'1"" .lit,
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PROOF OF PUBLICA TIOili OF NOTICE
IN CUMBERLAND LA W JOURNAL
(Under Act No. 5H7. upproved Muy 16. 1929). P. L,I784
STATE OF PENNSYLVANIA :
55,
COUNTY OF CUMBERLAND :
ROller M. Morllenthal, Esquire. Editor of the Cumberland Law Journal, of the County
and State aforesaid. being duly sworn. uccording to luw. deposes und suys that the Cumberland
Law Journal. a legal periodical published in the Borough of Carlisle in the County und Stute
aforesaid. was established Januury 2. 1952. and designated by the local courl~ as the officiul
legal periodical for the publication of ulllegal notices. and has. since Januury 2. 1952, been
regularly issued weekly in the said County. and that the printed notice or publiclltion attached
hereto is exactly the same as was printed in the regulur editions and issues of the said
C:Jmberland Law Journal on the following dutes.
viz:
NOVEMBER 14.1997
Affiant further deposes that he is authorized to velify this statement by the Cumberland
Law Journal, u legal periodical of ger.el1ll circulation. and that he is not interested in the subject
matter of the aforesaid notice or advertisement. and that all allegations in the foregoing
statements as to time. place and character of publication are true,
/
Roger M. Morgenthal. Editor
SWORN TO AND SUBSCRIBED before me this
14 day of NOVEMBER. 1997
../f:" ~ t~~jh( ,('//~
Notary /
NO"API"l S!,.I.l
IClS f SNYDER. "'''''y Pvblic
Carli". &cuo. Cumb.oond COllnty, PA
My CummluiOf1 bpirfl Man:h.5. 2001
.
!lanes
NO'I1CE IS HEREBY OIVEN that
on October 10. 1997, th. PoUtIon oC
Suun L. Betako wu rued In lho
Court oC Common PI... of Cumber.
land County. Ponnaylvanla. praying
lOr a dec.... to .hang< h.r daughl.er'1
name to Andrea Jane Uarclerode
Betako. An Am.nded PollUon wu
Died With th. Court on Oclober 27.
1997.
Th. Court hal fixed JanulU)l 29.
1998, at9:1J0A.M.ln Court Room No.
5 of the Cumberland County Court
House as the Ume and place (or the
heartng oC ..1<1 PoUUon. wh.n and
wh.... all po~no !nt.rooted may "I"
pear and show cause, If any they
have, why 111. pray.r of 111. PeUlloner
ohould not be granted.
MartIn Miller. Eoqul...
Nov. 14
Cumberlond ".UCII
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
IN THE MATTER OF PETITION
FOR CHANGE OF NAME OF
ANDREA JANE HARCLERODE
NO. 97-S6IS-CIVIL TERM
PROOF OF PERSONAl. SERVICE
Martin Miller, Esquire, hereby files a Proof of Personal Service and states that on the
131h of November 1997,the SheriffofYork County, Pennsylvania, being duly deputized by the
Sheriff of Cumberland County, Pennsylvania, did serve Jeffrey A. Harclerode a copy of the
Order of Court, Petition for Change of Name, and Amended Petition for Change of Name,
A copy of the Sheriffs Statement is aU ached hereto and incorporated herein by
reference as Exhibit "A",
Respectfully submitted,
LA W OFFICES OF NILES S. BENN, ESQUIRE
Wav'tt%/{ ~
Martin Miller, Esquire
AlIomey I.D. #63021
P.O. Box 5185
135 North George Street, Suite 303
York, Pa 17405-5185
(717) 852-7020
law Offices of
Nil.. S. Blnn, elqulr.
p.o. BOK 5185
1 35 No~h Goorgo 51.
Sullo 303
York. PA 17405.51B5
,
In The Court of Common Pleas of Cumberland County, Pcnnsylyunia
IN RE. In the Matter of Petition for Change of
Name of Andrea Jane Harclerode
VS,
SERVE. Jeffrey A. Harclerode
No.
'J7-~615 Ch'i 1
19_
Now, Nov. 3,
19~,1 SIIERIFF OF CUMBERLAND COUNTY, PA do hereby depullze Ih. Sherltrof
Counly 10 uecUI. Ihls Wrll, Ihls depulatlon belnll made allhe requesc and risk or Ihe Plalnllrr,
York
;~c".. ,.Y;y.~
.--~
SberlrrorCumberland Coun!)', Pa,
Affidavit of Sen:ice
Now,
wllhln
Noverrber 13
Order of Court, Petition
1997
for Chanqe of Name,
, al 6.33 o'clock
Amended Petition
P ~I. served Ihe
upon Jeffr~y A H~r~lprnrlp
al 1940 Old '{ork Rd., Dillsburg,
by h.ndlng 10 Jeffrev A. Harclercx:le
."eSlld copy orlhe origlnol Order of Court,
him the conlenls thereof.
.-
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PA 17019
Petition for Chan~ of Name,
Allltmdt:d titlull
o Irue ond
and made known to
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'f.,
elf f~/~tl ~~ t~ c~/~!.r~
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(fA;--- J SherifTof '{ork Cuunly, P..
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Royce Beaverson, Deputy Sheriff
COSTS
Sworn and 5ub"crihed hefore
me thi5 da~ or
19-2]
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SERVICE
~IILEAGE
AFFIDA \'IT
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EXHIBIT "A"
s
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 1997-0~G15 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
IN RE HARCLERODE ANDREA JANE
VS.
SERVE HARCLERODE
R, Thomas Klin~ . Sheriff, vho being duly svorn a~cording
to lav, says, that he made a diligent search and inquiry for the vithin
nam~d d~f~ndant, to vitI HARCLERODE JEFFREY
YORK COUNTY
OF COURT
County,
He therefore
Pennsylvania,
but vas unable to locate
deputized the sheriff of
to serve the vithin ORDER
Him in his bailivick,
the attached return from
YORK COUNTY
County,
receipt of
Pennsylvania,
On December
8th. 1997
, this office vas in
Sheriff's Costs:
Docketing
Out of County
Surcharge
YORK COUNTY
So ansvers:
18.00
9,00
2.00
43,25
5/~,L5 NILES BENN
12108/1997
~. /
IF ..../"",..J ';;'-e#-"
RJ lhcmas Kl~ne, ~her~!Z
~/
Svorn and subscribed to before me
this
19
day of
A, D.
I'rot.honot.ary
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
IN THE MATTER OF PETITION
FOR THE CHANGE OF NAME OF
ANDREA JANE HARCLERODE
No. 97-5615- Civil Tenn
PROOF OF NOTICE OF PUBLICATION
Martin Miller, Esquire, hereby files a Proof of Notice of Publication and states that
on the 41h day of November 1997, he did cause to be published in The Sentinel, a newspaper
of general circulation in and for Cumberland County, Pennsylvania, a notice of the date,
time, and place of Hearing in regard to above referenced matter, pursuant to an Order
entered by the Honorable J. Wesley Oler, Jr., Judge, Court of Common Pleas.
A copy of the Proof of Publication is attached hereto and incorporated herein by
reference as Exhibit "A".
Respectfully submitted,
Date: 11/1f/1r-
,
The Law Offices of Niles S. Benn, Esquire
BY:~~~
Martin Miller, Esquire ~
Attorney ID # 63021
P.O. Box 5185
135 North George Street
York, PA 17405-5185
(717) 852-7020
Law Omen of
Nil.. S. 8.nn, Elqulr.
P.O. Box 51B5
135 North George Sl.
Suile 303
York, PA 17405.5185
.
fRQQE
State of Pennsylvania,
County of Cumberland,
Sherry Clifford, Classified Advertising Manager 01 THE SENTINEL,
01 lhe COunly .nd SIal. .Iorll.Id, being duly 1W0rn, depo"l Ind "YI lhal THE SENTINEL, I newlpap.r 01
g.neral circulation In lhe Borough 01 Carllll., cuunlY and SIal. alor.sald. w8IlItablllhed Dec.mber 131h.
1881, linea which dat. THE SENTINEL hal bean regularly ISlued In laid County. and Ihalth. printed notlc.
or publication aUached herelo II exactly Iha same as was prlnled and published In Ihe reular edltlonl Ind
IHUII 01 THE SENTINEL on Ihe lollowlng dalll, vlz
Copy of Notice of Publication
November 4. 1997
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Affiant further deposes that he Is not Interested In
the subject matter of the aforesaid notice or
advertisement, and that all allegations In the
foregoing statement as to time, place and character
of publication are true.
i4!7 .~.,/
November 5. 1997
Sworn to and subscribed before me this 5th
day of November ,19 97
JJ4 1 ~PUbIlC
My commission expires:
rj('Jl.ll,,],,~.IHI
W d L MIlI.'{jfl( I'l<jtilr) r\,hllr.
on 'I. ~', '11'\1 t'~'Jl1ty
Call1~le BOloJ LUlfl ),'1 ',.; ~ ;COI
Mr' Cornl\ll!,~,:...n ~ _p,rt., .hll . .' ~
), . t,'1i'~ I)' ':C,I,If'6S
Mr.f;IV::, p,""",~ .jr'!, "~l, ".
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IN THE MATTER OF
PETITION FOR CHANGE OF tiAME
OF ANDREA JANE HARCLERODE
IN THE COURT OF CO~~ON PLEAS OF
CUHBERLAND COUNTY, PENNSYLVANIA
NO. 97-5615 CIVIL TERM
AND NOW,
ORDER OF COURT
this I'~day of October, 1997, upon consideration of
the Petition For Change of Name, it is ORDERED that a hearing on
Petitioner's request be held on Thursday, January 29, 1998, at
9100 a.m., in Courtroom No.5, Cumberland County Courthouse,
Carlisle, Pennsylvania.
IT IS FURTHER ORDERED that the notice of tho filing of said
Petition and the aforesaid date, time and place of the hearing be
published once in the Cumberland Law Journal and a newspaper of
general circulation in the County at least 10 days prior to the
hearing; in addition, petitioners shall comply with all other
requirements of C.C.R.P. 5, and the Act of December 16, 1982, P.L.
1309, S6, and 54 Pa. C.S. SS701 et seq.
BY THE COURT,
J
J.
Martin Miller, Esq.
P.O. Box 5185
Suite 303, 135 N. George Street > '''''''L~.,I C..".., Iu 1)-. 'i 7
York, PA 17405-5185
Attorney for petitioner
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MID NOW. hI 1\l1.lhis ___ da~ (If(kl(lhcr. 1')'17, upon consideration ofa Petition
II
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.-\ h~aril1g shall h~ scheduled and held hefore th~ HOl1orable
. . . n.' Judge. Coun (If ('1I1111110n Pleas, on the
da~ of.
_' 1'1'17.:11 .___ n _____ a.II1.1p.lI1. in Coun
Rooll1 #
oflhe CUlll!>erland County (",un House.
2
Pelil,on"r. Susan L. Belsko. ,halllJl(l1 I<k nollee of ,aid hc;mng upon JefTre~
!\ lI;uclcrod~. Ih~ 110n'p~ln;"l1l11g par~'11 of sail I child.
3 A eop~ "f this Order shall be pllhltsh~d 1I111~1I 'p.ll'er of general circula,tion
111 CUlllherland ('ouall. P~nthl II allla. ,1I1e of IIluch lIlay be the official paper
for I'uhhcallllll of kgnl''''llll' III s;,id elllll1l~
B) The ('ourt:
J.
Law Offices of
HII" a. Blnn, Eaqulrt
PO. Box 5185
135 Nonh George SI.
SUile 303
Yo",. PA 17405.5185
11\ TIlE ('OI,R r 01' (,O\I~ION PLEAS
OF C'l.IMIlUU.AND COUI\TY. PF'INSHVANIA
IN TilE M.\'1TI'R OF PETITION
FOR CHANGE OF N\ME OF
Ar\DREA JANE IIAR('I.ERODE
NO. r, '1. ':J' (. I"; Ct:vr./~__
l'nlTlO' FOR CIIA\C;F: OF N,\I\l~:
'r^-
,\ND NOW, 10 I\it. this IP _ d;l) IlrOctllbcr. I'J'J7, cOllies Ihe Petitioner, Susan L.
Bels.o. II ho on bchalf or hcr minor child. Andrea Jane Harclcrode. and Ihrough their
al1omeys. The Lall Oflices of Niles S BClln "'quir,'. hy Marlin \liller, Esquire, files the
lIilhinl'clilion ror Change or Nallle pnrsuanllu ~,ll'a C'.S.A Scdion 701 !<t. ~., and in
snpporllhereur rcpr,'s,'nI5 lhe 1'0111'" in!;
I. PClillolK'r. Susan I.. Bcls~o, i, an adull illdi\ idual currcnlly residing at 17~ I
\Vealherburu Dri\ e. l\ell ('lImhcrl;lIlll. CIIlIlhcrlmul County. Pennsylvania,
and has rcsidcd at said Itlcalilln sincc ~Iay 19% Prior to rcsiding at thc New
Cumbcrland residencc. she rcsidcd al 11).10 Old York Road. Dillsburg. York
('ounly. Pcnnsy I\'ania. 1i.1I'ilpplll,illlaldy 9 ycars
2. P,'lilioner. SUs.1n L IIclsko. marrrcd Jcmey A Ilmclcrodl' ("Harclerodc")
on OClohcr 13. 19X~.
3. Pelilioncr. Susan I.. Belsko. ;11111 Jcll're) A. Harderude arc Ihe nalural parents
of Andrca Jane H;lrclerodc. horn (kloh,'r 27. I'Jll3.lhe subject of the hcrcin
I'elilion.
4 Pelilloncr. Susan I.. Bcls~". ilnd Jcll'rc) A. Hmdch,dc divorced pursuant to a
Ikcrcc in DI\orce on Au['u,1 (', 1'1%.
LIW O"ICII 0'
NU.. S. Blnn, elqulrl
p.o. Box 5185
135 North Olorgl 51.
5uUo 303
York. PA 17405.5185
5
The Honorable 1"'11I1) L Bl,Kkllcl1. Jud~e. YOlk ('ounly Court OfC01111\10n
Pkas. grantcd Pclitillncr. SIIs;m I. Iklsl.o.llla,ltlllty phy sical custody of
Alldl~a J:lIl,'lla..c1~lllde 1'"'''IiIIII''.I11 flrd~r d.ll~d O~lub"r K. I'll)(, 'n,~
('('lIllli,rth.:r ~1I1~r~d .1 ('""', III (lrd~r UII /l.ol,'mber I, I 'll)(,. 'nl~ Court
~1I1~r~d allulh~r Ord~r 1I1l11ht'~ "'!l Ih~ NUl ~mb"r I 'III{, ()rd~r, on July 21.
11"11. A cOI'Y ofalllhrc~ ()rlk.., :II~ .I11.lch~d h,"~I" and II1corporal~d h~rein
as E\hihit "\", E\lub'l "II" .lI1d hlllbll "C", ..,speclli,lIy.
II TII" lIullorabl" Michael J 1J,.,lIh,ul. JudJ", Ynrk C,'lInly COllrt of('omll1on
Ilkas, ~1I1.:r~d all Order of ('uull d'II.'d Alml ~~. 1111)7. outlll1ingllarcl~rod~'s
obligalionlo pay n1<ll1l~s 10 P,III'oll~r. Susan I. Iklsko. for Ih~ support of
Alldr~a Jan~ Harcl~rod~ S:lId Suppllrt Ord~r lias subscllu~nlly modifi~d by
Ord"r ufComl dal~d July ~II. 1'1'17. and ,\lIgllsl ~6. 1'1'17. A copy oflhe
Ihre~ Onkrs ar~ allach~d h~rdo alld ill~Ilrpllral~d h~rdn by rcf~renc~ as
Eslllblt "[)". Eshihil "E" .1I1.! Eslllhll "F". r~sp~';li\ e1y.
7. P~tition~r. Susan L Bdsk". l1lalTl~d Jus<'jlh B~lsko on S~pl~l1lbcr 30. 1997.
K. Pclilion~r d~sir~s 10 chang,. Ih~ lIam~ llf .\lIdr~a Jan.; Harclerod~ 10 Andrea
lIarckrod.; B~tsko.
lJ I'~tition~r \\'sh~s 10 chan!',~ Ih~ n:uu~ of Alldr~a jail'; Harclerode because she
had a dul.!, Alyssa JlIslin~ Iktskll.IIl Jos~ph Eklsko on August 15, 1997, and
sh.; lIalllS Andr~a to bear Ih~ 'alll<' n:\llIe Alyssa Justin E1elsko or any olher
childr~n born ofth~ir marriag.; :\Ior,;ol~r. P~tllillller al.:rs Ihallh~r~ arc
certainl's~ cholog,c.11 alII alllag~s 10 I'erminingth.; nam~ change. Also, Ihere
II ill b~ a cOIISlstency of name us,' mlh.; Il~tskl) l;lIll1ly.
III. 1'"li"on,'r hdiel es. and lh.;r,,','r~ :\1 "rs. Ihal it.s IIIlhe best interests of
Andrea Jan,' Ilarcl.;rO\k III "'Ih' her nam.; ,'hallg,'d 10 Alldrea Harcl~rode
Ilctsko.
Law Offices of
Nil.. 8. B.nn, Elqulr.
P.O. Box 5185
135 North aoorgo 51.
Sulto 303
York, PA 17405.5185
II.
Ther.; .II''; no judgements or d\'~r,'" Ilrt i ~ e chara~ter of r.;cord against
..\IIdr,'a Jail'; Ilarderod"
WII~:IU:F(ll{t:. I'dllIOllcr', "'I',-,lillh r,qll"llhli 1I(lllorabl~ Court 10
~11I~r a d"r,'~ ""'"!,llIglh, 11(\11\, "r\II.!",';\ Jail. lIar.!.ro.k to Andr,a Jan~ B~lsko.
Rt'I'~l'lfull)' "Ihlllill~d.
I.A\\ O....'I('ES OF 'I1.t:S S. BENN, ESQUIRE
,~~-~
Allorne)' I.U. #6J021
Allomey for Pelition~r
P.O. Bo\ !i18!i
1J!i North (;eorg~ Str~el. Suite JOJ
York, p" 11./05-!l18!1
(7J718!12-7020
Law Ollie.. of
Nil.. S. Benn, Elqulr.
P.O. Box 5185
135 North Goorgo 51.
Suile 303
York, PA 17405.5185
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VF.RI FICA TION
I. Susan L Uetsko, verify thatthc statements contained in the foregoing
Petition For Change Of Namc are true ,lI1d Clllrectto the best ormy knowledge.
inl\lrIllation and belief I understand that tillse statements herein are made subject to
the penalties of IS Pa. (' S 4904, relating to unsworn falsitication to authorities.
Date:
I
_.LO!UlLrL__
~~4 4~L/
_ :~..r.:-__..
Sl n L. Betsko
Law Offices or
Nil.. S. Senft, Elqulr.
P.O. 80. 5185
'35 North George 51
Sulle 303
York. PA 17405.5'85
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IN TIlE COURT OF COMMON PLEAS OF YORK COUNTY. PENNSYLVANIA
JEFFRBY A. HARCLERODE.
Plalnlitr
No, 96-SU-oIBOO-02C
va.
Qvl1 Action. Law
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or ~
SUSAN 1.. HARCLERODE BETSKO,
Defendant
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Custody
APPEARANCES:
\
Susan A. Doctor, Esquire
for the Plaintiff (father)
MicheDe Pokrl1ka, Esquiro
for the Defendant (mother)
ORDER
Both parties and their respective coUllSel appeared at the conciliation conference
scheduled for Wednesday, October 2, 1996, before Conciliator, Dorothy Livaditis, Itls
noted that this action was initially commenced by the filing of a CllitOdy complaint in
Cumberland County, Pennsylvania, by the mother, Counsel advised the conciliator that the
parties amicably agreed to the withdrawal of that complaint and the action being beard In
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ilia jurisdiction of York County, Pennsylvania. Thereafter, Jeffrey A. Harclerode, the father
of the minor child, Andrea Jane Harclerode. born October 27, 1993, filed a custody action
in the York County Court of Common PlellS seeking majority physical custody of his
daughter. The mother then filed a counter-claim also seeking majority physical custody of
the chlld. It is further noted Ibal these parties entered into a Marital Settlement Agreement
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on or about July 23,1996, a copy of which is attached 10 Plaintiff's complaint and, therefore,
Exhibit "A"
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a part of the record. Furthennore, there have been some issues IlIised by both panies that
they have not been fully complying with the tenns and conditions of the custody
&rrall8ement set forth in that agreement,
At the conciliation conference, each party indicated his or her present desire to
continue to pursue majority phyaical custody of the child. All a result, it is Ordered and
Directed that these parties undergo Court.ordered mediation with Dr. Stanley Schneider,
(717) 732-2917, Both parties were provided wif.{i written instructions as to how to contact
Dr, Schneider to pursue this mediation. It Is the Court's desire that in addition to the usual
medJatlon Issues addressed, Dr, Schneider attempl 10 address with these parties the issllll
of communication between them as to any problems or difficulties arising regarding the
custody of thi3 child.
It is hoped that these parties wlll be able to reach an agreement regarding the
custody Issues through Court-ordered mediatioll. However, in the event that they are unable
to do so, counsel for the partlea are reserved thirty days after the completion of mediation,
to agree upon an independent evaluator to complete psychological evaluations of the parents
and their spouses If thi3 matter is to proceed to a full hearing. If the parties cannot agree
to an Independent evaluator within that thirty day period, either party may request
,
psycl1ological evaluations to be completed at his or her own full expense and each party and
their respective spouse are directed to cooperate with these evaluations. Furthermore, the
parties must also attend and complete the Kids First Custody Workshop on or before
December 6, 1996, Since both parties reside in the northern part of York County,
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Pennsylvania, it will be acceptable for either or both ot them 10 attend the lnl1ClWorks
CUslody Workshop spolUored by the Dauphin County Couns. In either case, each parenl,
upon completion, must file a Certificate ot Completion either of the Kids Firsl C1stody
Workshop or the lnnerworles C1slody Workshop with the Prothonotary's Office ot York
County on or before December 6, 1996. TIle panics are reminded that they arc under
Court Order 10 complele both the mediation and the cualody workshop and their failure 10
do .0 may result in their being brought before the Court and appropriale sanctiolU being
entered.
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Furthermore, in the event that mediation is IUlSIlCCeSsful, upon completion of
mediation, the custody workshop and the psychological evaluations, if reque51ed, counsel
shall then contact the Court to schedule a pre hearing conference so that this maner may
proceed to a finaJ hearing.
In the interim, II is Ordered and Directed that the custody provisions aa set forth in
the Marriage Settlement Agreement dated July 23, 1996, and incorporated into the Divorce
Decree and Order of Court on or about August 6, 1996, sball remain in full force and effect
and shall govern until further Order of Coun. That Agreement and Order provided for
shared legal and physical custody of the child which shall continue,
Itwaa acknowledged by the father at the concilialion conference that he bas not been
regularly exercising his CUlltody rights on Wednesd~ evenings puISuant 10 the agreement of
the parties. He has voiced some concerns about providing continuity for the chUd and
further indicated that he has not made a final decision as to whether he wishes to continue
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his cll8tody rights on Wednesday evenings or to waive them, The mother, however, clearly
stated that she wishes to continue exercising her rights on Wednesday evenings while the
father has physical custody of their daughter, It is directed that the father make a decision,
at least for the time being, as to whether or not he intends to exercise his custody rlghll on
Wednesday evenings. In fairness to the mother, she should be given advanced notice as to
the father's intentions. It has been suggested and is now direcled tbat once he reaches a
decision, which should be dOllflln the vc:ry immediate future, he should advise the mother
accordingly. 'IbIs Order is not termJuating the father's custody rights on Wednesday
evenings, but It Is specifically directing him to advise the mother of his present intentions,
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and, In the future, If he changes his mind, he should at least give the mother notice no later
than the time that cll8tody Is transferred to the mother on Friday evenings as 10 what his
intentions arc 88 to the upcoming Wednesday evening, Obviously, for both parties, this Is
not addressing any emergeocy situations which mlght prevent either of them from exercising
their custody rights on Wednesday evenings.
A copy of this Order shall be provided to both counsel so they may forward a copy
to their respective client. A copy shall also be forwarded to Stanley Schneider who shall he
conducting the Court.ordered mediation. Additionally, counsel are requested to provide a
copy to the selected evaluator should evaluations later be requested,
Date: ~ ~. l<<1cr/..
BY THE COURT:
\?, 'G.. .1j? ~~.e
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having custody lrom Wednesday. October 9. 1996 until Friday. October IB,
. 1996 and the lather having custody lrom Friday, October IB, 1996 at 4:00
p.m. until Wednesday, October 23, 1996 at B:OO a.m. I 9:00 a.m. and
alternating therealter;
b.
On alternate holidays, beginning New Years Day. The holidays are: New
Years Day, Memorial Day, Fourth 01 July, Labor Day and Thanksgiving Day.
Such custody shall begin at 9:00 a.m. and end at B:OO p.m.;
c.
The Christmas Eve and Christmas Day holidays shall be as mutually
agreed upon by the parties. In the event that the parties cannot reach an
amicable agreement as to these holidays, the lollowing schedule shall
apply:
In even numbered years, lather shall have partial physical custody
lrom 12:00 noon on Christmas Eve unU112:00 noon on Christmas Day.
This provision supersedes all others.
In odd numbered years, lather shall have partial physical custody
lrom 12:00 noon on Christmas Day until 12:00 noon on December
26th. This provision supersedes all others.
d,
During the summer, each parent shall be entitled to a two (2) week period
of uninterrupted custody, said period may be consecutive. Each parent
shall notify the other, in writing, sixty (60) days in advance, of his or her plan
to exercise this two (2) week period. In the event 01 a conflict the parent to
lirst notify the o.ther shall prevail.
e,
Father shall have right 01 custody on every Father's Day from 9:00 a.m. until
B:OO p.m. with Mother having that same right every Mother's Day from 9:00
a.m. until B:OO p.m. This provision supersedes all others.
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! I 5. Medical Caretrreatment. Both mother and father shall be immediately
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! ! Informed as to the medical care and treatment 01 the child.
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I : permanent, of either parent. that parent must immediately inform the other of hislher new
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6. Relocation. Upon the knowledge of pending relocation, temporary or
7. Seat Belts and Child Restraint Seats. Both parties shall utilize child restraint
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seats and seat belts when transporting the child by automobile,
8. Telephone ('A)ntact. The parties agree that the child is to have liberal rights of
telephone contact with the non-custodia! parent. no matter who is exercising his/her right
to physical custody,
I 9, Transportation. Unless otherwise agreed upon between the parties. the father
i shall be primarily responsible for providing transportation in the exercise of his custody
h ,'ll~~ Mo44.r re.lllC<\\<.i "'01'"(. it<"'" Il. t(., (10) 1"'; \.( ,..::d;lJS .fye". Oilb\;v'j;PA
~~"t~~"'I1.,,<l1=a.-tlw1 w;\1 s\.,<\.y( -\vlI"~pbd"hc" L~~"1.A li^,"1-<~ to 9tJ.~ ~"<I4-0I\l e.,. <ilk
6'''''' ~Mi). a!
I C lU. Leaal Residency. The leg residency of the aforementioned child. not
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, ; withstanding where the child may live at various times. shall be the same as that of
.1
. mother.
II, The mother and father agree that they are voluntarily entering into this
Agreement with fulllcnowledge and wish for the Court to adopt It as a Court Order.
IT IS SO ORDERED.
. BY~' elffiT~ I \ () 0
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....:--:::::Penny L. Blackwell. Judge HaV 0 I 1996
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, ; Witness
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We have read and consent to::> entry of the frJregoing Order,
': '1f!~2L~~
Wit '.
L.:.1L/~.~7h
Susan L. Harclerode-Betsko
Law Offices 01
. Nil.. 8,' S.nn. a.qulr. .
P.O. 80x 5135
135 North George Street, Suite 303
York. Penneyl"..",.. 17405-5185
(717)852-7020 . F".17171 852-8787
I 00 HEREBY CERTIFY THAT THIS IS A TRUE A
CORRECT COPY OF THE ORIGINAl. OOCUME
FILED OF RtCvnu
BY
IN THE COURT OF COMMON PLEAS
OF YORK COUNTY, PENNSYLVANIA
JEFFREY A. HARCLERODE
NO. 96-SU-01BOO-02C
v.
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\.n .,
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SUSAN L. BETSKO
.
CIVIL ACTION_- LA~
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......
AND NOH, TO HIT,
ORDER OF COURT
this ell:Jt day of
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1997, pursuant to the Agreement and
'J~7- . , i;
Stipulation of Jeffrey
A. Harclerode and Susan L. Betsko, is hereby ORDERED that
the undersigned Jeffrey A. Harclerode and Susan L. Betsko,
Father and Mother, respectively of Andrea Jane Harclerode,
born October 27, 1993, the subject of the above referenced
custody proceeding, hereby agree that the best interest and
welfare of Andrea Jane Harclerode would be served by
amending the Consent Order entered on the 19th of October
1996 as follows I
1. During such times as Susan L. Betsko is on
"maternity leave", the minor child will remain with her
rather than the previously agreed upon daycare provider.
Mother shall be utilized as the daycare provider during such
.
time as Father is working. Father shall be responsible for
dropping off and picking up the minor child before and after
his scheduled work.
Law OffIcII 0'
I S. Blnn, ESqUlr'j
P.O. Box 5'85
No~n George 51. ,
5uIle 303 I
<. PA 17.05.5185
EKhibit "c"
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2. In all other respects, the Order entered on the
19th of October 1996 shall remain in full force and effect.
BY THE COURT,
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L.aw Orficel of I
I S. 8.nn. Elqul,. Ii
P.O. 80. 5185 i
North G.org. 51. I
5u,.. 303
<. PA 11405.5185
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IN THE COURT OF COMMON PLEAS
OF YORK COUNTY, PENNSYLVANIA
v.
, NO. 96-SU-OlBOO-02C
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I CIVIL ACTION - LAW
JEFFREY A. HARCLERODE
SUSAN L. BETSKO
AGREEMENT AND STIPULATION FOR ORD~R OF COURT
TO THE HONORABLE PENNY L. BLACKWELL,
JUDGE, COURT OF COMMON PLEAS,
Susan L. Betsko and her counsel, The Law Offices of
Niles S. Benn, Esquire, by Martin Miller, Esquire, and
Jeffrey A. Harclerode and his counsel, Lori K. Serratelli,
Esquire, do hereby stipulate and agree that this Honorable
Court, before whom this matter has been assigned, may enter
the Order of Court attached hereto.
Yff~~~
MARTIN MILLER, ESQUIRE
-"
/&/
-$if SAN L. BETSKO
LORI K. SERRATELLI, ESQUIRE
w~~
A. HARC~ERODE
l.w ameli or
I S. 81nn, elqulr.
p.o. Box 5'85
; Nonh G.oIVO SI.
SUit. 303
'. PA 17405.5185
OS/22/17 TUU 10:01
F.tl 717 771 1&17
ft.
DOM. IU!J..\TIONS
fill 004
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PAGE TWO
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BJiililt .. ....
DRO No,~
.ldfu:'LA...llarclerode
lYctcn'dWU
Do~kel No, 423 SA IWI
ORDER OF COURT
NOW. , Ihe CoUrt does hereby order lhe Defendant to pay the Office of Domestic Relations the
sum of S r ~ for the support of llnC...Child as aUocalcd on page
one effective e tfifsorder to continue unTIrrurtIier Order of the Court.
Payment to conunencc y e Delen tine amount of the order (or change) unlll the awarded wage
attachment is deductedy e emp oyer. The .I'laillti~efendant Il[f' 10 provide health Insurance that Is available
for the ~ here Involved at reasonable cost. Both ponIes are reqUIred to comply with all Policies and Procedures
of Domesllc Relations including reporting changes of address, employment, lnStirance coveraJ!e/cost or custnrlv nf
children, in writing or person, within seven (7) days of the change, Willful failure to infonn Domesllc Relations of
this required infonnalion may result in the CoUrt adjudging the party In contempt pursuant to Rule 1910.21
punishable by one or more of the following: .Iail, fine or probal1on. Income win lie attached unless the obligor is
not thi!t)' days in arrear3l11l1 good cause exisis not to attach w: a written agreement is reached between the P.BrIies
providinS for an altemative arrangement, this second option applying to non-welfare cases only, Any past iiue
support IS a judgment by operation of law, Cases with qualifii:d arrears will be submitted to lIie IRS lrilerl:qlt
program. PUrsuant to 23 Pa.C.S.A. 4308,. noncustodial jlarent's state lottery winnings may be inlen:epted for
payment of back support. Pursuant to 23 Pa,C.S,A. 43S2(a), both parties ere entitle<l to request a review at least
once every 3 years from the date of the most recent order or modification upon the filing ofa pellllon to modilY.
There is a $,20 per week service charge that must be paid by the Defendant,
Arrears are l.4.S.llll owed 10 IlIaint.i.fl'. as of ~
Payments on arrears shall be liitIie1ollowing pnority,. ..
S.tllll per ~ on support arrears account number ti.4llll
$_ per _ on birth expenses account number
$_ per _ on HLA blood test account number _
$_ per _ on account number
S ~r _ on account number
If at any time after the entl')' of this order, the total support arrears exceed $!1ll..O.ll, the arrears payment on the case
shall automatically increase to $.1,O.ll!l per ~ to continue until fullJ,laymCii!Of all arrears or further order of
coUrt, A wage allachment in the mcreased amount shall automatically Issue without further notice, Arrears
payment listed above are minimum P!lrmenlS required by this Order of CoUrt.
Formula Income Amount Defendant MA Formula Income Amount PlaintiffNLA.
Ouideline Amnllnl (lfSup[X"rt S~ (B:lSe ~ AdditionallliA), .
Medical Split, if applicable ~% Defendant; 6.Q% PlaiatitT, which pertains to unreimburscd reasonable and
neces9lll')' medical services as defined by the P A statewide guideline for the children incurred on or after &brua1y
S 1997. This matter is to be handled directly between the parties unless default OCClU'5 at which point enforcement
action may be pursued through York Domestic Relations in accordance with the procedures in place for same,
=~~:.~,~I~~!~~~t~~~~t~~~:1~c8ffi~~~s~~ n~~:'~~~i~:i~~c~~
pc: [,Iaintin'; Ally. L. Serratelli
Defendanl; All)'. M. Pokrilka
JTS
if;TH",''''RT '. ,
/jI) ~p~~;o
Judge
Date Mailed 4/22197 Workcr ITS P&P enc. P jD .IBoth XX/No_
Exhibit "0"
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COURT OF COMMON PLEAS
YORK COUNTY
DOMESTIC RELATIONS SECTION
SUSAN L
Plaintiff
va
BETSKO
JEFFREY A HARCLERODE
Defendant
No. 423 Support Action 1997
Action In Support
DRO No. 62350
ORDER OF COURT
AND NOW, JULY 30, 1997, verification having been presented to the Domestic Relalions Section and to the Court that OIL.
JULY 17 1997 Ihe olaintiffs attornev advised York Domestic Relations that the oarties had reached an aoreement for the
lUOOOrt of Ihe child ANDREA J HARCLERODE !DOB 10/27/93) and orovided a coov of that aoreemenl II is recommended
In order be entered In accordance with this information
IT IS HEREBY ORDERED that the supoort order in the above enlitled case be modified effective FEBRUARY 22 1997 to
;91.00 oer week which is 534 50 oer week or 5150 00 oer month in base suooort olus S56 50 oer week reoresenlino 11, of the
:hild care exoenses for Andrea) olus S5 00 oer week on arrears oer the aoreement of the oarties Given this order arrears
lre Sl 52450 as of Auousl 2. 1997 In accordance with the aoreement durlno such times as the minor child is not enrolled in
lavcare due to Ihe olalntiffs exoected maternity leave the davcare exoenses reoresentino Ihe sum of 55650 oer week shall be
;usoended This action mav be taken bv soecial court order without a conference effective the date said child care sxoense
'/ould cease The olaintiff is advised 10 notify York Domestic Relalions of the exact date oavmenl of child care ceases wllhln
;even days of its occurrence All existino suooort orovisions oertainlno to Andrea unchanoed herein remain in full force and
!ffect The defendant's waoe attachment shall be increased accordinolv This order resolves Ihe Pelition for Amendment
,ubmilled on Mav 23 1997 therefore the conference scheduled for Seotember 3 1997 before Conference Officer Jennifer
;elbv Is hereby canceled Paymenl under this order is to be made to Domestic Relations Section, P.O. Box 1502, York, PA
7405 and Is to commence immediately in the amount of the order (or change) until the awarded wage attachment Is deducted
'y the employer. Bolh parties are required to comply with all Policies and Procedures of Domestic Relations. Parties are under
1e continuing obligation to inform the Domestic Relations Sllctlon and all olhllr parties In writing wilhi~ seven (7) days of any
laterial change in circumstances relevant 10 the level of support or the administration of Ihe support order, Including, but not
miled to, loss or change of income or employ men I and change of personal address or change of address of any child receiving
upport. Willful failure to inform Domestic Relations of this required Information may resull in the Court adjudging tha party In
ontempt pursuant to Rules 1910.21.1 through 1910.21-7 punishable by one or more of the following: jail, fine or probation. At
ny time a defendant Is not paying the order due 10 medical problems and/or insufficient Income, the monthly reporting/job
earch requiremenls of York Domestic Relalions must ba followed. Income will be attached unless the obligor is not thirty days
1 arrears iIDd. good cause exists nolto attach QLa written agreement Is reached between the parties providing for an alternative
rrangemen!, this second option applying to non-welfare cases only. Any past due support Is a judgmenl by operation of law.
.ases with qualified arrears, including medical accounts, will be submitted to the IRS Intercept program. Pursuant to 23
a.C.SA 4308, noncustodial parent's state lottery winnings may be inlercepted for paymenl of back support. Pursuant to 23
a.C.SA 4352(a), both ~arties are enlitled to request a review at leas I once every 3 years from the date of the most recent
rder or modification upon the filing of a pelition 10 modify Pursuanlto 23 Pa.C.SA 4309. names of obligors delinquent more
lan 30 days may be published in general or special circulation newspapers in the counly. Pursuant to Slate and federal law,
ames and accounl balances of obligors delinquent more than 60 days shall be provided 10 consumer reporting agencies upon
lquest There is a 5.20 per week service charge that must be paid by the Defendant
C Plaintiff, Defendant: L Serratelli Esq. Deft.: M Miller Esq - Plntf
MT/yzl
By .t~
If
]att' Mallec
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'JvortH~'
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Pd,P Ene P
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Hal"
Judqe ,;
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Rev 4/1/9€
Exhlhlt "E"
LORI K. SfRRATU II
SnVfN j. SCIIIFFMAN
MIlHAEl F. BRO\\'N
RONAlD L CALIIOON
GARY I.. ROTIISCfIlLll
ROBERT D. HAMILTON
VIRl:lNIA M. DIM
ANlJREW J. OSTROWSKI
GARTH A. SnNIENsoN
OF COUNSEL
(MD t( OC Ilw ONl ~l
Sum 201
2080 UNGLlrn)'tVN Ro..w
HAJUlnIUAG. PA
17110-%70
(717) 540.9170
FAX 1717) ~().~HI
-(,,~.
Ji:JV i :.i 1:]1)/
November 14, 19~7
Prothonotary
CUMBERLAND COUNTY COURTHOUSE
1 Courthouse Square
Carlisle, PA 17013
RE: PETITION FOR CHANGE OF NAME OF
ANDREA JANE HARCLERODE
NO. 97-5615 CIVIL TERM
OUR FILE NO. 97-024
Dear Sir or Madam:
Enclosed please find an original and three copies
of our Objections to Petition for Change of Name of
Andrea Jane Harclerode. Please file the original and
return three time-stamped copies of the same to me in
the enclosed self-addressed, stamped envelope.
Stamped envelopes, addressed to tha Petitioner and her
attorney, are also enclosed for your convenience,
I would appreciate this document being delivered
to Judge Oler at your earliest convenience,
If you have any questions, please do not hesitate
to contact my office. Thank you for your prompt
attention and anticipated cooperation,
Sincerely,
SERRATELLI, SCHIFFMAN,
BROW~,~~.O~:
L~~'erratelli
LKS/ted
Enclosures
cc: The Honorable J. Wesley Oler, Jr. (courtesy copy)
Martin Miller, Esquire
Jeffrey A. Harclerode
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN THE MATTER OF PETITION
FOR CHANGE OF NAME OF
ANDREA JANE HARCLERODE
NO, 97-5615 CIVIL TERM
OReBR
AND NOW, this
day of November, 1997, upon consideration
of the Objections to Petition for Change of Name of Andrea Jane
Harclerode, it is hereby ORDERED and DECREED that petitioner Susan
L. Betsko's Petition for Change of Name of Andrea Jane Harclerode
is hereby DENIED.
BY THE COURT:
J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN THE MATTER OF PETITION
FOR CHANGE OF NAME OF
ANDREA JANE HARCLERODE
NO. 97-5615 CIVIL TERM
OBJECTIONS TO PETITION FOR CHANGE OF NAME
OF ANDREA JANE HARCLERODE
AND NOW, comes Jeffrey A. Harclerode, the natural father of
the minor, Andrea Jane Harclerode, by and through his attorney,
Lori K. Serratelli, Esquire, and files his Objections to the
Petition to change of Name of Andrea Jane Harclerode filed on
behalf of the minor child by her natural mother, Susan L, Betsko,
and in support thereof represents the following:
1. Objector, Jeffrey A. Harclerode, is an adult individual
residing at 1940 Old York Road, Dillsburg, York County,
pennsylvania.
2, Petitioner, Susan L, Betsko, is the ex-wife of Objector,
Jeffrey A. Harclerode, the parties having been divorced on August
6, 1996,
J. petitioner has attached to her Petition relevant custody
Orders in this matter which indicate that Objector has significant
and frequent partial custody of the minor child, Andrea Jane
Harclerode.
4. Objector has faithfully and dutifully paid child support
for Andrea Jane Harclerode pursuant to the Support Orders attached
to Petitioner's Petition,
5, objector vehemently objects to changing the minor child's
name given to her at birth by both Petitioner and Objector, While
petitioner avers without foundation that there are "certain
psychological advantages to permitting the name change", the
obvious intent is to hold out to the community that Petitioner's
husband, Joseph Betsko, is the minor child's natural father,
6. Petitioner has requested in the past that Objector waive
his parental rights to the minor child and Objector has refused to
do so based on his love for his minor child and continued desire to
be her father.
7. Petitioner's filing of this Petition is evidence of
Petitioner's continued conduct to eliminate or diminish objector's
influence and relationship with the minor child.
S, peti tioner' s remarr iage and subsequent birth of another
child give no legal basis for the change of Andrea Jane
Harclerode's surname to the name of her step father and half
sister, In fact, in today's society it is quite normal for there
to be blended families in which the children or parents have
different names,
WHEREFORE, for all the above reasons, Objector respectfully
requests that this Petition be dismissed without hearing as
Objector will not consent to the change of name of his minor child
and both the custody and support orders of record are evidence of
objector's continued and faithful relationship with his child.
Respectfully submitted,
Lo ~e~~~l~~ire
~:LI' SCHIFFMAN,
BROWN , CALHOON, P.C.
2080 Linglestown Road
suite 201
Harrisburg, PA 17110
(717) 540-9170
Attorney for Objector
CERTIPICATE OP SERVICE
I, Lori K. Serratelli, Esquire, do hereby certify that on this
-1i.. day of November, 1997, I served a copy of the foregoing
document by United states Mail, First Class, postage pre-paid, to
the following person(s):
Martin Miller, Esquire
LAW OFFICES OF NILES S, BENN, ESQUIRE
135 North George Street
suite 303
P.O. Box 5185
York, PA 17405-5185
Lor re
SE TELLI, SCHIFFMAN,
BROWN , CALHOON, P.C.
2080 Linglestown Road
suite 201
Harrisburg, PA 17110
(717) 540-9170
Attorney for Objector
To
You are hereby notified to file a
wriuen response to .he enclosed
within twenty (20) days from ser.
vice hereof or a judgment may be
entered againn you
by
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17110-')44 ~
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Anomq
We do hereby <<"ify Ihar the
within is a true and correct wPy
of .he original filed in Ihi. actIon
by
Anomey
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.)
'I
IN THE MATTER OF PETITION
FOR CHANGE OF NAME OF
ANDREA JANE HARCLERODE
NO. 97-5615 CIVIL TERM
OBJECTIONS TO PETITION FOR CHANGE OF NAME
OF ANDREA JANE HARCLERODE
. ,
AND NOW, comes Jeffrey A, Harclerode, the natural father of
the minor, Andrea Jane Harclerode, by and through his attorney,
Lori K. Serratelli, Esquire, and files his Objections to the
Petition to Change of Name of Andrea Jane Harclerode filed on
behalf of the minor child by her natural mother, Susan L, Betsko,
and in support thereof represents the following:
1. objector, Jeffrey A. Harclerode, is an adult individual
residing at 1940 Old York Road, Dillsburg, York county,
Pennsylvania.
2. Petitioner, Susan L. Betsko, is the ex-wife of Objector,
Jeffrey A. Harclerode, the parties having been divorced on August
6, 1996.
J. Petitioner has attached to her Petition relevant custody
Orders in this matter which indicate that Objector has significant
and frequent partial custody of the minor child, Andrea Jane
Harclerode.
4, Objector has faithfully and dutifully paid child support
for Andrea Jane Harclerode pursuant to the Support Orders attached
to Petitioner's Petition.
5, objector vehemently objects to changing the minor child's
name given to her at birth by both Petitioner and Objector, While
Petitioner avers without foundation that there are "certain
psychological advantages to permitting the name change", the
obvious intent is to hold out to the community that Petitioner's
husband, Joseph Betsko, is the minor child's natural father,
6. Petitioner has requested in the past that Objector waive
his parental rights to the minor child and Objector has refused to
do so based on his love for his minor child and continued desire to
be her father.
7. Petitioner's filing of this Petition is evidence of
Petitioner's continued conduct to eliminate or diminish Objector's
influence and relationship with the minor child.
S. Petitioner's remarriage and subsequent birth of another
child give no legal basis for the change of Andrea Jane
Harclerode's surname to the name of her step father and half
sister. In fact, in today's society it is quite normal for there
to be blended families in which the children or parents have
different names.
WHEREFORE, for all the above reasons, Objector respectfully
requests that this Petition be dismissed without hearing as
Objector will not consent to the change of name of his minor child
and both the custody and support Orders of record are evidence of
Objector's continued and faithful relationship with his Ghild.
Respectfully submitted,
~
. Serratell , Esqu re
BE RATELLI, SCHIFFMAN,
BROWN' CALHOON, P.C.
2080 Linglestown Road
suite 201
Harrisburg, PA 17110
(717) 540-9170
Attorney for Objector
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You are hereby nOlified 10 file a
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wilhin !Wenry (20) days from ..r-
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by
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We do hereby cenify thaI the
within is a lrue and correct copy
of the original filed in IhlJ lICUon
by
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Anomey
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4
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTV, PENNSVLVANIA
IN THE MATTER OF PETITION
FOR CHANGE OF NAME OF
ANDREA JANE HARCLERODE
NO. 97-5615 CIVIL TERM
ORDER
AND NOW, this
day of November, 1997, upon consideration
of the Objections to Petition for Change of Name of Andrea Jane
Harclerode, it is hereby ORDERED and DECREED that Petitioner Susan
L. Betsko's Petition for Change of Name of Andrea Jane Harclerode
is hereby DENIED.
BV THE COURT:
J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN THE MATTER OF PETITION
FOR CHANGE OF NAME OF
ANDREA JANE HARCLERODE
NO, 97-5615 CIVIL TERM
L
OBJECTIONS TO PETITION FOR CHANGE OF NAME
OF ANDREA JANE HARCLERODE
AND NOW, comes Jeffrey A, Harclerode, the natural father of
the minor, Andrea Jane Harclerode, by and through his attorney,
Lori K. Serratelli, Esquire, and files his Objections to the
Petition to Change of Name of Andrea Jane Harclerode filed on
behalf of the minor child by her natural mother, Susan L, Betsko,
and in support thereof represents the following:
1. Objector, Jeffrey A. Harclerode, is an adult individual
residing at 1940 Old 'lork Road, Dillsburg, York County,
Pennsylvania.
2. petitioner, Susan L, Betsko, is the ex-wife of Objector,
Jeffrey A. Harclerode, the parties having been divorced on August
6, 1996.
3. petitioner has attached to her Petition relevant custody
Orders in this matter which indicate that Objector has significant
and frequent partial custody of the minor child, Andrea Jane
Harclerode,
.
4. Objector has faithfully and dutifully paid child support
Lor Andrea Jane Harclerode pursuant to the Support Orders attached
to Petitioner's Petition.
5, Objector vehemently objects to changing the minor child's
name given to her at birth by both Petitioner and Objector, While
Petitioner avers without foundation that there are "certain
psychological advantages to permitting the name change", the
obvious intent is to hold out to the community that Petitioner's
husband, Joseph Betsko, is the minor child's natural father.
6. Petitioner has requested in the past that Objector waive
his parental rights to the minor child and Objector has refused to
do so based on his love for his minor child and continued desire to
be her father.
7. Petitioner's filing of this Petition is evidence of
Petitioner's continued conduct to eliminate or diminish Objector's
influence and relationship with the minor child,
8. Petitioner's remarriage and subsequent birth of another
child give no legal basis for the change of Andrea Jane
Harclerode's surname to the name of her step father and half
sister. In fact, in today's society it is quite normal for there
to be blended families in which the children or parents have
different names,
WHEREFORE, for all the above reasons, Objector respectfully
requests that this Petition be dismissed without hearing as
Objeotor will not oonsent to the ohange of name of his minor child
and both the custody and support Orders of record are evidence of
objector's continued and faithful relationship with his child.
Respectfully submitted,
~
. Serratell , Esqu re
SE RATELLI, SCHIFFMAN,
BROWN , CALHOON, P.C.
2080 Linglestown Road
suite 201
Harrisburg, PA 17110
(717) 540-9170
Attorney for Objector
VERII'ICATION
I verity that the statements made in the foregoing document
are true and correct. 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.
Date:
.....-:;"ij '7'/ 'j"rJ
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LAW OFFICES OF NILES S. BENN, ESQUIRE
135 North George Street
Suite 303
P,O, 80x 5185
York, PA 17405-5185
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A
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN THE MATTER OF PETITION
FOR CHANGE OF NAME OF
ANDREA JANE HARCLERODE
NO. 97-5615 CIVIL TERM
ORDER
AND NOW, this
day of November, 1997, upon consideration
of the Objections to Petition for Change of Name of Andrea Jane
Harclerode, it is hereby ORDERED and DECREED that Petitioner Susan
L, Betsko's Petition for Change of Name of Andrea Jane Harclerode
is hereby DENIED.
BY THE COURT:
J.
I
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
t -, ." ,')
1 ,
, ,
IN THE MAi~ER OF PETITION
FOR CHANGE OF NAME OF
ANDREA JANE HARCLERODE
NO. 97-5615 CIVIL TERM
OBJECTIONS TO PETITION FOR CHANGE OF NAME
OF ANDREA JANE HARCLERODE
1:\
AND NOW, comes Jeffrey A, Harclerode, the natural father of
the minor, Andrea Jane Harclerode, by and through his attorney,
Lori K. Serratelli, Esquire, and files his Objections to the
Petition to Change of Name of Andrea Jane Harclerode filed on
behalf of the minor child by her natural mother, Susan L. Betsko,
and in support thereof represents the following:
1. Objector, Jeffrey A. Harclerode, is an adult individual
residing at 1940 Old York Road, Dillsburg, York county,
Pennsylvania.
2. Petitioner, Susan L. Betsko, is the ex-wife of Objector,
Jeffrey A. Harclerode, the parties having been divorced on August
6, 1996.
3. petitioner has attached to her Petition relevant Custody
Orders in this matter which indicate that Objector has significant
and frequent partial custody of the minor child, Andrea Jane
Harclerode.
I
4. Objector has faithfully and dutifully paid child support
for Andrea Jane Harclerode pursuant to the support Orders attached
to Petitioner's Petition.
5. Objector vehemently objects to changing the minor child's
name given to her at birth by both Petitioner and Objector. While
Petitioner avers without foundation that there are "certain
psychological advantages to permitting the name change", the
obvious intent is to hold out to the community that Petitioner's
husband, Joseph Betsko, is the minor child's natural father.
6. Petitioner has requested in the past that Objector waive
his parental rights to the minor child and Objector has refused to
do so based on his love for his minor child and continued desire to
be her father.
7. Petitioner's filing of this Petition is evidence of
Petitioner's continued conduct to eliminate or diminish Objector's
influence and relationship with the minor child.
S. Peti tioner' s remarriage and subsequent birth of another
child give no legal basis for the change of Andrea Jane
Harclerode's surname to the name of her step father and half
sister. In fact, in today's society it is quite normal for there
to be blended families in which the children or parents have
different names.
WHEREFORE, for all the above reasons, Objector respectfully
requests that this Petition be dismissed without hearing as
~
Objector will not consent to the change of name of his minor child
and both the custody and support Orders of record are evidence of
objector's continued and faithful relationship with his child.
Respectfully submitted,
~
. Serratell , Esqu re
SE RATELLI, SCHIFFMAN,
BROWN' CALHOON, P.C.
2080 Linglestown Road
suite 201
Harrisburg, PA 17110
(717) 540-9170
Attorney for Objector
J ,. - '- ,
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.
VI!lRII'ICA'1'ION
I verify that the statements made in the foregoing document
are true and correct. 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.
Date:
/~o '7/ '1''7
CBRTIPICATB OP SBRVICB
I, Lori K. Serratelli, Esquire, do hereby certify that on this
)<{ day of November, 1997, I served a copy of the foregoing
document by United states Mail, First Class, postage pre-paid, to
the following person(s):
Martin Miller, Esquire
LAW OFFICES OF NILES S. BENN, ESQUIRE
135 North George Street
suite 303
P.O. Box 5185
York, PA 17405-5l85
\
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. Serratell~, Esqu~re
SE TELLI, SCHIFFMAN,
BROWN' CALHOON, P.C.
2080 Linglestown Road
suite 201
Harrisburg, PA l7l10
(717) 540-9l70
Attorney for Objector
IN THE MATTER OF PETITION
FOR CHANGE OF NAME OF
ANDREA JANE HARCLERODE
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
.
.
.
.
: No. 97-5615 CIVIL TERM
ORDER OF COURT
AND NOW, this 29th day of January, 1998, upon
consideration of ths Petitioner's Amended Petition for Change of
Name of Andrea Jane Harclerode, and of the Objections to
Petition for Change of Name of Andrea Jane Harclerode, and
followin9 a hearing, the record is declared closed, and the
matter is taken under advisement.
By the Court,
() ()
J Wesley(~;~, J.
MARTIN MILLER, ESQUIRE
P.O. Box 5185
135 N. George street, suite 303
York, PA 17405-5185
For the Petitioner
_ c 1~w.' (1ll.ct&.L ;'/3/ n
,.A r
LORI K. SERRATELLI, ESQUIRE
suite 201
2080 Lin9lestown Road
Harrisburg, PA 17110-9670
For the Objector
wcy
IN THE MATTER OF
PETITION FOR CHANGE OF NAME
OF ANDREA JANE HARCLERODE
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-5615 CIVIL TERM
~ ORDER OF COURT
AND NOW, this Z~ day of January, 1998, upon consideration of
Petitioner's Amended Petition for Change of Name of Andrea Jane
Harclerode, filed by the child's mother, and of the Objections to
Petition for Change of Name of Andrea Jane Harclerode, filed by the
child's father, and following a hearing, the petition is DENIED.
BY THE COURT,
J.
Martin Miller, Esq.
P.O. Box 5185
Suite 303, l35 N. George Street
York, PA 17405-5185
Attorney for Petitioner
Lori K. Serratelli, Esq.
Suite 201
2080 Linglestown Road
Harrisburg, PA 17110-9670
Attorney for Objector
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